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Home My WebLink About00-06094 ~M't;,-i AMY R. BOYLE PLAINTIFF V. JEFFERYC. PAWLOWSKI DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 00-6094 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 11th day of September ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Snnday, Esq. , the conciliator, at 39WestMainStreet,Mechanicsburg,PA 17055 onthe 10th dayof October ,2000, at 9:30 a.m. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to defme and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: Isl The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~' "Ullll[:!!nij~ -.. tl"/3 -t4t) y -/3 -O,?l tJ - $-t1c/ ~ ~ ,,,-'~-'. ,,< <>, __,""~" 2&O'~ __<"~" ~-~~o" _~, ~ _""~~ '. ,R-f ,",,-, ::~; n \'1 \,!'.) JJ ('! Jr;,," -, - ....."...'Hi',l;: _I t,....,_;,J\i:Y I )!:I'l)\iSYI \ I,:'.. \H_1 -" , . cAI-~~~4~ /I~ ~ ~ rff 4-~< ~ ~ 4> 4~ -~~ . 1M$l~l'li<!;I("3'~~'M"<f#)r"-".':!lII~-f;'iliffl'!!t~~~.~~~1'!!~jqfl!ru~""'''''''''''~l_'''r_',~,_ _,~""_, ~,--, ~~ ....:... OM_ "" ~m;!'0 , AMY R. BOYLE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ~ NO. 00-(d)Q1 CIVIL TERM : CIVIL ACTION - CUSTODY v. JEFFERY C. PAWLOWSKI , Defendant ORDER OF COURT AND NOW, this day of , 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , Esq., the Conciliator, at on the day of 2000, at .M., for a Pre-Hearing Custody Conference. At such conferem:e, an . effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to ' define and narrow the issues to be heard by the Court, and to enter into a temporary order. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible! facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE. OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 II I " . ~.-- 'i~j' --,~ ,- AMY R. BOYLE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00- &09'1 CIVIL TERM v. JEFFERY C. PAWLOWSKI, Defendant : CIVIL ACTION - CUSTODY COMPLAINT FOR CUSTQDY 1. Plaintiff is Amy R. Boyle, an adult individual whose residence is at 106 D Wolfs Bridge Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Jeffery C. Pawlowski, an adult individual whose residence is .. at 2001 Whitehall Street, Apartment B-4, Allentown, Lehigh County, Pennsylvania. . Plaintiff seeks custody of her child Jonathan X. Pawlowski, born September 23, 1995, currently residing at 106 D Wolfs Bridge Road, Carlisle, Cumberland County, Pennsylvania. 3. The child is presently in the custody of Plaintiff. 4. Since the child's birth, the child has resided at the following addreSSE1S: Name Address Dates Mother Wolfs Bridge Road Add. September 19!98/ to Present March 11998/ September 19!98 Mother 321 Market Street Tamaqua, PA Mother & Father 20 W. Broad Street Tamaqua, PA January 1996/ March '1998 Mother 321 Market Street Tamaqua, PA September 1995/ January 1996 5. The relationship of the Plaintiff to the children is that of natural mother. 6. The relationship of the Defendant to the children is that of natural father. 7. The Plaintiff has not participated as a party or in any other capacity, in other litigation concerning the custody of the child in this or any other Court. II "",-, hl~!lt.J """'.r.' _ " 8. Plaintiff has no information of a custody proceeding concerning thl~ child pending in a Court of this Commonwealth. 9. The best interest and permanent welfare of the child will be served by granting the relief requested because the Plaintiff is the primary care giver with n~spect to the child. 10. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. Not other persons are known to have or claim to have any right to custody or visitation of the child other than the parties to this action. WHEREFORE, Plaintiff requests your Honorable Court Respectfully Submitted TURO LAW OFFICES ," : 9/ stat Date ::;;i%~JJM(~ Robert J. ulderig, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff :1 II . ,-- '~." ~ ~~"~Ilfp", , , VERIFICATION I verify that the statements made in the foregoing Custody Complaint are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. Date cr(~/ (J'J II i 'M' ~ ~, ,~ " "'w'r-( . .'"c_.."""",_ - ~l!iIinJI\~~~:UL ~ 1~ ~~ ~ IS ~' a ~- .. . , ~_,' -'_' <'.,0='. ". "'~-, "iiij'-']it-illTI' L ~ .~ ~ J ~ -; o ", 'm J.' c~ ~";,,:~ ;. ..<+ ~--- fi~ r 'il ~ (") ~ ~TJ f'::: !TlfT 2:T. :;':-'~: c_:- C') .' r' :< ,-':'- c) )~~ ~ :.:~ :~ c::) CJ U) ." :-0 ,~, '-.' "1-1 (71 -~\(~) ~I:";: -,--, .~- '" ;'-':;f"ll ~: ':..7 -< t, 0' _ - - - "_"~~ -',' ~. "~--'-~ -~~ . ,-- AMY R. BOYLE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-6094 CIVIL TERM JEFFERY C. PAWLOWSKI, Defendant : CIVIL ACTION - CUSTODY AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT I served a true and correct copy of the Divorce Complaint filed in the above captioned case upon Jeffery C. Pawlowski, by cElrtified mail, return receipt requested on September 7, 2000 addressed to: Jeffery C. Pawlowski 2001 Whitehall Street Apt. B-4 Allentown, PA 18104 and did thereafter receive same as evidenced by the attached Post Office receipt card dated September 13, 2000. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF, I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. TURO LAW OFFICES ~t,/M I te ! Robert . u aerig, Esqui 28 So Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff II ~a t '~ I! :' II .-,,'; -_..-<', Z 452 476 189 ~ Postage I $ ,86 I . '-iO Ce<liliedFee Special DoIiwy Fee Res1IIt\ed DeIiveJy Fee "'" ill R.lorn Receipt Showing to I '\ c:.. ~ Whom & Dale DeHvered . ()(.;..! 'C RelumRei:eiptSl1llWinglil\\11om, .:r IlaJe,&AddressedsAiltess g TOTAL Postage & Fees $ f) q (J GO ~, () ('II) PostmaIk or Date ~' ~.~, 2lXiO ~-~~----"-------- ._-----,----.._._"~~---- - - ,'-, .. GO ''D ,.,-,'" , J Ii I S!$NDEA: [J p.omplete ~ems 1 anellor 2 for additional se JjmprefEl items 3, 4a, and 4b. 1lIf\\int "lour name an1$ adrlress on 1M rev qard to you I also wish to receive the foll~~ ing services (for an extra feet: 1. 0 Addressee's AdiJress 2. 0 Restricted Delivery 7. Dale of Delivery 5. eceived By: (Print Name) 8. Addressee's Address (Only if requested i/iIIII fee is paid) J' t~'.-tJ-_3 ,,,,,..1t, Domestic Return Receipt . ".' ~)ill..iid~ J I I .r l' J: ~ I. __ ~tiIlrtf'.1u ,~ h. ~- Ji&'tlm._b~L~.ni_Jij'~~~.- '....ir';..',. '...;" M'<,",o:'""'''';'' .;,...". , ~ ~" , , ; \,"",c:"f"""::" - ,;"'''';.''.OC;'",, ,;;,';,. , " " . ... (") c- ? .......'-"- rXtD ~ln,,: <~).) ~~,~: ;:S h, kU Pc, ;:s (j Pc: .2 :< c::, o CI> r:;: ,'0 --./ h ::Ji: S? ,0,) c.;, o ~T1 :;'l ~'T'jiD .~j'0' 2~$f? o:lj 5(') (yo $ -.;;: . II: ~ , I I I I J i I I Ii i ,. II Ii I' !: " ; I j r-' j -~" .. r-_...........__, ~~ A ... AMY R. BOYLE, Plaintiff : IN THE CXlURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . . . . vs. . . NO. 00-6094 CIVIL TERM : JEFFERY C. PAWLOWSKI, Defendant . . CIVIL ACTION - LAW IN CUSTODY : ORDER OF COURT AND NCM, this \0 consideration of the attached and directed as follows: day of Custody ~~ Conciliation Report, , 2000, upon it is ordered 1. The Mother, Amy R. Boyle, and the Father, Jeffery C. Pawlowski, shall have shared legal custody of Jonathan X. Pawlowski, born September 23, 1995. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. The Mother shall have primary physical custody of the Child and may relocate with the Child to South Carolina. 3. The Father shall have partial physical custody of the Child as follows: A. The Father shall have custody of the Child from Thursday, November 2, 2000 at 2:30 p.m. through Saturday, November 4, 2000 at 6:00 p.m. For purposes of this provision, the parties shall exchange custody of the Child at a location mutually convenient to the parties and selected by agreement. B. The Father shall have custody of the Child for 4 consecutive weeks during the summer school break upon providing notice to the Mother by May 1 of each year of the Father's selection of dates under this provision. C. The Father shall have custody of the Child for 1 additional week during the school year upon providing at least 30 days advance notice to the Mother and conditioned upon obtaining school approval. D. The Father shall have custody of the Child over the Christmas holiday in even numbered years. For purposes of this provision, the Christmas holiday period of custody shall run fran the first day after school terminates before the holiday for a period of 7 days. E. In odd numbered years, the Father shall have custody of the Child over the Thanksgiving holiday from the Tuesday before , ,,,- ""~ < 1iIIIiIriI- - ~ jim, .. Thanksgiving through the Saturday following Thanksgiving. F. In years when the Father does not have a period of custody over the preceding Christmas holiday, the Father shall have custody of the Child over the Easter/Spring break. G. The Father shall have custody of the Child any time the Mother travels to pennsylvania or the Father travels to South Carolina, at times to be arranged by agreement of the parties. 4. The parties shall exchange custody of the Child at a halfway point between the parties I residences. 5. The Father shall have liberal and reasonable telephone contact with the Child, at least one time per week, with the parties to alternate in initiating the telephone calls. 6. This Order is entered pursuant to an agreement of the parties at a Custody conciliation Conference. The parties may modify the provisions of this order by mutual consent. In the absence of mutual consent, the terms of this order shall control. / BY THE COURT ,// ,'-,' ~c// J. cc: Robert J. Mulderig, Esquire - Counsel for Mother Jeffery C. pawlowski, Father ) >~ ~ /I_t.-.W '-f'- > ~ : ,-, 'I " ~ ~ ~,~ ,0_ UliL_" ~ -',,' .,- "-'~-< . ~ .~-- ",- ,- H , ---. Q:~" A; n ;;/" '<: cCil 01> {. Y' v If/ / >?r-~l :y,:1t. 1//"J/,/ '..1'>/, ~;'}.. /i (.I; -.-"I'-l- ......,,: \.-1 " ' ~ ",11.", I.1i O~ v0!'" !/&"J.t_> of Ii/', A^'.'''' '9,,, , "''')'f- <:-;f~"01.;" la. 'v." 'I" . " is'h,.J I'. .j > '1('1/1:0/ '1, . . vq '-1V-)- .. ~~i'@\i!f<lmWffi~~WI~~wml!$';WilI~Wf~ _ :Ii;~_Wli\llm:~~_,,=_....... _j' ~! ~~- ,- ,~~ --~- ,,' '=w ~ AMY R. BOYLE, . IN THE COURT OF COMMON PLEAS OF . Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . . vs. . NO. 00-6094 CIVIL TERM . . . JEFFERY C. PAWLOWSKI, : CIVIL ACl'ION - LAW Defendant : IN CUSTODY ~ <X:'NCILIATICN SUMMARY REPCRl' IN Accx:m>ANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDlJRE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Jonathan X. Pawlowski September 23, 1995 Mother 2. A Conciliation Conference was held on October 25, 2000, with the following individuals in attendance: The Mother, Arrrj R. Boyle, with her counsel, Robert J. Mulderig, Esquire, and the Father, Jeffery C. Pawlowski, who is not represented by counsel in this matter. 3. The parties agree to entry of an Order in the form as attached. Date CJr Jvbu q(}: ~ Il..cr~ Dawn S. Sunday, Esquire Custody Conciliator