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Home My WebLink About00-07914 If JULIE PANDOLFI, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-7914 CIVIL TERM MICHAEL PANDOLFI, Defendant ; CIVIL ACTION - CUSTODY AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT I served a true and correct copy of the Custody Complaint filed in the above captioned case upon Michael Pandolfi, by certified mail, restricted delivery, return receipt requested on November 9,2000 addressed to: Michael Pandolfi 3 Melwood Lane Mechanicsburg, PA 17055 and did thereafter receive same as evidenced by the attached Post Office receipt card dated November 15, 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 //II/pfJ Date ~L6.< 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff , ;~ 'i; ;', ,~! ;!! U ','j! ", ", , , 1:: ,,' ". '" ';l " :( 'I . ' ff + Custody Complaint Z 452 476 192 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Do not use for Intemational Mail See reverse Sentto MIchael Pandolfi _& Numbet 3 Melwood Lane PostOffice, state, & ZIP Code Mechanicsburg, PA 170'5 Postage $ .33 1.40 Certified Fee Special Delivery Fee Restrided Delivery Fee "' 81 Relum R6ceIpt Showing to :::: Whom & Date Delivered ." RelumReceipl5howi\lIOWOOm, ~ Dale, & Add......', Address o Q TOTAL Postage & Fees CD C'J Postmark. or Date E ~ November 9, '" 0.. 2.75 1 . 25 $ 5.73 2000 -" ~. ~ SENDER:"... '" '. , , ' "" ,,," Oiij 0 Complete iterht t ~miio~ 2: for addilio~al seniiCe~. C\) Complete items 3, 4a, and 4b. I~ CI Print your name and address on the reverse of this form so that we can re~urn thi card to you. C Attach this form to the front of the maiipiece, or on the back it s~ce cfaes not . permit. :Ii lijI'V/rite "Return Receipt R9quested~ on the mailpiece below1hEl article number. c:. ll!I'The Return Receipt will show to whom the article was delive!'$d and the date i!j !!Ielivered. 13. Article Addressed to: tIichael Pandolfi i Melwood Lane Aechanicsburg, PA 4a. Article Number Z 452 476 192 1m Certified 17055 =ag;~ Iii II: ~ = o ,.. .!! ii"'~. ~ ~ 102S95-~"'B-0.223 Domestic Retum Receipt .' i: _ ~__ 'i if i . j J I l " t I "'11: ... il ~" ~ lWllIl'l1il'll"", '" . ~~~!ilJIlIlI~~~~~ ~l~~:jl -. ~- ~ ~"V ~- -~ ~.- ' -t~' Y''''''-l''''''f' f'r"" t ~""-'1"'n_' nU~j~iH'Y-MNt'r;""-'''}if:tt''1'ift',~ o ~ ~. ? ;:g f~~ ?;,!}! vi .--. ,-';: ~' ~\~:: -"" -'-, --c: ~ ''-..) ( ~._, ,:::, <::J c: -f; :~ ,-, ,:,::: <-..~! ~.y.? -t~,,~..,_ .~~'l!F.iI~ij~M1~.b~~""!11ll~~!J'1');""<n't""f'fJ!>_r'-~'1,,-,!}f!~,"'r~W'lI~O;:WIf!$lW#m<t'il~~~Il""'j"Ijffi~"'1<;~llilllJ~ ,,"'" ""a~~~ ~ t JULIE PANDOLFI PLAINTIFF V. MICHAEL PANDOLFI DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-7914 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 17th day of November, 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on the 14th day of December ,2000, at ---.2.: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 Hubert X. Gilroy. Esq.OI1 Custody Conciliator 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 ATIORNEY AT ONCE. IF YOU DO NOT HAVE AN ATIORNEY 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, Pennsylvania 17013 Telephone (717) 249-3166 ''''''f'i.,~, , ~~ ~~J....J_~~':" ~-- - ;n.':Wiii"""""<'.ljJ>.JI';~,j'_"""-"Yu,;"i&,",_~-"",,,,,_'<!d1J"_""""-~.I,~"'~j;i,-iJiiS.'_ -'~~""."~~<I~"*,""ill!:l,toi~"N~@. ' ~~- if. ~-oo j/-~;J- 1)0 , )/-,;2;;). . &.fI ". ---,,-~ '""-~-"""~. ~ ~~~ '''-'''~~'- ~- ' "'C'l. e .~ "~ , - ~-~"'I ''"~- " ~ 'iYTi\Fd ~;O~.I!';I;'22 Hl ::::: 17 ......! Ii c'-,,-,, " r,-,',', ,'-""\i rl'!~IV I L"~'".,;-I'_'I '-"_,' . 'l;Wj'IJ , ...,: 'I'}'...._.I ,_.I 'L-" "' PENNSYLV:t\l\1IA Uif. ~ ~do -:if ~ '71~~72; ~~~ ~~,/~ /V-~~ , 1" ',' 0 _~,' rr JULIE PANDOLFI, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ~ NO. 00- '1 q I ~ CIVIL TERM : CIVIL ACTION - CUSTODY v. MICHAEL PANDOLFI, 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 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. 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 rr " JULIE PANDOLFI, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00- 7"J N CIVIL TERM : CIVIL ACTION - CUSTODY v. MICHAEL PANDOLFI, Defendant COMPLAINT FOR CUSTODY 1. Plaintiff is Julie Pandolfi, an adult individual whose residence is at 12B Richland Lane #205, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant is Michael Pandolfi, an adult individual whose residence is at 3 Melwood Lane, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of her child Gage Pandolfi, born November 4, 1990, currently residing at 3 Melwood Lane, Mechanicsburg, Cumberland County, Pennsylvania. 4. The child is presently in the custody of Defendant. 5. Since the child birth, the child has resided at the following addresses: Name Address Michael Pandolfi 3 Melwood Lane Mechanicsburg, PA 17055 12B Richland Lane #205 Camp Hill, PA 17011 Julie Pandolfi 6. The relationship of the Plaintiff to the children is that of natural mother. 7. The relationship of the Defendant to the children is that of natural father. 8. 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. 9. Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. 10. The best interest and permanent welfare of the child will be served by granting the relief requested because the parties agreed as part of their divorce '- ""J--' If settlement that Plaintiff would have the child every Monday and Wednesday and alternating Fridays, Saturdays and Sundays. Defendant would have custody on Tuesdays, Thursdays, and alternating Fridays, Saturdays and Sundays. 11. Beginning in August 2000, the child began to refuse to leave Defendant's home and come with Plaintiff. 12. Plaintiff believes and therefore alleges that Defendant is encouraging the child to refuse to go with Plaintiff because she has a new boyfriend. 13. 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 to schedule a Custody Conciliation to reduce the parties divorce agreement to an order and to order the defendant not to allow the child to remain in his household during Plaintiffs periods of Custody. Respectfully Submitted TURO LAW OFFICES It! tfro Da e ~/ff~ . Robert J. ulderig, E~ 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff " . rr c ,i , VERIFICA liON 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. I !l ,- tJ - DD Date ~ RnJ'1 Julie andolfi wr ; I'"~ 1M" """Tl ~ D ~ ~ -- . fJ; ~ (3 ~ ~ g ~ cJ 3 5=" - ~ t.:Q' ~ 0 (:::J C) C C.:I- --,', 5: :-,z: ,:.] "U (J) c~ ~,~!~ m r",' 1 -- 2::.:,' , ~~~ <Xi S~~ r::c __,2 <" ~c~ - ""-~ ,-.., '-:? "5fT! Pc ~ Z c- :Ii =< --t -< _,~~W'~~. _._...Jjill,_J~ ~-. . - g~""~J[li'!!'llW'~IM:.!i\1iI~., 1iiiij;!jj!iffili!\'1:~$~'f)!!lll*1I.\;~,_",_. '1[!T1l1J~,11_,/!.:W~~""\!lM~,' '., 0.. .,._~~,- ... JAN - 8 2DO~ v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW NO. 00-7914 CIVIL IN CUSTODY JULIE K. PANDOLFI, Plaintiff MICHAEL T.PANDOLFI, Defendant COUR.TORDER AND NOW, this Gfl' day of January, 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Julie K. Pandolfi, and the Father, Michael T. Pandolfi, shall enjoy shared legal and shared physical custody of Gage M. Pandolfi, born November 4, 1990. 2. Unless agreed otherwise by the parties, physical custody of the minor child shall be alternated on a week on/week off basis. Exchange of custody shall be every Friday at 6:00 p.m. 3. The parties shall meet again for another Conciliation Conference on Thursday, March 22, 2001 at 9:30 a.m. 4. It is understood that Mother shall not consume alcohol or be under the influence of any illegal drugs while she has custody of the minor child. 5. Both parents shall enjoy reasonable telephone contact with the minor child when the child is in the other parent's care. The parties may between themselves modifY the custody schedule if they agree. Absent any agreement, the custody schedule set forth above shall control. 6. Both parents of the minor child shall participate in family counseling. The counseling shall be scheduled with a counselor as arranged between the parties. Costs of the counseling shall be split equally between the parties after all payments are made from any applicable insurance that may cover the counseling. cc: Robert J. Mulderig, Esquire Judith A. Caulkin, Esquire Michael T. Pandolfi 3 Melwood Lane Mechanicsburg, P A 17055 BY THE COURT, .A4- 1. L~ (f) a.0- OI~/{)-()1 p. K .?> . ,'''.-- "1'0' "1 -.' le,~ ,-.' . - '-" ~ -~ ,~ '-., '~ v IN THE CqYIU OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 00 -7914 CIVIL IN CUSTODY JULIE K. PANDOLFI, Plaintiff MICHAEL T. PANDOLFI, Defendant Prior Judge; CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE I 915.3-8(b), the undersigned Custody Conciliator submits the following report; I. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Gage M. Pandolfi, bom November 4, 1990. 2. A Conciliation Conference was held on January 4,2001, with the following individuals in attendance: The Mother, Julie K. Pandolfi, with her counsel, Robert Mulderig, Esquire; and the Father, Michael T. Pandolfi, who appeared without counsel.. 3. The parties agree to the entry of an order in the form as attached. " ;;.-( 0 t DATE - ~.< "",_-"J',"""'-" ,,~-- -I ,. ~ ~ ., . ~~;. '" MAR 3 0 2001f11 JULIE K. PANDOLFI, Plaintiff i",,' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW MICHAEL T. PANDOLFI, Defendant NO. 00 -7914 CIVIL IN CUSTODY COURT ORDER AND NOW, this "3bt day of March, 2001, upon consideration of the attached Custody Conciliation Report and agreement of the parties, it is ordered and directed as follows: 1. This Court's Order of January 9, 2001 shall remain in effect. The parties shall continue with family counseling. Additionally, the parties may modifY the custody schedule pursuant to an agreement reached by the parties. 2. In the event either party desires to have another Conciliation Conference, that party may contact the Conciliator directly in writing to request that a conference be scheduled. BY THE COURT, K~~' /lL 1. .~ (ar'" ~ oyO \ o ~~ cc: Robert J. Mulderig, Esquire Michael T. Pandolfi 3 Melwood Lane Mechanicsburg, P A 17055 !I i 'I Ii:",,<__< '^'" ""',,,-j._ -~I"-^' wO'_ I ,e,,, -,','_"'-_' " "r,O;;' .-. -, ~, ~~ . JULIE K. PANDOLFI, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW MICHAEL T. PANDOLFI, Defendant NO. 00 -7914 CIVIL IN CUSTODY Prior Judge: Kevin A. Hess CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The Conciliator met with the parties and Attorney Mulderig for a second Conciliation Conference, during which the parties agree to the entry of an order in the form as attached. 3/J'110f DATE -~~< ~,~ "" - ~'9-,. I"'" ~- .- ~ ,- _ _" .,. c " ''\, -"'J ' ~ , ' OC1~ JULIE K. PANDOLFI, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW MICHAEL T. PANDOLFI, Defendant NO. 00-7914 CIVIL IN CUSTODY COURT ORDER AND NOW, this 2>:1 day of Och btx ,2001, upon consideration ofthe attached Custody Conciliation Report, it is ordered and directed as follows: I. The prior custody orders entered in this case are vacated. 2. The Mother, Julie K. Pandolfi, and the Father, Michael T. Pandolfi, shall enjoy shared legal custody of Gage M. Pandolfi, born November 4, 1990. 3. The Father shall enjoy primary physical custody ofthe minor child. 4. The Mother shall enjoy physical custody of the minor child as follows: A. On alternating weekends from Friday at 5:00 p.m. through Monday at 7:00 a.m. B. Every Wednesday from 5:00 p.m. until 7:00 a.m. on Thursday. C. After the parties have undergone counseling as set forth below and when the counselor suggests additional time for the Mother, Mother's periods of custody with the minor child shall be expanded to include every Tuesday from 5:00 p.m. until Wednesday at 7:00 a.m. 5. During the summer months, Mother shall also enjoy custody for one week during the months of June, July and August, the times to be arranged between the parties. Mother shall give Father notice at least on or before of May 151 of each year as to when she intends to exercise her weeks. It is understood that Father shall also have the ability to take vacation time with the minor child and Father shall notifY Mother in advance as to when he will be exercising vacation with the minor child. 6. The parties shall alternate custody of the minor child on holidays from 8:00 a.m. until 7:00 p.m., the holidays to be New Year's Day, Easter, Memorial Day, July 4th, Labor Day and Thanksgiving. The Mother shall have Thanksgiving 2001. i".,~ , ,.. '-, - , -'--'" .'- '" .~ '-,'- -1~~1~ , .. -',-'-~'~ -o_'f'-"~," "~-~~-,~' ,~ '-,~,-',' -~ ,,--~~.., ~,_,_"_~o", ,,_,<'; ._ "'0__' ,~,- ., ,!< ,~, ,- " ~--~ ...;..,<..,-- Iii ,n". T "e I -,-1.,,) ....,/ f 'J , - ~;: .j: Int. CUtl/;~~~;':'tJ~i'jLJ :";0' H\.f1V 1---;-fl..JNI;;,\f;'/,,: ,U,'!! j _I Vi L..'I'/'\rJtA ~~ ,_~ "_M_"~ __.~, ,.,." > _~ "~",n~ """'!'""'""'."~"_''''"" ,_ ~"UI~~~IWlil~IlJl\~"l-" em ."" -.. qc__,';;:, , . <~; ;.~:" -'"~"'"' ,,1Mlr_ -~ 7. For the Christmas holiday, the Father shall have custody of the child from 6:00 p.m. on Christmas Eve until 3:00 p.m. on Christmas Day in odd numbered years and the Mother shall have the same in even numbered years; the Mother shall have custody of the minor child from 3:00 p.m. on Christmas Day until 6:00 p.m. on December 26th in odd numbered years, and the Father shall have the same in even numbered years. 8. The Mother shall always have custody of the minor child on Mother's Day and the Father shall always have custody of the minor child on Father's Day, the timeframe being from 8:00 a.m. until 7:00 p.m. 9. Transportation for exchange of custody shall be handled such that the party receiving custody shall pick up the minor child at the other party's residence. 10. Both parties shall inform the other parent immediately of all medical appointments or any other medical, social, educational or important issues relating to the child. 11. Neither party shall disparage the other parent to the child or in any way estrange the child from the parent. 12. Both parents shall enjoy liberal and reasonable telephone contact with the minor child when the child is in the custody of the other parent. 13. The custodial parent shall provide copies of the child's report card and other reasonable papers affecting the child's education, medical condition or welfare to the other parent. 14. Both parents and the child shall participate in family counseling. Mother shall pay for the counseling provided that the counselors are a participant in Mother's health insurance plan. Mother shall select the counselor to ensure Mother's ability to take advantage of a counseling agency that will be covered through her insurance plan. BY THE COURT, cc: Robert 1. Mulderig, Esquire ~- 1f;J 1 Kd t~ ;,jJ /(J -0:< -f( i}(s Michael T. Pandolfi 3 Melwood Lane Mechanicsburg, P A 17055 ,,^,- n,_ '"", ,,1' '''' ,",',_ ','_" _-~I "'.'" , ''', c~ ,," - ,," ,,_ " H ,', _I~ ", ,_ __~ ""~,__,, , ". ,,'c. ., e,~_ . . JULIE K. PANDOLFI, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW MICHAEL T. PANDOLFI, Defendant NO. 00-7914 CIVIL IN CUSTODY Prior Judge: Kevin A. Hess CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: I. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Gage M. Pandolfi, bom November 4, 1990. 2. A Conciliation Conference was held on September 27,2001, with the following individuals in attendance: The Mother, Julie K. Pandolfi, with her counsel, Robert J. Mulderig, Esquire; and the Father, Michael T. Pandolfi, who appeared without counsel. 3. The parties agree to the entry of an order in the form as attached. rf.:l?/Ol D TE ' tJ;JJ ~. , "!__' _ _ "_1',-~__,~ _ ',~.._ ",. . ----,- . , "'. ,-, - ,,',r-, ....."., ,':n - "-~ .,