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HomeMy WebLinkAbout03-2235NABIL NASR, Plaintiff v. CHRISTINA A. NASR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW CUSTODY COMPLAINT FOR CUSTODY TO THE HONORABLE, JUDGES OF SAID COURT: AND NOW COMES, the Plaintiff, Nabil Nasr, by and through his legal counsel, Coyne & Coyne, P.C., and avers the following in support of this Complaint for Custody: 1. The Plaintiff is Nabil Nasr, an adult individual, with a residence of 113 Bungalow Road, Enola Cumberland County, Pennsylvania 17025. 2. The Defendant is Christina A. Nasr, an adult individual, who Plaintiff avers is living with a sister, Stepanie Unger, at 108 McKinley Avenue, McClellandtown, Pennsylvania 15458 with a phone number of (724) 737-1146. 3. Plaintiff and Defendant are husband and wife and are the parents of a minor child, Sayed Nasr . 4. Plaintiff seeks custody of the minor child who currently resides with the father. 5. The child was born during wedlock. 6. The child is presently in the custody of the father. 7. During the child's lifetime the child has resided with the following persons and at the following addresses: Nabil Nasr Christina Nasr Nabil and Christina Nasr Nabil and Christina Nasr Nabil and Christina Nasr Enola 201 Maple Ave. Apr 1 Marysville, PA 17053 201 Maple Ave. Aprl Marysville, PA 17053 Rt. 74 Dover, PA 113 Bungalow Road Enola, PA 17025 Eazly 2003- Eazly May 2003 Nov 2002- Eazly 2003 Oct 2002 Nov 2002 Birth - Oct 2002 8. The relationship of Plaintiff to the child is that of natural father. 9. The relationship of Defendant to the child is that of natural mother. 10. 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. 11. Plaintiff has no information of a custody proceeding concerning the child pending in any other court in the Commonwealth. 12. 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. 13. Plaintiff seeks primary custody for the following reasons: a. Mother abandoned the child with the baby sitter when father was working b. Mother acknowledges she is incapable of Gazing for her son c. Father has a stable environment to raise his son 14. Each pazent whose pazental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, the Plaintiff, Nabil Nasr, respectfully requests this Court to grant primary physical and legal custody of the child to the Plaintiff with the Defendant have supervised custody until further Court Order Respectfully submitted, Austin F. Grogan, quu'e Attorney for Plaintiff 24 North 32"~ Street Camp Hill, PA 17011 (717) 737-1956 ID # 59020 VERIFICATION I, Nabil Nasr, verify that the statements made in the foregoing Custody Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date .~ ~ ~ ~ 3 ~ asr NABIL NASR . IN THE COURT OIL COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTINA A. NASR • 03-2235 CIVIL ACTION LAW . IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, May 16, 2003 upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. ,the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, June 24, 2003 at 10:00 AM for aPre-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. A11 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: Is/ uvn t~ndav, F~q Custody Conciliator The Court of Common Pleas of Cumberland County is required bylaw 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 32 South Bedford Street Carlisle, Pennsylvania ].7013 Telephone (71.7) 249-3 ]. 66 mss' ~~ ~ ~o~if ~p ~ ~ as ~.~s .,,~ ~ ~ .~ ~ ~ 9rf r ~3 ~L~.' i~ y.. ; x `~ ~ ~ a ~, ~~ v " ... ~,~ NABIL NASR, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. b 3 - al.~ 35 ~~p -7-.~-~.~., CHRISTINA A. NASR, :CIVIL ACTION -LAW Defendant :CUSTODY COMPLAINT FOR CUSTODY TO THE HONORABLE, JUDGES OF SAID COURT: AND NOW COMES, the Plaintiff, Nabil Nasr, by and through his legal counsel, Coyne & Coyne, P.C., and avers the following in support of this Complaint for Custody: 1. The Plaintiff is Nabil Nasr, an adult individual, with a residence of 113 Bungalow Road, Enola Cumberland County, Pennsylvania 17025. 2. The Defendant is Christina A. Nasr, an adult individual, who Plaintiff avers is living with a sister, Stepanie Unger, at 108 McKinley Avenue, McClellandtown, Pennsylvania 15458 with a phone number of (724) 737-1146. 3. Plaintiff and Defendant are husband and wife and are the parents of a minor child, Sayed Nasr . 4. Plaintiff seeks custody of the minor child who currently resides with the father. 5. The child was born during wedlock. 6. The child is presently in the custody of the father. 7. During the child's lifetime the child has resided with the following persons and at the following addresses: Nabil Nasr Enola Earl Ma 2003- resent Christina Nasr 201 Maple Ave. Apr 1 Early 2003- Early May 2003 Marysville, PA 17053 Nabil and Christina Nasr 201 Maple Ave. Aprl Nov 2002- Early 2003 M sville, PA 17053 Nabil and Christina Nasr Rt. 74 Dover, PA Oct 2002 Nov 2002 Nabil and Christina Nasr 113 Bungalow Road Birth - Oct 2002 Enola, PA 17025 8. The relationship of Plaintiff to the child is that of natural father. 9. The relationship of Defendant to the child is that of natural mother. 10. 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. 11. Plaintiff has no information of a custody proceeding concerning the child pending in any other court in the Commonwealth. 12. 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. 13. Plaintiff seeks primary custody for the following reasons: a. Mother abandoned the child with the baby sitter when father was working b. Mother acknowledges she is incapable of caring for her son c. Father has a stable environment to raise his son 14. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, the Plaintiff, Nabil Nasr, respectfully requests this Court to grant primary physical and legal custody of the child to the Plaintiff with the Defendant have supervised custody until further Court Order Respectfully submitted, ~~ Austin F. Grogan, Es~quue ~ Attorney for Plaintiff ~~ 24 North 32`~ Street Camp Hill, PA 17011 (717) 737-1956 ID # 59020 VERIFICATION I, Nabil Nasr, verify that the statements made in the foregoing Custody Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date ,~ /a D 3 ~ asr ..1 ""`~ -~~1 ~. W ~ ` rv ~~ ~ ~ `_ ~ _S J _ ` C J ~ ~ ~.:~ ~ ~~ NABIL NASR, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CHRISTINA A. NASR Defendant 03-2235 CNIL ACTION LAW IN CUSTODY ORDER OF COURT .~~.. AND NOW, this / j~ day of 2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Nabil Nasr, and Christina Nasr shall have shazed legal custody of E1Sayed Nasr, born Februazy 9, 2001. 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. Pursuant to the teens of this pazagraph each pazent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 2. The Mother shall contact the Fayette County Children and Youth Agency, other appropriate agency or an individual selected by agreement of the parties, to obtain ahomestudy/assessment of the residence in which the Mother currently resides. The Mother shall authorize the agency or individual to provide the homestudy report to the Father's counsel. The purpose of the homestudy shall be to verify the safety and adequacy of the mother's current home environment. 3. The parties, through counsel, shall make arrangements v/ith the YWCA, or PazentWorks Inc., or other appropriate agency to provide observation during a period of custody for the Mother with the Child. The observed period of custody shall be scheduled on the first available date for both the Mother and the agency. The parties shall authorize the observing agency to release information concerning the interaction between the Mother and Child to the parties' counsel. The purpose of the observation shall be to verify whether the Child is ready to begin snore extended periods of custody with the Mother despite the recent interruption of ongoing contact between the Mother and the Child. The Mother shall have a period of custody with the Child immediately following the conciliation conference on June 24, 2003 at the pazk beside the Child's babysii:ter's residence. 4. Pending receipt of satisfactory results on the homestudy and observed visitation, the Mother shall be entitled to have periods of custody with the Child on a weekly basis with the specific arrangements to be made by agreement between the parties. 5. Upon receipt by the Father's counsel of confirmation b}+ the agencies of satisfactory completion of the homestudy and observed visitation, a shazed physical custody schedule shall be implemented on an alternating weekly basis, beginning with the Mother having custody of the Child on the first Sunday at 5:00 pm. Thereafter, the parties shall exchangf; custody every Sunday at 5:00 pm at the halfway point between the parties' residences or as otherwise agreed between the parties. 6. The Mother shall be entitled to have regulaz telephone contact with the Child at both the Father's residence and the babysitter's residence. The Father shall also be entitled to have regulaz telephone contact with the Child during the Mother's periods of custody. 7. Promptly upon receipt of this Order, the Father shall provide any and all passports to his counsel. The parties agree that the Father shall not be granted access to the passports except upon the written consent of the Mother pending further Order of Court or agreement of the parties. 8. Counsel for either party may contact the conciliator to schedule afollow-up telephone conference or office conference within ninety days of the date of this Order, if necessary, to review the homestudy or observed visitation reports or to otherwise implement the provisions of this Order. 9. Neither party shall do or say anything which may estranl;e the Child from the other pazent, injure the opinion of the Child as to the other pazent, or hamper the; free and natural development of the Child's love and respect for the other pazent. Both parties shall ensure that third pazties having contact with the Child comply with this provision. 10. This Order is entered pursuant to an agreement of the p;u-ties at a Custody Conciliation Conference. The parties may modify the provisions of this Order b;y mutual consent. In the absence of mutual consent, the terms of this Order shall control. J. cc: Austin F. Grogan, Esquire -Counsel for Father ~u, ~,.t~.~, ~j.p/-a3 Joan Cazey, Esquire and Shaleeta Washington, Legal Intern - Counsel for Mother HINF1~'ilSf~~fJ?d es:r!~1~ f- a~~r~o ,t~dly ~ ~ ::~~ ;; .o :1~1 ~` ~C~ u-~a NABIL NASR, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CHRISTINA A. NASR Defendant 03-2235 CIVIL ACTION LAW IN 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 infonnation concerning the Child who :is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF E1Sayed Nasr February 9, 2003 Father 2. A Conciliation Conference was held on June 24, 200:3 with the following individuals in attendance: The Father, Nabil Nasr, with his counsel, Austin F'.Grogan, Esquire, and the Mother Christina A. Nasr, and her counsel, Shaleeta Washington, Legal Intern and Joan Carey, Esquire. 3. The parties agreed to entry of an Order in the form as attached. as' avo Date Dawn S. Sunday, Esquire Custody Conciliator NABIL NASR, Plaintiff v. CHRISTINA A. NASR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.03-2235 CIVIL ACTION-LAW CUSTODY PETITION FOR CONTEMPT PURSLfANT TO PF.NNCVT VANTA RTTT FR nF ('iV** pR()(`FFDTR2FC 1915 12 TO THE HONORABLE EDWARD E. GUIDO: AND NOW this ~~ day of October, 2003, the Plaintiff/Petitioner, Nabil Nasr, by and through his legal counsel, Coyne & Coyne, P.C., and avers the following in support of this Pefition for Special Relief:: The Plaintiff/Petitioner is Nabil Nasr, hereinafter "Father", is an adult individual residing at 113 Bungalow Road, Enola Cumberland County, Pennsylvania 17025. 2. The DefendanURespondent is Christina A. Nasr, hereinafter "Mother", is an adult individual, who moves throughout western Pennsylvania and the Petitioner believes she is residing with her sister, Stepanie Unger, at 108 McKinley Avenue, McClellandtown, Fayette County, Pennsylvania 15458. 3. The parties are the natural pazents of a minor child, El Sayed Nasr, bom Febmary 9, 2001. 4. The Mother abandoned the child in May of 2003 when. she was evicted from her apartment leaving El Sayed Nasr in the caze and custody of the babysitter. A copy of Mother's note to the babysitter is attached. 5. On or about May 16, 2003, Father through the undersigned Counsel initiated the custody action requesting that he be awazded primary custody of the minor child due to the Mother's erratic lifestyle, frequent moves and the Mother's abandonment of the child. 6. The parties participated with counselin a Custody conference on June 24, 2003 before Attorney Dawn Sunday at which point the parties with counsel entered ageed upon Order which is attached. 7. The Court Order rafifies Father's primary custody and required the Mother to obtain a home-study and complete a limited custody evaluation to assure Father the child would be safe while in the Mother's caze and custody. 8. The Mother completed a home evaluation at her sister's home and quickly moved from her sister's home and requested expanded time with the minor child. 9. The Mother has since moved at least two time and possibly three times while living in the McClellandtown/Fayette County azea and the Petitioner believes she may be back with her sister Stephanie Unger. 10. The Mother has failed to follow through on her legal requirements to obtain ahome-study of her current home environment and to obtain a custody observation for the purpose of verifying whether the child and Mother are ready for expanded partial custody. 11. Since the Mother's relocation to the western part of the State, the Father has initiated regulaz and frequent phone contact between the Mother and minor child and continued to make regular phone contact between the Mother and minor child to foster a healtlry relationship between Mother and child. 12. Mother had a partial custody in late August 2003, which resulted in a favorable visitation between Mother and child. 13. Through the month of September and eazly October tlhe Father continued to initiate daily contact with the Mother to foster a healthy relationship between Mother and child. 14. On or about Tuesday, October 7, 2003, Father and Mother spoke regarding expanded custody. 15. The Father offered the Mother expanded custody in order to promote and a healthy relationship between Mother and child. 16. The Father agreed to allow the Mother to have partial custody from Friday, October 10, 2003 at 3:00 P.M. until Monday, October 13, 2003 at 4:00 P.M. In that the Mother would pick the child up and return the child to the Father. 17. The Father spoke with the Mother on Saturday, October 11, 2003 and Sunday, October 12, 2003, and confirmed the Mother's requirement to return the child to the Father on Monday, October 13, 2003 at 4:00 P.M. 18. The Mother refused to return the child and the Father subsequently contacted the Mother at the Mother's last known residence and phone number, which is (724) 737-0750. The phone number has been disconnected. 19. The undersigned Counsel attempted to contact that phone number (724) 737-0750 on Tuesday October 14, 2003 and confirmed the phone number is not in srrvice. 20. Undersigned Counsel and Mother's Counsel participated in a status conference with Attorney Sunday on October 3, 2003 during which Mother's Counsel was unsure of the correct address of the Mother's residence but believed to be across the street from her sister, Stephanie Unger. 21. The Father has attempted to contact Mother's sister, Stephanie Unger, who indicates she does not want to be involved in any dispute. 22. The Mother contacted the Father on Tuesday, October 14, 2003, and indicated she would return the child but refused to acknowledge when she was going to rehun the child, if at all and denied that her phone had been disconnected. 23. The undersigned Counsel has attempted to contact Mother's Counsel to seek assistance in returning the child to the Father pending further Court Order. Attorney Cazey has been unable to return the phone call. 24. The child continues to be at risk as long as the Mother is maintaining custody. 25. The Father is concerned Mother lacks the maturity, parenting skills, and the life-skills to caze for the parties' child and the child is in danger of neglect and physical injury. 26. Father avers the child is in eminent harm should an emergency hearing not be granted and respectfully requests this Honorable Court to bypass Conciliation Conference and schedule an emergency hearing as soon as possible. WHEREFORE, the Plaintiff/Petitioner respectfully requests this Honorable Court bypass the normal conciliafion process schedule an emergency Hearing to reestablish the status quo of the custody limit the Mother's custody to supervised visitation until further Order of Court and issue a Rule Returnable on Defendant/Bespondent as to why she should not be help in contempt of this Honorable Court's July 1, 2003, Order of Court. Respectfully submitted, COYNE & COYNE., P.C. Dated: l~I ts'~d3 BY: GCac~~~~ '~---~ Ausfin F. Grogan 3901 Mazket Street Camp Hill, PA 1 70 1 1-422 (717)737-0464 ID # 59020 Attorney for Plainti~Petitioner I, Nabil Nasr, verify that the statements made in the foregoing Petition for Special Relief are true and con•ect to the best of my larowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date _ /~ Jil J~ ~~ Nabil Nasr '" ~4GuQ~~ G~CU1.-t U ~~l L%~D C.f'c'~ ~~ /!'Yl~.~di2 ~~ ~~E~~i'c~` ~id2.~ ~~ vt/.~ /)'lit 6~~f;iJ~2e.. ~~~4?r~' ~Cin iyYl~~ ~~z ~ t ~i~ - ~-~~ .~~ ~luo ~~d ~ /!'`e `~irJ ~~ ~--z`v mod, ~t ~ ~ar/~ - ~~~ ~it ~~r ~t~t~~~~ ~~ ~ ~~ ,~//~ ~~ ~ ~ ~~n ~~~~u ~~~~~~~ ~ . ~~. ~~'e ~~ ~~ -- --- ~-_ __ ~f i end ~ ~ l~y~1 L/C.~14u~. ~~ ~-~~ ~~ ~ ~~ lti{~a'c~o ~~~ u~ ~ f ~ ~~ ~ ~~~ Z~-~ ~~~ ~~ ~~ ~ ~,~ ~ueo ~~ ~Pl~,~e ~~e ~~ge ,~~ ~ ~ .~~ ~ ~°~-~~s~ ~ ~ ~ ~~ ~~ %- ~3~- l l~~v ~, i '~ c NABIL NASR, I' ~~ Plaintiff ,~ i'_.._. vs. CHRISTINA A. NASR Defendant ~~ r r ~ ~, '_ ~J~1No9~ 7 2003 _'~ 20D3 IN THE COURT OF COMMON PLE - C,LERLAND COUNTY, PENNSYLVANIA' CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this %.oa- day of ~L_ 2003, up consideration of the attached Custody Conciliation Report-~, t is ordered and directed as follows: 1. The Father, Nabil Nasr, and Christina Nasr shall have shared legal custody of E1Sayed Nasr bom February 9, 2001. Each pazent shall have an equal right, to bf; exercised jointly with the other pazent, to make all major non-emergency decisions affecting the C'hild's general well-being including but not limited to, all decisions regazding his health, education and religion. Pursuant to the terms of this paragraph each pazent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 2. The Mother shall contact the Fayette County Children azid Youth Agency; other appropriate agency or an individual selected by agreement of the parties, to obtain ahomestudy/assessment of the residence in which the Mother cuaently resides. The Mother shall authorize the agency or individual t. provide the homestudy report to the Father's counsel. The purpose; of the homestudy shall be to verify the safety and adequacy of the mother's current home environment. 3. The parties, through counsel, shall make arrangements with the YWCA, or PazentWorks Inc., or other appropriate agency to provide observation during a period of custody for the Mother wi the Child. The observed period of custody shall be scheduled on the first available date for both the Mother and the agency. The parties shall authorize the observing agency to release information concerning the interaction between the Mother and Child to the pazties' counsel. The purpose of the observation shall be to verify whether the Child is ready to begin more extended periods of custody with the Mother despite the recent interruption of ongoing contact between the Mother and the Child. The Mother shall have a period of custody with the Child immediately following the conciliation conference on June 24, 2003 at the pazk beside the Child's babysitte;r's residence. 4. Pending receipt of satisfactory results on the homestudy and observed visitation, the Mother shall be entitled to have periods of custody with the Child on a weekly basis with the specific arrangements to be made by agreement between the parties. 5. Upon receipt by the Father's counsel of confirmation by the agencies of satisfactory completion of the homestudy and observed visitation, a shazed physical custody schedule shall be implemented on an alternating weekly basis, beginning with the Mother having custody of the Child c the first Sunday at 5:00 pm. Thereafter, the parties shall exchange custody every Sunday at 5:00 pm < the halfway point between the parties' residences or as otherwise agreed between the parties. 6. The Mother shall be entitled to have regulaz telephone contact with the Child at both the Father's residence and the babysitter's residence. The Father shall. also be entitled to have regulaz telephone contact with the Child during the Mother's periods of custody. 7. Promptly upon receipt of this Order, the Father shall provide any and all passports to his counsel. The parties agree that the Father shall not be granted access to the passports except upon the written consent of the Mother pending further Order of Court or agreement of the parties. 8. Counsel for either party may contact the conciliator to schedule afollow-up telephone conference or office conference within ninety days of the date of this Order, if necessazy, to review the homestudy or observed visitation reports or to otherwise implement the provisions of this Order. 9. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other pazent, or hamper the free and natural development of th Child's love and respect for the other pazent. Both parties shall ensure that third parties having contac with the Child comply with this provision. 10. 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 mutual consent, the terms of this Order shall control. BY THE COURT, J. cc: Austin F. Grogan, Esquire -Counsel for Father Joan Cazey, Esquire and Shaleeta Washington, Legal Intern - Counsel for Mother ~ al. q 1,.~.w~~ Er'k Z 1~ is v Y z '~f~ j $Y~ ~J.:i ifr Stk1A; [ ~i ~~~. 2 ~ - R_we i... ~~ W F"GQF"{I®r'it"P°t ~J NABIL NASR, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA., vs. CHRISTINA A. NASR Defendant 03-2235 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLANI) COUNTY RULE OF 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 follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF E1Sayed Nasr February 9, 2003 Father 2. A Conciliation Conference was held on June 24, 2003 with the following individuals attendance: The Father, Nabil Nasr, with his counsel, Austin F.CiTOgan, Esquire, and the Mot] Christina A. Nasr, and her counsel, Shaleeta Washington, Legal Intern and Joan Cazey, Esquire. 3. The parties agreed to entry of an Order in the form as attached. ~ as` .~,o a Date Dawn S. Sunday, Esquire Custody Conciliator 7 CERTIFICATE OF SERVICE I, Austin F. Grogan, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy ~Of the foregoing Petition for Contempt in the Form of Special Relief was served this date upon the referenced individuals at the below listed address by way of first class mail, postage pre-paid: -^ Joan Carey Mid Penn Legal Services 8 Irvine Row Carlisle, PA 17013 Dated: j0-~6~3 ~ `~ Austin F. Grogan c~ ~ _ ~ _.~ , ~\ ~, ., I ~ \ / 4 / ~ i ~.. ~r.~ N ^ w ~ I L.. .. 'o Q N Nabil Nasr, Plaintiff vs. Christina A. Nasr, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.03-2235 CIVII, TERM CIVIL ACTION -CUSTODY AND NOW, this ~` day of ~~ ` , 20(13, upon consideration of the Petition for Contempt in the form of Special Relief, the Defendant/Respondent, Christina A. Nasr is hereby ordered and directed to immediately return the child EI Sayed Nasr to the natural Father Nabil Nasr. Pending further order of Court Mother shall have supervised visitation at Father's discretion. on e e en an espon en , s ma asr as o w y s e s u eanng is sc f; - , FOR TISE (~O By: ~.... Edward E. Guido, J C£ Austin F. Grogan,Esq.~~~~~t~ ~°P~ geva~ Attorney For Plaintiff/Petitioner 0 Joan Carey, Esq. , Attorney For DefendanURespondent C pQy /17R l~ ~~ ~, t ~ u ' . ~ ~-,, I n,. w X1.1. it i:.(~.:i ': NABIL NASR, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 03-2235 CIVIL ACTION LAW CHRISTINA A. NASR Defendant IN 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 Child who is the subject of this litigation is as follows: ~ NAME i DATE OF BIRTH CURRENTLY IN CUSTODY OF i E1Sayed Nasr ', February 9, 2003 Father 2. Pursuant to the Order entered in this matter on July 1, 2003, the Mother's counsel scheduled a follow-up telephone co ference to review the home study and/or observed visitation reports to ba performed under the prior Order. The telephone conference was held on October 3, 2003, with counsel for both parties participaf g. It was determined at the conference that the Mother would obtain a home study on her cun•ent res~ ence rather than the one in which she resided at the time of the initial conciliation conference d that the Mother would schedule a session with a counselor who would assess the Child's readine s to begin more extended periods of custody with the Mother. 3. It was agreed ghat an additional telephone or office conference could be scheduled by counsel, if necessary, afte completion of the home study and counseling session. 4. It was determined that no further Order is necessary at this time. Date cc: Austin F. Grogan, Esgi Joan Carey, Esquire - ~~~ Dawn S. Sunday, Esquire Custody Conciliator - Counsel for Father ~ -"/ mti~~, /~_ a3 - v3 nsel for Mother y~i~~(?.yJ^n~~i~st yf~C~ °~ ~z ~d ~-~~~~o ~~,(Gi'~~ti c: ~i~ ' ~~1~~!;;!-(~7lj~j~ ~0 COYNE & COYNE, P.C. Lisa Marie Coyne, Esq. 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Petitioner NABIL E. NASR, Plaintiff, vs. CHRISTINA A. NASR, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.04-4914 CIVIL TERM IN DIVORCE PETITION TO WITHDRAW AS COUNSEL FOR PLAINTIFF TO THE HONORABLE, JUDGES OF SAID COURT: AND NOW comes, Coyne & Coyne, P.C., by and through its counsel, Lisa Marie Coyne, Esquire, and avers the following in support of this Petition requesting for permission to withdraw from representation of Plaintiff in this matter. 1. On or about, May 10, 2003, the Plaintiff, Nabil E. Nasr, engaged the professional services of the Petitioner, the law firm of Coyne & Coyne, P.C. through its associate attorney, Austin F. Grogan who is presently on active duty with the U.S. Army Reserves and serving in Afghanistan. 2. Subsequent to Plaintiff entering into that written contract with Petitioner, and after Petitioner performed a significant amount of legal work on behalf of the Plaintiff concerning various custody matters, Petitioner submitted invoices to Plaintiff for payment for services rendered. 3. Plaintiff refuses to remit payment of outstanding invoices due and owing to the undersigned. 4. The undersigned legal counsel respectfully requests Court permission to withdraw from representation of Plaintiff in this matter. 5. Pursuant to an Order of this Honorable Court, dated July 1, 2003, at paragraph 7 of that Order, it was directed that Petitioner, as Plaintiff's counsel, to retain possession of all of Plaintiff's passports except upon further Order of this Court. (Copy of the Order is attached as Exhibit "A".) r 6. The undersigned legal counsel requests this Honorable Court's permission to deposit with the Office of the Prothonotary the Plaintiff s passport issued by the Government of Egypt. A Copy of the Egyptian passport is attached hereto as Exhibit "B". 7. Petitioner's withdrawal as Plaintiff's legal representative will not cause any delay in these proceedings. WHEREFORE, the Petitioner, Coyne & Coyne, P.C., respectfully requests that it be permitted to withdraw as legal counsel of record for the Plaintiff and that Petitioner be directed and ordered to deliver and deposit with the Prothonotary of Cumberland County the Plaintiffs Egyptian passport which Petitioner has retained per prior Order of this Court. Respectfully submitted: Dated Ca ~. d ~ COYNE & COYNE, P.C. By: '''- Lisa arie Coyne, E uire upreme Ct. No. 3788 3901 Market Street Camp Hill, PA 17011 (717) 737-0464 Petitioner . 9 ti t 4 _. x~ S t 4' i E~ ~ s. t -~ s~ II II N 7 2003 NABIL NASR, ' ~ ~ ~' ~; ' ~ '~~~~ ~. ~'~HE COURT OF COMMON PLE~S ` ~~ ~`' :4 -~ ~ ~ G~ ~ ERLAND COUNTY, PENNSYLVANIA Plaintiff ~;~ =1' ~_ ...- _ . vs. ~t,.. ,v - -- 5 CIVIL ACTION LAW CHRISTINA A. NASR Defendant IN CUSTODY ORDER OF COURT AND NOW, this %,,~,t- day of ~ 2003, upon consideration of the attached Custody Conciliation Report, t is ordered and directed as follows: 1. The Father, Nabil Nasr, and Christina Nasr shall have shared legal custody of E1Sayed Nasr, born February 9, 2001. 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. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 2. The Mother shall contact the Fayette County Children and Youth Agency,~other appropriate agency or an individual selected by agreement of the parties, to obtain a homestudy%assessment of the residence in which the Mother currently resides. The Mother shall authorize the agency or individual to ;. provide_the homestudy report to the Father's counsel. The purpose of the homestudy shall be to verify the safety and adequacy of the mother's current home environment. 3. The parties, through counsel, shall make arrangements with the YWCA, or ParentWorks Inc., or other appropriate agency to provide observation during a period of custody for the Mother with the Child. The observed period of custody shall be scheduled on the first available date for both the Mother and the agency. The parties shall authorize the observing agency to release information concerning the interaction between the Mother and Child to the parties' counsel. The purpose of the observation shall be to verify whether the Child is ready to begin more extended periods of custody with the Mother despite the recent interruption of ongoing contact between the Mother and the Child. The Mother shall have a period of custody with the Child immediately following the conciliation conference on June 24, 2003 at the park beside the Child's babysitter's residence. 4. Pending receipt of satisfactory results on the homestudy and observed visitation, the Mother shall be entitled to have periods of custody with the Child on a weekly basis with the specific arrangements to be made by agreement between the parties. 5. Upon receipt by the Father's counsel of confirmation by the agencies of satisfactory completion of the homestudy and observed visitation, a shared physical custody schedule shall be implemented on an alternating weekly basis, begintling with the Mother having custody of the Child on the first Sunday at 5:00 pm. Thereafter, the parties shall exchange custody every Sunday at 5:00 pm at the halfway point between the parties' residences or as otherwise agreed between the parties. 6. The Mother shall be entitled to have regular telephone contact with the Child at both the Father's residence and the babysitter's residence. The Father shall also be entitled to have regular telephone contact with the Child during the Mother's periods of custody. 7. Promptly upon receipt of this Qrder~ the ~a er shall provide any and all passports to--his counsel. The parties agree that the Father shall not be granted access to the passports except upon \tl~ written consent of the Mother pending further Order of Court or agreement of the parties. __...- 8. Counsel for either party may contact the conciliator to schedule afollow-up telephone conference or office conference within ninety days of the date of this Order, if necessary, to review the homestudy or observed visitation reports or to otherwise implement the provisions of this Order. 9. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Child comply with this provision. 10. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, cc: Austin F. Grogan, Esquire -Counsel for Father Joan Carey, Esquire and Shaleeta Washington, Legal Intern - Counsel for Mother ~i3 1~~::~z'Y~~3?~Y t":'~c'~',t~f3¢S t d~~E*~ ..=~'i1 .r~~ ~~..r ,yam ~ ~„• ., - • .~ ~4 ~ili~4~~i ~'V t .,~< __-- .. c~ ~ - - - T ~ t °~ A Y..~ 5 ~C,F ~q3" Y st•~4A`t.u:.,L~w ~t Y ~~. 3 3'ac A'..:: ~. `ffi' ~~ ~' 7 ,`"y,..^~ h2~ x(~s.~%;...?t~~z ~~",mid. ~ H" xyz',~ z> ~ .. l_ `a: ,0,8 '`a'.~ ` ,~ ~ : ,. ~'z~1~ ~ ;.,air" ~; [ 4 zz V o''.:~4«<~ '~s S ~' ~ ~ ~ ,rug., . ~. Z,C ~ s `Yt ~z i. ~"` ~ ~. _ . ~ ~ .~ ,~~ ~ , .. ~'^ ~ ~. - .. .~ ... ' ^. ., y s,. V g L ~ ~ 3 d O~ •y Cs .7 ~ b _M W 1 ..~ -r- d,... ..:- .._.. ~ __.._~ ~ ~ ~ t~ - - _ .. - - - - -- _ _ 4 ~ - - - - _, _. , , i ~~ s _ _ { _ CERTIFICATE OF SERVICE I, Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the foregoing Petition to withdraw was served this date upon the below-referenced individuals at the below listed address by way of first class mail, postage pre-paid: Mr. Nabil Nasr 113 Bungalow Road Enola, PA 17025 Mr. Nabil Nasr P.O. Box 174 Enola, PA 17025 Dated: 6 0 6 ~- Lis Ma a Coyne na ~.~ C~. ~~ "~ [ _ ( ~ ~... , . L-. ~- ~ / F'r iJy ~'l w.~ / . ~ COYNE & COYNE, P.C. Lisa Marie Coyne, Esq. OC7 2 3 20Q6 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 ~ Petitioner NABIL E. NASR, Plaintiff, vs. CHRISTINA A. NASR, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • D3~~35 - CIVIL TERM IN DIVORCE RJJU__LE TO SHOW CAUSE AND NOW THIS ~M day of U ~~ 2006, upon consideration of Petitioner, the law firm of Coyne & Coyne, P.C.'s, Petition to Withdraw as Counsel for Plaintiff and Permission to deposit Plaintiff's Egyptian passport with the Prothonotary of Cumberland County, a Rule is issued upon the Plaintiff to show cause the Petition should not be granted. This Rule is Returnable pfd days after service upon the Plaintiff. CF: Lisa Marie Coyne, Esquire, Attorney for Petitioner Nabil E. Nasr, Plaintiff Edward E. Guido, Judge ?4 ~$ '~'.'~ '~Z l~~ 9~0~ .~~j~~„E~ ~~ ~ NABIL NASR, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. N0.03-2235 CHRISTINA A. NASR, CIVII. ACTION -LAW Defendant :CUSTODY CERTIFICATE OF SERVICE I, Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the foregoing Rule to Show Cause, dated October 20, 2006 was served this date upon the below-referenced individuals at the below listed address by way of first class mail, postage pre-paid: Mr. Nabil Nasr 113 Bungalow Road Enola, PA 17025 Mr. Nabil Nasr P.O. Box 174 Enola, PA 17025 Respectfully submitted, COYNE & COYNE, P.C. Dated: ! ~ ~~ / ~~ BY: Marie Coyne Pa. Supreme Ct. No. 53788 3901 Market Street Camp Hill, PA 17011-4227 (717)737-0464 Petitioner :, ; ~ '1'1 ^~ , ~. f ' ~ ( }J r ~ ._ ""C~? "3 el~.~f ,_ ~~~ '~. tiw+ NABIL NASR, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. N0.03-2235 CHRISTINA A. NASR, :CIVIL ACTION -LAW Defendant :CUSTODY PETITION TO MAKE RULE ABSOLUTE TO THE HONORABLE, JUDGES OF SAID COURT: AND NOW comes, Lisa Marie Coyne, Esquire, counsel for Plaintiff and avers the following in support of request far Rule Absolute to Permit withdrawal of representation of Plaintiff in this matter. 1. On October 20, 200b, this Honorable Court issued upon the Plaintiff, Nabil Nasr, a Rule to Show Cause why the Petitioner, Lisa Marie Coyne, Esquire, should not be permitted to withdraw as counsel to the Plaintiff, Nabil Nasr. 2. On October 26, 2006, the Petitioner, Lisa Marie Coyne, Esquire, served a true copy of the Rule to Show Cause upon the Plaintiff, Nabil Nasr. (See attached Certificate of Service, Exhibit "A"). 3. Defendant has not answered the Rule to Show Cause and ten days have elapsed since service of the Rule to Show Cause was made upon the Plaintiff. WHEREFORE, the Petitioner, Lisa. Marie Coyne, Esquire, requests this Honorable Court to issue a Rule Absolute and thereby permit the Petitioner to withdraw as legal counsel of record for the Plaintiff and directs the Plaintiff's Passport be held by the Prothonotary. Respectfully submitted: COYNE & COYNE, P.C. 1,~' ~ I~A ^---- Dated: 7 ~~~~~ BY~ ' sa Marie Co e, Esquire 901 Market Street Camp Hill, PA 1 70 1 1-4227 (717) 737-0464 Pa. Supreme Ct. No. 53788 Petitioner ~ ~s ~~ ~N~ & CO~Y~NE, P.C. Jisa Mane Coyne, Esq. y,' ~ ~ ~ ~~_~ 3901 Market Street Camp Hill, PA 1 70 1 1-4227 (717) 737-0464 ~ Petitioner NABII, E. NASR, Plaintiff, vs. CHRISTINA A. NASR, Defendant. IN THE COURT' OF COMMON PLEAS OF CUiVIBERLAND COUNTY, PENNSYLVANIA . 03-335 =8664 CIVIL TERM IN DIVORCE RULE TO SHOW CAUSE Al NOW THIS da of 2006 a on '~ y r consideration of Petitioner, the law firm of Coyne & Coyne, P.C.'s, Petition to Withdraw as Counsel for Plaintiff and Permission to deposit Plaintiff's Egyptian passport with the Prothonotary of Cumberland County, a Rule is issued upon the Plaintiff to show cause the Petition should not be granted. This Rule is Returnable ~ days after service upon the Plaintiff. CF: Lisa Marie Coyne, Esquire, Attorney for Petitioner Nabil E. Nasr, Plaintiff ~~~ ~~~~ ~ ... 1P8~,1 hers iii S@t i~1y ~~ ~F~ ~~18 Ste! ~ laid C4t9 St CatKSlB, P8. ~~ ~ h~l~ „ , Edward E. Guido, Judge NABIL NASR, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. N0.03-2235 CHRISTINA A. NASR, :CIVIL ACTION -LAW Defendant :CUSTODY CERTIFICATE OF SERVICE I, Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the foregoing Rule Absolute was served this date upon the below-referenced individuals at the below listed address by way of first class mail, postage pre-paid: Mr. Nabil Nasr 113 Bungalow Road Enola, PA 17025 Mr. Nabil Nasr P.O. Box 174 Enola, PA 17025 Respectfully submitted, COYNE & COYNE, P.C. c Dated: T l ~ ~ BY: -----~ a- Li Marie Coyne a. Supreme Ct. N .53788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Petitioner r ~, j.,r (~ ~ ~ ~ APR 16 2007 /~ NABIL NASR, Plaintiff v. CHRISTINA A. NASR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.03-2235 CIVIL ACTION -LAW CUSTODY RULE ABSOLUTE AND NOW this ~ day of ~ , 2007, it appearing that. Plaintiff, Nabil Nasr, was served on October 26, 2006 a Rule to Show Cause why Attorney Lisa Marie Coyne should not be permitted to withdraw as his counsel, and the Plaintiff did not answer said Rule within ten (10) days of service of same, Petitioner, Lisa Marie Coyne, Esquire is hereby granted permission to withdraw as counsel of record for the Plaintiff, Nabil Nasr and directs the Plaintiff's Passport be held by the Prothonotary. Cc: i arie Coyne, Esquire, Petitioner ^ abil Nasr, Plaintiff (~jJ, J Edward E. Guido, J. ,gin t~-~ i 4`;C~1 ~ , try.. ,.,;~t`~i 1~ f~~~i~~',..j w~ _. 4l~ n.t (( - n 1 4 ~S S~ ~~ .~ ~ ;-;~ ti~ Cl ~" is • , COYNE & COYNE, P.C. Lisa Marie Coyne, Esq. Pa. Supreme Ct. No. 53788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 i NABIL NASR, Plaintiff v. CHRISTINA A. NASR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.03-2235 CIVIL ACTION -LAW CUSTODY PRAECIPE TO THE PROTHONOTARY: Pursuant to Rule Absolute, dated May 1, 2007, kindly withdraw the appearance of Coyne & Coyne, P.C. on behalf of the Plaintiff, Nabil Nasr in the above matter. Further, pursuant to said Rule Plaintiff's Passport issued by Egyptian Republic is hereby deposited to the Prothonotary pursuant to the said Rule Absolute. (A copy of the Rule Absolute is attached as Exhibit "A.") COYNE & DYNE, P.C. r.... By. ~//7 /o,~ Lis arie Coyne, ESQ 1 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 v ~~~ r~/' ~~~ ,_ ~ ~~~ , ~ NABIL NASR, Plaintiff v. CHRISTINA A. NASR, Defendant IN THE COURT OF CO~l H1 CUMBERLAND COUNTY, N0.03-2235 CIVIL ACTION -LAW CUSTODY RULE ABSOLUTE ,L 16 2007 /1'? .S VANIA NOW this ~ ~ da of ~ 2007 it a earin that Plaintiff AND y ~, PP g Nabil Nasr, was served on October 26, 2006 a Rule to Show Cause why Attorney Lisa Marie Coyne should not be permitted to withdraw as his counsel, and the Plaintiff did not answer said Rule within ten (10) days of service of same, Petitioner, Lisa Marie Coyne, Esquire is hereby granted permission to withdraw as counsel of record for the Plaintiff, Nabil Nasr and directs the Plaintiff's Passport be held by the Prothonotary. Edward E. Guido, J. Cc: Lisa Marie Coyne, Esquire, Petitioner Nabil Nasr, Plaint EXHIBIT "A" r t . COYNE & COYNE, P.C. Lisa Marie Coyne, Esq. Pa. Supreme Ct. No. 53788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 r i NABIL NASR, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. N0.03-2235 CHRISTINA A. NASR, :CIVIL ACTION -LAW Defendant :CUSTODY CERTIFICATE OF SERVICE I, Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the foregoing Praecipe to Withdrawal was served this date upon the below-referenced individuals at the below listed address by way of first class mail, postage pre-paid: Mr. Nabil Nasr 113 Bungalow Road Enola, PA 17025 Mr. Nabil Nasr P.O. Box 174 Enola, PA 17025 COYNE & COYNE, P.C. Dated: ~-' ~ ~ f ~ 7 BY: ~~ sa arie Coyne Pa. Supreme Ct. No. 53788 3901 Market Street Camp Hill, PA 1 70 1 1-4227 (717) 737-0464 Petitioner ~ ~` G ~ . _.--t " ,' ~, ~ ~ i _: .1 --y~ ... Y' ~.~ _ ~>" 7 ` 5 / ~ t f ...~~ ' f~ ~Y ~ .r.' " .+F~