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HomeMy WebLinkAbout01-2824 FX '<Y :->~,~:r.;~." . . . . JUN 0 7 zao,t! VICTORIA E. GREEGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA V. : NO. 2001-2824 CIVIL TERM CIVIL ACTION - LAW BRETT A. GREEGER, Defendant IN CUSTODY ORDER OF COURT AND NOW, this ~ day of )~ ,2001,upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1, The Mother, Victoria E. Greeger, and the Father, Brett A. Greeger, shall have shared legal custody of Garrett Quinn Greeger, born February 2,1999. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. Mother shall have primary physical custody ofthe child. 3, follows: Father shall have periods of partial physical custody of the child as a. Beginning Jnne 14, 2001, alternating weeks from Thursday at 7 :00 p,m, to Sunday at 5 :00 p.m. b, Such other times as the parties agree. 4, birthday, Each party shall be entitled to a block of time with the child on their 5. Transportation shall be shared such that Mother will transport the child to Father's residence and Father shall return the child to Mother's residence, unless otherwise agreed by the parties, 6. Both parents shall have liberal and reasonable telephone contact with the child when the child is in the custody of the other parent. 7, The parties shall keep each other advised immediately relative to any medical care or medical emergencies concerning the child and shall further take any l_-~~'~~ "_, ^'~.",- ,-- II . T , ..~~~- ~~ ~~ !l"'l!Ii((X:;"\';;',U "".o-".,;".II!1..~ .. . ~~ necessary steps to ensure that the health and well being of the child is protected. During such illness or medical emergency, both parents shall have the right to visit the child as often as he/she desires consistent with the proper medical care of the child, 8. Neither parent shall do anything nor permit anyone else to do anything which may estrange the child from the other party, or injure the opinion of the child as to the other party, or which may hamper the free and natural development of the child's love or affection for the other party, 9. This Order is an interim Order entered pursuant to an agreement ofthe parties at a Custody Conciliation conference. Either party may contact the Conciliator within sixty days from the date of this Order to schedule another conciliation conference, 10. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. cc: Ronald E. Johnson, Esquire - Counsel for Mother Jason P. Kutulakis, Esquire, Counsel for Father 5 Cop I , /YQ(.bL ~/~t/ol ~ ~ --, I :fl , ''1 ' , ~ i: , , I: i,'" 1lIl!III!h"~",,_v~ .~ =.," ~&"~" ..~,.^ .., ". ALIi "'Nit Ii/O') ~02t0V:)'d \_',I."t'"7".,:;''' 1/2' :8 . ':'''Oi'W7J />" , (", ;:'/It'. , , I ID ...~ 'n' ;.A' ,,~,~ " . ~- !-"'~{"140~ di' J,~ .~.,.f!'~_~ :!!fil!i(~~~'~"'~~I\f!~l'1"t"f!\"''>:''"''I'C''~'::r;~'''''''''~f-''''"('''''''^'~''''',"-'';';'~1'~'ii'Il!"!t,"^OfT:-'"-W'-w;r.%~'W:l~""""1:;,"'i'C')":'D'P!:""n'f~~1!ff<'@jlj~~ " . -'~~>')'~ 'I. VICTORIA E. GREEGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLV ANIA V. 2001-2824 CIVIL TERM CIVIL ACTION - LAW BRETT A. GREEGER, Defendant IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: I. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Garrett Quinn Greeger February 18, 1999 Mother 2, A Conciliation Conference was held in this matter on June 6, 2001, Mother, Victoria E. Greeger, was present with counsel, Ronald E, Johnson, Esquire, and Father, Brett A. Greeger, was present with counsel, Jason P. KutuJakis, Esquire. 3, The parties agreed to an interim Order in the form attached. Io-,-o( Date ~~.~~, acq line M. Verney, Esquire Custody Conciliator =-~-~" I"" '0 -~ " . " '''- ..- AUG 1. ., 2001tP VICTORIA E. GREEGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLV ANIA V. CIVIL ACTION - LAW BRETT A. GREEGER, Defendant NO. 2001-2824 CIVIL TERM : IN CUSTODY ORDER OF COURT AND NOW, this drP day of consideration ofthe attached Custody Conciliati follows: + ,2001, upon Report, it is ordered and directed as 1, A Hearing is scheduled in Court Room No. :<., of the Cumberland County Court House, on the 'f':'1 day of (1)(' ~ , 2001, at 'b " qs- o'clock, JL, M" at which time testimony will be taken. For purposes of this Hearing, the Mother shall be deemed to be the moving party and shall proceed initially with testimony, Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness, These Memoranda shall be filed at least ten days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the prior Order of Court dated June 20, 2001 shall remain in full force and effect. J. Ronald E, Johnson, Esquire, Counsel for Mother Jason p, Kutulakis, Esquire, Counsel for Father ~ I ~ \'~ ,0\ ~ ~ ()~' <)J .""'7.l"l'"_,, '_ ".," 1 -loW p~, 1 ,-, ~- ,- ,~~.,..., - "B~ .~~:-. <1{(~;:~ Ii," ! Ii I" 1:1 II' I !''Th1 "p <-'+ '?.. 'dC-- ;::;,,:( , ,;..\ \', "-~, !~ "' \ ~ 't;,~ -'()~ C) ~;> (~7; 'tfW, ^-~I?f !-G.{i;> " \.\cv <,'\..... "'7.:- ''? D o <5'~\ ~1>- ,~, ,/ : ~~~~- ~~""'". ,'~ . ~,~""- ~",," M~ _ '''~",-",","''- -, . ',. ","' ,r !'lIlfiIL"'l""""_ J~!!!!,'I;!~."~~I'!II$'~!;iW;-m'~1\j"'~';;;''-'''~~:-';::",,'';:4?~~'''''''-C~~''-,"",,-,. "':'_:Ci,,,f:'l'F!1'e~~~"c;P~~'f1"fiF;''''''''r;,,,~,.,Wl'~';n''''111!~)ll~1~~ ... ' , AUG 1 7 2001 tf7 . VICTORIA E. GREEGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLV ANIA V. CIVILACTION -LAW BRETT A. GREEGER, Defendant : NO. 2001-2824 CIVIL TERM : IN CUSTODY PRIOR JUDGE: Edgar B. Bayley, J. CUSTODY CONCIlLIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Garrett Quinn Greeger February 18, 1999 Mother 2. A Conciliation Conference was held August 16, 2001 with the following individuals in attendance: Mother, Victoria E, Greeger, with her counsel, Ronald E. Johnson, Esquire; Father, Brett A. Greeger, with his counsel, Jason P. Kutulakis, Esquire. 3. Following a Conciliation Conference, an Order of Court dated June 20, 2001 was entered by The Honorable Edgar B. Bayley wherein Mother and Father shared legal custody and Mother maintained primary physical custody with Father having periods of partial physical custody on alternating weeks from Thursday to Sunday. 4, Mother's position regarding custody is as follows: She seeks shared legal and primary physical custody of the child, 'She maintains that Father has not previously shown an interest in the child, but recently threatened to remove the child from Mother's custody which prompted Mother to file this custody complaint. Mother asserts that Father did not take advantage of the custodial time granted to him under the Order of Court dated June 20, 2001. 5. Father's position regarding custody is as follows: He seeks shared legal and shared physical custody on a week on/week off basis. He maintains that he took advantage of the time granted in the prior Order of Court, although he admits shortening at least one visit for a birthday celebration. I;,;'o/_I!;>,'t'.. I-",n -,. -- - " , "'~"' ..... ! . .c""..""',,...:w , . 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing, The prior Order of Court shall remain in full force and effect until the hearing, It is expected that a hearing will require one half day, r ~ I Ce -0 I Date 9n.r; que eM. Verney, Esquire ~ ustody Conciliator ." Ii 'f. . ~,,-~ ~~ i , ~- . -, VICTORIA E. GREEGER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA V. 01-2824 CIVIL ACTION LAW BRETT A, GREEGER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, November 29, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before JacqueliueJ"l.yeruey, Esq._, the conciliator, at 4th Floor, Cumberlaud Couuty Courthouse, Carlisle on Tuesday, January 10,2006 at 9:30 AM 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. 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. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: Isl ac ueline M. Veme Es 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 A TTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 " 1""1, " ~ - ._~lW!Mlli'i"irf''!t~''''~c'td~,',g'''''i:"i''''i>i\.a'~~')<;r''',-ili'';;:i:f;:];J;."-, __~ "',>,,-,,,",b.,,,,,,,;;._;;j,.;iwlll;,,,'!I2,il.~!iL~~Iii"'~ "' 1""~.jl1liillWl~~ l!ilfio" ,(9 $.0S- /02 -.505- /~-S"OS "~ ~ F\ltn-O~F\CE ~~ IH;- D",r,.~-I I"'\"'I(''-~'~'PY ur ,I!: l ;'LI'j' .',_::'",~)1h, O,['DOU1\L~C' _r:, P'!' \'i' 'l" ... 1...1.1, ~-' ..., II (.... wJ CkTt'~~$~~ 0~~ :z~ C'~~ ~ ~~~ . _"'"",~'~!" ,,_''''_''''--_'''''.',~.~., ., ~ _.,''C' ',_,~__u _. ~"~'_'"'"__" ,~= ,. ,"~ ~ _~ "h ~~,~ ,,~ ,='."."....... ,~ ~ i [' NOH 2 "i:A J ~ ' ,. ~c 'it VICTORlA E, GREEGER Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY,PENNSYL VANIA v, NO: 2001-2824 BRETT A. GREEGER DefendantlPetitioner CNIL ACTION - LAW " IN CUSTODY ORDER OF COURT AND NOW, ,.2005, upori consideration of the attached Complaint, it is ' hereby directed that the parties and their respective counsel appear before _ _ _~ the c_oncili~t~r,_ a~ on the , day.of ,),Q05, at .~. ~ 9rclock, . _,m" for a Pre~Hearing Custody Conference" At such conference, an effort will be made to resolve the issues in dispute; or ifthiS cannot be accomplished,todetine and narrow the issues to be heard by the' Court, and to enter into a temporary order. All children age five or older may arso be present at the conference, Failure to appear at the conference may provide grounds for entry ofa temrJOrary or permanent order. FOR THE COURT: By: Cus.lody Conciliator The Court ofComirionPleas ofCumherlarid'County is required by law to comply with the Americans with Disabilifies 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 32 North Bedford Street Carlisle, PA 17013 717-249~T166 ~> /"'- ... .- VICTORlA E, G:REEG:ER , PIaintiffIRespondent :IN THIi:COURT OF CqMMON ,PLEAS : CUMBER1AND COUNTY,PENNSYL VANIA v, : NO: 2001-2824 BRETT A. G:REEG:ER Defendant/Petitioner ,: ,CIVIL ACTION - LAW : JNCUSTODY PETITION TO MODIFY CUSTODY , , 1. Petitioner is Brett A. G:reeger, who resides at 120 G:reenview Drive, Carlisle, Crn:nberland County, Peunsylvania 17013, 2, Respondent is Victoria E"G:reeger, who resides at 175 E, North Street, Carlisle, CUmberland County, pennsylvania 17013, 3. On June 21, 2001, the HonorabkEdgar B, Bayley entered a Clistody Order attached ,as. Exhibit "A". 4, Since the entry of said Order, there has been a significant change in circrn:nsJances in that: a) Petitioner believes and avers thattlie child is not receiving the basic needs.$uch as food and clothing. b) Petitioner is best sUited to provide a stable environment for the child, c) Petitioner is best able to provide the care and nurture which the child needs for healthy development. 5, The best interest of the child wilI be served by the Court modifying said Order. ';-~r", 1~'''''"'1, ~'1 -"r', "." ,._, , "'~1'1, I, r. ~'. ) '. ~ . '. WHEREFORE, Petitioner prays this Court to grant the modification of the Custody Order as follows: Primary physical custody in: Father with partiaLcustody in Mother; Respectfully submitted, ROMINGER, BAYLEY & WHARE Date: 11-1'tJ-o~ r1~"4G/( MichaelJ,' Whilre, Blquire 155 South Hanover Street Carlisle, PA17013 (717) 241"6070 Supreme Court 10# 89028 Attorney for Defendant/Petitioner ' "~'H~, ,. . ,- '-'7"~ -'-~_"'?f ~';'~ '~_-''- <""~, "'-' 'c-:" '''!o "~''''-1 .of"" ~ 'I"''1~ _., ." d_ _".oF ,~, ~_ __ ' . . VERIFICATION , I verify that I am the petitioner and that the statel1lents made in the foregoing Petition are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa, C, S, S 4904, relating to unsworn falsification to, authorities, Date: \ \ / \7/0:{ ~~oS3l!O~ " Brett Greeger/ Defen ant ~<cWl.' _ ,.,. . "~,,"._~,;;o;~'" "~'",,"'Yr,,-'9~'"_l_;_, _ v'", ~"J - ,~ 'c- --',,_,~ ~~-''''r'''w, ' -"'.,-.-" -~-- =<'" 0" ""c" ,,",' ,. . n. , oJ ~_ _ A ..." ,,~ ""~~- '~"",'-", "",'> ,. . JUN (} 7200Ft! VICTORIA E. GREEGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLV ANIA V. : NO. 2001-2824 CIVIL TERM : CIVIL ACTION - LAW BRETT A. GREEGER, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this ~ day of )~ ,2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Victoria E. Greeger, and the Father, Brett A. Greeger, shall have shared legal custody of Garrett Quinn Greeger, born February 2,1999. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. Mother shall have primary physical custody of the child. 3. follows: Father shall have periods of partial physical custody of the child as a. Beginning June 14,2001, alternating weeks from Thursdayat 7:00 p,m, to Sunday at 5:00 p,m. b. Such other times as the parties agree. 4. birthday. Each party shall be entitled to a block of time with the child on their 5. Transportation shall be shared such that Mother will transport the child to Father's residence and Father shall return the child to Mother's residence, unless otherwise agreed by the parties, 6, Both parents shall have liberal and reasonable telephone contact with the child when the child is in the custody of the other parent. 7. The parties shall keep each other advised immediately relative to any medical care or medical emergencies concerning the child and shall further take any , , II -1'" ", '."'~_i_r., - . necessary steps to ensure that the health and well being of the child is protected, During such illness or medical emergency, both parents shall have the right to visit the child as often as he/she desires consistent with the proper medical care of the child, 8. Neither parent shall do Mything nor permit anyone else to do anything which may estrange the child from the other party, or injure the opinion of the child as to the other party, or which may hamper the free and natural development of the child's love or affection for the other party. 9. This Order is an interim Order entered pursuant to an agreement of the parties at a Custody Conciliation conference, Either party may contact the Conciliator within sixty days from the date of this Order to schedule another conciliation conference, 10. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. cc: Ronald E. Johnson, Esquire - Counsel for Mother Jason p, Kutulakis, Esquire, Counsel for Father 5 C1opl~ m~LbL ~/~t/Ol :::::I?r) .". r"'I' ..~-, ~ ~~'. ,~<,'""" ,-",~,~~ < -~ , -~ . 'T ,"'':'" C,,-,'_.~-,' ~ '"', '"','".. ",~-""'" - ~~ ~ , ~8 :::J t :::: ~, " ~ ~ ~J,~t 'lJll _!~~~R!f.fI'~_ "",,,~_...,_~~;~~~,~,~"'.0"""'Flm~"')>,IY*lt,,'w-r,e''''''J'~,!f_''''r~":>'-"-"-'-,,'-" r "'1!:r'if"""%'irni'Y' CiTFii LllJllrrrmrnfillillllwnr 1"'1'111'11'. ,-~ " '~_l:;\i'('''''-"'-'' .; .. ., ~ ~' o r- ,-;:;;: to., i':3.{ C~l ~ C::' ""'" o ~n :;t 111.:?:? r- "'r<-, 'I: :JJ'~ () y ~[l9 ,~~?/~' -~:f :53 ._,- OT' :',:- ,r,', - c) i, - ~ -,,~~ C' - - ~ r' ~I . .IAN 1 0 200b ~ - - - - ----..--- ~----~. -- VICTORIA E. GREEGER, : IN THE COURT OF COMMON PLEAS OF PlaintiffJRespondent; CUMBERLAND COUNTY,PENNSYL VANIA V. : NO. 2001-2824 CIVIL TERM ; CIVIL ACTION - LAW BRETT A. GREEGER, DefendantlPetitioner: IN CUSTODY ORDER OF COURT AND NOW, this ').. ~,r~ day of --{ r>.....-.l IV....I ,2006, upon consideration of the attached Custody Conciliation Report; it is ordered and directed as follows: 1. The prior Order of Court dated June 20, 2001 shall remain in full force and effect with the following modification, 2. Father shall have periods of partial physical custody every weekend from Thursday to Monday until after school, except for the third weekend of every month, when Mother shall have physical custody of the child, 3. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modifY the provisions of this Order by mutual consent. In the absence ofmutua1 consent, the terms of this Order shall control. Another Conciliation Conference is scheduled for March 14,2006 at 10:30 a,m, BY THE COURT, cc:4hael1. Whare, Esquire - Counsel for Father vNathan Wolf, Esquire, Counsel for Mother ,_'Of_ ~ ,',11 . "~., .. -...,-" \fJ',\",,:l\:~)'5,;1 _\N3d }.J.N(\~( 'i' "'".2~,(~\r\~f() ot: :5 \\1"1 CZ N~r ~fJGZ ",.)!'"\' ,n"'"'' , 'J' ']..10 f\OV,_Ui\\UI d.\JC10 -,H ..J :\,",!.uC,-03l\:\ "..>"');~.i,"' ,;.. ;..i ~7 ~.~~ ".!<"'~'o ~ t_ .._~~~ _ ~'~ ~o .. .. ~ ~~"""..~~~:..."""I!!I, --".' . '< .' -,",-.","'~- ,,~. ..... . .,,,,,,~ ,--"", ~u .. '...... """",,,,,,,-l';(7~'''l'''''~.''l{'JF'.''''''''''''e'''''- ,~ ,,,~,w.)''''-''!lm'''''''''~jl",,~~'\;lW~FI'"~!j'i''.llW'_ "Rl'il~!:'lt"~'W__ . '''''T~' " VICTORIA E. GREEGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY,PENNSYL VANIA V. : 2001-2824 CIVIL TERM : CIVIL ACTION - LAW BRETT A. GREEGER, DefendantIPetitioner: IN CUSTODY PRIOR JUDGE: Edgar B. Bayley, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Garrett Quiun Greeger February 18, 1999 Mother 2, A Conciliation Conference was held in this matter on January 10,2006, Father, Brett A, Greeger, was present with counsel, Michael J, Whare, Esquire, and Mother, Victoria E. Greeger, was present with counsel, Nathan Wolf, Esquire. 3, A prior Order of Court was entered by the Honorable Edgar B. Bayley dated June 20,2001 providing for shared legal custody, Mother having primary physical custody and Father having alternating weekends, Thursday to Sunday, 4, The parties agreed to an Order in the form attached, (.- ( 0 ro ~ Date (~~ fi;t, ~ {;(acqu ineM. Verney,ESqui~ Custody Conciliator , I ',0' __~_'_" "'" _,~w"", ._.~ ". ",.. ~__ _, ,,_"_''''''L~ _ .~_ VICTORIA E. GREEGER PLAINTIFF V. BRETT A. GREEGER DEFENDANT IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA 01-2824 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, May 18, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, June 06, 2001 at 1:30 p.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. The court hereby directs the parties to furnish any and all existiug Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Jacqueline M. Verney. Esq. ftJ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with DisabiJites 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 TIllS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 (7]7) 249-3166 '."''J",-T'''''''~ ~:~ 0 ~"T_ ,~ , _or I~ ~_~&,re"L';dt<""3'~"";;",0l'1,,""C.!",:f,",,",,"";;..1%)';;'f-<l-1 ;,;;""""~',d;;' ,'W",r,;-._,,,,,:;_,,,..l,,,:"b~,,,,;"~;;'~t.-,,i,:t:>-_M~~,_ij~jjj~adI;liIIIlJiil\~~~ C""-'-"\:ilIU<l""""""~-~"-. ~1I!t 'l" C',h t..,'" . . 'I" \ )'~ l' \ 'j';' \ 1', ~ ~', " ..; ,', ,.{,\ j\~\'I 0,",'_\\ \.)-..J'- ("l \1,jlcC!cJ'.'J\~S;\[Pl'\\i\ ;,)...} o~N\~' ~ I \.~. ,- f>'f.'~/ w t'~~-d;4~ S/r-~/ ~ ~4:a/ Z ~ J,/g"?J/ ~~...:.,. 4 ~:<::># "61!.1L.Urnm.,JUll~JI.1._ _,._~.II1JL.L" ,.".!,,,, ,J.........._ .. . " co, ~ ,.'.. '_' __ ,[,"._~_ ,,<._, ,,,,Y~"~ .,'.~ , - ~ ,--.~ ~ - ~ ji1 . NATIIAN C, WOLF, ESQUIRE ATTORNEY ill NO, 87380 WOLF & WOLF 10 WEST HIGH STREET CARliSLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF JUN21Y VICTORIA E. GREEGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2001-2824 BRETT A. GREEGER, Defendant : IN CUSTODY ORDER OF COURT r( AND NOW this 1-\ day of :C,,'t.; ,2006, upon consideration of the attached Motion, it is hereby ordered that the custody hearing scheduled for June 28, 2006, at 9:30 o'clocka.m, be rescheduled to Tuesday, July 11, 2006, at 1:30 o'clock p.m BY THE COURT: \ -L u4\ J. I)istribution: vMichael J. Whare, Esquire V'lathan C. Wolf, Esquire ~ \,0 ,~ 0\9 '-~'''~__Wl!J.~ '-'_:,,,'rt__~,,_ ,,'._, _ ~'. .,.~. _ > ",__.1"",.". , _ _ ~ ~ j, !ll~, ~ '~'" ~ - o. ", ." _",. _ _ ~, ,'4 <_ ,__~_~ _, " ,_~,&"" ,,"~ Aj , '1.'.1""',) _-r ,'f j\ g'"' ,.,::":1 Vf AUVi(i<,'-,- r; -. 3h!~~::I~~; I'l "1"'>" j C {Jfr an[]7 ..I\.iJt.,. )i::<-r :]'/' ,,,,,_ rl''',!.eC.L :Ji ' , .. ~~i /.-} '"-' -, . ~ 0 '-<'H~'- ""''''''1 ,,' .- '-"'llrI"UJI17' c~Ii~.Ii!m'W1!~""",I,'~w,'I;r"'1~<W~':'1"WT"''':~f!>t~.f:-i!~'''~'''f''!I'll:''Y#l~~!l'~'''''~~Mm'ff~ Ii '---,-' NATHAN C, WOLF, ESQUIRE ATTORNEY ill NO, 87380 WOLF & WOLF 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241.4436 ATTORNEY FOR PUINTIFF VICTORIA E. GREEGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2001-2824 BRETT A. GREEGER, Defendant : IN CUSTODY MOTION FOR CONTINUANCE NOW comes the Plaintiff, Victoria E. Greeger, by her attorney, Nathan C. Wolf, Esquire, and presents the following motion for continuance of June 28, 2006, custody hearing, representing as follows: 1. Plaintiff is Victoria E. Greeger (hereinafter "Mother"), the plaintiff in the above captioned matter who resides at 175 East North Street Carlisle, Gunberland County, Pennsylvania 17013. 2. Defendant is Brett A Greeger (hereinafter, "Father"), the defendant in the above captioned matter who resides at 17 South Baltimore Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 3.' The patties are the parents of one minor child, namely: Garrett Quinn Greeger, born February2, 1999, age 7 years 4. The patties are subject to a custody order issued by this Court dated June 20, 2001, wherein Mother has primuy physical custody and Father has periods of alternating weeks of partial physical eustodyof the child. 5. As a result of a petition to modify custody filed by Father on November 18, 2005, a custody hearing was seheduled for Wednesday, June 28, 2006. ,,,,,,,. """"~- 'I'. - '''~_' ,. - -],-" ,_-"^, -.f n -1__ '1-'" " , , 6. Counsel for Mother was unable to contact Mother in preparation of the eustody hearing presently scheduled until the date of the instant motion. 7. Upon contacting Mother, counsel has learned that Mother gave birth to a daughter on June 21, 2006, the morning of the instant request and is still in the hospital reeuperating. 8. No previous continuances have been requested in this matter. 9. Father's counsel's concurrence was sought in this request for continuance, and such concurrence was not given. 10. The undersigned has, nevertheless, verified the availability of the Court and Father's eounsel for July 11,2006 at 1:30 p.rn. WHEREFORE, Plaintiff, Victoria E. Greeger, respectfully requests that the Court issue an Order rescheduling the custody hearing, currently scheduled for June 28, 2006, at 9:30 a.rn. to July 11, 2006, at 1:30 p.rn. and any additional relief that the Court may deem appropriate and just. ---..---- l>ated:Jun~(,2006 By: Nathan C. W , quire 10 West Street Carlisle 17013 Supreme Court 1.1>. No. 87380 (717) 241-4436 Attorney for Plaintiff ;:!'''''~> ""--",,'V''"'f'-''''-_~___ -'",.1_0'-__ ~-,'I -_~ -, 1"'"1' ' -- ,. .- ,,0. " , VERIFICATION I, the undersigned, do hereby verify I am counsel for Movant, and the facts set forth in this motion are true and correct to the best of my knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.CS. Section 4904, relating to unsworn falsification to authorities. June -11-, 2006 _;'-_~1"~_"~",- """'., ' , ~'""_~~__' __' '-. >,. " ,-' 'C. '., 'I'" I . .""N",., NATHAN C, WOLF, ESQillRE ATTORNEY ID NO. 87380 WOLF & WOLF 10 WEST H1GH STREET CARL1SLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINT1FF VICTORIA E. GREEGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2001-2824 BRETT A. GREEGER, Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Nathan C Wolf, Esquire, hereby certify that I have served a true and correct copy of Plaintiff's Motion for Continuance upon the following person and in the matter indicated: SERVICE BY U.S. MAIL: J\1ichael J. Whare, Esquire Rominger & Whare 155 South Hanover Street Carlisle, PA 17013 Respectfully submitred, Dated: Jun~, 2006 WOLF & W athan C. Wo squire 10 West' treet Cadis , P 7013 Supr Court I.D. No. 87380 (717) 241-4436 Attorney for Plaintiff ~.,,~- ilI!'1 ^, '_,,!,~ ,,- " . " '_EI'!'''I_'> _"'__r_'[_ -, , "" - ~J .__~ .1lI!"ll!~, ~. , ~^ t'l_~....? "~. . --~ .- "" "'~'" ^- ,-, ~C' "",- '"_0<'"' ~~..., c) '0.': "- .., ft ~JQ;l <~......< [I' tr , ", = '.~:,,:) ""', <,... ,~;,-, C) I:1 ? r;'j."Jl ;-:..: r'\) - ~', ,-. _~<(":c ~~ i-l ~"--, " - T.i;i IV . ..~ r~~) ,r,';n :~:f .'J.:J -, ....'.J ~.~_ 'lI!'IlJIIIl ,,~'_'~'~'ilil'l!prio-l>jffi!;\W'WMIT']'-_''"'''f~'1i1<1'l'~j1\~'m~~~!I!('(~r~-W!~E\'lI~'"':;~~'~"_'d_~.J~! *', ~- .~~ .- ~~~ 1!k9fQ VICTORIA E. GREEGER, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-2824 CIVIL V. BRETT A. GREEGER, DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 5th day of July, 2006, upon consideration of the Motion for Leave to Withdraw as Counsel filed by Nathan C. Wolf, Esquire, and the Court noting that a custody hearing which was continued at the Plaintiff's request is scheduled for Tuesday, July 11, 2006 at 1 :30 p.m" IT IS HEREBY ORDERED AND DIRECTED that the Motion of Nathan C. Wolf, Esquire is DENIED at this time. The Motion will be reconsidered upon conclusion of the custody hearing scheduled for July ii, 2006, By the Court, Victoria E. Greeger Plaintiff Nathan C, Wolf, Esquire Attorney for Plaintiff Michael J. Whare, Esquire Attorney for Defendant bas ~f ' -', I~~I- . - ,-- , , VICTORIA E. GREEGER, Plaintiff/Respondent . ~J""~r---.""",,,~"V' ..c:;:"'~J' , :.:~-i t ":-.: ~..' :;,0( ~ I ~." .........~~....~... .,...1) ! APR 1 7 Z006J: IBY: 1... . : IN THE COURT OF COMMON PLEAS OJ< : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2001-2824 CIVIL ACTION - LAW BRETT A. GREEGER, DefendantIPetitioner : IN CUSTODY ORDER OF COURT AND NOW, this 0l.t.J day of ~ ,2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A Hearing is sche~d in Court Room No, 5 , of the Cumberland County Court House, on the df5 day of ~ ' 2006, at g~ -3 D o'clock, lL, M., at which time testimony will e taken, For purposes of this Hearing, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten days prior to the Hearing date, 2. Pending further Order of Court or agreement of the parties, the prior Orders of Court dated June 20, 2001 and January 23, 2006 shall remain in full force and effect. 3. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, M. L. Ebert, Jr" J. cc~haeIJ. VVhare, Esquue, counsel for Father lJ>l'than C, Wolf, Esquire, counsel for Mother ~ ~),i@"~ . , <':'":""~,,.~-,.- '-"''';'!'_'~'">-.?'''?-''''''~' - '-_'0<'_. .1" ,,-, of>"',' '~I!"1 , ~ ~, ]-" ,', .,-- l.:, -~,~' , "'1 . \ \ 1'\'1 '."I)'. 't'!\! Ad'ilOi<::/i ::,~)\~ , ,"~ ~~ ~, ~_' ","""',,..-. I '7 \! H-2 \\1';c;7 "h" ccn ~1l.i1.;,.} ,-",~ :)' 'j' : ,L,~)i,lu ......n. ~~(~)'-'G:il\::I ::10 ~l ~_ _ -.~" . 0 ~.., ~, ,~~-~-,- 11_ ~ :'H"!.~ -.lJ-"'~_Jl)~'I'~~~'!-,",~-.r.!!"f~!lIIlillt'l%'1i~9m~!'i~I-'~~II;;2l';j!lil:J~:WSIJ\1~1"'~~ . . VICTORIA E. GREEGER, PlaintifflRespondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, . : NO. 2001-2824 CIVIL ACTION LAW BRETT A. GREEGER, DefendantJPetitioner : IN CUSTODY PRIOR JUDGE: M. L. Ebert, Jr., J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Garrett Quinn Greeger February 18, 1999 Mother 2. A Conciliation Conference was held April 13, 2006 with the following individuals in attendance: The Father, Brett A. Greeger,with his counsel, Michael J, Whare, Esquire, and the Mother, Victoria E, Greeger, with her counsel, Nathan C, Wolf, Esquire, 3, The Court previously ,entered Orders dated June 20, 2001 and January 23, 2006 providing for shared legal custody, Mother having primary physical custody and Father having 3 weekends per month from Thursday to Monday, 4. Father's position on custody is as follows: Father seeks shared legal Md primary physical custody with Mother having alternating weekends, Father maintains that Mother does not properly care for or supervise the child, Another child in the home was recently rushed to the emergency room when Mother suspected the child ingested an adult's prescription medication, In the rush to the hospital, the child who is the subject of this matter was left at home alone, Father asserts that he is better fit and capable to care for the child. He also suggests that Mother's paramour has criminal charges pending. 5, Mother's position on custody is as follows: Mother seeks shared legal and primary physical custody with the current Orders remaining in effect. Mother asserts that Father works the overnight shift and is not available to care for the child. The child "'~~r, 'C-, '_'_,<,,"'".,..,. ~"c__,' _~ ."",!!"I"<>_. d _ i,.' -- .' . . complains that Father spends little time with him, Father does not properly supervise homework, 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and maintaining the status quo. It is expected that the Hearing will require one day, t-/-I '-1-0 I. Date ~A.(~c Jacq eline M, Verney, Esquire 6 Custody Conciliator "~,~-~ '^;,,:-,~ ""","',.,.."_"""'"_____ ",,___' <___ ~_~,_,."..b_.''''''' ~.' ., " RECEIVED JUN 19 2~ VICTORIA E. GREEGER Plaintiff /Respondent : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO: 2001-2824 BRETT A. GREEGER DefendantlPetitioner CIVIL ACTION - LAW : IN CUSTODY CUSTODY MEMORANDUM Defendant, by and through his attorney, Michael J, Whare, Esquire, hereby submits this Custody Memorandum pursuant to the Order dated April 24, 2006. I. mSTORYOF THE CASE: The Defendant in this matter is Brett A. Greeger (hereinafter referenced as "Father"), who resides, at 17 South Baltimore Aveune, Mt. Holly Springs, P A17065 and Piaintiff, Victoria E, Greeger (hereinafter referenced as "Mother"), who resides at 175 East North Street, Carlisle, PA 17013. Father and Mother are the natural parents of one child, Garrett Quinn Greeger, born February 2,1999, Father filed a Petition to Modify Custody on November 18,2005, ashefelt that the basic needs such as food and clothing were not being provided to the minor child and as such is seeking primary physical custody of the child with visitation in the Mother. Father is best able to, provide a stable environment for the child. II. NAMES AND AGE OF THE CHILD: Garrett Guinn Greeger-February2, 1999 III. ISSUESBEEORE THE COURT Best interest of the Child. :'-'" '-.. ~,_.~~ .- .. ,-~""', ,._"~~,~. - IV. NAMES AND ADDRESSES OF FACTUAL, WITNESSES: 1. Brett A. Greeger-Natural Fa,ther will testify to his caregiving capabilities as well as his close relationship with the child, ' 2, Victoria A. Greeger-Natural Mother-To be questioned as on cross-examination 3, Rebecca O'Donnell-Paramour of Father-Will testify to her observations of the interactions between father and child, 4, Phyllis Opilo~Maternal grandmother-Will testify to her observations of the relationship between father and child, Defendant/Petitioner reserves the right to supplement this witness list prior to the custody trial. V. LEGAL AND FACTUAL ISSUES FOR RESOLUTION: The Court willbe called upon to determine whether Father should be awarded primary physical custody and shared legal custody of Garrett Quinn Greeger. VI. ESTIMATED LENGTH OF TRIAL: It is Mticipated that the testimony presented on behalfof the Plainj:iff will take a half day. Respectfully submitted, ROMINGER l!;,WHARE Date: June 19,2006 h.-./l MichaelJ, Wllare, E uire 155 South Hanover Street , Carlisle, PA 17013 (717)241-6070 Supreme Court ID # 8902,8 Attorney for Defendant ~,r_, <,~,~"':";"~'_"'"o':~'-',-_O""'I7A!,''i,,,_, ,~,q>- ,''''''" c ~""'I""'I,," "'_I c" fi ,_,-"~,_r-.""_~_~'_CI_~__I,_ ,',f. ,-- . . . VICTORIA E, GREEGER Plaintiff/Respondent VI. BRETT A. GREEGER Defendartt/Petitioner :IN THE COURTOF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO: 2001-2824 : CIVIL ACTION - LAW : IN CUSTODY CERTIFICATE OF SERVICE I, Michael J ,Whare, Esquire, attorney for Defendant, do herebycertity than this day served a copy oftheCustody Memorandum upon the following by first class mail postage paid at Carlisle, Pennsylvania addressed as follows: Dated: June 19,2006 'Iel,,,=, ""-"",P "'",.-.f..c',,'_"__:,' .., '-"-~'"I"',I".' "'y,,'.r, -"',~, ",,,,.",<,, ~,.-,"^_ , ",.,"~ .", _ _ _ ~_. ,"" , .- Nathan C, Wolf, Esquire lOWest High Street Carlisle, PA 17013 fl/l.-.J ~ ~A MichaelJ.Whare, Esq'e 155 South Hanover Street Carlisle, PA 17013 (717) 241 c6070 Supreme Court ID # 89028 Attorney for Defendant , , VICTORIA E. GREEGER Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW : CUSTODYNISITATION ~ NO, (j (- ;;J...g ~ 4 CIVIL TERM BRETT A. GREEGER, Defendant ORDER OF COURT AND NOW, ,20_, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at on the day of ,200-, at o'clock, _.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. 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: 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 MY 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 Asssociation 2 Liberty Avenue Carlisle, PA 17013 Phone: (717) 249-3166 -_."""'..,.-..,, - r ',' _:<", ~~ 1'1 - 11 , . - ,-,~, ~~ ~~- VICTORIA E. GREEGER Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW : CUSTODYNISITATION : NO, 0/- ;Z f'.l 'I CIVIL TERM (1) BRETT A. GREEGER, Defendant COMPLAINT FOR CUSTODY 1, The Plaintiff is Victoria E, Greeger, residing at 20 East Street, No, 10, Mt. Holly Springs, Cumberland County, Pennsylvania 17065, 2. The Defendant is Brett A. Greeger, whose current address is believed to 632 North West Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks custody of the following child: NAME RESIDENCE DOB AGE Garrett Quinn Greeger 20 East Street, No, 10 February 18, 1999 Mt. Holly Springs, P A 17065 2 years The child was not born out of wedlock. The child is presently in the custody of Victoria E. Greeger. During his life, the child has resided with the following persons and at the following addresses: NAME ADDRESS DATES Victoria E. Greeger and Step-sister, Akira S, Opilo 20 East Street, No, 10 Mt. Holly Springs, PAl 7065 Dec, 20, 2000 to present '-['-"""~""~" ~- -~-" ., ." ','~ . ~-- ! ~I""I - , ' '''~ '^' Victoria E, Greeger, Step-sister, Akira S, Opilo, Father, Lewis Opilo, Jr. Mother, Phyllis Opilo Brother, Alexander Opilo And niece Jessie Opilo 715 Sherwood Drive Carlisle, P A 17013 October 2000 to December 2000 Victoria E, Greeger and Step-sister, Akira S, Opilo 10 Hamilton Street, Apt. C Norristown, PA August 2000 to October 2000 Victoria E, Greeger and Step-sister, Akira S. Opilo 109 Third Street, Apt. 2 Boiling Springs, P A 17007 March 2000 to August 2000 Brett A. & Victoria E, Greeger Step-sister, Akira S, Opilo 109 Third Street, Apt. 2 Boiling Springs, P A 17007 Birth until March 2000 The mother of the child is Victoria E, Greeger, currently residing at 20 East Street, Apt 10, Mt. Holly Springs, PA 17065. She is married, The father of the child is Brett A. Greeger, currently is believed to be residing at 632 North West Street, Carlisle, P A 17013, He is married, 4, The relationship of the Plaintiffto the child is that of Mother. The Plaintiff currently resides with the following persons: daughter, Akira S, Opilo and son, Garrett Quinn Greeger 5, The relationship of the Defendant to the child is that of Father. The Defendant currently resides with the following persons: Rebecca O'Donnell and her child 6, Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court, Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. -"'"'---"""1' ,~._ '""^~_"_"_' ',~ I~I ~- , '.r ~""", Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7, The best interest and permanent welfare of fue child will be served by granting the relief requested for fue following reasons: A. Plaintiff has untaken and performed fue primary parental responsibilities for the child; and B. Plaintiff is best able to provide fue care and nurture which fue child needs for healthy development; and C. Over fue last several months the Defendant has rarely had partial custody of fue child and has seen fue child or ofuerwise had contact wifu the child on few occasions. The Defendant has, however, threaten to remove fue child from the primary custody of the mother. Therefore a Court Order determination of custody is required to avoid continuing conflict between fue parties regarding parental responsibility for custody and support, D, In addition and referenced to fue above a Court Order of custody ofa structured visitation and/or partial custody is desired so that fue Plaintiff and fue child may plan their schedules accordingly and so that misunderstandings and unmeet expectations regarding custody and visitation can be avoided, E, Plaintiff desires to maintain the family household, which has been established, and fue continued stability of fue household is in fue best interest of the child, 8, Each parent whose parental rights to fue child has not been terminated and fue person who has physical custody ofthe child has been named as parties to this action. - ;'--~A"'!I'~'II!1~17 ~I-I, " -', ~ .- ,,~ =~~~ WJ:IEREFORE, Plaintiff requests the Court to grant custody of the child to Plaintiff pending the hearing, Respectfully submitted, ANDREWS & JOHNSON By: Ronald E. Jo Attorney for 78 West Po et Street Carlisle, P A 17013 Telephone: (717) 243-0123 Supreme Court ID No, 16453 i'''''~_~..~ " 1'1 ' , . ""; ."-~~ . "''''''~"-~ COMMONWEALTH OF PENNSYLVANIA ) : SS, COUNTY OF CUMBERLAND ) I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S, 94904, relating to unsworn falsification to authorities, DATE: S {<:&( OJ GV~"""~~~ .'C' ~, '1""1 ~- . ~ l--l~ _Ill . ",H'="~ ,,~. - ~~~ ~R \.}.. ~ "-S:\ -- ~ - }:; - UJ lS'" ~..~ ~~'--w~'<<~'_~"'''"~ ,,""'''_^'''.;,~,_~~'''='''''~._. __ _~"~ ~ 0;:::::--" c..J I;J v" (:- --,0, ~'--I ~, Ie: ". Uti 0 c> (j c -q S - ~ ~, 0) :~~ ~ " , rn fT -< Z r"~'. ,"-;1 z ('-'" 5Q~T c.) ~( ';) ~:::, ".. '~2 -i--: <.yl _, :J~ ;:') ~'- (--\ <;? ~:"'-,cn ;;:c >:~ Z ::;) ~ =< 01 =< _~ ,,' ~ ^__~, ~'i"i'W~~"'~'.~j!,~:\l~-"_'!j!"!'Hlii"ll'~~!:f'l'_"SfE'W-,~j',j"7"i'm":'Y"Wi1E'''_''''''f;-i''-';''''~'_'''''''t.;w~~'''',ll~'~~tj!<:~~I~>l'$'\'f~f'lffil-~f1:~l?f.ll.~~~~ " VICTORIA E, GREEGER, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-2824 CIVIL V. BRETT A, GREEGER, DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 5th day of July, 2006, upon consideration of the Motion for Leave to Withdraw as Counsel filed by Nathan C. Wolf, Esquire, and the Court noting that a custody hearing which was continued at the Plaintiff's request is scheduled for Tuesday, July 11, 2006 at 1:30 p.rn:, IT IS HEREBY ORDERED AND DIRECTED thaUhe Motion of Nathan C. Wolf, Esquire is DENIED at this time, The Motion will be reconsidered upon conclusion of the custody hearing scheduled for July 11, 2006, By the Court, yVJctoria E. Greeger Plaintiff Aathan C, Wolf, Esquire Attorney for Plaintiff ~ichael J, Whare, Esquire Attorney for Defendant \ bas fJ'D ~clJ D '~"~!~,"",.," f',. '-"'''''-'7'--,. ~__ - __~,~n , ,il!!ml . '1 --~, - , - - 'I ""' '[, -~._~ - ",., ,- ", /~-~ " - - ,,'"' ~ ~ JI~<'1"""~ ~"'"~~. -~1. .-.-.- '" _~'o'n"",.'''C''O.o, '" .,.,'.,"",'"',.',... 0"T'''~:'ID:'0'TI''lrjj:'n''''rlrlflltlt(11JiiirIliii'UlfJi I JltfD"-'!ii '0 " 'I: 90 ~;~ ~Ll l~ - .,- ~,) ~:l,![Z AHVLU Jill :!Ci ',1('1 (FiT:! \'",'i ~ _"",,,,,~~~~,I"''>\"6'~lj!_j!!:WE"#Wj;;w1''-'T."'";iO''!f>''fR'';Pi~m'~-W~~~~~'Wi[';l~:;i!'~i'Wffl"""!f-"~~~~ ,. , , 5 r)::-'~'r-r'/C:l Jr_!~' () n "1",.... "_.~L, . 'Cc.' .~(, ,- ',' _U Y NATHAN C. WOLF, ESQUIRE A;ITORNEY ID NO, 87380 WOLF & WOLF 10 WEST HIGH STREET CARLiSLE PA 17013 (717) 241-4436 VICTORIA E. GREEGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2001-2824 BRETT A. GREEGER, Defendant : IN CUSTODY MOTION FOR LEAVE TO WITHDRAW AS COUNSEL FOR PLAINTIFF NOW COMES counsel of record for Plaintiff Vietoria E. Greeger, Nathan C. Wolf, Esquire, and respectfully submits this Motion for Leave of Court to Withdraw as Counsel for Plaintiff, Victoria E. Greeger, pursuant to Pa.RCP. 1012, and in support thereof, avers as follows: 1. Plaintiff, Victoria E. Greeger, is an adult individual who is a resident of the State of Pennsylvania, and whose last known address was 175 East North Street Carlisle, Pennsylvania 17013. 2. The undersigned counsel was retained by the plaintiff on or about December 19, 2005. 3. The undersigned counsel contacted Plaintiff, Victoria E. Greeger, and Plaintiff orally communicated with the undersigned counsel, and the undersigned counsel sought oral confinnation, that Plaintiff no longer wished the undersigned to represent her. 4. Moreover, the undersigned counsel has performed legal services for the plaintiff in the nature of custody and divorce and has not been compensated for some such services. 5. The undersigned counsel believes and therefore avers that no prejudice would be suffered by his client if theinst~nt motionis.granted,~d_thauhis Courtsho.uldgrant the relief requested in accordanee with his elient's wishes. "'~'~"""'" .,,"" ,,-,~, .f<:"'_ -_-_~ ,-,' - ~-I'fJ'l - '" "., ',- . ,. ~ ~ ~, " --~ .-. . , ,/ 6. The undersigned counsel contacted Michael J. Whare, Esquire, counsel for Defendant, for concurrence in the filing of this motion and sueh concurrence was given. WHEREFORE, the petitioner, Nathan C. Wolf, Esquire, respectfully prays that this Court grant leave for the undersigned to withdraw his representation of Plaintiff, Vietoria E. Greeger, and to grant any further relief that the Court deems appropriate. Respectfully submitted, WOLF& WO F Dated: June 21, 2006 By: _ _olf; F.li1'1111re_ igh Street Ca e, PA 17013 Supreme Court J.D. No. 87380 (717) 241-4436 Attorney for Plaintiff >"~"7, "",,,"'r'-":!:f',,,~,,,~,- . '-';'7I'~r"~~,-;_ -~ , ,,1 ]' T" " .-- VERIFICATION I, the undersigned, do hereby verify that the facts set forth in this Motion are true and correct to the best of my knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.CS. Section 4904, relating to unswo alsification to authorities. Bated: June -.11, 2006 ,:;;'li'f-''''''''''J=OI! '~"';r~<f' ,,' ^, ".-r1' -r- 'I" ., -,-.,"- NATHAN C. WOLF, ESQUlRE ATIORNEY ID NO, 87380 WOLF & WOLF 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 VICTORIA E. GREEGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2001-2824 BRETT A. GREEGER, Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Nathan C. Wolf,Esquire,herebycertifythat I mailed a true and eorrect copy of the foregoing Motion for Leave to Withdrawas Counsel to the below-listed persons: Victoria E. Greeger 175 East North Street Carlisle, PA 17013 Michael J. Whare, Esquire Rominger & Whare 155 South Hanover Street Carlisle, PA 17013 Counsel for Defendant Dated: June ~ 2006 olf, Esquire ~-'-'''''''__l,. - _, .. ,,~'"' .l'S,-- '" ~,,' -~-,:,;:tfl: - . ,,.-- ,,,,. T' 'n.,,: <,-' . L ~ l' ~ ,~" ,. ~-, ,. "',- _~_~,~___.. '!lIIII,Ml " -- ..,. ~ ~"_"'M ~,_ ''''',''>^ ~.W~~_ ~-" ~2 '" _'~ ~c "'" ,~, un . ' '" c-:;;;. c..--;:; (.:J", o -" c__ ~~;-~ -c. r-',) t.D -"'l r-., '-'-.' .!Ml!M!!I_,,!",,~, ~~NWlfJJt .,~ 5._~~\iWJJifiT-"~~&;I~1'~~m:OOWfi"iJj%r~~!~'I~"J:'1~',$~~~ ,.../I!! " ~.::: :_~, E: v E J JU>~ ~ I:, '- .,,'~j y VICTORIA E. GREEGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2001-2824 BRETT A. GREEGER, Defendant : IN CUSTODY ORDER clay of June, 2006, upon consideration of the foregoing AND NOW this Motion for Leave to Withdraw as Counsel forPlaintiff, Victoria E. Greeger, the-requestedrelief therein his hereby GRANIED and counsel is hereby authorized to file a praecipe to withdrawas counsel with the Prothonotary and to serve notiee of this Order and such praecipe uPQnPlaintiff, Victoria E. Greeger, and counsel for all other parties to this matter. J. Nathan C. Wolf, Esquire Victoria E. Greeger MichaelJ. Whare, Esquire .""~'~ _ ~-r-" "'~"'-':~;_ -~.. f"I~-~ - ='--' ~- - ~l- ,-",.[ "p - ~- ,- . 1_"f"',O " c,'-' r '\.T ' I' 0 C ' " -"" ,,-" ' - y VICTORIA E. GREEGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2001-2824 BRETT A. GREEGER, Defendant : IN CUSTODY ORDER AND NOW this day of June, 2006, upon consideration of the foregoing Motion for Leave to Withdraw as Counsel for Plaintiff, Victoria E. Greeger, the requested relief therein his hereby GRANIED and counsel is hereby authorized to file a praecipe to withdrawas eounsel with the Prothonotary and to serve notice of this Order and such praecipe upon Plaintiff, Victoria E. Greeger, and counsel for all other parties to this matter. J. Nathan C. Wolf, Esquire Victoria E. Greeger MichaelJ. Whare, Esquire -"fll'!1f&!1f-""" -" , -~ , 1"1 .. "..' ,r ''-, ! ' ~ , , " ,', - ~ r i \,: L ., ~" -, ~ '-- . II" r, f\' ~,~,' '" ,.,:1 ff VICTORIA E. GREEGER, Plaintiff v. BRETT A. GREEGER, Defendant AND NOW this : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA No. 2001-2824 IN CUSTODY ORDER clay of June, 2006, upon consideration of the foregoing Motion for Leave to Withdraw as Counsel for Plaintiff, Victoria E. Greeger, the requested relief therein his hereby GRANTED and counsel is hereby authorized to file a praecipe to withdraw as counsel with the Prothonotary and to serve notice of this Order and suc.h praecipe upon Plaintiff, Victoria E. Greeger, and counsel for all other parties to this matter. Nathan C. Wolf, Esquire Victoria E. Greeger MichaelJ. Whare, Esquire -~",.~:u""~ ^_~ '. )='"I~I" J. - j 71~ 1: .,.. r.' ,-- " ,,' , \: 1\' ') 0.. ' ,,'~t, "". . [ '\: '-.: ~'''' . . - .... <{' VICTORIA E. GREEGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. No. 2001-2824 BRETT A. GREEGER, Defendant IN CUSTODY ORDER AND NOW this day of June, 2006, upon consideration of the foregoing Motion for Leave to Withdraw as Counsel for Plaintiff, Victoria E. Greeger, the requested relief therein his hereby GRANTED and counsel is hereby authorized to file a praecipe to withdraw as counsel with the Prothonotary and to serve notice of this Order and such praecipe upon Plaintiff, Victoria E. Greeger, and counsel for all other parties to this matter. J. Nathan C. Wolf, Esquire Victoria E. Gteeger Michael]. Whare, Esquire ,-,~~--", :-~r(_'-_';_':"f.\~___':-_ ~ ," 'I~'I""!' :1'-:';' 'M'"if~J[ , "(~=:", ,~", .' :J fU,CEIVE.lJ Jut 1 CI 'l\l1i VICTORIA E. GREEGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2001-2824 BRETT A. GREEGER, Defendant : IN CUSTODY ORDER AND NOW this \ () -n.. day of July, 2006, upon consideration of the foregoing Motion for Reconsideration of the Motion for Leave to WIthdraw asE'ounsel for Plaintiff, Victoria E. Greeger, filed by Nathan C Wolf, Esquire, reconsideration of the denial of said motion is hereby GRANTED. Furthermore, the Court's Order of July 5,2006 is hereby V ACAlED and counsel is hereby authorized to file a praecipe to withdraw as counsel with the Prothonotary immediately and to serve notice of this Order and such praecipe upon Plaintiff, Victoria E. Greeger, and counsel for all other parties to this matter. The parties should be advised that the hearing scheduled in this matter for July 11, 2006, at 1:30 p.rn. in Courtroom 5 of the Gunberland County Courthouse will proceed as scheduled before the undersigned. BY THE COURT: Distribution N.ath~ C. Wolf, Esquire - C!oJ~~ p€4.SD&Ja.ll'f 9/or0 Vlctona E. Greeger I /1 l L .f / MichaelJ. Whare, Esquire' ~f'tr ~I so.. ",10/0& "4 . ,- ,---~p IS- ,-- "':~ " -.--..,". ,', 'r' ,."- i;i;1 ~~ f"9 ._ = ~1lI!~~,_. "..- --" ~~[l!IlIrr: -~ ,:,.... ,.,.,. ~ ['.~ , >'- " ,'C~W., 'l,C,ft'i't-'f'~ "'ff0! .,c. '(Y) '~']";"t:tr'" 1!~~,<~;;;;'-"Y?rY~i~I"~f'~' ~',: iri'ii!Iii;~!f'~~-:''i~b:~''; :->'JHf '. -,.~! ....,;:'. .~, ~~ ~ '. ~_"'_," ~, .,.;r~1~~W'!'l'JI:<c"~~Vff-i1<1~m,~,mxnrv.fF:'ln~!IPi!l~!fi );'f~" _ ". - NATHAN C, WOLF, ESQUIRE ATTORNEY ill NO, 87380 WOLF & WOLF 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 VICTORIA E. GREEGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2001-2824 BRETT A. GREEGER, Defendant : IN CUSTODY MOTION FOR RECONSIDERATION NOW COMES counsel of record for Plaintiff Vietoria E. Greeger, Nathan C Wolf, Esquire, and respectfully submits the following motion for reconsideration, pursuant to Pa.RCP. 1701, and in support thereof, avers as follows: 1. Plaintiff, Victoria E. Greeger, is an adult individual who is a resident of the State of Pennsylvania, and whose last known address was 175 East North Street Carlisle, Pennsylvania 17013. 2. The undersigned filed a motion to withdraw as eounsel on or about June 29, 2006. 3. This Honorable Court issued an order denying the relief requested in said motion by Order dated July 5, 2006. (A true and eomct copy is attached hereto as Exhibit A) 4, The undersigned respectfully requests that the Court reconsider its Order on the following grounds: a. The Plaintiff stated to eounsel that she did not want him to represent her at the hearing because she could not afford his services. b. The Plaintiff informed counsel that she would, if necessary, represent herself in the proeeedings. ., ~:"~_. ;c ,x,,, , :-1 -,-;")"7l"'Frl.l'i_,>-. - ! 1 ~_~ d ,.--=~.,' c. The Plaintiff promised counsel that she would contact him to confinn this position following her release from the hospital which occurred on or about June 23,2006. d. O:>unsel has attempted to contaet Plaintiff approximately five times prior to June 21,2006 to communicate with her concerning the preparation of the required pretrial memorandum with no response. e. O:>unsel has attempted to contact Plaintiff at least four times since her release from the hospital on or about June 23, 2006 concerning his representation of Plaintiff, with no response. f. O:>unsel has communieated with Plaintiff's mother requesting her assistance in contacting Plaintiff and Plaintiff's mother has represented that Plaintiff was aware of counsel's attempts and that Plaintiff did not see a need to respond to counsel. 5. The undersigned has, moreover, informed Plaintiff that without appropriate compensation, she had breached the fee agreement between plaintiff and counsel, and that he would seek leave to withdraw from the case. 6. The undersigned believes and therefore avers that no prejudice would be suffered by his client if the instant motion is granted, and that this O:>urt should grant the relief requested in accordance with his client's wishes. 7. The undersigned believes and therefore avers that the O:>urt's granting of the instant motion would not delay the proceedings scheduled before the O:>urt. 8. The undersigned counsel contacted Michael J. Whare, Esquire, counsel for Defendant, for concurrence in the filing of this motion and such concurrence was given. '-"'F', ..,,,,"-,.,.- - ",,1'1' _or ".1'" " I~ WHEREFORE, the movant, Nathan C Wolf, Esquire, respeetfullyprays that this Court reconsider its prior denial of leave to withdraw from his representation of Plaintiff, Victoria E. Greeger, and to grant said relief and permit counsel to withdraw, and to grant any further relief that the Court deems appropriate. Respectfully submitted, WOLF&WO F Dated: July ~ 2006 By: --::;""-'"..~ .,'___.._,'1'_, -, 1 --T ~: 'TI',[', --J f ":"1. n,_ ._. ", -~ "" , , iA'c.!!!_.. VERIFICATION I, the undersigned, do hereby verify that the facts set forth in this Motion are true and correct to the best of my knowledge and belief. 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. Dated: July -1-, 2006 ,.. --, L ;I~ 0" -,-,~~ ,'.-, ~-,,- '''-~l- - "'!"'- RECEIVED JUl 062006 VICTORIA E. GREEGER, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-2824 CIVIL V. BRETT A. GREEGER, DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 51h day of July, 2006, upon consideration of the Motion for Leave to Withdraw as Counsel filed by Nathan C. Wolf, Esquire, and the Court noting that a custody hearing which was continued at the Plaintiff's request is scheduled for Tuesday, July 11, 2006 at 1 :30 p,m" IT IS HEREBY ORDERED AND DIRECTED that the Motion of Nathan C. Wolf, Esquire is DENIED at this time. The Motion will be reconsidered upon conclusion of the custody hearing scheduled for July 11, 2006. By the Court, Victoria E. Greeger Plaintiff Nathan C. Wolf, Esquire Attorney for Plaintiff Michael J. Whare, Esquire Attorney for Defendant bas ---'-~~' ~" P'''_',\'f__",,,_~_-_ ," ,., ".~ ,~_ , I-Y 'j'- r~_ ,_ . , ~-~ NATHAN C. WOLF, ESQUIRE ATTORNEY In NO, 87380 WOLF & WOLF 10 WEST IDGH STREET CARliSLE PA 17013 (717) 241-4436 VICTORIA E. GREEGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF :CUMBE~COUNTY,PENNSYLVAN~ v. : No. 2001-2824 BRETT A. GREEGER, Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Nathan C. Wolf, Esquire, hereby certify that I maileQa,tnleand correct copy of the foregoing Motion for Reconsideration of Motion for Leave to Withdraw as Counsel to the below- listed persons by u.s. Mail addressed as follows: Victoria E. Greeger 175 East North Street Carlisle, PA 17013 MichaelJ. Whare, Esquire Rominger & Whare 155 South Hanover Street Carlisle, PA 17013 Counsel for Defendant Dated: July -1-,2006 olf,Esquire -''''~-~ "",'1,-~<-" . '1-1 " - ! '1"- ...- 4 ~J~ c~~ ,~" .~~' '00>>" . _~~'~~,~ , ~. ",- -,-.~. ,~, ~''"'-'>-I'~''o<''1 -~ -.~ ,~, unn 111" (' ,~, D '^";:;. '., "~ ~T\ ,~--- C. .-1 L_~ fi"i;Q I '-r' I --- , . C:) ) ~--" c..) :T} c:~ .~ .,-- _, ~ '_ ~'._, '_'," "" ,,_ 1!IIIIII'MI'1~~, ~ _" .-" .7,'t_ _ '" _ _ ,11 ~~!i>7';'-"('I"'--~-'1'~~,,",lW$'1<~':'~""'''''--,~ "_.",_~./,$J_ ' .~,~J .,_~I~~~.-~,;,_",3"~ ~~ NATHAN C. WOLF, ESQUJRE ATTORNEY ill NO, 87380 WOLF & WOLF 10 WEST HIGH STREET CARliSLE PA 17013 (717) 241-4436 VICTORIA E. GREEGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF :CUMBE~COUNTY,PENNSYLVAN~ v. : No. 2001-2824 BRETT A. GREEGER, Defendant : IN CUSTODY PRAECIPE FOR WITHDRAWAL OF APPEARANCE OF COUNSEL OF RECORD TO THE PROTHONOTARY: Kindly WITIIDRA W the appearance of NAlHAN C WOLF, ESQUIRE, as attomeyfor the plaintiff, Victoria E. Greeger, in this matter. JulyL 2006 AT F, ESQUIRE 10 West H' eet Carlisle, 7013 SUPRE COURT LD. No. 87380 (717) 241-4436 xc-,. <H,"C',y_", ,---r. ,;", _ ; CF_" ,-, -r-cr-I' 1'- L 1-, , 'f i.J fl13 ",-' , -~~-- <<-- ~-" --~ TIL m'fl~,. . _~_'u,~_ ,-.'"_'r_ ,-~ ',"";C,',,,"-' -~ ,'.., '-Z;'"5i~,Y,;/Z"~'__ -.. ,O."""",_^,,,"''"" ~.~,-"~" ,,,- lit' (~, .,. -=-,:! n ;'-,.::, 'C._'. =.:J t;.~E~, C) .,' "_~__' ,_,~" _"W~ > ",_ h_' .",_~J~jmJllj~!Iil'n"r%i'&-R~fiJl~~~:i!!,~~~IlII"~ffl!i~II~li~!i~'~;j "'-'~ -~,; COMMONWEALTH OF PENNSYLVANIA . . COUNTY OF CUMBER,LAND NO:2001-2824 Victoria E. Greeger . Plaintiff vs. Brett A. Greeger Defendant AFFIDAVIT OF SERVICE . . COMMONWEALTHOFPENNSYLVANlA) . COUNTY OF CUMBERLAND ) AND NOW, this I 01h day of July, 2006, I, Jennifer McKeehan, Legal Assistant for . .. Rominger&Whare Law Offfice, hereby swear that I have served a true copy of the attached . . . . . Subpoena, executed by the Plaintiff in the above-captioned matter, upon Officer Matthews at the . . Carlisle Police Department, Carlisle, Pennsylvania for Officer Latshaw of the Police Department by personal service. Date: July 10,2006 It < rJo COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NO:2001-2824 Victoria E. Greeger Plaintiff vs. Brett A. Greeger Defendant SUBPOENA DUCES TECUM To: Officer Latshaw Carlisle Police Department 240 Lincoln Street Carlisle, P A l7013 1. You are ordered by the court to come to the Courtroom #5, Cumberland County Courthouse at Carlisle, Cumberland County, Pennsylvania, on July 11,2006 at 1: 15p.m. o'clock, p.m., to testifY on behalf of Brett Greeger, in the above case, and to remab until excused. 2. And bring with you the following: Any documents relating to any incidences regarding the Plaintiff, Victoria Greeger and the Carlisle Police Department. If you fail to attend or to produce the documents or things required by this subpoena, you may be subject to the sanctions authorized by Rule 234.5 of the Pennsylvania Rules of Court Procedure, including but not limited to costs, attorney fees and imprisonment. Requested by a party/attorney in compliance with Pa. R.C.P. no. 234.2(a): Michael J. Whare, Esquire 155 South Hanover Street Carlisle, PAl 7013 (717) 241-6070 Supreme Court ID # 89028 BY THE COURT, Date: YUPf Ie .2.0IJt.,. Seal of he Court By: Prothonotary Q//,,~(} fl1,oOj.J p Deputy '7;:'.~1'!':i'f1ll'i "..' _'I'"" "., ,_oj'" I,~ r' , - -'~, "I: I'~ ,'1-, ';; If& 'f~ ,~ ~. ~.~~ -,.~~ ~, - . ~-," "",~ -~ .,..""- 'o,.~" ~", 'i"'''''''' .,,,, -~ "J,'~,' _"'>'-.""'''''',->-_'.YW",,:,' ^~";iT,,,""-'.:,lid1",,~"i<"~ 'f"'''''-.'''~rnlr~I"._':t~-- r-'. ,_ -11 '"n ~ c; C') c. ...... ' " ,,; TlJI!OOI-'l~i!l~ ~ f~l!!1~~ ~~pFi~'\~r""i'.;"T'-"P';;'~-"';"'_S'~!~~~~IW~~."ll;a.1~~!'Ilim~~~~~ 'n ~ I' ... COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NO:2001-2824 VictoriaE. Greeger Plaintiff VS. Brett A. Greeger Defendant AFFIDAVIT OF SERVICE coMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND ) o s~::~ :,:',:-- " 1.1 AND NOW, this 10th day of July, 2006, I, Jennifer McKeeban, Legal Assistant for Rominger & Whare Law Offfice, hereby swear that I have served a true copy oftbeattached Subpoena, executed by the Plaintiff in the above-captiQned matter, upon Phyllis Opilo at 715 Sherwood Drive, Carlisle, Pennsylvania by personal service. Date: July 10,2006 '"';~- "'__,0 . , ~1"".rT;;r-"- , :--' '1";- ..., 'c.::'J 'C) ~ -n -I fh:lJ ,- in ~~j (_.. c: ~ a ~~, .." ,-:-:-J"i (":Sf~l~ c-1 ?z: -~ C",) CJ'9 a ... ,- . . A COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NO:2001-2824 Victoria E. Greeger Plaintiff vs. Brett A. Greeger Defendant SUBPOENA DUCES TECUM To: Phyllis Opilo 715 Sherwood Drive Carlisle, PA 17013 I. You are ordered by the court to come to the Courtroom #5, Cumberland County Courthouse at Carlisle, Cumberland County, Pennsylvania, on July 11,2006 at I :15 o'clock, p.m., to testifY on behalf of Brett Greeger, in the above case, and to remain until excused. If you fail to attend or to produce the documents or things required by this subpoena, you may be subject to the sanctions authorized by Rule 234.5 of the Pennsylvania Rules of Court Procedure, including but not limited to costs, attorney fees and imprisonment. Requested by a party/attorney in compliance with Pa. R.C.P. no. 234.2(a): Michael J. Whare, Esquire 155 South Hanover Street Carlisle, P A 17013 (717) 241-6070 Supreme Court ID # 89028 BY THE COURT, ~) , ! II Date: \,-1,...1:<.1 iO 8,(rO L. Sea'\ orthe Court By: /5/ C..el.v; R .f,"<---r Prothonotary ~. J ~Q - )j1_d.e.~ Deputy -',''!'''''~''-'''''~~ ""-" , "",-",." eo"__~,_!_ P '.'- ,''''+'1 - l' '>-'''1 - ~ . ~ VICTORIA E. GREEGER, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-2824 CIVIL V. BRETT A. GREEGER, DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 11th day of July, 2006, the parties having agreed to the attached stipulation with regard to custody of the minor child Garret Quinn Greeger, born February 2, 1999, IT IS HEREBY ORDERED AND DIRECTED that the stipulation as to custody is entered as an Order of Court. By the Court, Michael Whare, Esquire Attorney for Defendant Victoria E. Greeger Plaintiff ~ ~ '7_n-o~ ~, . ~.~rry;;}"- 11'-' . c -,- '. -1"'1' 'r ,-" , "' Jlil ., Ii ~ ::r' .. ~,_",,",~' _. 0 .,.'-' _'_~ l~'lll~JW~ '~ ,,-.'-....,- " ,~'.~,,~'. .... ,~; -, !(, 'C, AU, -~. ' ,"""'-".,..",,"-'" ,'- "'- '~.^'~,- '''-" " - ,~~- ~ ~-~-' '"""" l'trT-"[ r , ,,~-- ~~m:!Jfl\iI~_~,~,_~~ll~i!li0,C"~'""'~','-'<r"mn"l'5:~f~;O:~ffi'i1i-Wl'!!%FI;);'/W!!Jll~~~~~l".~ " . '--~'''1'"', . . VICTORIA E. GREEGER, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-2824 CIVIL V. BRETT A. GREEGER, DEFENDANT IN CUSTODY STIPULATION AND NOW, this 11th day of July, 2006, upon agreement of the parties, IT IS ORDERED AND DIRECTED as follows: 1. The Father, Brett A. Greeger, and the Mother, Victoria E. Greeger, shall have shared legal custody of Garrett Quinn Greeger, born February 2, 1999. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well being including, but not limited to, all decisions regarding his health, education and religion. 2. Father shall have primary physical custody of the child. 3. Mother shall have periods of partial physical of the child as follows: a. Beginning July 21, 2006, on alternating weekends from Friday at 6:00 p.m. until Monday at 6:00 p.m. during the Summer. b. During the school year, on alternating weekends from Friday at 6:00 p.m. until Sunday 6:00 p.m. c. Such other times as the parties agree. 4. Both parents shall have liberal and reasonable telephone contact with the child when the child is in the custody of the other parent. 5. The parties shall keep each other advised immediately relative to any medical care or medical emergencies concerning the child and shall further take any necessary steps to ensure that the health and well being of the child is protected. During such illness or medical emergency, both parents shall have the right to visit the child as often as he/she desires consistent with the proper medical care of the child. 6. Neither parent shall do anything nor permit anyone else to do anything which may estrange the child from the other party, or injure the opinion of the child as to the other party, or which may hamper the free and natural development of the child's love or affection for the other party. 'rl ~ .- r -' . :""'''''''''''''' . 7. The parties may modify the provisions of this order by mutual consent. In the absence of mutual consent, the terms of this order shall control. ~~. G'!:..} r-( ~Jd/~ ~.doJ fI/1~ f fr-/L . II .., ,