The URL can be used to link to this page

Home My WebLink About01-03302 -,~- -,< -- - '," ~ -" ,"'c_,,_ - < ~ "' ',,> _"'_~,,_<- ,- ,;~ ',-_ '"' __ '~I _, _",", de. ,',' ",~,--1--.""I'" ""% '-'_~,~"~,n~y,,,_, ,k~'",R'",'-~-,",-~';-""'_"~' "'0 ,. .. MAXINE D. PIPAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-3302 CIVIL ACTION - LAW CYRIL F. PIPAN, Defendant : IN CUSTODY L: I !'; ORDER OF COURT i~ ,. i~ 1/ l): ~,; ri if I:; I';: ~i! i~ ri: I'. ~ ii- AND NOW, upon consideration of the attached Petition, it is hereby directed that the parties and their respective counsel appear before Melissa Peel Greew , the Custody Conference Officer, on the day of , 2001, at . a.m.lp.m. at , Pennsylvania, 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. Children need not be present at the Conference unless their presence is . requested by the Custody Conference Officer. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. Ii "i FOR THE COURT, Date of Order: By: Custody Conference Officer 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 1-800-990-9108 - < , . ~ '''-- ,,, - ""'"~,,-- , , MAXINE D. PIPAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. Defendant : NO. C>l- .J16;;J.. : IN CUSTODY C;0~CY~ CYRIL F. PIPAN, ORDER AND NOW, this day of , 2001, upon consideration of the attached Petition for Emergency Relief, it is hereby ORDERED AND DECREED that Alexandra Pipan shall be returned to the primary physical custody of Plaintiff pending further Order of Court or a full hearing. BY THE COURT, J. I . --.,;-;,,~~' ,,,'-~ ~llI!i~" MAXINE D. PIPAN, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. D/- 330;>"" C:o~[ (.. ,~ : IN CUSTODY v. CYRIL F. PIPAN, ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , the Custody Conference Officer, on the day of , 2001, at a.m.lp.m. at , Pennsylvania, 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. Children need not be present at the Conference unless their presence is requested by the Custody Conference Officer. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT, Date of Order: By: Custody Conference Officer 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 1-800-990-9108 ,;:.'" t 1-,' , -~- """"',,",u '" .. MAXINE D. PIPAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 01- 3302- : IN CUSTODY v. CYRIL F. PIPAN, Defendant RULE TO SHOW CAUSE AND NOW, this I~ day of ~ , 2001, upon consideration of the Petition for Emergency Relief, a Rule is issued upon Defendant, Cyril F. Pipan, to show cause why Plaintiff's relief should not be granted. - a;, ~()Ol. RULE RETURNABLE UI.INI' 1-;',' "A 'I . ~.~4___=-::-"jI_I\'j_";;;II=-_..".",-_, ~.IiU"t.JlLI!!. RULE RETURNABLE JUNE 8, 2001, at 2:00 P.M. IN COURTROOM # 5 OF THE CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PENNSYLVANIA 17013. EdW~te.J E, Cu,.,JlJj J. /J opu-nJ L- 6-/-01 @ -, ." " ~"- -- """" " ~+ '~, ^ ''';-;1' "--'~'"'''''"-''',^,,,.,,~,,,,,,,,,,,, '01,',- ,._",'-- ""'."'f'''''''"'''''' --='i11iitln11 n-illi ] r r "r~-"'''''''-T~'' . F1LEf}-(}fFiCE ('r ""r "C)r -. ;"', 'OT. ir' i >""j-. i-' ~,- , ) t ,",\, Ji'l MY ~ "_,,,,' :.~ ,I ;\." o I JUN - I PM 12: 53 CUMBEfil.f\ND COUNlY PENNSYLVANIA t .. , ,,_' , ,," _....... _"', ,. ~~!lll~iijl!!!M-~~~;jlf!~U'ji~\J,~~,-!tti'.j~H!,>,;",,,-,,~,*,,<,,p;jW~~~~~~l:<liijl!l[;!\if~'1Nt~l'ij!j!~HWWjftW~I[)1f"JJ~~~ ~" 'd I '-, '. ~ - ~~"" ~'" < "-'--i<&"~~,,i_, f MAXINE D. PIPAN, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNlY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. : IN CUSTODY v. CYRIL F. PIPAN, PETITION FOR EMERGENCY RELIEF AND NOW COMES Plaintiff, Maxine D. Pipan, and petitions this Honorable Court as follows: 1. The parties are the parents of two minor daughters, Alexandra, born September 27, 1986, and Audrey, born September 26, 1995. 2. Until Friday, May 25, 2001, the parties and both of the children resided together at 416 Allendale Way, Camp Hill, PA 17011. 3. Plaintiff recently instituted a divorce action against Defendant docketed to No. 01-3132 and a copy of said Complaint was served on Defendant on May 25, 2001. ~ k iliIiiI ." ,,.;~=, " ...."'.""'~~>i, ~ 4. On May 25, 2001, Defendant left the marital residence and took Alexandra, the parties' 14 year old daughter and neither has returned to the home since that date, except for a short stop at the residence to retrieve clothing for Alexandra. 5. Defendant has refused to advise Plaintiff where he is residing and where Alexandra is residing. Defendant has refused Plaintiff access to Alexandra and Plaintiff is unaware of Alexandra's exact location. His general response to questions concerning Alexandra's whereabouts is that "she is with me". 6. Since May 25, 2001, Defendant advised Plaintiff that while he was working, Alexandra was with certain family members (patemal aunt; paternal grandparent) and keeps changing her location so that when Plaintiff contacts the family member that Alexandra is to be staying with, she is advised that the child is not there. 7. Defendant advised Plaintiff that he has legal counsel, but refuses to advise Plaintiff of the name of his attorney. 8. Plaintiff is concerned that Defendant will attempt to take custody of the parties' other daughter, Audrey. 9. Plaintiff has been the primary care giver for the children. , -' ,-,'I 'J, '--'~ ~~.....,-',,- w .~< '~->"~: 10. Simultaneous with the filing of this Petition, Plaintiff has filed a Complaint for Custody and it is her desire that Alexandra be returned to her primary physical custody until custody can be resolved through the Courts. WHEREFORE, Plaintiff requests the Court to grant her primary physical custody of the parties' two children, Alexandra and Audrey, until further Order of Court or a hearing on the issue of custody. ~~H~/ "'Sandra L. Meilton, Esquire TUCKER ARENSBERG & SWARTZ 111 North Front Street, P.O. Box 889 Harrisburg, PA 17108-0889 (717) 234-4121 ATTORNEYS FOR PLAINTIFF .,<,e .,L ,L. '.->'':'_0'. ,-, ".~'" .-'n"'iiri'f"; VERIFICA liON I, the undersigned, Maxine D. Pipan, acknowledge that the facts stated in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to the penalties of 18 Pa. C.SA Section 4904 relating to unsworn falsification to authorities. 0---CY Maxine D. Pipan -----------.._, Dated: ?/?{)/o/ , 40220.1 ~~~l/l~~~li&iJWll&m1~~:U.w.i>i>j~ii>1WJ;4s'~;:~""'~,k,l\;Ii';'J'_'~'g}B!ii&;)&'ill;M,<M"..mIJ,:~~~rr ~>, ~ ,', lit-r ifd > -, l>!nli\.ur~"~"l.>Ml~'~ fV (J " p ~ -~ ~' v " r " r~-; ".,~ "g f a ~ - ,) . . , ()) . ' C' -, J ~) ~::=\,-- .~ '- <> ,~-' ,-- ~ "-7 \ ; ......... ~~ 10 tJ \.,,~' .' -" ~ -'':'r t =2 7:J ~ ~ f"v -, --...0 ~ '-:..... -";!,!)+.,t;",:!]~,,:JJ~'-.,,,~JI,-,,~,t.,M:r.nJJ::1:rr JU._U_"_-"_"'1'c,<"-,,,_,L'~0(<"_>~''''';:' U_"~<01",~'"",~~'"'1'''~''''''ry;~~._-, ,,_c, "'.' -'0" _<' .~,. _ ,~_ . ""~ ~ " ~L ,-~ ~ " ",""''''''~~ ' -, >~ ~,~~ - 1.-,; .'~ 1Ill1!lli'" ""'-"~i~-, ._ -( -..i_' . , MAXINE D. PIPAN, Plaintiff :1N THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :NO.01-3302 CYRIL F. PIPAN, Defendant :CIVIL ACTION - LAW :1N CUSTODY PRAECIPE FOR ENTRY OF APPEARANCE To the Prothonotary: Kindly enter the appearance of Thomas A. Beckley, Esquire, Elizabeth S. Beckley, Esquire and Beckley & Madden, of Counsel, on behalf of the Defendant, Cyril F. Pipan, in the above-captioned matter. DATED: (i4!q h~~ Of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, Pennsylvania 17108 (717) 233-7691 " .-, , 1,1., ';.;,;_" '-i!,jj~\:-! , CERTIFICATE OF SERVICE I, Elizabeth S. Beckley, hereby certify that a true and correct copy of the foregoing document was this day served upon the persons and in the manner indicated below. DATED: &/tlClI FIRST CLASS MAIL Sandra L. Meilton, Esquire Tucker Arensberg & Swartz III North Front Street P.O. Box 889 Harrisburg, Pennsylvania 17108-0889 . . "' '-~- '.'.-'f ~ - ''"'.''''"",~-fj~' COMMONWEALTH OF PENNSYLVANIA COUNTY OF: DAUPHIN SERVICE OF ,PROCESS COllllllonwealth of PClIIlsylval1ia Pennsylvania State Constable *"- ~ ,. . f'1i(.), fv;/lX'rV[ fl. 7/f/J~1 DEFENDANT: ,- VS. NAME and ADDRESS "I Michael P. Maugans 11r:;, CYI;/L f, 7/1/;/I' Pager nO-H20 I (717) 5..t5-<H.IX L Docket No.: tJl ~ ;3/.:7..2 Date Filed: CIV/L ~.t;l1 .5'')1 tfl .J ... , ,--':,'.....',,' ....., .' . . . Servedupon L'/!<IC f, 7r7/ld Describe Documenl(s): /, )> J Vt'fl..\E C,.t.1?f/)//j ffu) ::TJ CrAl'f'j'f;UI///2> Cn,,,j'7'V" tJ/, 313'2... :(,C,r/i1rLI1i,.(/ fu,J( LN~7<')1 &1' /111'*1... CJ//i)X;:I\( /:f. tl/~:JYd.:z ./ ],. i7/'(II1'/ hi<. flVt'ffL&[rtcy tJdlt;C /1 tJi' 3;J~~ C/v/L 'ffA",tI1 tf. Lf.-c1t r~/o1 S/14/JKIj j, /11E/t;"A( ,/"-;;;c!(1R- /l/lEr!Jlb(',? .J. Si'.//!R1~ r;;)( '/ /f / ,.11/ t:: p~ C 0. IVIE. d -r.f/ taX' C -r? -rp (Person Actually Served) (Person 10 be Served) , by handing a copy of >CLf (Relationship) on 5/.71 II'I I ' (Date) , at 3: If' <? 7r .M., at (Time) 0;fJN/ !it)5 Wtf;ZI1IJCI/ I J:Jt /(Lfl,lE Vtt/?{L 5f1t17f}/C CE-if/Efl- i!JlG./M, (Location) For Landlord/Tenant complaints: Since none of the above found, served by posting a copy of the complaint conspicuously on the premises on , at .M., (Dale) (Time) .. at (Location) Miles Traveled: ~~-9~~ -iiiR . M~~. , S I A!:!l.t: AOPC 624.95 (Print Name and Title) ~ <~,~. -''''''^'>,, ._,,-'" ,... ,~ ~ -,~ ;[,J._,,cfi:9,.~,,;';"_-,,,~,y.:c~Wi:m~~~il:frJ~J!l!it;.~Idicl1m!IS~ o ~ -at?..; r;l(~:: ~-~~~' ~f5 ~~C-' ~7() ~-c: L ~ ~- -~ ~~ =. "_~, , ',0'" ", -~~ ~- _~i o I.:; "1'1 :.i= -~, , -c- '-"'T' ,~~ ...::-';...r') O\~n j;! ::rJ -< :? w C.f! ~ " ""I, " --"- -.-koi";"t"'~i:1;;!li, MAXINE D. PIPAN PLAINTIFF V. CYRIL F. PIPAN DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-3302 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, Jnne 11, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 214SenateAvenue,Suitel05,CampHilI,PA 17011 on Tuesday, July 17,2001 at 11:00 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. The court hereby directs the parties to furnish auy 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 Melissa P. Greevy. Esq.Ob 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 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 (717) 249-3166 , II II II 'I Ii I'I~"".- ~ "".I" _ 1111Jfl >.<, ,- .~ , ~,'''..J_ '",~ ',,~ yr,. . -~- <10,e ,'_ _C' - -.<_~ .'.,,,' [-,-,'f,'"'' ',-,,-- "'"'-~'''~,,"''''''h''''' -f,0<",'d "~",,'.,- ~",,-,,-;-, "-!G1'0:';1-'ltfi[Iii,j"'t'i\;M0'"-&J"i-;---'~""h'-"'''jJ'l'iffifi(i'~:l'f't~'''''t- F!l.ED--{)i:r:CE OF ,. "-'~l"j".!Gli\RY 01 JUN I 3 Pi! I: I; I; CUI'~;"i:I"! ',:d,', ('U'.u'mt iV.t..J.... ,u~'J,...r \.,) I'll v PENNSYI.VA:\JIA t'/3-CJ1 W. c'~ /P2~~ :t a5' ~ tb -13 -01 71du ~ -z, djfI 6-13-01 ~ /n~ 1$ ~ ~ .. , ~ "'".Jh,."....,.__,".,~~,~~ ~""f"~"'!.,T, " ~!ffill!"c:'_,p~~,.-"''lI!f,-'f,''-'1_:<ir-r'i!'>1-,~'-,~1t'~'''''N.JJw.<<;lrKJ;f''!W'''~'#$.ff1-ID'FiW',,''R"W11f1,~~~~~MJ~~~~ .= -. -~:i'- MAXINE D. PIPAN, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 01- 3302 C,..,,'II~"" CYRIL F. PIPAN, Defendant : IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Maxine D. Pipan, who resides at 416 Allendale Way, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant is Cyril F. Pipan, has not resided at the marital residence (416 Allendale Way, Camp Hill, PA 17011) and his current residence is unknown. 3. The parties have two minor children: Alexandra Pipan, bom September 27, 1986 and Audrey, born September 26, 1995. Plaintiff seeks shared legal custody in the parties and primary physical custody of the children in her. Alexandra was born out of wedlock and Audrey was born during the parties' marriage. Currently, Audrey resides with Plaintiff at 416 Allendale Way, Camp Hill Cumberland County, Pennsylvania, and the exact location where Alexandra resides '. , is currently unknown. " . - '~ '- - -'~,,",- ~'"'.;t.i~-.;! During the past five years, the children have resided with the following persons and at the following addresses: Plaintiff, Defendant and both children 416 Allendale Way Camp Hill, PA 17011 Until 5/25/01 Plaintiff and Audrey 416 Allendale Way Camp Hill, PA 17011 From 5/25/01 to the present Defendant and Alexandra Unknown address or Addresses From 5/25/01 to the present The mother of the children is Maxine D. Pipan, currently residing at 416 Allendale Way, Camp Hill, PA. She is married. The father ofthe children is Cyril F. Pipan, whose current residence is unknown. He is married. 4. The relationship of Plaintiff to the children is that of Mother. The Plaintiff currently resides with the parties' daughter, Audrey. 5. The relationship of Defendant to the children is that of Father. The Defendant's current living arrangements are unknown to Plaintiff except that he is alleged to be residing with Alexandra. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 1Il1& '~-i1l'- Plaintiff has no information of a custody proceeding conceming the children pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because Plaintiff has been the primary care giver for the children and can provide a more stable and nuturing environment for the children. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff requests the court to grant shared legal custody in the parties with primary physical custody of the children in her. 4A1d1A/~~~ Sandra L. Meilton, E quire TUCKER ARENSBERG & SWARTZ 111 N. Front St., P.O. Box 889 Harrisburg, PA 17108-0889 (717) 234-4121 ATTORNEYS FOR PLAINTIFF . -. "' , VERI FICA liON I, the undersigned, Maxine D. Pipan, acknowledge that the facts stated in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Dated: 40217.1 A;--(-J!-a Maxine n. Pipan 5/50/0/ -. - . w ~ ' i&2;~4 ! ,,~'"~~,~, ,-' -~ 1'r?" "'-[~Ii:~Mi~Wl1~~",jlUl<,"","iil_@iIIH!l'--Yi1,oUili!i,ih-s*W'Jth;~';f~1€r%iftj''-'''' ~tP .th:.m"I!IIIUlL _ "o_'~."~' .J~"",~" " _~ _,~, o/',,,",,,,,",."..",.;".',c-,_,'- >=_",,", ',"', ~^~< ", _ '.'\'-'_o~ "it '0, ~ 1iil lIIiIiIIiJ~tltiMI-'~-~-'~' -,:;G~ ~ t ~ ~ B tJ '- '- 10 t 'V ~..- ~, ~- ~ < ' u F J .. r,'" ,,_ ,., ~" H -;:,; GJ, t~~~ .0__ " ~:: :~:C' ;~ t :..------;: -< h . ::L'--, ',,0 :.J cr. ~~ ; ". L ~ _"'__J_","-I,,,";",'"'';;; , . ,-' . ." ""~ ,,^--\ "'- MAXINE D. PIPAN, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW CYRIL F. PIPAN, Defendant IN CUSTODY : NO. 01-3302 Civil Term INTERIM ORDER OF COURT AND NOW, this l.v *" day of ~ , 2001, pending resolution at a custody conciliation conference currently being scheduled before Melissa Peel Greevy, upon stipulation of the parties, it is HEREBY ORDERED AND DECREED AS AN INTERIM ORDER OF COURT, that: 1. Deborah L. Salem, MHS, CAC of Inner Works (or another agreed upon counselor if Ms. Salem is not available) shan provide therapeutic family counseling to the parties and their children to assist them in establishing appropriate lines of communication and addressing custodial issues as they arise. 2. Any non-covered expenses incident to the counseling shall be shared equally by the parties. 3. Pending the results of the counseling, custody shall be as follows: a. The parties shall share legal custody of Alexandra and Audrey. b. Father shall have primary physical custody of Alexandra. '"""",.,,,,,,,,,,- . ~ -I " ~ -- <-" ~. - -",ci';';';"'"_~'~j: , If. . c. Mother shall have primary physical custody of Audrey. d. The children shall spend weekends together alternating the weekends between their parent's home. The alternating schedule shall begin with Mother having custody of both children on Friday, June 8, 2001 at 5:00 p.m. through Sunday, June 10, 2001 at 6:00 p.m. 4. This Order shall remain in effect until modified by the Court or by mutual agreement ofthe parties. 40345.1 i/ .~~~ \' ~-~\'\)\ \JV J. ~--~, ~, "'~--" ..; I ~, -~bI!Ii_I.!i'- ":"'~-''"~'-'''WI~ . ,.- ~. MAXINE D. PIPAN, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CYRIL F. PIPAN, Defendant IN CUSTODY NO. 01-3302 civil Term STIPULATION .yh AND NOW, this J day of <f4fLL- ,2001, Maxine D. Pipan, Plaintiff (hereinafter referred to as "Mother"), together with her attorney, Sandra L. Meilton, and Cyril F. Pipan, Defendant (hereinafter referred to as "Father"), together with his attorney, Elizabeth Beckley, hereby inform your Honorable Court that they have reached an interi~ agreement with regard to the custody issues involving their minor children, Alexandra Pipan, born September 27, 1986, and Audrey Pipan, born September 26, 1995, and do hereby stipulate as follows: 1. Deborah L. Salem, MHS, CAC of Inner Works (or another agreed upon counselor if Ms. Salem is not available) shall provide therapeutic family counseling to the parties and their children to assist them in establishing appropriate lines of communication and addressing custodial issues as they arise. 2. Any non-covered expenses incident to the counseling shall be shared equally by the parties. 3. Pending the results of the counseling, custody shall be as follows: a. The parties shall share legal custody of Alexandra and Audrey. " ,~ > ~ ~-- . I' . " ~ ,"~-" floW- - ~~ ..I. )!i~lI~.'i . b. Father shall have primary physical custody of Alexandra. c. Mother shall have primary physical custody of Audrey. d. The children shall spend weekends together alternating the weekends between their parent's home. The alternating schedule shall begin with Mother having custody of both children on Friday, June 8. 2001 at 5:00 p.m. through Sunday, June 10, 2001 at 6:00 p.m. 4. This Order shall remain in effect until modified by the Court or by mutual agreement of the parties. ~~~~~~ s"andra L. Meilton L~&(fi' Maxine D. Pipan ~ Cyril F. Pipan ~~~~__~iIinii!tl<<I~fI;1~j~~m<;W~~,"';.i"i1'"""4i,;r":"';"i""'-2'~",~>iJFw..ii~d~~ t;')n (.1 "l-j( /.-j;,;->;;L,"m;1~\.JL;~~.!L!MJt~~)_Ju.",_~~,l:,:u~u.r ;,-L,,,,L,.,~,>,,,t.:_,_-,,,.,,,~'t1"',~~_:;e,'_ ___~",'!c,' '_'~ _,~_, -, ',',_J DJliiin "",.- -1fJ~~'''t.,.......-,,,,,,~~ ,"'" ~ ~- ,~" in" -, - . (") 0 0 C 'n s:: C- -urn c: -'" rl1rr_ z d Z'T- i='. ZC -'-,",'{ ~~~ G) - ~:; '.:,:7 -0 ~: ~:~ ~;} ,- -~- " "'-"'c. ~""Q-" .,~~ 'Tj ZCS ~"j ,''''', ----;;?I..,J S>c: N OITt Z ,~ s;j ~ (~ ~ ~~. ~ ~_e ., ---:' '""- , , " , . _ , " \-~,,' -)., "" ,_.ii--,j,' .1 __'''. '" .' ,- ~' _ ' '-.',-,;:, ( -~ -- Plaintiff JUL3 02~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3302 ; ,. , MAXINE D. PIPAN, vs. CYRIL F. PIPAN, Defendant CIVIL ACTION - LAW CUSTODY TEMPORARY ORDER OF COURT AND NOW, this 30'" day of :r ~ , 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Maxine D. Pipan and Cyril F. Pipan, shall have shared legal custody of their minor Children, Alexandra P. Pipan, born September 27, 1986, and Audrey M. Pipan, born September 26, 1995. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of Pa. C. S. S 5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. The Mother and Father shall have shared physical custody of their minor Children with Alexandra residing primarily with Father and Audrey residing primarily with Mother. 3. Mother shall have custody of Alexandra on Mondays and Thursdays from 3:30 p.m. until 9:15 p.m. During the school year, Father shall pick up Alexandra at Mother's home at 9:15 p.m. on these evenings. During the summer, Mother shall pick up the Child at Father's home. 4. Father shall have custody of Audrey on Tuesdays and Friday from 4:00 p.m. until 9: 15 p.m. until school starts. When school has begun, Father's Tuesday periods of custody shall begin after school until 8:00 p.m. 5. The parties shall have custody of both Children on alternating weekends. The parents shall have additional periods of custody with their daughters at such times as the parties may agree. ,""" - '<"', <- j [.,-,;- L "',~ ,-'-" C~ '-,' --.. "' "" , , '; lif:! No. 01-3302 Civil Term 6. Telephone Contact. The non-custodial parent shall have reasonable telephone contact with the Children when they are in the custody of the other parent. 7. Holidays. The parties shall share time with the Children on the following holidays to include: New Year's Day, Easter, Memorial Day, Independence Day, labor Day, Thanksgiving and Christmas. Mother shall have custody on Mother's Day and Father shall have custody on Father's Day. The parents shall arrange for the Children to see the non-custodial parent on each of the Children's birthdays for no less than two hours. 8. Summer Vacations. Each parent shall be entitled to one continuous week of custody with both Children for the purposes of taking a summer vacation each year. 9. Neither party shall do or say anything which may estrange the Children from the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development of the Children's love and respect for the other parent. Each parent shall ensure that other family members and/or third parties also comply with this provision during his or her periods of custody. 10. Counseling. The parties shall cooperate fully with the counseling services they are presently receiving at Inner Works by attending appointments regularly and making the Children available for the appointments as indicated by the Children's therapists. Any expenses incident to the counseling which are not reimbursed by insurance shall be shared equally by the parties. 11. This Order is entered by agreement of the parties. It is contemplated that it may be appropriate to change this Temporary Order following a period of counseling as the parties and their Children make the adjustments to the parties' separation. 12. The Custody Conciliation Conference shall reconvene at the office of the Conciliator, Melissa Peel Greevy, Esquire, 214 Senate Avenue, Suite 105, Camp Hill, Pennsylvania 17011, on Monday, October 15, 2001, at 11:00 a.m. ~ f\~ BYTHE T, u.3\.()\-'I ~tc Edward E. Guido, J. Disl: Elizabeth Beckley, Esquire, 212 N. Third Street, PO Box 11998, Harrisburg, PA 17108-1998 S@ndra L Meilton, Esquire, 111 N. Front Street, PO Box 889, Harrisburg, PA 17108-0889 .- L'_ 'I. -~-_' , ,~- = _'ok>' ","'.'~ '" 0 ,";."__,.'_. ,....;-, ~ JUL 3 0 7001 ~ . MAXINE D. PIPAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3302 vs. CYRIL F. PIPAN, Defendant CIVIL ACTION - LAW CUSTODY 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 Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Alexandra P. Pipan Audrey M. Pipan September 27, 1986 September 26, 1995 Father Mother 2. The parties' first Custody Conciliation Conference was held on July 17, 2001, with the following individuals in attendance: the Mother, Maxine D. Pipan, and her counsel, Sandra L. Meilton, Esquire; the Father, Cyril F. Pipan, and his counsel, Elizabeth Beckley, Esquire. 3. The parties reached an agreement for a Temporary Order in the form as attached. 7b1/o/ Ltlt;/';;JLa-- Melissa Peel Greevy, Esquire Custody Conciliator --~~ Date '-'-, ,j -I~ , ',;---~ ':iE'~uth MAXINE D. PIPAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY CYRILF. PIPAN, Defendant : NO. 01-3302 PETITION FOR LEA VB TO WITHDRAW AS DEFENDANT'S COUNSEL AND NOW comes Thomas A. Beckley, Esquire, Elizabeth S. Beckley, Esquire, and Beckley & Madden, Of Counsel, and hereby petitions the Court for leave to withdraw as defendant's counsel, and in support thereof avers as follows: 1. In May, 2001, at the request of the Defendant to Elizabeth S. Beckley, Esquire, Beckley & Madden agreed to represent Defendant in the above-captioned matter. 2. Counsel undertook representation in the above-captioned matter based upon a written Retainer Agreement with Defendant, whereby Defendant would pay outstanding invoices on a monthly basis. 3. In early August, 2001, Elizabeth S. Beckley, Esquire, of Beckley & Madden, Sandra L. Meilton, Esquire, Plaintiff's counsel, and Debra Salem of Inner Works, the parties' family counselor participated in a conference call because Defendant walked out of a family counseling session. 4. Since that conference call, Elizabeth S. Beckley, Esquire, has tried to contact the Defendant numerous times both by telephone and by mail; however, the Defendant has failed and refused to respond to counsel. - __l "-j o ,j. I, ~, .. - ~_ ; , "." ill "'M ~ 1i ~~~x-,,_~ . 5. The parties' custody conciliation conference date was rescheduled so Elizabeth S. Beckley, Esquire, sent the Defendant notice of the same. The Defendant returned the letter to Ms. Beckley unopened with writing on the envelope. A true and correct,copy of the envelope is attached hereto marked as Exhibit A and incorporated. , , 6. Elizabeth S. Beckley, Esquire, contacted the Custody Conciliator, Melissa Greevy, Esquire, eXplained the situation and requested that she send notice of the new conciliation date directly to the Defendant. 7. Counsel for the Defendant is unable to communicate with the Defendant and therefore unable to effectively represent him in this matter. 8. Elizabeth S. Beckley, Esquire, contacted Sandra L. Meilton, Esquire, about counsels' desire to withdraw from this action and Ms. Meilton indicated that she did not have any objection. Wherefore, Thomas A. Beckley, Esquire, Elizabeth S. Beckley, Esquire, and Beckley & Madden, Of Counsel, respectfully request leave of Court to withdraw as Defendant's Counsel DATED: r-(c../~ Respectfully submitted, Of Counsel ~~-- omasA B ey ~~ BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108 c~' _, _, EXHIBIT A '1,-,-"-<><,--- - - -, - -J - ,~, - , -;. ..: '<J} fi 'j j I 1 , 1!l '" z i 1';1 ... A ~ ~ ~ 9.j~q~ ~~8L~ .ra(pi~~ ~IJJU ~ ~ .. ~ c5 1';1 ;: ~ ~ III ! " L f T ~~-, '1 e '''' w <l ~~ ~;5 J "" GJ ~ <( ~~ ,-.;, LIo e. I '__'H :_,0.,. " .. -,,~.--::,:,.-,-.;.'" 'w, . . "", '"""'jj-. ) <......J -, r ! -S- "S } J J o ~ ~ q' R ~ ' 'i -%0.' ~ 1 1 t ~ 'f'1 'i. -, :~ T ' ? ~ ~ ~ 3 ~ L ~~ ~ 0 \l C) -=<. y-( r-l '<J 'I< ----- '~;"'::'::"~.:f~:_,'__~". '-''0'-; 't' o ~. _lP ~, ~ ~ "" = '" ) - ~ .~ t: 4. If: :; i ~ <.N V ('l -< ~~ ~:t;- J/\ .+ ill o 1 ( ':-""":'-'." "~"""';' ," I "~~, ,'_ ,..J, t,; 7 ' ~ _&', - """" -""-', ~ . CERTIFICATE OF SERVICE I, Elizabeth S. Beckley, hereby certify that a true and correct copy of the foregoing document was this day served upon the persons and in the manner indicated below. FIRST CLASS MAIL Sandra 1. Meilton, Esquire Tucker Arensberg & Swartz III North Front Street P.O. Box 889 Harrisburg, Pennsylvania 17108-0889 Cyril F. Pipan 1124 Columbus Avenue Lemoyne, P A 17043 PATEP: 1~/4~f ~~~~~Il!i;tiit))!it~)_lliljW",*;!.J1frdtMjiilgiijjMtiis'.JH'.Ji<Ui'ii,",;",~-;~;-"lt~'"]<i"W'":iH,~,~jttiii4:1l-[;-!Milli';-,jill:l~~~~~~''''''''''''''' !1'<" -" ,~"'" ~ '<"--,,, ,>,>; ",,", ~. ^ ","'~''''-'---''-~ .."", ~"'~"'''-'''''''''''''"'''-~ ~~ ~- ~, ,,'" .~ , ~,..", ~~, "W ,,~ ,~^ , ""'j - C) C.l C S~ J) i] ,,~ q r'''' l ~ ~ " 'YJ ~.? 2-: Z 'il Q (j) .-J C) -< () r;::: . , -=.~i ~~ "-:;1 -ri :> , .., C) ~-". .' (") ~ 0 C-Y m )> C S'2 ~ z => :;t Iv ~ ,. '__;,l"""""'" - I.'., ~~ 1 [ , ~- ~ ~~ - '~"<.iMWil,,: ~ MAXINE D. PIPAN, Plaintiff : IN THE COURT OF COMM:ON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CNIL ACTION - LAW : IN CUSTODY CYRILF. PIPAN, Defendant : NO. 01-3302 ORDER AND NOW, this ~ day of ~001, it is hereby ORDERED that the Petition for Leave to Withdraw as Defendant's Counsel is GRANTED. Thomas A. Beckley, Esquire, Elizabeth S. Beckley, Esquire, and the Law Firm of Beckley & Madden are hereby granted leave to withdraw as Defe~d~- <". /~ ~. ~~ jI~ ~J. L 1'2()-OI R ~ 1_i11!ll1Jlf "~ _ _._ ~ ~.~ =,-- ~~~"'~ ~-'- "~,,' ""-- ',..",,~ ._, -. ^'~" . "-",,,",. ~'-'4~'-_ . " '. ~'"~"''' ..,"",~ r:1/ r; 'h 1 rlfw11n I nv,Clf\()ilAr( ! C ~""ioMI ('{)ur~!" I !..tIIll\J'-J'.o", '. ~? . ;)0'01 "0, O.-J--1l:R,. .~- M~ _, ~~"-. _, _-.l< ',~~' ~ .~,,~ ...,. r_ ~!iR, ~1'\!$~llllli~~!!'JiiM'l_~I,,,,,,,,,i'~7',,1'Wj':<"ii:':',~_o/'i,~,.~'I",,"!l,--,',--,,~;g'%i'-}i'C'1iM-""K-,"i,Hi_~~Wffi!%W~~M"!"!f~f'i\iIw.!!~~~~: .-;PI . ,~ . ~ ,~ ~L~": .~ Ill'::. --"" ... , ... ..<I MAXINE D. PIPAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY CYRIL F. PIPAN, Defendant : NO. 01-3302 PRAECIPE TO WITHDRAW TO: The Prothonotary Kindly withdraw the appearance of Thomas A. Beckley, Esq., Elizabeth S. Beckley, Esq. and the law firm of Beckley & Madden as counsel for the Defendant, Cyril F. Pipan, in accordance with the the attached Order granting leave to do so. DATED: 1-).)~C11 Of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, P A 17108 l' .... , " l~c_I' ~ , '" ___ {J;-,--~, ~ ~ ' ~J - ~~ , .. - , .:;;:- ")- ~' ~".. ~\ MAXINE D. PlPAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN CUSTODY v. CYRIL F. PlPAN, Defendant : NO. 01-3302 ORDER AND NOW, this .2..0 day Of&.pL, 2001, it is hereby ORDERED that the Petition for Leave to Withdraw as Defendant's Counsel is GRANTED. Thomas A. Beckley, Esquire, Elizabeth S. Beckley, Esquire, and the Law Firm of Beckley & Madden are hereby granted leave to withdraw as Defendant's Counsel in this matter. /5/ tYrL A. &.11 " .". J,--., ,-, -, '~ - ~,"" (' ~ . ~ .. , CERTIFICATE OF SERVICE I, Elizabeth S. Beckley, hereby certify that a true and correct copy of the foregoing document was this day served upon the persons and in the manner indicated below. FIRST CLASS MAIL Sandra L. Meilton, Esquire Tucker Arensberg & Swartz III North Front Street P.O. Box 889 Harrisburg, Pennsylvania 17108-0889 Cyril F. Pipan 1124 Columbus Avenue Lemoyne, P A 17043 DATED: 9---)-j--o/ -ii ~~f:\iil~OOI~t!';"i~#i!F.ii~jjMle;>iI1'L~j,,""'i';'Jh<""'f,?",;;~;*-,<>jb~$l;l#(i~i*li~~.iI!lmW~~~!Mllil/li ~ , . C) ':'~''-'' C__::: C;.: :n u "-'1 11'1 ,. ..;) :-:::::-)'i !~.J ,"- /1" (75 ~~'-- (':: " L~C:)- -~-, ~;L~ >c.: z ,:.n .~ ~ :"'J if! -< ~":,: I~f; 'j: '~ '~ '" ',.,.. . .~'.'~=.<~ .,'~ M'. .c",..",,\,, . MAXINE D. PIPAN PLAINTIFF IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNIY, PENNSYLVANIA v. 01-3302 CIVIL ACTION LAW CYRIL F. PIPAN DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, November 26, 2001 , upon consideration ofthe attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Snite 105, Camp HiD, PA 17011 on Monday, December 17, 2001 at 3:00 PM 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 TIIE COURT, By: Isl Melissa P. Greevy. Esq.~ 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 HA VB AN ATIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE SET FORTIl BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsytvania 17013 Telephone (717) 249-3166 ",l@l,~l;i~ltllil~Wf".~~;:jkt;.(,<f"';li~~"ilS!:2l,(S",cih"'l;Iiil~!\~,\.'iW:~~'}1itj:,,,',~,';l~!,H,,\,,~!,,i:,,c''::{'-'' ,~:,o>",.""_~,,,"hi!i", ,>"-wm~iJ!~~di{_~i<l!JilI~"'- -~'~~~" .Lij ------llill_- ~ ~;:f t-' cst r ?- 11~,& t~ ~ 1 Jifjtk ~~ -t~~ fr ~-l !; - ~~'j ~ -~.~ ~ ~ ~l ,- ~r ~~ p ~1 t $2 1=' '-.,.... '- ~n S. Z rgcn ;2 i rr ., , Zx' ZC;:: N - .- 0)-....,- -.J ,"'-c --<L:'" '-~~.~ ::~) kCf 0:>0 )> zO :::: i:3~ )>0 --.,...( -' C LD OlTI Z """ :r;! -' -< '0 ::D --<, e <~' ..., . ~ ~,~, -~, ~~" .,~ -'~'---" ~,~",,, . -~,,~,-"'-~ ~ , . ~ .. ~ - q ,. ~ '.~' " ,= ., _~,. .' ~ ,-,~ ~~, """"~ VH~<' ., ' ..', Y"'j ... \ MAXINE D. PIPAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. Defendant : NO. 01-3302 CIVIL ACTION - LAW : IN CUSTODY CYRIL F. PIPAN, PETITION FOR MODIFICATION 1. Plaintiff is Maxine D. Pipan, who resides at 416 Allendale Way, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant is Cyril F. Pipan, who resides at 1124 Columbus Avenue, Apartment 8, Lemoyne, Cumberland County, Pennsylvania. 3. The parties have two minor children: Alexandra Pipan, born September27, 1986 and Audrey, born September 26,1995. 4. Plaintiff petitions this Honorable Court to modify the Temporary Order of Court entered on July 30, 2001 and seeks shared legal custody in the parties and primary physical custody of Audrey in her. ~ ,t -- ,C' "J, ,'.' ,_,.",,_ ","",~ ":"j,,; ",,;;," ___j;;';,~- '. ,'-;"<-'i.ii;', .',' . !, '.1 ,0' ~ t;;;~:;,;'b.-'_,>" ~.'"', ," ,,<~ _ .'. ",,;-'{jjjJ , . 5. Plaintiff desires to move to the Chambersburg, Pennsylvania area with Audrey. WHEREFORE, Plaintiff requests the court to grant shared legal custody in the parties with primary physical custody of Audrey in her. <,~~ -'Sandra L. Meilton, squire TUCKER ARENS BERG & SWARTZ 111 N. Front St., P.O. Box 889 Harrisburg, PA 17108-0889 (717) 234-4121 ATTORNEYS FOR PLAINTIFF '-'. , , ,~,,'.--~"',;.',-- "","' "~,-, ;.-'.'"',,"'," ""'0"4'"' :"'-"'''K~,''''-'');''''''~;-' ""-',,,,'-", -,--j""'lif ... - VERIFICA rlON I, the undersigned, Maxine D. Pipan, acknowledge that the facts stated in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to the penalties of 18 Pa. C.SA Section 4904 relating to unsworn falsification to authorities. ~ (YI ~ne D. Pipan -- Dated: 1/-C7-/Y I 44789.1 ~~"#dj~IWllitilliffi'...l1i.",M';:~';'''' ',,," ..~.., _~,~_~H,,, .,_ " "" ,,"~<, "",~,""""',,,^,, ~, -"";~~~i~~~~ .- - -~~,~ - , ~ ,,~,~ ,;, ,=", " -,-," I: I I ... Y?v t{~ lq. Ct , 0 Cl 0 C ,\ s: ;;1': --, -0 0: 0 ","', nlrn .--.0:=:- z:;:; ~'"":~~ :zc ::Q;;;' w , , kC~' -0 ~:jr;J -- ~O :::&: gf~ :Pg w '"" z 0 51 =< (T\ -< " ...... "\) ~ ~ ?-J 8 .-J {' -0 G r ~ ---L:... -~ ., ~.- ,",- ",- I ,,,--"~- ~, 'L , "" ,,~ I " ;~ In IilI ,..~~ "'alllliifitli'---"'; i I ."'\ )' .0 "I. ,., ,,1': 0.L, if Z ":Z v- MAXINE D. PIPAN, Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 01-3302 CYRIL F. PIPAN, JR., Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this 20th day of December 2001, the Custody Conciliation Conference scheduled for December 20, 2001 on Plaintiff's Petition for Modification has been continued. The parties and their respective counsel appear before Melissa Peel Greevy, Esq., the conciliator, at 214 Senate Avenue Suite 105 Camp Hill, PA 17011 on the 8th day of April, 2002 at 9:15 a.m. for a Pre-hearing Custody Conference regarding the Petition for Modification and Plaintiff's plan to relocate. 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 a temporary order. 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 TIlECO"U B~C'"dl~!~ 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 individual having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE 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 Dist: Cyril F. Pipan, Jr. 1124 Columbus Ave Apt. Lemoyne, PA 17043 Sandra 1. Meilton, Esq. P. O. Box 889 Harrisburg, PA 17108-0889 "' h:;rt 0;) "-~.l .~~~ . .,,,( <T,~. .J", "~" ," -v. -~."-"I'- ~"'-"^' ,~"<"-,,,'''''~'~',-'-o-~~-''.M'''~''''''''~~''''~"~ -'='~""<~~,~'~-; "[r-~)lt!lIf.Y!':~ OF ..", ,,...,~~j~,'''C f"" LO. _t '1'.-' c. -1~._~"~,.-~, \)~.I^.rr.R\! ..-"r '_",,'-l :".,,;i-,Ult'\ l\ ! ,~' - , ", I' "." H "Q Dk'\ 2: 2" 02Jr:J~t..~, ~t ,,.,.~ '-1",""\1 G \\l\Er,~'\ ,;\HI) ()..)J\~l \ v"'PE~lNSYlVN")\f\ &'~/U~~df ~ 'I-!b tlf'. .~..~-~ ...~,,,_,~~,.",T,,, ~.i':""Y",..,I~,....~Wl~00;~~!!ffi'~,\Hff.;ff)ffi'i1""-W;l"li"'-U.@il~~~~'Wlili~,~,'j\1l!~W~~~ Ie"" -',I ',,_ , ~^> ."'~ ,l., " '~~ l 'e!t' ...........~ , , , J,l\11 '4 2::2 /vl 15 MAXINE D. PIPAN, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3302 CYRIL F. PIPAN, JR., Defendant CIVIL ACTION - LAW CUSTODY 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 Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Alexandra P. Pipan Audrey M. Pipan September 27, 1986 September 26, 1995 Father Mother 2. A Custody Conciliation Conference was held on December 20, 2001, with the following individuals in attendance: the Mother, Maxine D. Pipan, and her counsel, Sandra L. Meilton, Esquire; the Father did not attend. 3. The Conference was scheduled upon Mother's Petition for Modification because she has plans to relocate to the Chambersburg area, which she intends to do following the completion of the 2001-2002 school year. 4. Counsel for Mother reports that she served the DefendanUFather with a copy of the Order scheduling the Conference by both regular and certified mail on December 9, 2001. Neither the regular mail letter or the certified mail green card has been returned to the office of Plaintiff's counsel. The address used for service is known to be the residential address of the DefendanUFather and is the location where Mother has, on occasion, gone to retrieve the Children for custodial visits or to speak with Father.. Mother states that Father informed her that he did not intend to attend the Conference because he had to work. 5. The Conciliator met with the Plaintiff and her counsel for approximately one-half hour. During that time, the Father did not appear for the Conference nor did he contact the Conciliator's office. Therefore, the Conciliator will reschedule this Conference for April 8, 2002, at 9:15 a.m. Mother will, through counsel, serve Father with a letter proposing the move and a schedule for alternative custodial arrangements as a result of the move. It will then be up to Father to take action prior to the Conference or to appear at the Conference. In the event that Father does not attend, the Conciliator will recommend to the Court an Order c' . , " _, .,,~; '_H'. ,; ~ - ;,j',j '0(~, "" _1 ,. , No. 01-3302 - Civil Term permitting Mother to relocate with Audrey and adopting whatever reasonable schedule she would propose for an alternative custodial plan. Such proposal to be sent to Father shall be served upon him in such a way as is permissible by the Pennsylvania Rules of Civil Procedure to include certified restricted delivery mail, professional service by Sheriff or Constable, or publication if necessary. 1/15/a~ , , vtJJ:l/ IJ---c Melissa Peel Greevy, Esquire Custody Conciliator Date Dis!: Cyril F. Pipan, Jr., 1124 Columbus Avenue, Apt. 8, Lemoyne, PA 17043 Sandra L. Meillon, Esquire, PO Box 889, Harrisburg, PA !7108-0889 , ~ '~. "L.,' r APR 2 6 2002 !:> MAXINE D. PIPAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3302 CIVIL TERM v. CIVIL ACTION - LAW CYRIL F. PIPAN, JR., IN CUSTODY Defendant ORDER OF COURT AND NOW, this ;}'1~ day of April, 2002, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Cyril F. Pipan and Maxine D. Pipan, shall have. shared legal custody of the minor children, Alexandra Pipan born September 27, 1986 and Audrey Pipan born September 26,1995. 2. Physical Custody. Father shall have primary physical custody of Alexandra. Mother shall have primary physical custody of Audrey. 3. Audrey. Mother shall be permitted to relocate to Chambersburg, Pennsylvania with 4. The parties shall cooperate with each other to assure the daughter spends sufficient amount of quality time together and that the non-custodial parent is afforded custodial periods with the daughter that is not in his or her primary custodial care. J. Dis!: SandraL.Meilton,Esquire,POBox889,Harrisburg,PA 17108-0889 _ ~ ~ 'fjd'llo::2.. Cyril F. Pipan, Jr., 1124 Columbus Avenue, Apt. 8, Lemoyne. PA 17043 . .J<8. "f'. / , ", -=,-,~ w= ,~," .~ ,,- ~"~ ~_"~'c"~ ,~. _~ . ^"" -~" t~ ') . If fi O,D n, ,~. '.. .,; 'i ,("'::{ i '!Y";TAR' '." ,-":l-\ '11 {', r'd ,. ~. (19 ru/.;,,::,,,, ~ .'v,ur';'(L "":,'"'" , P,fr:'I',,\,iS:JU .(;OUivrv "",, \ '( IL\!/)/'i/I1' i .f \I\/i ~^_~'M ~6"_ ~" ~." - """"._,,!!"!,,,,,,_~ji!1lI1!i11! ,4:~~" ,~j ~~ ,~~'" _Il!:lllll!liW!i!llJliI~IilI$!'~1'~:'!"~~-+1WJill'jf\'>TiN':i'i~Iffi';(l'(ii',!"'ii:'W'':~"1f""'!fJ1:11l1!;im~~jli\?,}il'j!?#1~~q";'f,;!?-,!!'f.W~~"fflNc,"'J!~~~ " . . , ^~~. ~<,.,'" ." ,.~, ,'.-" -'~'.' ,.,; -" MAXINE D. PIPAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3302 CIVIL TERM v. CIVIL ACTION - LAW CYRIL F. PIPAN, JR., IN CUSTODY Defendant 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 THE CUSTODY OF Alexandra Pipan Audrey Pipan September 27, 1986 Father September 26, 1995 Mother 2. The parties were scheduled for a Custody Conciliation Conference to be held on April 8, 2002. However, prior to the conference, it appears that the parties reached an agreement with regard to the custody of their children. Therefore, the attached Order is recommended to the Court. The Conciliator was notified by counsel for mother that the parties have reached an agreement which was subsequently provided in writing to the Conciliator. After review, it appears that the parties have reached an agreement .<.; 1~5/~ Date Melissa Peel Greev ,Esquire Custody Conciliator 3. An agreement in the form of an Order is att :157351