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HomeMy WebLinkAbout03-1578 COURT DAUPHIN OF COMMON PLEAS COUNTY CIVIL ACTION SUITS 2O00 Printed by: IMR Limited-Form397 E917322 2000-S ~4~q Entry By Summons ( ) Date of Entry Complaint ( V'~' Petition ( ) Appeal Writ of Execution Issued: Custody Assumpsit Appearance For: Divorce ( ) Mortgage Foreclosure ( ) Change of Name ( ) Ejectment ( ) Quiet Title ( ) Appt. of Viewers ( ) Replevin ( ) Declaration of Taking ( ) ~r~. Forma Pauperis ( ) Mental Health ( ) Protective Order ( ) District Justice ( ) Kl_t~J. [t4. gt~t'xz3 AND NOW, upon consideration o{ tho. attached ¢-omp!9!~ it is hereby directed that the parties and their respective counsel appear u~ure._,J ucwt~,, ~. ~ ~i' v,. the Conciliator, on the ~'/.& day ~ ~*~ht~. ;xdc/e~ - _. e~ . , .-- ~ ___ ~. .... .... , ,at 1 2 ~ ~,t~' e~,,.~O I N, for a Pre-Hearinfl Custody Ooniomneo.. See Order oI Coua, filed /sl~;~1 d~ ~ Cm~ Oonoil~tor~d~ ~,. II-lq-O J~ 12~2001-the p~tSes ~d pla~t~ff's eo~sel~hav~ng ap~ared for a custody conference on J~ua~ 8~2001,~fore ~udSth A. Calk~n~Esqu~e,and havSng reached a~e~t ~th regards to the best ~nterests ~d ~lf~e of their ~nor ~ld~St 5s hereby 0~ ~ DE~ as follow (1)The parties will share joint legal custody of Michael A. Konetsco,born March 14,1995. (2)Primary physical custody of the minor child shall be with the Mother,Linda M. Konetsco. (3)Father,Michael A. Konetsco,shall have partial custody of the minor child. See Visitation Schedule. /s/Todd Hoover,Judge. Copies To Atty 1-12-01 January 19, 2001 - The parties, having appeared for a custody conference on January 8~ 2001, before Judith A. Calkin, Esquire, and an Order dated January 12, 2001 is hereby amended to read as follows: 1. The correct name of the minor child is Andrew MichaeI Konetsco, born March 14, 1995. In all other respects the Order of January 12, 2001, shall remain in full force and effect Date/Amount (OVER) Date/Amount Filing Fee ()(~1~ '~ Ot~~ Adm. Fee-Divorce A~. Appe~ce ~ ~ ~ Adm. Fee- Custody /00 ~O Sheriffs Costs App't. of Master Disconfinu~ce Cash Bond Praecipe for ~gt. Ce~. of Read.ess 'PaITg ',-r,~ElOD ~I0 h~GtIO GM~ aaS agpnp '~aAOOH ppo,I, /S/ GROAII~0O 000Z S 6~6~ Date: 3/.~_5/2003 Time: 03:15 PM Page 1 of 1 Dauphin County ROA Report Case: 2000-CV-4959-CU Current Judge: No Judge Linda M Konetsco vs. Michael A Konetsco CustodyNisitation User: LGARCIA Date Judge 11/~2000 10/9/2001 2/14/2003 2/18/2003 2/20/2003 3/6/2003 3/19/2OO3 New Civil Case Filed This Date. See Docket Book for prior entries. ...the parties and their respective counsel having appeared for a custody conference on Oct 2, 2001 before Judith A Calkin, Esquire and having reached agreement with regards to the best interest and welfare to the minor child, it is hereby ORDERED and DECREED as follows: 1. It is the intention of the parties and the parties agree that they will share joint legal custody of Andrew Michael Konetsco born Mar 14, 1995. 2. Primary physical custody of the minor child during the school shall be with the Mother Linda M Konetsco. 3. During the school year Father Michael A Konetsco shall have partial custody of the minor child in accordance with the following schedule: See Visitation Schedule. ,See Complete Order. Filed 10-09-01. Petition for leave to proceed in forma pauperis, filed Custody complaint, filed ORDER GRANTING LEAVE TO PROCEED IN FORMA PAUPERIS approved by the Court. 02-18-2003. Upon consideration of the attached Complaint it is hereby directed that the parties and their respective counsel appear before the Conciliator, on the 4th day of March 2003, at 11:00, AM, on the 4th Floor, Dauphin County Courthouse, Front and Market Streets, Harrisburg, Pennsylvania, for a Pre-Hearing Custody Conference. See Order of Court, filed. Copies to Concil. 02-20-2003. It is hereby ORDERED AND DECREED that the above-captioned case is hereby transferred to Cumberland County, Pennsylvania because both parents and the minor child have resided in Cumberland for a period in excess of six months and there is no significant information concerning the child located in Dauphin County. See ORDER, filed. Copy to Concil. 03-07-2003. The Prothonotary is hereby ORDERED AND DIRECTED to transfer the above-captioned case to Cumberland County, Pennsylvania because both parents and the minor child have resided in Cumberland County for a period in excess of six months and there is no significant information concerning the child located in Dauphin County. See ORDER, filed. No Judge No Judge Todd A. Hoover No Judge No Judge Jeannine Turgeon Mark T. Silliker Todd A. Hoover Todd A. Hoover LINDA M. KONETSCO, Plaintiff VS. MICHAEL A. KONETSCO, Defendant IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA qqS _s. 000 CIVIL ACTION -- LAW CUSTODY/VISITATION ORDER OF COURT YOU, MICHAEL A. KONETSCO, Defendant, have been sued in court to (obtain) (modify) custody, partial custody or visitation of the child: ANDREW MICHAEL KONETSCO. You are ordered to appear in person at , at q,'/0' o'clock conciliation or mediation conference. pretrial conference. ( ) A hearing before the court. If you fail to appear as provided by this order an order, for custody, partial custody or YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 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. DAUPHIN COUNTY LAWYER REFERRAL SERVICE 213 North Front Street Harrisburg, PA 17101 (717) 232-7536 The Court of Common Pleas of Dauphin County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and visitation may be entered against you or the court may issue a warrant for your arrest. 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 heating. THE COURT: Dated: II [lc/ ]~.) LINDA M. KONETSCO, Plaintiff VS. MICHAEL A. KONETSCO, Defendant IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA .s_ 000 CIVIL ACTION m LAW CUSTODYNISITATION COMPLAINT IN CUSTODY AND NOW, comes the Plaintiff, LINDA M. KONETSCO, by and through her attorneys, the law offices ofBATUR1N & BATURIN, and respectfully sets forth the Plaintiff's Complaint as follows: 1. The Plaintiff is LINDA M. KONETSCO, an adult individual, sui juris, residing at 4005 Green Street, Harrisburg, Dauphin County, Pennsylvania 17110. 2. The Defendant is MICHAEL A. KONETSCO, an adult individual, sui juris, residing at 922 Harrisburg Pike, Carlisle, Cumberland County, Pennsylvania, 17013. 3. The Plaintiff and Defendant are the natural parents of one (1) minor child, ANDREW MICHAEL KONETSCO, bom March 14, 1995, being 5 years of age. Said minor child is the subject of this Custody Complaint. The child was not bom out of wedlock. Plaintiff and Defendant were married on September 21, 1991, and are presently 5. separated. 6. The child is presently in the custody of his natural mother and residing at 4005 Green Street, Harrisburg, Dauphin County, Pennsylvania. 813 Grantham Road 1996 to Grantham, PA 4/14/00 4005 Green Street 4/14/00 to Harrisburg, PA Present Said minor child has resided at the following addresses since birth: PERSONS RESIDED WITH Natural Mother/Father Natural Mother 8. Plaintiff/natural mother seeks full legal and primary physical custody of ANDREW MICHAEL KONETSCO. 9. Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the aforementioned minor child. 10. Plaintiff has no information of a custody proceeding concerning the minor child pending in a court of this Commonwealth. 11. Plaintiff knows of no other person or party to the within proceeding who has physical custody of ANDREW MICHAEL KONETSCO or who claim to have custody or visitation rights with respect to said child. 12. The best interest and permanent welfare of the said minor child will be served by granting the relief requested because: a. Plaintiff/natural mother is well able to adequately provide for the continuing health, educational needs and general welfare of the child; b. Plaintiff/natural mother is well able to adequately provide the said child with a proper and wholesome environment, physically, emotionally, psychologically and socially, within which to live; 2 c. Plaintiff/natural mother is able to provide said child with a stable environment. and Defendant/natural father is not able to provide said child with a stable environment. d. Plaintiff/natural mother has been said child's primary caretaker and care giver since the child's birth. e. It is in the best interest of the said child generally that primary physical and legal custody be granted to the natural mother, LINDA M. KONETSCO, Plaintiff herein. WHEREFORE, Plaintiff, LINDA M. KONETSCO, respectfully requests that this Honorable Court grant the relief requested, and any other relief deemed appropriate, and enter a Final Order granting primary legal and physical custody of said minor child, ANDREW MICHAEL KONETSCO, to the Plaintiff/natural mother, LINDA M. KONETSCO. Respectfully submitted, BATUR1N & BATURIN BY: MAI)ELAINE N. BATURIN, ESQUIRE Attomey I.D. No. 68971 717 North Second Street Harrisburg, PA 17102 (717) 234-2427 (Attorney for Plaintiff) Dated: VERIFICATION I VERIFY THAT THE STATEMENTS MADE IN THIS COMPLAINT ARE TRUE AND CORRECT AND THAT THE DOCUMENT IS SUBMITTED IN GOOD FAITH. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA. C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES AND THAT THE COURT MAY IMPOSE AN APPROPRIATE SANCTION FOR A BAD FAITH VIOLATION. 'L~A M. KON~TS 0 LINDA M. KONETSCO, Plaintiff VS. MICHAEL A. KONETSCO, Defendant IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. 4959 - S - 2000 CIVIL ACTION -- LAW CUSTODY/VISITATION CERTIFICATE OF SERVICE I, Madelaine N. Baturin, Esquire, of the law firm ofBaturin & Baturin, attorneys for the Plaintiff in the above captioned matter, do hereby certify that on November 14, 2000, I deposited in the United States Mail, Harrisburg, Pennsylvania, an article of Certified Mail - Return Receipt Requested, a certified copy of the Complaint In Custody, Notice to Defend and Order of Court attached thereto, beating Article No. Z 483 895 058, addressed to: Michael A. Konetsco, 922 Harrisburg Pike, Carlisle, PA 17013. The said article of Certified Mail, as shown by the Postal Return Receipt Card was received by the Defendant herein on November 15, 2000, was signed for, and which card is attached hereto and marked as Exhibit "A", along with the deposit slip dated November 14, 2000, for said article of Certified Mail aforementioned. BATURIN & BATURIN By: Madelaine N. Bamrin, Esquire Attorney I.D. No. 68971 717 N. Second Street Harrisburg, PA 17102 (717) 234-2427 Attorneys for Plaintiff Dated: November 20, 2000 Z 483 895 ~58 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Do not use for International Mail (See reverse Sent to Michael A. Konetsco Street & Number 922 Harrisburg Pike Post...Offic~,, ~at%& ZIP ~,q~e car±is-e, ~ 17013 Postage $ .5 5 Certified Fee 1,4'0 Spedal Delivery Fee Restricted Delivery Fee Retum Receipt Showing to Whom & Date Delivered Return Receipt Showing t~ When, Date, & Adae~ee's Add~s 1.25 TOTAL Postage & Fees $ 3.2 0 Postmark or Date 11/14/00 S R: · Complete items 3, 4a, and 4b. · Print your name and address on the reverse of this form so that we can return this c~rd to yo~. · Attach this form to the front of the mailpiece, or on the back if space does not permit. · Write 'Return Receipt Requested' on the mallpiece below the article number. · The Retum Receipt will show to whom the article was delivered and the date delivered. I a~o wish to receive the following sewices (for an extra fee): 1. [] Addressee's Address 2. [] Restricted Delivery Consult postmaster for fee. o Carlisle, PA 17013 ~ 5. Received By: (Pdnt Name)~ / 3. Article Addressed to: Michael A. Konetsco 922 Harrisburg Pike --~ PS Form 3811, December 1994 4a. Article Number ~. 483 895 O58 4b. Service Type [] Registered ~ertified [] Express~~ [] Insured [] Return I:~eipt~ [] COD ~o~~ Do. Bric ~otum ~oipt EXHIBIT "A" LINDA M. KONETSC0, Plaintiff vs. MICHAEL A. KONETSCO, Defendant : NO. 4959 S. : : IN CUSTODY : iNSTRUCTIONS Case settled-se.e attached order Case continued Case not settled Judith A. Calkin, Esquire Date Submitted: 1/11/01 IN THE COURT OF COMMON PLEAS DAUPHIN coUNTY, PENNSYLVANIA 2000 Motion to Discontinue No Interim order See attached Interim order Assign to Judge Reassign to Judge LINDA M. KONETSCO, Plaintiff vs. MICHAEL A. KONETSCO, Defendant IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA No. 4959 S. 2000 IN CUSTODY AND NOW, to wit this /~ay of , 2001~-the parties and plaintiff,s counsel, having appeared for a custody conference on January 8, 2001, before Judith A. Caikin, Es~ire, and having reached agreement with regards to the best interest and welfare of their minor child, it is hereby O~E~D AND DEC~ED as follows: 1. The parties will share joint legal custody of Michael A. Konetsco, born March 14, 1995. The parties agree that major decisions concerning their child, including, but not necessarily limited to, the child,s health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the child,s best interest. Each party agrees not to impair the other party's rights to shared legal custody of the child. Each party agrees not to attempt to alienate the affections of the child from the other party. Each party shall notify the other of any activity or circumstance concerning their child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However~ that parent shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party as a parent. 2. Primary physical, custody of the minor child shall be with the Mother, Linda M. Konetsco. 3. Father, Michael A. Konetsco, shall have partial custody of the minor child on alternating weekends from Friday at 6:00 p.m. until Monday morning when the child is delivered to school. For so long as there is an existing PFA, the Friday pick up will occur at the YWCA Visitation Center. If there is no PFA the parent beginning their uustodial period will provide the transportation. Until father has a residence the periods of partial custody will occur at the residence of the paternal grandmother, Mary Konetsco. 4. The parents will alternate the following major holidays: Easter, Memorial Day, Fourth of July, Labor Day, and Thanksgiving. The custodial period shall run from 9:00 a.m. to 6:00 p.m. 5. Mother will have the child every December 24th until December 25th at 10:00 a.m. aid father will have the child every December 25th at 10:00 a.m. u~'~til December 26th at 6:00 p.m. 6. Father shall have custody on Fathers,s Day from 9:00 a.m. to 6:00 p.m. and Mo-~her shall have custody of Mother's Day from 9:00 a.m. to 6:00 p.m. 7. The holiday schedule shall take precedence over the regular custody schedule. 8. Durin9 any period of custody or visitation the parties to this order shall not possess or use any controlled substance, neither shall they consume alcoholic beverages to the point of intoxication. Neither will have any alcoholic beverages when they are driving the chi2.d nor shall they use tobacco in the car with the child. The parties shall likewise assure, to the extent possible, that other household members and/or house 9uests comply with this prohibition. 9. Both parents shall refrain from making derogatory comments about the other paren~ in the presence of the child and to the extent possible shall prevent third parties from making such comments in the presence of the child. BY THE COURT: Jo Date Submitted: 1/19/01 JAC Report LINDA M. KONETSCO, Plaintiff MICHAEL A. KONETSCO, Defendant : IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNSYLVANIA : : : NO. 4959 S. 2000 : : IN CUSTODY X INSTRUCTIONS Case settled-see attached Order Case continued Case not settled Motion to Dismiss No Interim Order See attached Interim Order Assign to Judge Reassign to Judge LINDA M. KONETSCO, Plaintiff vs. MICHAEL A. KONETSCO, Defendant DAUPHIN COUNTY, PENNSYLVANIA IN THE COURT OF COMMON PLEAS NO. 4959 S. 2000 CHILD CUSTODY AMENDED ORDER OF COURT AND NOW, to wit this/~day of~ , 2001, the parties, having appeared for a custody conference on January 8, 2001, before Judith A. Calkin, Esquire, and an Order dated January 12, 2001 is hereby amended to read as follows: 1. The correct name of the minor child is Andrew Michael Konetsco, born March 14, 1995. In all other respects the Order of January 12, 2001, shall remain in full force and effect. BY THE COURT: Jo IN THE COURT OF COMMON PI JF~AS OF DAUPHIN COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LINDA M. KONETSCO, : Plaintiff/Respondent : MICHAEL A. KONETSCO, Defendant/Petitioner No. 4959 S 2000 IN CUSTODY ORDER OF COURT AND NOW, /~,'~/d~ Z~~/~ ., upon consideration of the attached Petition for Modification, it is hereby directed that the parties and their respective counsel appear before Judith A. Calkin, Esquire, the Conciliator, on the t~_ ~'( day of ~ 2OOl , at / 0 ,~/5' ~ .m., at ~/t~ ~---~_ 4~ ~-~ ~o ~ /d~ g .~ p~.~ 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 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. By: FOR THE COURT: Ju~h A. Calkin, Esquire Custody Conciliator The Court of Common Pleas of Dauphin County is required by law to comply with the Americans with Disabilities Act of 199o. 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 heating or business before the Court. You must attend the scheduled Conference or Heating. YOU SHOUI.D 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. Dauphin County Lawyer Referral Service 213 North Front Street Harrisburg, PA 17101 (717) 232-7536 IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA CML ACTION - LAW LINDA M. KONETSCO, Plaintiff/Respondent Ve MICHAEL A. KONETSCO, Defendant/Petitioner NO. 4959 S 2000 IN CUSTODY ~ PETITION FOR MODIFICATION OF CUSTODY ORDER AND NOW comes MICHAEL A. KONETSCO by and through his attorney, Maryann Murphy, Esquire, of MIDPENN LEGAL SERVICES, and avers as follows: 1. Defendant/Petitioner is MICHAEL A. KONETSCO who currently resides at 922 Harrisburg Pike, Carlisle, Cumberland County, Pennsylvania. 2. Plaintiff/Respondent is LINDA M. KONETSCO whose local address is 4005 Green Street, Harrisburg, Dauphin County, Pennsylvania. 3. Petitioner and Respondent are the biological parents of one (1) minor child, namely, ANDREW MICHAEL KONETSCO, born March 14, 1995. 4. A prior Order dated January 12, 2OOl granted Petitioner and Respondent shared legal custody of the minor child, with primary physical custody in Respondent. (a copy of this Order is attached hereto, incorporated by reference herein, and marked as Exhibit "A"). 5. Petitioner avers that it is in the best interests of the minor child that he be granted primary physical custody. Since the inception of the Custody Order, Respondent has disregarded a number of provisions in the Order to the detriment of the minor child and to the detriment of Petitioner's relationship with the minor child, including but not limited to, the following: (a) (b) (c) (d) (e) (g) (h) Respondent uses alcohol to excess when the minor child is with her, and is often intoxicated when the parties speak on the phone and when they transfer custody; Respondent makes disparaging remarks about Petitioner and his sons in the presence of the minor child; Respondent makes disparaging remarks to Petitioner in the presence of the minor child; Respondent spends the majority of the time in Juniata County where her boyfriend resides, and is infrequently at her Green Street address; The minor child will begin first grade in the fall, and Petitioner does not believe Respondent will be responsible in ensuring the child's attendance since she is rarely at the Green Street address; Respondent frequently threatens Petitioner that he cannot exercise his custodial time with the child; Respondent did not allow the minor child to be with Petitioner on Father's Day because she felt it was more important for him to go fishing with her boyfriend; Respondent does not alternate holidays with Petitioner as is stated in the Order. 6. Although the parties separated in April of c, ooo and the Custody Order was entered on January 12, 2OOl, Petitioner and Respondent continued to reside together on an irregular basis until May of 2OOl. Since that time, Respondent has attempted to alienate Petitioner and the minor child. 7. Petitioner believes that the child is being used by Respondent to hurt him, however, in the process, the child is being hurt. 8. Petitioner avers that he will make the minor child available to Respondent and will encourage her relationship with the child if he is granted primary physical custody. 9. Petitioner believes that the best interests and permanent welfare of the minor child, ANDREW MICHAEL, will be served if he is granted primary physical custody with a reasonable partial custody schedule for Respondent. WHEREFORE, Defendant/Petitioner requests this Honorable Court to modify the existing Custody Order and grant him primary physical custody of the minor child. Respectfully submitted, Maryanr[JMurphy, Esquird [] MIDPENN LEGAL SERVICES 213-A North Front Street Harrisburg, PA 17101 (717) 232-0581 I.D. # 61900 Attorney for Defendant/Petitioner VERIFICATION I, MICHAEL A. KONETSCO, verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of x8 Pa.C.S. §4904, relating to unsworn falsification to authorities. '~ ~HA~L A~-KONg~Co LINDA M. KONETSCO, Plaintiff vs. MICHAEL A. KONETSCO, Defendant IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA No. 4959:S. 2000 IN CUSTODY AND NOW, to wit this 13 day of , 200~j the__. parties and plaintiff's counsel, having appeared for a custody conference on January 8, 2001, before Judith A. Caikin, Esquire, and. having reached agreement with regards to the best interest and welfare of their minor child, it is hereby ORDERED AND DECREED as follows: 1. The parties will share.joint legal custody of Michael A. Konetsco, born March 14, 1995. The parties agree that major decisions 'concerning their child, including, but not necessarily limited to, the child's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the child's best interest. Each party agrees not to impair the other party's rights to shared legal custody 6f the child. Eac~ party agrees not to attempt to alienate the affections of the child from the other party. Each party shall notify the other of any activity or circumstance concerning their child that could reasonably be expected to be of concern to the other. Day to day decisions shall : be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the child at the time of the emergency shall be permittec to make any iLt~ediate decisions necessitated thereby. However~ that parent s~all inform the other of the emergency and consult %iith him or her as soon as possible. Each party shall be entitled tD complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given tc either party as a parent. 2. Primary physicai custody of the minor child shall be with the Mother, Linda M. Konetsco. 3. Father, Michael A. Konetsco, shall have partial custody of the minor child on alternating weekends from Friday at 6:00 p.m. until Monday morni'~g when the child is delivered to school. For so long as there is an existing PFA, the Friday pick up will occur at the YWCA Visitation Center. If there is no PFA the parent beginnin~ their custodial period will provide the transportation. Until father has a residence the periods of partial custody will occur at the residence of the paternal grandmother, Mary Konetsco. 4. The parents will alternate the following major holidays: Easter, Memorial Day, Fourth of July, Labor Day, and Thanksgiving. The custodial period ~.hall run f~om 9:00 a.m. to 6:00 p.m. 5. Mother will have the child every December 24th until December 25th at 10:00 a.m. a~d father will have the child every December 25th at 10:00 a.m. ~'til December 26th at 6:00 p.m. 6. Father shall have custody on Fathers's Day from 9:00 a.m. to 6:00 p.m. and Mother shall have custody of Mother's Day from 9:00 a.m. ~o 6:00 p.m.: 7. The holiday schedule shall take precedence over the regular custody schedule. 8. During any period of custody or visitation the parties to this order shall not possess or use any cOntrolled substance, neither shall they consume alcoholic beverages to the point of intoxication. Neither will have any alcoholic beverages when they are driving the chi~.d nor shall they use tobacco in the car with the child. The parties shall likewise assure, to the extent possible, that other household members and/or house 9uests comply with this prohibition. ~9. Both parents skall refrain from making derogatory comments about the other paren~ in the presence of the child and to the extent possible shall prevent third parties from making such comments in the presence of the child. BY THE COURT: J. IN THE COURT OF COMMON pLEAS OF DAUPHIN cOUNTY, PENNSYLVANIA cML ACTION - LAW LINDA M. KoNETSCO, ' Plaintiff/Respondent : :NO. 4959 S 2ooo MICHAEL A. KoNETSCO, : Defendant/Petitioner : PRA~CIPE TO PROCEED IN FoRM~ PAUPERIS To the Prothonotary: Kindly allow, MICHAEL A. KONETSCO, Defendant/Petitioner, to proceed in forma ~. I, Maryann Murphy, Esquire, of MidPenn Legal Services, attorney for the party proceeding in forma ~, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. MidPenn Legal Services 213-A North Front Street Harrisburg, PA 17xo~ (7x7) 232-O581 I.D. # 6x9oo Attorney for Defendant/Petitioner- Date Stephen E. Farina, Prothonotary IN THE COURT OF COMMON PI,F, AS OF DAUPHIN COUNTY, CIVIL ACTION - LAW LINDA M. KONETSCO, Plaintiff/Respondent Vo MICHAEL A. KONETSCO, Defendant/Petitioner :NO. 4959 S 2000 : : IN CUSTODY PENNSYLVANIA AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am MICHAEL A. KONETSCO, Defendant/Petitioner in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: Address: (b) Social Security Number: If you are presently employed, state Employer: N/A Address: N/A Salary or wages per month: Type of work: N/A MICHAEL A. KONETSC0 c)22 Harrisburg Pike, Carlisle, PA 17013 166-46-2682 N/A N/A If you are presently unemployed, state Date of last employment: Salary or wages per month: Type of work: highway flagging (c) Other income within the past twelve months Business or profession: -o- Other self-employment: -o- Interest: -o- Dividends: -o- Pension and annuities: -o- Social Security benefits: -o- Support payments: -o- Disability payments: -o- July 2om $2,4oo.oo gross per month Workman's compensation: -o- Public Assistance: -o- Other: -o- (d) Other contributions to household support (Wife)(Husband) Name: N/A (the parties are separated) If your (husband) (wife) is employed, state Employer: N/A Salary or wages per month: N/A Type of work: N/A Unemployment compensation and supplemental benefits: $242.00 per week from 10/OO-51/01 (e) (f) Contributions from children: -o- Contributions from parents: -o- Other contributions: -o- Property owned Cash: $30.00 Checking Account: $e5.oo Savings Account: -o- Certificates of Deposit: -o- Real Estate (including home): N/A Motor vehicle: Make Pontiac Cost $1,000.00 Stocks; bonds: -o- Other: -o- Debts and obligations Mortgage: -o- Rent: -o- Year 1987 Amount owed Loans: - o- Monthly Expenses: approximately $.~oo.oo (g) Persons dependent upon you for support (Wife) (Husband) Name: Children, if any: Name: Andrew N/A Age: 6 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Date: B/~ j o [ ~I~._EL A. kONETSCO Entered by IN THE cOURT OF COMMON pLF_a~ OF DAUPHIN cOUNTY, cML ACTION - LAW pENNSYLVANIA LINDA M. KoNETSCO, Plaintiff/Respondent MICHAEL A. KONETSCO, Defendant/Petitioner PRA~CIPE TO PROCEED IN FO~ PAUPERIS To the Prothonotary: Kindly allow, MICHAEL A. KONETSCO, Defendant/Petitioner, to proceed i__n forma aup_g_U_p_e~. I, Maryann Murphy, Esquire, of MidPenn Legal Services, attorney for the party proceeding i_B forma ~, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of lit~gatxon ~s attached hereto. MidPenn Legal Services 213-A North Front Street Harrisburg, PA 171ol (717) 232-°581 AUG 0 Date I.D. # 61900 Attorney for Defendant/Petitioner Stephen E. Farina, Prothonotary pLEAS OF DAUPHIN COUNTY, pENNSYLVANIA IN THE coURT OF COMMON LAW cML ACTION' LINDA M. KONET$CO, Plaintiff ]Respondent MICHAEL A. KONETSCO, Defendant/Petitioner :NO. 4959 S 2ooo :IN cUSTODY ORX oF IN sUPP AU~PERIS FOR LEAVE TO PK~r~- ! x. I am ~IC~L~ KO~CO, Defendant/Petitioner in the above ma~er and because of my finandal condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. ~. I am unable to obtain ~n~ ~om anyone, inclu~ng my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my abiliW to pay the ~ees and costs is true and correct. (a) Name: MICHEL A. KoNETSCO Address: ~ ~) Sodal Securi~ Number: ~ If you are presently employed, state N/A Employer: ~ Address: ~~ SalaU or wages per month: ~ T~e of work:~ 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 28 Pa. C.S. 4904, relating to unsworn falsification to authOrities. Date:_~,/3 / O_~_t Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Hamsburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff I. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania County of Dauphin Sheriff's Return No. 4959-S -2000 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for KONETSCO LINDA M the PLAINTIFF named in the within ORDER OF COURT & CUSTODY COMPLAINT and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, September 10, 2001 PER JAMES WILLIRD, STATED THAT THE DEFENDANT NO LONGER LIVES AT 4005 GREEN ST, HBG. SHE MAYBE LIVING IN THE NEWPORT AREA. So Answers, Sheriff of Dauphin County, Pa. KONETSCO LINDA M IN THE COURT OF COMMON P~ OF DAUPHIN COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LINDA M. KONETSCO, Plaintiff/Respondent Vo MICHAEL A. KONETSCO, Defendant/Petitioner : No. 4959 S 2ooo : : IN CUSTODY ORDER OF COURT Li AND NOW, , upon consideration of the attached Petition for bMe~od~ c~t~int, hi~i. sc~le~ienb~ Ed~eu~;;~ tthhe~ ~;il~ aatlir~ So ~;~ ~h e i~ ~p e c~; ~u~. 1~ ef~;~t ~' ' ' ' ' ' ' ' 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: Judith A. Calkin, Esquire Custody Conciliator The Court of Common Pleas of Dauphin County is required by law to comply with the Americans with Disabilities Act of 199o. 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. Dauphin County Lawyer Referral Service 213 North Front Street Harrisburg, PA 17101 (717) 232-7536 IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA CML ACTION - LAW LINDA M. KONETSCO, Plaintiff/Respondent Ve MICHAEL A. KONETSCO, Defendant/Petitioner NO. 4959 S 2ooo~:: IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY ORDER AND NOW comes MICHAEL A. KONETSCO by and through his attorney, Maryann Murphy, Esquire, of MIDPENN LEGAL SERVICES, and avers as follows: 1. Defendant/Petitioner is MICHAEL A. KONETSCO who currently resides at 922 Harrisburg Pike, Carlisle, Cumberland County, Pennsylvania. 2. Plaintiff/Respondent is LINDA M. KONETSCO whose local address is 4005 Green Street, Harrisburg, Dauphin County, Pennsylvania. 3. Petitioner and Respondent are the biological parents of one 0) minor child, namely, ANDREW MICHAEL KONETSCO, born March ~4, ~995. 4. A prior Order dated January ~2, 2oo~ granted Petitioner and Respondent shared legal custody of the minor child, with primary physical custody in Respondent. (a copy of this Order is attached hereto, incorporated by reference herein, and marked as Exhibit "A"). 5. Petitioner avers that it is in the best interests of the minor child that he be granted primary physical custody. Since the inception of the Custody Order, Respondent has disregarded a number of provisions in the Order to the detriment of the minor child and to the detriment of Petitioner's relationship with the minor child, including but not limited to, the following: (a) (b) (c) (d) (e) (0 (g) (h) Respondent uses alcohol to excess when the minor child is with her, and is often intoxicated when the parties speak on the phone and when they transfer custody; Respondent makes disparaging remarks about Petitioner and his sons in the presence of the minor child; Respondent makes disparaging remarks to Petitioner in the presence of the minor child; Respondent spends the majority of the time in Juniata County where her boyfriend resides, and is infrequently at her Green Street address; The minor child will begin first grade in the fall, and Petitioner does not believe Respondent will be responsible in ensuring the child's attendance since she is rarely at the Green Street address; Respondent frequently threatens Petitioner that he cannot exercise his custodial time with the child; Respondent did not allow the minor child to be with Petitioner on Father's Day because she felt it was more important for him to go fishing with her boyfriend; Respondent does not alternate holidays with Petitioner as is stated in the Order. 6. Although the parties separated in April of 2000 and the Custody Order was entered on January 12, 2OOl, Petitioner and Respondent continued to reside together on an irregular basis until May of 2OOl. Since that time, Respondent has attempted to alienate VERIFICATION I, MICHAEL A. KONETSCO, verify that the statements made in the foregoing document are tr~e and correct. I understand that false statements herein are made sa~jec~ ~o the penalties of z8 Pa.C.S. ~49o4, relating ~o answorn falsification ~o authorities. parent having physical custody 9f the child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However~ that parent s~all inform the other of the emergency and consult %~ith him or her as soon as possible. Each party shall be entitled tD complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given tc either par'ty as a parent. 2. Primary physicai custody of the minor child shall be with the Mother, Linda M. Konetsco. 3. Father, Michael A.' Konetsco, shall have partial custody of the minor child on alternating weekends from Friday at 6:00 p.m. until Monday morni'~g when the child is delivered to school. For so long as there is an existing PFA, the Friday pick up will occur at the YWCA Visitation Center. If there is no PFA the parent beginning their custodial period will provide the transportation. Until father has a residence the periods of partial custody will occur at the residence of the paternal grandmother, Mary Konetsco. 4. The parents w±ll alternate the following major holidays: Easter, Memorial Dalf, Fourth of July, Labor Day, and ~a~ f~om 9 00 a.m. to Thanksgiving. The custodial perio~ ~.~1 run : 6:00 p.m. 5. Mother will have the child every December 24th until December 25th at 10:00 a.m. a~d father will have the child every December 25th at 10:00 a.m. ~-~til December 26th at 6:00 p.m. 6. Father shall have custody on Fathers's Day from 9:00 a.m. to 6:00 p.m. and Mother shall have custody of Mother's Day from 9:00 a.m. [o 6:00 p.m.{ 7. The holiday schedule shall take precedence over the regular custody schedule. 8. During any pe~3iod of custody or visitation the parties to this order shall not possess or use any cOntrolled substance, neither shall they consume alcoholic beverages to the point of intoxication. Neither will have any alcoholic beverages when they are driving the child nor shall they use tobacco in the car with the child. The par~ies shall likewise assure, to the extent possible, that otherhousehold members and/or house ~uests comply with this prohibition. ~9. Both parents sl~all refrain from making derogatory comments about the other parent in the presence of the child and to the extent possible shall prevent third parties from making such comments in the presence of tke child. BY THE COURT: Jo Sheriff KONETSCO LINDA M 4005 GREEN ST HBG, PA 00000 KONETSCO MICHAEL A VS. No. 4959-S - - -2000 ORDER OF COURT & CUSTODY COMPLAINT Directions to Sheriff of Dauphin County, PA HEARING DATE 09/04/2001 TIME 10:15 COURTROOM 0 MURPHY MARYANN 845 SIR THOMAS COURT. SUITE ll-A HBG, PA 17109 540-5100 IN THE COURT OF COMMON pI~F~AS OF DAUPHIN COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LINDA M. KONETSCO, : IN THE COURT OF COMMON PI,EAS OF DAUPHIN COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LINDA M. KONETSCO, Plaintiff/Respondent Ve MICHAEL A. KONETSCO, Defendant/Petitioner :NO. 4959 S 2ooo : IN CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, MICHAEL A. KONETSCO, Defendant/Petitioner, to proceed in forma pauperis. I, Maryann Murphy, Esquire, of MidPenn Legal Services, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. Maryann~,~Vlurphy, Esquire MidPenn Legal Services 213-A No~h Front Street Harrisburg, PA 17101 (717) 232-o581 I.D, #,6,19DO Attorney for Defendant/Petitioner Date Stephen E. Farina, Prothonotary IN THE COURT OF COMMON PI.RAS OF DAUPHIN COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LINDA M. KONETSCO, Plaintiff/Respondent Ve MICHAEL A. KONETSCO, Defendant/Petitioner :NO. 4959 S 2000 : IN CUSTODY AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am MICHAEL A. KONETSCO, Defendant/Petitioner in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: MICHAEL A. KONETSCO Address: (b) Social Security Number: If you are presently employed, state 9ee Harrisburg Pike, Ca~lisie, PA 17o13 166-46-e68e N/A Employer: N/A Address: N/A Salary or wages per month: Type of work: N/A N/A Sheriff KONETSCO LINDA M 4005 GREEN ST HBG, PA 00000 KONETSCO MICHAEL A VS. No. 4959-S - - -2000 ORDER OF COURT & CUSTODY COMPLAINT Directions to Sheriff of Dauphin Cottnty, PA HEARING DATE 09/04/2001 TIME 10:15 COURTROOM 0 MURPHY MARYANN 845 SIR THOMAS COURT. SUITE ll-A HBG, PA 17109 540-5100 If you are presently unemployed, state Date of last employment: Salary or wages per month: July 2001 $2,400.00 gross per month Typ.e of work: highway flagging (c) Other income within the past twelve months Business or profession: -o- Other self-employment: -o- Interest: -o- Dividends: -o- Pension and annuities: -o- Social Security benefits: -o- Support payments: -o- Disability payments: -o- (d) Unemployment compensation and supplemental benefits: $242.00 per week from 10/00-3/{)1 Workman's compensation: -o- Public Assistance: -o- Other: -o- Other contributions to household support (Wife)(Husband) Name: N/A (the parties are separated) If your (husband) (wife) is employed, state Employer: N/A Salary or wages per month: Type of work: N/A N/A Contributions from children: -o- Contributions from parents: -o- Other contributions: -o- (e) Property owned Cash: $30.00 Checking Account: $e5.oo Savings Account: -o- Certificates of Deposit: -o- Real Estate (including home): N/A Motor vehicle: Make Pontiac Cost $1,000.00 Stocks; bonds: -o- Other: -o- (f) Debts and obligations Mortgage: -o- Rent: -o- Year '1987 Amount owed N/A Loans: -o- Monthly Expenses: approximately $300.00 (g) Persons dependent upon you,for support (Wife) (Husband) Name: Children, if any: Name: Andrew N/A Age: 6 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 49o4, relating to unsworn falsification to authorities. Date: ~]5 ] O [ lV~I(~i-Si~L A. kONETSCO Sheri f f KONETSCO LINDA M 4005 GREEN ST HBG, PA 00000 KONETSCO MICHAEL A VS. '1 'No. 4959-S - -2000 ORDER OF COURT & CUSTODY COMPLAINT Directions to Sheriff of Dauphin County, PA HEARING DATE 09/04/2001 TIME 10:15 COURTROOM 0 MURPHY MARYANN 845 SIR THOMAS COURT. SUITE ll-A HBG, PA 17109 540-5100 Judith A. Calkin, Esquire' Date Submitted: 10/08/01 LINDA M. KNOETSCO, Plaintiff vs. MICHAEL A. KONETSCO, Defendant : IN THE COURT OF COMMON PLEAS : DAUP/~IN-'COUNTY, PENNSYLVANIA : NO. 4959 S. 200 : IN' CUSTODY : INSTRUCTIONS x Case settled-see attached Order Case continued Case not settled Motion to Discontinue No Interim Order See attached Interim Order Assign to Judge Reassign to Judge LINDA M. KONETSCO, Plaintiff vs. MICHAEL A. KONETSCO, Defendant IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA No. 4959~S. 2000 IN CUSTODY ORDER OF COURT AND NOW, to wit this ~ day of , 2001, the parties and their respective counsel, having appeared for a custody conference on October 2, 2001, before Judith A. Calkin, ~squire, and having reached agreement with regards to the best interest and welfare of their minor child, it is hereby ORDERED AND DECREED as follows: 1. It is the intention of the parties and the parties agree that they will share joint legal custody of Andrew Michael Konetsco, born March 14, 1995. The parties agree that major decisions concerning their child, including, but not necessarily limited to, the child's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the child's best interest. Each party agrees not to impair the other party's rights to shared legal custody of the child. Each party agrees not to attempt to alienate the affections of the child from the other party. Each party shall notify the other of any activity or circumstance concerning their child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possi~ble. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party as a parent. 2. Primary physical custody of the minor child during the school year shall be with the Mother, Linda M. Konetsco. 3. During the school year Father, Michael A. Konetsco, shall have partial custody of the minor child in accordance with the following schedule: a. The first, second and fourth full weekends of each month from Friday at 6:00 p.m. to Sunday at 6:00 p.m. b. At other times as the parties may mutually agree. 4. During the summer school vacation each year Father will have custody of the minor child. Mother will have the child for one (1) week in June, one (1) week in July and one (1) week in August and for three weekends. Mother will give Father thirty (30) days notice of the specific weeks and weekends. 5. The parents will share transportation. 6. The Christmas school vacation will be divided into two (2) equal segments which segments will alternate year by year. Father will have the first segment in 2001. 7. Any school spring break will be divided equally between the parents. 8. Mother's Day Weekend will be Spent with Mother and Father's Day weekend will be spent with Father. 9. The parents will share or alternate all other holidays as they may agree. 10. Each parent will have daily phone contact with the child when he is not in their primary custody. If the child has not spoken to the other parent by 8:30 p.m. each day he will place a call to the other parent. 11. Both parents will have a drug and alcohol evaluation. Father will initially pay the cost of both evaluations. Mother will reimburse the cost of her evaluation to Father within thirty (30) days of its completion. The results of the evaluations will be sent to each of the parent's counsel. Should Mother not directly reimburse Father, she will promptly request that the amount be reduced from the arrearages on her child support order. 12. The holiday schedule shall take precedence over the regular custody schedule. 13. During any period of custody or visitation the parties to this order shall not possess or use any controlled substance, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this prohibition. 14. Neither parent shall permanently relocate if the relocations would necessitate a change in the visitation schedule or if the relocation would exceed a fifty (50) mile radius without a minimum notice of sixty (60) days to the other parent. The sixty (60) day notice is designed to afford the pa~ents an opportunity to renegotiate the custodial arrangements or to have the matter listed for a Court hearing. 15. Both parents shall refrain from making derogatory con~nents about the other parent in the presence of the child and to the extent possible shall prevent third parties from making such comments in the presence of the child. 16. It is understood and stipulated by the parents that upon mutual agreement an expanded or altered schedule may be agreed between the parents for and in the best interests of the child. BY THE COURT: Jo LINDA M. KNOETSCO, Plaintiff vs. MICHAEL A. KONETSCO, Defendant X Judith A. Calkin, Esquire Date Submitted: 10/08/01 : IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNSYLVANIA : : NO. 4959 S. 2000 : : IN CUSTODY : INSTRUCTIONS Case settled-see attached Order Case continued Case not settled Motion to Discontinue No Interim Order See attached Interim Order Assign to Judge Reassign to Judge LINDA M. KONETSC0, Plaintiff vs. MICHAEL A. KONETSCO, Defendant IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA No. 4959 S. 2000 IN CUSTODY ORDER OF COURT AND NOW, to wit this ~ day of ~~ , 2001, the parties and their respective counsel, having appeared for a custody conference on October 2, 2001, before Judith A. Calkin, Esquire, and having reached agreement with regards to the best interest and welfare of their minor child, it is hereby ORDERED AND DECREED as follows: 1. It is the intention of the parties and the parties agree that they will share joint legal custody of Andrew Michael Konetsco, born March 14, 1995. The parties agree that major decisions concerning their child, including, but not necessarily limited to, the child,s health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the child's best interest. Each party agrees not to impair the other party's rights to shared legal custody of the child. Each party agrees not to attempt to alienate the affections of the child from the other party. Each party shall notify the other of any activity or circumstance concerning their child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party as a parent. 2. Primary physical custody of the minor child during the school year shall be with the Mother, Linda M. Konetsco. 3. During the school year Father, Michael A. Konetsco, shall have partial custody of the minor child in accordance with the following schedule: a. The first, second and fourth full weekends of each month from Friday at 6:00 p.m. to Sunday at 6:00 p.m. b. At other times as the parties may mutually agree. 4. During the summer school vacation each year Father will have custody of the minor child. Mother will have the child for one (1) week in June, one (1) week in July and one (1) week in August and for three weekends. Mother will give Father thirty (30) days notice of the specific weeks and weekends. 5. The parents will share transportation. 6. The Christmas school vacation will be divided into two (2) equal segments which seg~ents will alternate year by year. Father will have the first segment in 2001. 7. Any school spring break will be divided equally between the parents. 8. Mother's Day Weekend will be spent with Mother and Father's Day weekend will be spent with Father. 9. The parents will share or alternate all other holidays as they may agree. 10. Each parent will have daily phone contact with the child when he is not in their primary custody. If the child has not spoken to the other parent by 8:30 p.m. each day he will place a call to the other parent. 11. Both parents will have a drug and alcohol evaluation. Father will initially pay the cost of both evaluations. Mother will reimburse the cost of her evaluation to Father within thirty (30) days of its completion. The results of the evaluations will be sent to each of the parent's counsel. Should Mother not directly reimburse Father, she will promptly request that the amount be reduced from the arrearages on her child support order. 12. The holiday schedule shall take precedence over the regular custody schedule. 13. During any period of custody or visitation the parties to this order shall not possess or use any controlled substance, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this prohibition. 14. Neither parent shall permanently relocate if the relocations would necessitate a change in the visitation schedule or if the relocation would exceed a fifty (50) mile radius without a minimum notice of sixty (60) days to the other parent. The sixty (60) day notice is designed to afford the parents an opportunity to renegotiate the custodial arrangements or to have the matter listed for a Court hearing. 15. Both parents shall refrain from making derogatory co~,ents about the other parent in the presence of the child and to the extent possible shall prevent third parties from making such comments in the presence of the child. 16. It is understood and stipulated by the parents that upon mutual agreement an expanded or altered schedule may be agreed between the parents for and in the best interests of the child. BY THE COURT: Jo Entered bY Plaintiff Defendant IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW CUSTODY ACTION ORDER GRANTING LEAVE TO PROCEED IN FORMA PAUPERIS ,~- --: AND NOW, this day of ~ ,2~ upo_R. presentation and consideration of the within petition and attached Certification~e g~nt the relief prayed for, and grant Petitioner leave to proceed with this case in forma pauperis, without the need to pay any costs connected therewith, all of which is pursuant to Pa.R.C.P. No. 240. BY THE COURT: Mo Plaintiff Defendant IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. ~' ~' ~" ~' CIVIL ACTION - LAW CUSTODY ACTION PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS Date TO THE HONORABLE JUDGES OF SAID COURT: Pursuant to Pa. R.C.P. No. 240, I hereby certify that I am without financial resources to pay the costs associated with my custody case, and therefore believe that I am entitled to proceed in forma pauperis. In support of my petition, I have attached to it a certification of indigency and incorporate it herein by reference, a certification which fully and truthfully describes my overall financial condition at the present time. WHEREFORE, the undersigned asks leave of court to proceed in forma pauperis, without the need to pay any costs in connection with the instant custody/visitation action. Respectfully submitted, .~,-' , ¢ ×.../' .,.~.]~.~ ~, :' , Petitioner, Pro Se Plaintiff Defendant IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. ~',5- c; -g CIVIL ACTION - LAW CUSTODY ACTION CERTIFICATE OF INDIGENCY . I am the (plaintiff) ~ in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting or defending the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct: (a) Name: ,;)L'dld l,q ~ Address: ~,P Z .'J'--i.~ 1 Social Securi~ Number: (b) Employment If you are presently employed, state Employer: Address: Salary or wages per month: <o.(~, ~ >11 :~ ~'~-~'~' (c) If you are presently unemployed, state Date of last employment Salary or wages per month: Other income within the past twelve months Business or profession: ,/b/~'~./(~ Other self-employment: t//L(,'/'Dh/'~. Interests: /~/O A/' ~ Dividends: ~/~ (~ Pensions and annuities: Social Security benefits: Support payments: Disability payments: Unemployment compensation and supplemental benefits: J)k~///~, D ~ ~ ')\~. Workman's compensation: ~/(~,~ ,~ Public Assistance: /~] ~~ Food Stamps per month (average) Other: (d) Other contributions to your household support (Wife) (Husband) Name: ~./~~ · (e) If your (wife) (husband) is employed, state Employer: .A/~.'/~/~ , Salary or wages per month: Type of work: ~ ~ Contributions from children: Contributions from parents: Other contributions: Property owned Cash: ~ / ~/2 ~ Checking account: ~) Savings account: ~o<0~'', Certificates of deposit: Real estate (including home): Motor vehicle: Make ~z. rc/~ Year Cost $~_.~-~,r.z:) Amount Owed $ ~.~,,~--Z~ Stocks; bonds: /~/'/-J~ Other: ~/--J~_ (f) Debts and obligations - average per month Mortgage: Rent: Loans: ~)0¢._~' Qo~?.._., Clothing: (g) Electricity: Gas: Telephone: (z~.~(,. ~1/.5"~, Transportation: ~l;// ~Z)' Non-food household goods: Other: /~//~tVL. Persons dependent upon you for support (Wife) (Husband) Name: Children, if any: Name: ?r~[).e,~c,o i~"1, ~::)H~.'~¢oAge: 7 Other persons: Name: ~/D/{-/~-_._ .~ Relationship: 4, I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit are true and correct. understand that false statements herein are being made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. HONORABLE jUDGES OF SA~O COUP'f: certi~J that % am Cut financial . ,~ oD ~ (', No 9.40, t hereby 'fO -f~E u -,* ..... P' ' and thereCetieve that resources to pay the costs assodtated with m~ h~ffached to it to~m~ pmupedS, t~ supp°~ ut m~ petition, t mm entitled to p~oceed m inco~po~mte it he~e[n b~ ~ete~ence, ~ ceti°n which a ce¢~cati°n ut ~nd~gen~ and condition at the Pres~e' {u%ty and truthfully describes mY ovate t~nancat ~d in forma un~erSigne~ asks te~ve ut coU¢ to ~ERE~ORE, the con~ectioo ~ith the i paupedS, ~ithout the nee~ to pay any costs in custod¥1Visitati°n actiOn. Date ~_~,~ '~o t~e above u~ ~'dog o~ 6e~e~dt~9 e _ ~ (o~tot~) ~' _~ costs o~ 9~°sec ack, OB o~ uoa~e ~o ~. ~ am ~t~ga~O~. ~e~a~to9 to m~ a~W to pa~ ~e ass~tates' ~o pa~ t~e costs o~ e co tees ~ coStS is t~e ~ Sod~ sec~dW ~ ' Emp~o~men~ ~ ~o~ed, state ' . S~W o~ ~ges ~e~ (e) If your (wife) (husband) is employed, state. Employer: A/~,~,q , Salary or wages per month: .~//~,,~t Type of work: ~ ~ Contributions from children: ,,~/'~ Contributions from parents: Other contributions: //~./ Property owned Cash: ~//~'? ~, Checking account: ~ Savings account: ~ Certificates of deposit: Real estate (including home): Motor vehicle: Make ~'~-~c/~- Year Cost $ ~._.~-~,cD, Amount Owed $ ~.~,..,~-z~- Stocks; bonds: /~/"~ Other: .~. (f) Rent: Loans: Clothing: Debts and obligations - average per month Mortgage: (g) Electricity: Gas: Telephone: (~ ( Transportation: ~l?/ ~ Non-food household goods: Other: ,A/~ Persons dependent upon you for support (Wife) (Husband) Name: Children, if any: Name: ~ ~'l~.e~_uo Other persons: Name: ~/¢/,-/,~_ , Relationship: 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit are true and correct. understand that false statements herein are being made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. (~~ .CUSTODY 1 The plaintiff is ~ ' C~ [ ¢._ $ r residing . ', PA o plaintiff seeks custody of the following chik:lJren: 4. The children were bor~ wedlock. The child/ten are presently ) %_/^ I¥~ ~' who resides at in the custody oL/:~'~~~ PA. persons and at the following addresses: During the past five years, the chi~d/ren have resided with the following ~ ~b ~'~ ~; ~other of the children ,s ~ _, ~, PA. currently residing at 6. The relationship of plaintiff to the children is that of The Plaintiff currently resides with the following persons: 7. The relationship of defendant to the child/ren is that of ~ The defendant currently resides with the following persons: Name Relationship 8. Prior order was entered on. ~e._-'~. c=O. ~42) ~i~ and is attached hereto as Exhibit A. Plaintiff has no information of a custody proceeding concerning the child/ren pending in a court of this Commonwealth or any other state. Plaintiff'does not know of a person not a party to the proceedings who has physical custody of the child/ren or claims to have custody or visitation rights with respect to the child/ren. If any of the above are not true, cross it out and explain: 9. The best interest and permanent welfare of the child/ren will be served by granting the relief requested because 0 . 10. Each parent whose parental rights to the child/ren have not been terminated and that person who has physical custody of the child/ren have been named as parties to this action. WHEREFORE, pursuant to the Custody Act, 23 Pa. C.S. Section 5301, et sea., Plaintiff requests the court to grant me custody/visitation of the child/ren. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. {}4901 relating to unsworn falsification to authorities. te Plaintiff, Pro Se Phone Number , LINDA M.'KON~SCO, Plaintiff MICHAEL A. KONETSCO, Defendant IN THE COURT OF COMMON 'PLEAS DAUPHIN COUNTY, PENNSYLVANIA No. 4959 S. 2000 IN CUSTODY ORDER OF COURT AND NOW, to wit this day of , 2001, the parties and their respective counsel, having appeared for a custody conferencep ..~- on October 2, 2001, before Judith A. Calkin, Esquire, and having reached agreement with regards to the best interest and welfare of their minor child, it is hereby ORDERED AND DECREED as follows: 1. It is the intention of the parties and the parties agree that they will share joint legal custody of Andrew Michael Konetsco, born March 14, 1995. The parties agree that major decisions concerning their child, including, but not necessarily limited to, the child's health, welfare, education, religious training and upbringing shall be made by them'jointly, after discussion and consuitation with each other, with a view toward obtaining and following a harmonious policy in the child,s best interest. Each party agrees not to impair the other party,s rights to shared legal custody of the child. Each party agrees not to attempt to alienate the affections of the child from the other party. Each party sb~ll notify the other of any activity or circumstance concerning their child that could reasonably 'be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With reg~d~o any emergency decisions whic~ must be m~de, th~ parent having physical custody of the child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party as a parent. 2. Primary physical custody of the minor child during the school year shall be-with the Mother, Linda M. Konetsco. 3. During the school year Father, Michael A. Konetsco, shall have partial custody of the minor child in accordance with the following schedule: a. The first, second and fourth full weekends of each month from Friday at 6:00 p.m. to Sunday at 6:00 p.m. b. At other times as the parties may mutually agree. 4. During the summer school vacation each year Father will have custody of ~he minor child. Mother will have the child for one (1) week in June, one (1) week in July and one (1) week in August and for three weekends. Mother will give Father thirty (30) days notice of the specific weeks and weekends. 5. The parents will share transportation. 6. The Christmas school vacation will be divided into two. (2) equal segments which segments will alternate year by year. Father will have the first segment in 2001. 7. A/ly school spring break will be divided equally · ~a between ~e rents. ' , ' 8. Mother's Day Weekend will be spent with Mother and Father,s Day weekend will be spent with Father. 9. The parents will share or alternate all other holidays as they may agree. 10. Each parent will have daily phone contact with the child when he is not in their primary custody. If the child has not spoken to the other parent by 8:30 p.m. each day he will place a call to the other parent. 11. Both parents will have a drug and alcohol evaluation. Father will initially pay the cost of both evaluations. Mother will reimburse the cost of her evaluation to Father within thirty (30) days of its completion. The results of the evaluations will be sent to each of the parent's counsel. Should Mother not directly reimburse Father, she will promptly request that the amount be reduced from the arrearages on her child support order. 12. The holiday schedule shall take precedence over the regular custody schedule. 13. During any period of custody or visitation the parties to this order shall not possess or use any controlled substance, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house ~uests comply with this prohibition. 14. Neither parent shall permanently relocate if the relocations would necessitate a change in the visitation schedule or if th~ re~6eation would exceed a fift~ (50~ mile radius 'wi~hou~ a minimum notice of sixty (60) days to the other parent. The sixty (60) day notice is designed to afford the parents an opportunity to renegotiate the custodial arrangements or to have the matter listed for a Court hearing. 15. Both parents shall refrain from making derogatory comments about the other parent in the presence of the child and to the extent possible shall prevent third parties from making such comments in the presence of the child. 16. It is'understood and Stipulated by the parents that upon mutual agreement anexpanded or altered schedule may be agreed between the parents for and in the best interests of the child. BY THE COURT: Jo 112O01 Plaintiff v. · CIVIL ACTION - CUSTODY ' c, ~"~, ~-'~--~C~ 'NO. ~,C/..~-~ .Z' D. oo~ Defendant · IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their, respective counsel pppear before the Custody _C,o~er,~c~etoO, off~ice~r, o~n th~ ~.-~1 day of Jl/~O/"_~,}'7 , 20Q-~)__, at ?/.'~t'a.m./~.~ ,.,t z_xjL~,nn;n (~un?~ (_o~/rff/~_d--larrisburg, Pennsylvania, at a Pre-Hearing Custody Confer6nce. At such Conference, 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. All children age five or older need only be present upon request of the Custody Conference Officer. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent Order. 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. Dauphin County Lawyer Referral Service 213 North Front Street Harrisburg, PA 17101 (717) 232-7536 Z ~ AMERICANS WITH DISABILITIES ACT OF 1990 ~ The Court of Common Pleas of Dauphin County is required by la~: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. Date · idlaintiff Defendant : IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNSYLVANIA : : NO. ~ 5-~ 5' D, ooo : : CIVIL ACTION - LAW CUSTODY ACTION CUSTODY COMPLAINT 1. The plaintiff is ,)L/~, ~0, q L ~, ~-~ ~.~. residing ~hone) ~hone) 2. The defendant is · ~ _ /,~ /'~0 ~- . ~phone number at home is ~/7-7~-o/of and at work is 3. Plaintiff seeks custody of the following child/ran: Name Present Residence Date of Birth 4. The child/ran were bor~out of wedlock. The child/ran are'presentiy in the custody of ! i,~'/c/,'3 }~/J ]~' Ne"~-~ c_~-b who resides at ~' "'~ 5. During the past five years, the child/ren have resided with the following persons and at the following addresses: Persons Addresses Dates ~" The mother of the child/ren is currently residing at , She is sin.ql~ 6. The relationship of plaintiff to the child/ren is that of Mother/r~the'~.~ The Plaintiff currently resides with the following persons: Name Relationship _ 7. The relationship of defendant to the child/ren is that of Father~othe~r~ The defendant currently resides with the following persons: Name Relationship (~ ' , 8. Prior order was entered on O C_~"~ c'~ C)42) ~i~ and is attached hereto as Exhibit A. Plaintiff has no information of a custody proceeding concerning the child/ren pending in a court of this Commonwealth or any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child/ren or claims to have custody or visitation rights with respect to the child/ren. If any of the above are not true, cross it out and explain: 9. The best interest and permanent welfare of the child/ren will be served by granting the relief requested because · 0 .- , 0 r..3' ~J 10. Each parent whose parental rights to the child/ren have not been terminated and that person who has physical custody of the child/ren have been named as parties to this action. WHEREFORE[, pursuant to the Custody Act, 23 Pa. C.S. Section 5301, et seq., Plaintiff requests the court to grant me custody/visitation of the child/ren. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4901 relating to unsworn falsification to authorities. Plaintiff, Pro Se Phone Number LINDA M. 'KO~SCO, Plaintiff vs. MICHAEL A. KONETSCO, Defendant IN THE COURT OF COMMON 'PLEAS DAUPHIN COUNTY, PENNSYLV~IA No. 4959 S. 2000 IN CUSTODY ORDER OF COURT AND NOW, tO wit this day of , 2001, the parties and their respective counsel, having appeared for a custody conference on October 2, 2001, before Judith A. Calkin, Esquire, and having reached agreement with regards to the best interest and welfare of their minor child, it is hereby ORDERED AND DECREED as follows: 1. It is the intention of the parties and the parties agree that they will share joint legal custody of Andrew Michael Konetsco, born March 14, 1995. The parties agree that major decisions concerning their child, including, but not necessarily limited to, the child's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consuitation with each other, with a view toward obtaining and following a harmonious policy in the child's best interest. Each party agrees not to impair the other party's rights to shared legal custody of the child. Each party agrees not to attempt to alienate the affections of the child from the other party. Each party shall notify the other of any activity or circumstance concerning their child that could reasonably 'be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With reg&~-d-~to any emergency decisions whic~ must be m~de, th~ parent having physical custody of the child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party as a parent. 2. Primary physical custody of the minor child during the school year shall be-with the Mother, Linda M. Konetsco. 3. During the school year Father, Michael A. Konetsco, shall have partial custody of the minor child in accordance with the following schedule: a. The first, second and fourth full weekends of each month from Friday at 6:00 p.m. to Sunday at 6:00 p.m. b. At other times as the parties may mutually agree. 4. During the summer school vacation each year Father will have custody of ~he minor child. Mother wilt have the child for one (1) week in June, one (1) week in July and one (1) week in August and for three weekends. Mother will give Father thirty (30) days notice of the specific weeks and weekends. 5. The parents will share transportation. 6. The Christmas school vacation will be divided into two- (2) equal segments which segments will alternate year by year. Father will have the first segment in 2001. 7. Any school spring break will be divided equally -3ua~ed ~aq3o ag3 o~ II~O ~ aD-Id II~a ~q X~p qD~ 'm'd 0£:8 Aq ~ua~d ~q3o ~q3 o~ ua~ods ~ou '~ag~ q~ ~ads ag II~ pua~aa~ X~G s,~aq~ pu~ ~ag~oN q~a ~uads ag II~a pua~aaM X~G s,~ag~oN '8 MICHAEL A. KONETSCO, Plaintiff : IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNSYLVANIA VS. : NO. 4959 S 2000 LINDA M KONETSCO, : CHILD CUSTODY Defendant rT~ - AND NOW, this ~ day , , 2003 it ~s '< hereby ORDERED AND DECREED that the above-captioned case is hereby transferred to Cum.berland County, Pennsylvania because both parents and the minor child have resided in Cumberland for a period in excess of six months and there is no significant information concerning the child located in Dauphin County. BY THE COURT: Jo Stephen E. Farina Prothonotary OFFICE OF ygO I'HONOTAR¥ County of Dauphin Front & Market Streets Harrisburg, PA 17101 (717) 780-6520 Curtis R Long, Prothonotary Cumberland County Courthouse Hanover & High Street Carlisle, Pa l.$&InJ lqo / ~ RE: Michael A Konetsco Vs Linda M Konetsco Dauphin County Dkt No 4959 S 2000 Cumberland County No. April 2, 2003 Dear Sir/Madam: By Order of March 19, 2003 by Hon. Todd A Hoover, Judge The above matter has been transferred to the Court of Common Pleas of Cumberland County. I am, accordingly, sending originals of all the papers herewith. I Will appreciate the remm of the attached receipt address to the Attention: of Ms. Lisandra Garcia. Very Tmly Yours, Stephen E. Farina Prothonotary MICHAEL A. KONETSCO, Plaintiff : IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNSYLVANIA VS. NO. 4959 S 2000 LINDA M KONETSCO, : CHILD CUSTODY Defendant ORDER AND NOW THIS I~ day of ~~ , 2003, the Prothonotary is hereby Ordered and Directed to transfer the above-captioned case to Cumberland County, Pennsylvania because both parents and the minor child have resided in Cumberland County for a period in excess of six months and there is no significant information concerning the child located in Dauphin County. BY THE COURT: