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Home My WebLink About01-04680MAX SPIEGEL, Plaintiff v. BY THE COURT: ANITA SPIEGEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-4680 CIVIL-ACTION -LAW IN CUSTODY ORDER OF COURT AND NOW to wit, this ~2q day of~~~a~, 2002, upon consideration / of the attached Motion for Hearing, a hearing is set for the ~ day of ~~y: ~2002,(~~ ~ ` // at~ • 3~ o'clock. ~~, in Courtroom No. ~ , of the Cumberland County Courthouse, 1 Courthouse Square, Cazlisle, Pennsylvania. .fa/~,rAR~~ ~u...`~a J. O `r ~) ~~ t/~f~liP,IAS~VPd~d tlU~Y.~t.'i ~~' 7fi _- 'i 1, m,1a ~r ;ri~`~.._. ~. ~~fi~ _ ~ ~~ MARIA P. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIItE Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 1701 I Telephone No. (717) 909-4060 Attorneys for Plaintiff MAX SPIEGEL, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. ANITA SPIEGET~, Defendant NO. 01-4680 CIVIL-ACTION -LAW IN CUSTODY MOTION FOR HEARING AND NOW, comes Plaintiff, Max Spiegel, by and through his attorney, Maria P. Cognetti, Esquire, and moves this Court to enter an Order setting this case for a hearing and respectfully represents as follows: Plaintiff is Max Spiegel who currently resides at 29 South Church Street, West Chester, Pennsylvania. 2. Defendant is Anita Spiegel who currently resides at 418 Boxwood Court, Mechanicsburg, Pennsylvania. 3. Otr or about August 10, 2001, Plaintiff filed a Complaint for Custody to the above term and number, 4. A Custody Conciliation Conference was held on September 5, 2001 before Custody Conciliator, Melissa Peel Greevy. 5. As a result of said conference, an interim Order of Court was entered on September 12, 2001. Pursuant to the aforementioned Order, the parties were to participate in a Custody Evaluation to be performed by Dr. Arnold T. Shienvold. Due to time constraints, Dr. Chrissi Hart of Riegler, Shienvold & Associates, performed the evaluation under the supervision of Dr. Shienvold with the consent of the parties. 7. On or about August 19, 2002, the parties received Dr. Hart's Custody Evaluation. 8. Since the receipt of Dr. Hart's report, the parties have been unable to resolve the issues contained in Plaintiff s pending Complaint for Custody. 9. Plaintiff believes and therefore avers that the only way the Complaint for Custody can be disposed of would be with a full hearing on the issue of primary custody. WHEREp'ORE, Plaintiff respectfully requests this Honorable Court set this matter for hearing. Respectfully Submitted: MARIA P. COGNETTI & ASSOCIATES Date: September ~ , 2002 By: MARIA P.'COGN)~'I, ESQUIRE Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff VERIFICATION I, Maria P. Cognetti, Esquire, attorney for the Plaintiff, have personal knowledge of the facts contained in the foregoing and therefore do verify that the information contained therein is true and correct to the best of my knowledge, information and belief. Maria P. ognett' squire DATE: September ~3 , 2002 ~ . ,y CERTIFICATE OF SERVICE I, Maria P. Cognetti, Esquire, Attorney for Plaintiff herein, do hereby certify that on this date I served the foregoing Motion for Hearing, by depositing a true and exact copy thereof in the United States mail, first class, postage prepaid, addressed as follows: Sandra L. Meilton, Esquire TUCKER ARENSBERG & SWARTZ 111 North Front Street P.O. Box 889 Harrisbtug, PA 17108-0889 MARIA P, COGNETTI & ASSOCIATES Date: Septembero~`'' , 2002 By: MARIA P.`COGN ~ T 'I, ESQUIRE Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff . ,. N ~~ _V O w ~ YNI 0 V ~l w c~ ,~ c rv ~. '*a ~ s 'n j G/ra, li~ "~...' ~ ~. _ ~ l~ \~f.~ f+ ~ -~,_ . i_~i1 ~lJ =G~ T ['.1 K MAX SPIEGEL, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 0113680 ANITA SPIEGEL, :CIVIL ACTION -LAW pefendant IN CUSTODY RULE TO SHOW CAUSE AND NOW, this ~7~ day of ~'~C~~1~' a ~. 2002, upon consideration of the Petition to Withdraw as Counsel, a Rule is issued upon Plaintiff, Max Spiegel, to show cause why Sandra L. Meilton, and TUCKER ARENSBERG & SWARTZ, should not be granted leave to withdraw as counsel for Defendant in this case. RULE RETURNABLE ~ ~ DAYS FROM THE DATE OF SERVICE. J. ~~ ~S ~ ~ -~~ -oa ~~. ~c~1~-on ~ __ `r `~ L: i= !~ 4 ~k ~' _ _ +~..., _~I ~~ ~ G. ~_!~ ~.i ~!~ ~~ x"93 - - . _ ~ v ~~ MAX SPIEGEL, Plaintiff v. ANITA SPIEGEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01 X680 CIVIL ACTION -LAW IN CUSTODY PETITION TO WITHDRAW AS COUNSEL AND NOW, comes Petitioner, Sandra L. Meilton, for the law firm of Tucker Arensberg & Swartz and hereby avers as follows: 1. On or about September 5, 2001, the law firm of Tucker Arensberg & Swartz was retained by Defendant and commenced legal representation on her behalf in connection with the above matter. 2. Defendant contacted Petitioner's office by telephone on October 23, 2002 and indicated that she will no longer require the services of Petitioner. WHEREFORE, counsel respectfully requests that this Honorable Court grant the law firm of Tucker Arensberg & Swartz permission to withdraw as counsel for Defendant, Anita Spiegel. Respectfully submitted, TUCKER ARENSBERG & SWARTZ T~Sandra L. Mei to~ I.D. # 32551 111 North Front Street, P.O. Box 889 Harrisburg, PA 17108 .` CERTIFICATE OF SERVICE AND NOW, this ~` r'\day of /Vm~~~/L, 2002, I, Gloria M. Rine, Paralegal to Sandra L. Meilton, Esquire, for the firm of Tucker Arensberg & Swartz, hereby certify that I have this day served a copy of the within document, by mailing same by first class mail, postage prepaid, addressed as follows: Maria P. Cognetti, Esquire 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Mrs. Anita Spiegel 418 Boxwood Court Mechanicsburg, PA 17055 ~~ Gloria M. Rine 54018.1 f~ ' f ~? -_ ~ J t;i - i:? x-'.. __.._,.. -. C. ~1 ~~ _ )~ Y _,_ ~ ~ _~ J' (:J ~-ee~~a,e+'+vr i.. ,~ ~s3.., i -<r~a~n. ar nm~~aa t>nxSy'. _._ _ MAX SPIEGEL IN THE COURT OF COMMON PLEAS OF PLAIN'ITFF CUMBERLAND COUNTY, PENNSYLVANIA V. ANITA SPIEGEL • 01-4680 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, August 10, 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 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on Wednesday, September 05, 2001 at 12:00 p.m. 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. 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 schednled hearing. FOR THE COURT, By: /s/ 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 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 ~~~ dirti~m~s~~~rd U ~ ~~~ ~~ ~, ~ ~`J~~ ~ :~J~~:?t.~i ~..jl~ ~i .a~m~ iF'm 6`.P.WNR~'Ri4~P.~4 .. ~~J/?3 'nSq YivAS.: 5as.':a} F ~i 4}A fl iT' `vFMW~5E+p4Yfi11'~FSAF~RTi_ _ MAX SPIEGEL, Plaintiff v. ANITA SPIEGEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. of - 4~d ~'u ~L `T~2r,"1 CIVIL-ACTION -LAW IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Esquire, Conciliator, at the Pennsylvania, on the day of at 2001, .m., 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. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT DATED: BY: Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 MARIA P. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIRE Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Aill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Plaintiff MAX SPIEGEL, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. Ul - ~~~1.,° ANITA SPIEGEL, Defendant CIVIL ACTION -LAW IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Max Spiegel, residing at 29 South Church Street, West Chester, Pennsylvania. 2. Defendant is Anita Speigel, residing at 418 Boxwood Court, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following child: Name Present Address Alexis Spiegel 418 Boxwood Ct. 11 Mechanicsburg,PA D.O.B. 03/10/90 4. The child was born out of wedlock. The child is presently in the custody of Anita Spiegel, who resides at 418 Boxwood Ct., Mechanicsburg, Cumberland County, Pennsylvania. 5. During the past five (5) yeazs, the child has resided with the following persons at the following addresses: Name Anita Spiegel Address Dates 418 Boxwood Ct. 07/01/01 -Present ,_, __, ,._ ~ ~~.~4_ r _ e Mehanicsburg, PA Anita Spiegel 132 Beacon Dr. 07/00 - 07/01 Harrisburg, PA Anita Spiegel 378 Old Blue Rock Rd. 08/99- 6/00 Only Millersville, PA Anita Spiegel and 378 Old Blue Rock Rd. 09/98 - 08/99 Max Spiegel Millersville, PA Anita Spiegel and Downingtown, PA 01/96 - 09/98 Max Spiegel 01/96 - 09/98 6. The mother of the child is currently residing at 418 Boxwood Ct, Mechanicsburg, Cumberland County, Pennsylvania. She is married. 7. The father of the child is currently residing at 29 South Church Street, West Chester, Pennsylvania. He is married. 8. The relationship of Plaintiff to the child is that of Natural Father. Plaintiff currently resides with the following persons: Name None Relationship 9. The relationship of Defendant to the child is that of Natural Mother. Defendant currently resides with the following persons: Name Alexis Spiegel Relationship Daughter 10. Plaintiff has not participated as a party or a witness, or in any other capacity in other litigation concerning the custody of the child in this or any other Court. 11. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this 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. The best interest and permanent welfare of the child will be served by granting the relief requested. 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, Plaintiff requests the Court to grant him custody of the child. Respectfully Submitted: MARIA P. COGNETTI & ASSOCIATES Date: August 1, 2001 By: ~ MARIA P. COGN I, ESQUIRE Attorney LD. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff s,- ~ ~-~.~,~„ ,. -~ VERIFICATION I, Max Spiegel. hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. ---_~ Max Spiegel, Plaintif DATE: ~ / ~~/~ ~Ep Y 0 200~~ MAX SPIEGEL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01-4680 ANITA SPIEGEL, CIVIL ACTION -LAW Defendant CUSTODY INTERIM ORDER OF COURT AND NOW, this '~~ day of , 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Leaal Custodv. The Mother, Anita Spiegel, and the Father, Max Spiegel, shall have shared legal custody of the minor Child, Alexis Spiegel, born March 10, 1990. 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 her health, education and religion. Pursuant to the terms of Pa. C. S. § 5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child 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. Mother shall have primary physical custody subject to Father's rights of partial physical custody. Father's periods of custody shall be arranged as follows: A. Effective September 14, 2001, on alternate weekends from Friday at 7:00 p.m. until Sunday at 7:00 p.m. In the event that a Monday school holiday coincides with Father's custodial weekend, Father shall have the option of extending his custodial weekend until 7:00 p.m. on Monday. 3. Transportation. The parties shall share transportation with the parent beginning their period of custody as the parent to provide transportation. For example, Father shall provide transportation on Fridays of his custodial weekend and Mother shall provide transportation on Sundays at the beginning of her custodial period. 4. Holidays. A. Thanksgiving. Mother shall have custody for the Thanksgiving holiday 2001. No. 01-4680 Civil Term B. Christmas 2001. Father shall have custody from the last day of school prior to the Christmas break through fo the evening before school resumes. 5. The parties shall submit themselves and their minor Child to an independent custody evaluation to be performed by Arnold T. Shienvold, Ph.D. The parties shall sign aU necessary releases and authorizations for the evaluator to obtain medical and psychological information pertaining to the parties. Additionally, the parties shall extend their full cooperation in completing this evaluation in a timely fashion and in the scheduling of appointments. Mother shall be obligated to pay one-third of the cost of the evaluation up to a maximum of $1000.00(one-thousand dollars), Father shall be responsible for the remaining costs of the evaluation. 6. Following the receipt of the report of the Custody Evaluator, either party may request to reconvene the Custody Conciliation Conference prior to requesting a trial date. Dist: Maria P. Cognetti, Esquire, 210 Grand Avenue, Suite 102, Camp Hill, PA 17011 Sandra L. Meilton, Esquire, 111 N. Front Street, PO Box 889, Harrisby~g, PA 17108-0889 ~~ ~ Cdq•i3~oe ~ t/IN~i1lASNN3d ~ttNno~ ~r!~~,,~~:A~~~~~ i U ~~ W'~ ~ 1 dJ5 l~ I~tfb'1CI~':i;'~Cii~,:,i : h~~i :,~i7 ,,,; ~~; ~,_~:1-ij~ .~ MAX SPIEGEL, Plaintiff vs. . ANITA SPIEGEL, . Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-4680 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 Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Alexis Spiegel March 10, 1990 Mother 2. A Custody Conciliation Conference was held on September 5, 2001, with the following individuals in attendance: the Father, Max Spiegel, and his counsel, Maria P. Cognetti, Esquire; the Mother, Anita Spiegel, and her counsel, Sandra L. Meilton, Esquire. 3. The parties reached an agreement as to an Interim Order in the form as attached. ~ D Date Mersa Peel Greevy, Esquire Custody Conciliator MAX SPIEGEL, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-4680 ANITA SPIEGEL, CIVIL-ACTION -LAW Defendant : IN CUSTODY AND NOW, to wit, this ~A "~ ° day of D ~ 2002, it is hereby ORDERED and DECREED that aPre-Hearing Conference is scheduled for/f 7(J ~ . 2002 at ~~' ~ o'clock q . m. in the Chambers of the undersigned. BY THE ~- ~, 0 ~~ ;'t s~ `. y~~ ~~ i ~_ 3~~ r ' , f , NOV 4 ° 2C1~12 l~ ~o ~®~~°~~ ~ ~~~®~~~~°~~ Attorneys and Counselors at Law Practice Limited to Matrimonial Law Maria P. Cognetti* Attorney at Law *Fellow, American Academy of Matrimonial Lawyers *Fellow, International Academy of Matrimonial Lawyers October 30, 2002 The Honorable Edward E. Guido Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 RE: SPdEGEL a SPIEGEL No. 01-4680 Our File No. 270 Dear Judge Guido: Karen A. Sheriff Paralegal Candith Y. Hill Paralegal A custody Bearing `has been scheduled in the above-referenced matter for December 9, 2002. I fiave jest reeeptlglearried that the Defendant, Anita Spiegel, has released the services of her attorney Sandra L. Ivleilfon. ?s of yet, I have not been contacted by new counsel. If the Court would be willing to schedule aPre-Hearing Conference in this matter, I am hopeful that it may move this case towards settlement. I enclose herewith a Scheduling Order in the event your honor feels aPre-Hearing Conference is appropriate. Thank you for your attention to this matter. I look forward to hearing from you. Very truly your , Maria P. ognett MPC/waw Enclosure cc: Max-Spiegel (w/enclosure) - Sandra L. `1Vieilton; Esquire (w/enclosure) - AnitaSpiegel(w/en~closiue)~~~" ~ ~ ~ _ 210 Grandview Avenue, Suite 102 • Camp Hill, PA 17011 Telephone (717) 909-4060 • Fax (717) 909-4068 Email CognettiLaw@aoLcom MAX SPIEGEL, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 07-4680 ANITA SPIEGEL, :CIVIL ACTION -LAW Defendant IN CUSTODY ORDER AND NOW, this ~~ day of ~~ , 2002, upon consideration of the Petition to Make Rule Absolute, it is hereby ORDERED AND DECREED THAT Sandra L. Meilton, Esquire, and the law firm of Tucker Arensberg & Swartz shall be withdrawn as counsel for Defendant, Anita Speigel, in the above matter. E COURT: 12- 9-o a C~`°~. LD• ~De~'~. II /a. C o ne'5~.~ ~(Yle;~~~t~ J. ., b'13Vy1~'rhS~~'~Jd {{~~~ ++ll ,; _ _ _ .;e_ ae~.-.=~ ~ ~'-~~F~~Sxn x xls Vie-. ~$q ,'. MAX SPIEGEL, Plaintiff v. ANITA SPIEGEL, Defendant r IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-4680 CIVIL ACTION -LAW IN CUSTODY PETITION TO MAKE RULE ABSOLUTE AND NOW, comes Sandra L. Meilton, Esquire, and the law firm of Tucker Arensberg & Swartz, and petitions this Honorable Court as follows: 1. The Petition to Withdraw as Counsel filed by the Petitioner on November 12, 2002, along with the Rule entered by the Honorable Edward E. Guido on November 14, 2002 was served on counsel for Plaintiff and on Defendant. Plaintiffs counsel received same by certified mail on November 19, 2002. Defendant was served by first class mail (mailing on November 18, 2002) and by fax to her work place where she received same on November 19, 2002. 2. A copy of Petitioner's letter to Plaintiffs counsel and to Defendant forwarding the said Petition and Rule, along with the certified mail receipt card are attached hereto as Exhibit "A". A copy of the fax confirmation sheet to Defendant's work place forwarding the Rule is attached hereto as Exhibit "B". 3. Said Rule was returnable in ten (10) days. 4. More than ten days has elapsed since service and neither Plaintiffs counsel nor the Defendant have responded to said Petition and Rule. WHEREFORE, Petitioner respectfully requests that this Honorable Court to make the Rule absolute and allow Petitioner to withdraw as counsel for Defendant in the above matter. TUCKER ARENSBERG & SWARTZ By:~li ~~' fr~!~i,~t~ Sandra L. Meilton, No. 32551 P.O. Box 889 Harrisburg, PA 17108 (717) 234-4121 TUCKER ARENSBEF ,~~5 SVUARTZ T. ~: 'r~ „ ~ ~~ CELEBRAT7NC A CENTURY OF SERVICE x November 18, 2002 ~~~~ ~ s~, ~° ~~~ ~ ~~ ~~~ Maria P. Cognetti, Esquire 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Mrs. Anita Spiegel 418 Boxwood Court Mechanicsburg, PA 17055 Dear Maria and Anita: Enclosed to each of you is a copy of the Petition to Withdraw as well as the Rule to Show Cause. Anita, this will also confirm the telephone conversation you had today with my paralegal, Gloria, wherein Gloria advised you that the Rule had been signed and we would sending it to you by regular mail and not by certified mail and that the document should arrive at your home tomorrow. This was done to expedite your receipt of the document. Gloria advised you that, per the Judge's signed Rule attached to the Petition to Withdraw, you have ten days to respond to the Court if you desire to do so. Sincerely, TUCKER ARENSgERG Sr SWARTZ Sandra L. Meilton SLM:gmr Enclosure to each 54603.1 711 NOFlTH FRONT STREET PO BOX 889 HARRISBURG, PA 77108-0889 717-234-4721 800-257-4727 FAX 777-232-6802 Pittsburgh Pittsburgh Airport Area Lewistown E-mail: tapc®[uckedaw.com ~- www.tuckerlew.wm P~ m SE. 9 " w ^ Complete items 1 and/or 2 for addttionel services. - m Complete itema 3, 4e, and 4b. ~ ^ Pnm your name and atltlress on the reverse of this form so that we can return This ~ card to you. - ~ O Attach this form to the hoot of the mailpiece, or on fhe back'rf space does not y Permit. t. ^Wdle 'Return ReceiptRequested'on the mailpiece below the article number. ~ ^ The Return Receipt will show to whom the article was tlellvered aniJ the date p delivered. '~ 3. Article Addressed to: L+Fa. Article N Maria P;. Cognetti, Esq. 210 Grandview Ave Suite 1~,2 Camp Hill PA 17011 WI o \I a a ~ a y .. I also wild to receive the follow- ing services (for an extra fee): ~~ ^ Addressee's Address 2. ^ Restricted Delivery 3400 0016 3623 6405 ":^Registered ~~gertified `'i'DExpressMail ^Insured -, ^Retum Receipt for Memhandise ^COD 7. Date of telivery ( R. Addressee' !ee is paid) 102595-99-e-0223 r.ri S -D u 2 W ~r a .~ p 2 9 m ¢' 'N `o 'o Y W slit Re~[um Wr3eeipt ~ Postage $ f>1 Certified Fee Postmark -,n ReNrn Receipt Fee Hera ~ (Endorsement Requiretl) ~ Restricted Delivery Fee ~ (Endorsement Required) p Total Postage 8 Fees ° 11 18 02 ~ P rrl Redpianf5 Name (Please Print Clearly) (to be completetl by mailed - ----~~--- g---- Co~netti+---Esq_.--------- - ----- Q- Sfreeq o.; or PO ox Q' Gran"c~view Ave Suite 102 O -------- ---- ------------------------------------------------------------------------------- - - r, Qty, Sfete, ZIP+d Cam,-Hill, PA 17011 ~~~frt~c D 1 TRANSMITTED/STORED PILE MODE 2091~MEMORY TX ^ * * COMMUNICATION RESULT REPORT ( NOV. 19.2002 11:08AM) >K ~~ ' ~ TTI NOV. 19. 2002 11 : 07AM OPTION ADDRESS RESULT PAGE -------------------------pK-------------Z/2 5314010 REASON FOR ERROR E-3) NONANSWERR LINE FAIL TI..ICKER AEZENSBbRG ~ SWAFZTZ ... .. >: .;i CELEBRATING A CENTURY OF SERV ICE E-2) BUSY E-4) NO FACSIMILE CONNECTION FACSIMILE COVER LETTER DATE: I I """' ~-O ~ ~ ~ ~` ~~ ~~ THIS DOCUMENT SHOULD BE DELIVERED IMMEDIATELY ADDRESSEE'S FAX: S 3 I - C~ I C.~ FROM: ~4 '~. P.2 ~ RE: ~ ~ P ~ ~P ~ i ~ l e TOTAL PAGES (INCLUDING THIS COVER LETTER) IF YOU DO NOT RECEIVE ALL Z PAGES, PLEASE CALL OUR OFFICE IMMEDIATELY. r TELEPHONE: (717) 234-1F121 FAGSIMILE: {717) 232-6802 COMMENTS: THE INFORMATION CONTAINED IN THIS FACSIMILE MESSAGE IS ATTORNEY PRIVILEGED AND CONFIDENTIAL INFORMATION fNTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE- IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPY OF THIS COMMUNICATION IS STRICTLY PROHIBITED- IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE IMMEDIATELY NOT{FY US BY TELEPHONE AND RETURN THE ORIGINAL MESSAGE TO US AT THE ABOVE ADDRESS VIA THE U.S. POSTAL SERVICE. THANK YOU. 111 NORTH FRONT STREET PO BOX 88g tiARRISEURG. PA 1>108-0899 ]1T-234.0.12[ BOO.28T-4121 FAX Tl].232.eBp2 Piasburgh Pllarbwrgh Nrpon Aree . Lewi¢[own /w~vw.iw )C . I ANITA SPIEGEL, Defendant t 11 NORTH FRONT STR$F_T P.O. BOX 889 HARRISBURG, PENNSYLVANIA 17108-0889 - - ~ ,, ~.. 3eAJ M b. (717)?34-4L1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. .0111680 :CIVIL ACTION -LAW - IN CUSTODY RULE TO SHOW"CAUSE AND NOW, this ~T~ day of /~/UYfiIY'lEiF.~ 2002, upon consideration of the Petition to Withdraw as Counsel; a Rule is issued upon Plaintiff, Max Spiegel, to show cause why Sandra L. Meilton, and TUCKER ARENSBERG & SWARTZ, should not be granted leave to withdraw as counsel for Defendant in this case. RULE RETURNABLE ~ ~ DAYS FROM THE DATE OF SERVICE. J. MAX SPIEGEL, Plaintiff - - v. CERTIFICATE OF SERVICE ,d /~, AND NOW, this ~ day of .QEer~~l'ol. , 2002, I, Gloria M. Rine, Paralegal to Sandra L. Meilton, Esquire, for the firm of Tucker Arensberg & Swartz, hereby certify that I have this day served a copy of the within document, by mailing same by first class mail, postage prepaid, addressed as follows: Maria P. Cognetti, Esquire 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Mrs. Anita Spiegel 418 Boxwood Court Mechanicsburg, PA 17055 -~/J'L~- ~~~ 7~ r Gloria M. Rine 54864.1 cz ~:~ ~ R`.d _i ,i ti~ '(`, =: ~~ G {V }tom ( ~ _ ~' (_ CTJ 'A' rl "3 ~~'} ~ ~~ MAX SPIEGEL, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-4680 ANITA SPIEGEL, :CIVIL ACTION -LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, to wit, this (O~ day of , 2002, it is hereby ORDERED and DECREED that the attached Stipulation for Custody be made an Order of this Court and said Stipulation is adopted in its entirety and incorporated herein as an Order of Court. J. oP yes C a~1e~ R~s to~- /De~t. ,~ o~. -1"~}e,~-L~o~ Co~ne~~- 'ail ~i`if~ it ~~IN7d y~ ~d ~.r 0 l~~f ?;.u ~~"'; '' ; L :;C, _ aAm+wvm~~ mwstxa.=L ms RY~3"""° F~rF.R~aa~Y*!Ti4s'_ ~.. .~. MARIA P. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIRE Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 1701 I Telephone No. (717) 909-4060 Attorneys for Plaintiff MAX SPIEGEL, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. ANITA SPIEGEL, Defendant NO. 01-4680 CIVIL ACTION -LAW IN CUSTODY STIPULATION FOR CUSTODY AND NOW, this ~ ~~ day of ~~, 2002, the parties having the best interest of their minor child, Alexis Spiegel, born March 10, 1990, in mind, do hereby agree and stipulate as follows: The parties agree to share legal custody of their minor child, Alexis Spiegel. All decisions effecting the child's growth and development including, but not limited to: medical and dental treatment; psycho-therapy, psychoanalysis, or like treatment; decisions relating to actual or potential litigation involving the child, directly or as a beneficiary, other than custody litigation; education, both secular and religious; choice of camp, if any; athletic pursuits and extracurricular activities shall be considered major decisions and shall be made by the parties jointly, after discussion and consultation with each other and with a view towards obtaining and following a harmonious policy in the child's best interest. Primary physical custody of the minor child shall remain with Mother until the end of the 2002 - 2003 school year. On the first Friday following the close of school for the 2002 - 2003 school year in June, 2003, primary physical custody of Alexis shall switch to Father. 3. Until the end of the 2002-2003 school year, the alternating weekend schedule currently in place shall remain in effect with Father having alternating weekends from Friday at 7:00 PM until Sunday at 7:00 PM. Should the Monday following Father's custodial weekend be a school holiday, Father shall be entitled to extend his weekend until Monday at 7:00 PM. 4. Beginning at the end of the 2002-2003 school year, Mother shall have rights of partial physical custody from that point forward in accordance with the following schedule: a. Alternating weekends from Friday at 7:00 PM until Sunday at 7:00 PM. In the event that Monday is a school holiday which coincides with Mother's custodial weekend, Mother shall have the option of extending her custodial weekend unti17:00 PM on Monday. b. The Thanksgiving holiday shall be Father's custodial time in 2002 and all even numbered years thereafter and Mother's custodial time in 2003 and all odd numbered years thereafter. c. The Christmas holiday shall be defined as the last day of school prior to the Christmas break through the evening before school resumes. Mother shall have the Christmas holiday in 2002 and all even numbered years thereafter. Father shall have the Christmas holiday in 2003 and all odd numbered years thereafter. d. The remainder of the holidays shall be shared by the parties as they can agree. e. The parties agree that the holiday schedule shall take precedence over the other regularly scheduled custodial periods. 5. The party who is to receive custody shall provide transportation. 6. While in the presence of the child, neither parent shall make any remarks or do anything which could in any way be construed as derogatory or uncomplimentary to the other parent. It shall be the express duty of each parent to uphold the other parent as one whom the child should respect and love. 7. After a period of one year from the time custody switches to Father, Mother may request that a reevaluation of the custody situation be undertaken by Dr. Chrissi Hart. The parties agree to equally pay the fees associated with Dr. Hart's reevaluation. Father agrees to cooperate in the reevaluation process. 8. The parties agree that this Stipulation shall be entered as an Order of Court and as such shall have the same full force and effect as if the matter had been tried and decided. 9. This Stipulation and Order of Court shall supersede any existing custody arrangements between the parties. This Sfipulation and Order of Court shall continue in full force and effect until further Order of Court and/or amended agreement in writing between the parties. 10. The parties hereby waive the right to present this Stipulation in open court or to have this their case heard by the Court at this time. 1N WITNESS WHEREOF, the parties have hereunto set their hands and seals the date and year first above written. ~it e~s ~i '' _ i ess ~,r~,.~t,d~ ~c Anita Spiegel ~:, 1~~~ ~o cC®~~°~°°~ ~ ~~~®~~~~~ Attorneys and Counselors at Law Mazia P. Cognetti* Attorney at Law *Fellow, American Academy of Matrimonial Lawyers *Fellow, International Academy of Matrimonial Lawyers December 3, 2002 The Honorable Edwazd E. Guido Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 RE: SPIEGEL v. SPIEGEL No. 01-4680 Our File No. 270 Dear Judge Guido: Karen A. Sheriff Paralegal Candith Y. Hill Paralegal Enclosed please find three (3) copies of the Stipulation for Custody which have now been signed by both parties. Once the Order has been signed, could you kindly have the Prothonotary's Office conform and certify our copies and return them to me in the self-addressed, stamped envelope provided. Pursuant to your Local Rules, I have also enclosed an addressed, stamped envelope for Defendant, Anita Spiegel and her counsel, Sandra L. Meilton, Esquire. Should you have any questions, please do not hesitate to contact me. Thank you for your assistance in this matter. Very truly your Maria P. C gnett MPC/waw Enclosures Practice Limited to Matrimonial Law cc: Max Spiegel (w/enclosure) Anita Spiegel (w/enclosure) Sandra L. Meilton, Esquire (w/enclosure) MAX SPIEGEL IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COiJNT'Y, PENNSYLVANIA y'' ~ 01-4680 CIVIL ACTION LAW ANITA SPIEGEL IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, July 28, 2004 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 301 Market Street, Lemoyne, PA 17043 on Monday, August 30, 2004 at 10:30 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. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Melissa P C~-eevy Esq. mhc 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 attangements 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 HAVL AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~~~ ~,~~ ~~~~C ~a ~sz~=~ r~v~n~~,s~,~~~±r,~ ~£ ~~ ~d 8i 1~f ~0~~ ~~ },~~f~~h'-31i~}~. ~~ ~~ JUL 2 2 2004 ~ MAX SPIEGEL, IN THE COURT OF COMMON PLEAS Plaintiff/Respondent :CUMBERLAND COUNTY, PENNSYLVANIA vs. NO.OI-4680 ANITA SPIEGEL, :CIVIL ACTION -LAW Defendant/Petitioner :CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Petition, it is hereby directed that the parties and their respective counsel appear before ,the Conciliator, on the day of , 2004 at _.m. at Pennsylvania, 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. All children age five or older may at the request of either attorney or party, be present at the conference. 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 Conciliator 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. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, 4th FLOOR 1 COURTHOUSE SQUARE CARLISLE, PENNSYLVANIA 17013 3387 (717) 240-6200 MAX SPIEGEL, : IN THE COURT OF COMMON PLEAS Plaintiff/Respondent :CUMBERLAND COUNTY, PENNSYLVANIA vs. NO.Ol-4680 ANITA SPIEGEL, :CIVIL ACTION -LAW Defendant/Petitioner :CUSTODY PETITION TO MODIFY CUSTODY TO THE HONORABLE, THE JUDGES OF THE SAID COURT: AND NOW comes the Defendant/Petitioner, ANITA SPIEGEL, by his attorney, MAX J. SMITH, JR., Esquire, and respectfully represents the following: Defendant/Petitioner is ANITA SPIEGEL, who resides at 80 Rosedale, Hershey, Dauphin County, Pennsylvania. 2. Plaintiff/Respondent is MAX SPIEGEL, who resides 617 S. Matlack Street, West Chester, Chester County, Pennsylvania. Plaintiff and Defendant are divorced and are the natural parents of one child, ALEXIS H. SPIEGEL, born March 10, 1990. 4. On December 6, 2002, pursuant to an agreement of the parties, an Order of Court was issued in the Court of Common Pleas of Cumberland County awarding the parties shared legal custody of said child and awazding Father primary physical custody beginning in June 2003, subject to Mother's rights of partial custody. (See copy of Order, mazked Exhibit "A", attached hereto and made part hereof.) The best interests and welfare of ALEXIS H. SPIEGEL, require that primary physical custody be with Petitioner. Also, Alexis has expressed a clear preference to return to her Mother's primary custody. 6. The minor child has resided at the following addresses for the past five (5) years: (a) From February 2000 until June 2001 at Williamsburg Estates, Dauphin County, Pennsylvania with both parents. (b) From June 2001 until June 2003 at Delbrook Apartments, Cumberland County, Pennsylvania with Mother. (c) From June 2003 until present at 617 S. Matlack Street, West Chester, Chester County, Pennsylvania with Father. Petitioner does not have any information of any custody proceeding concerning said minor child in any court in Pennsylvania or any other State, other than the heretofore referenced proceedings entered to the within term and number. 8. Petitioner has not participated as a party, witness or otherwise in any other litigation concerning the custody of said minor child in Pennsylvania or any other State, other than the heretofore referenced proceedings entered to the within term and number. 9. Petitioner does not know of any person not a party to these proceedings who has physical custody of the said minor child or who claims to have custody or visitation rights with respect to her. WHEREFORE, Petitioner respectfully prays that your Honorable Court order that primary physical and shared legal custody of the minor child, ALEXIS H. SPIEGEL, be placed with Petitioner. Respectfully submitted, Date: July 2004 lu' MAX J. SMITH, JR., squire I.D. No. 32114 JARAD W. HANDELMAN, Esquire I.D. No. 82629 James, Smith, Dietterick & Connelly LLP P.O. Box 650 Hershey, PA 17033 (717) 533-3280 I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. (J(..~ , ~n ~ • e p ~ ANITA H. SPIEGEL v MAX SPIEGEL, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. N0. 01-4680 ANITA SPIEGEL, CNIL ACTION -LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, to wit, this (O~ day of t~ "'- `, 2002, it is hereby ORDERED and DECREED that the attached Stipulation for Custody be made an Order of this Court and said Stipulation is adopted in its entirety and incorporated herein as an Order of Court. r TRUE C{3PY FROAA REGCi€t2 to Testimony whereof, i here unto set my hand and,l6~ sea! of sai,~', Court arCarliste, Pa. MARIA P. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIKE Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Plaintiff MAX SPIEGEL, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. ANITA SPIEGEL, Defendant NO. 01-4680 CIVIL ACTION -LAW IN CUSTODY STIPULATION FOR CUSTODY AND NOW, this .~ lc ~ ~ day of `~ 1(°;1 `'Ii'! ~ ~_(", 2002, the parties having the best interest of their minor child, Alexis Spiegel, born March 10, 1990; in mind, do hereby agree and stipulate as follows: The parties agree to shaze legal custody of their minor child, Alexis Spiegel. All decisions effecting the child's growth and development including, but not limited to: medical and dental treatment; psycho-therapy, psychoanalysis; or like treatment; decisions relating to actual or potential litigation involving the child, directly or as a beneficiary, other than custody litigation; education, both secular and religious; choice of camp, if any; athletic pursuits and extracurriculaz activities shall be considered major decisions and shall be made by the parties jointly, after discussion and consultation with each other and with a view towards obtaining and following a harmonious policy in the child's best interest. 2. Primary physical custody of the minor child shall remain with Mother until the end of the 2002 - 2003 school year. On the first Friday following the close of school for the 2002 - 2003 school year in June, 2003, primary physical custody of Alexis shall switch to Father. Until the end of the 2002-2003 school yeaz, the alternating weekend schedule currently in place shall remain in effect with Father having altemating weekends from Friday at 7:00 PM until Sunday at 7:00 PM. Should the Monday following Father's custodial weekend be a school holiday, Father shall be entitled to extend his weekend until Monday at 7:00 PM. 4. Beginning at the end of the 2002-2003 school yeaz, Mother shall have rights of partial physical custody from that point forwazd in accordance with the following schedule: a. Alternating weekends from Friday at 7:OO PM until Sunday at 7:00 PM. In the event that Monday is a school holiday which coincides with Mother's custodial weekend, Mother shall have the option of extending her custodial weekend until 7:00 PM on Monday. b. The Thanksgiving holiday shall be Father's custodial time in 2002 and all even numbered yeazs thereafter and Mother's custodial time in 2003 and all odd numbered yeazs thereafter. c. The Christmas holiday shall be defined as the last day of school prior to the Christmas break through the evening before school resumes. Mother shall have the Christmas holiday in 2002 and all even numbered years thereafter. Father shall have the Christmas holiday in 2003 and all odd numbered yeazs thereafter. ,~ , _, d. The remainder of the holidays shall be shared by the parties as they can agree. e. The parties agree that the holiday schedule shall take precedence over the other regularly scheduled custodial periods. The party who is to receive custody shall provide transportation. 6. While in the presence of the child, neither pazent shall make any remazks or do anything which could in any way be construed as derogatory or uncomplimentary to the other parent. It shall be the express duty of each parent to uphold the other parent as one whom the child should respect and love. After a period of one year from the time custody switches to Father, Mother may request that a reevaluation of the custody situation be undertaken by Dr. Chrissi Hart. The parties agree to equally pay the fees associated with Dr. Hart's reevaluation. Father agrees to cooperate in the reevaluation process. The parties agree that this Stipulation shall be entered as an Order of Court and as such shall haverhe same fuii force and effect as if the matter had been tried and decided. 9. This Stipulation and Order of Court shall supersede any existing custody arrangements between the parties. This Stipulation and Order of Court shall continue in full force and effect until further Order of Court and/or amended agreement in writing between the parties. 10. The parties hereby waive the right to present this Stipulation in open court or to have this their case heard by the Court at this time. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the date and year first above written. I ~ %l7lVJ f( ~ %i~^t ~ WWitness Witness J ~~~.Lti'~~ ~~ ax SpiegelL' ~ Anita Spiegel ~ :-~ - . ,,_ 0 ~ ^~ r ,., ::,> ,_. ~,~ t~3 r., a-~ ,~ .~ ~T '-~ ~, ,~ ~~ ?' ~I _l ~ _~ . n .. _ .- R~REb~Li~~6ngc+,~~5wM2nF39~~r~ ,. rtSvzxr .. , - -~. ~._, ...~ ,_ e. r o- ems.," ~~, __,. REGINA McREDMOND, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. NO. 01-6831 CIVIL TERM JOHN McREDMOND, Defendant : IN DIVORCE ELECTION TO RESUME PRIOR NAME I, Regina McRedmond, do hereby elect to resume my prior name, to wit: Regina Morris. As noted above, I am a party in the divorce action entered to the above nureber and term, and give this written notice avowing my intention in accordance with the provisions of 54 Pa.C.S.A. Section 704, as amended by Act 2000-92, effective January 21, 2001. e Re i McRedmond, to be,lcnown as 0~-~-. Regi orris Sworn to and subscribed before me this ~ day of "s~, 2004. i ~ , G~~'r~- G otary Public (SEAL) COMMONWEALTH OF PENNSYLVANIA NOYgItl Seal (?rnele E. Wagbr, Notary P~Nc Oily OfHanhbwg, ~h 70388. S My Commbeim E~Ires Juno 10; 2003 Msmbar, PennayWania Association Of NotaAes ~~~- O 4 ]~' \ ~ ~ 1, ~; ~~~ m ~ ~- ~ •zy r° F, n~r- r- trn.? ~ -- ' try ~.C= ~ ~-~. ~ ~. ~ ~ ~ ~ ~ f~ v~ C[ AUG 1 ~ 2UDa MAX SPIEGEL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-4680 ANTI'A SPIEGEL, CIVIL ACTION -LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, to wit, this f d~ day of , 2004, it is hereby ORDERED and DECREED that the attached Stipulation for Custody be made an Order of this Court and said Stipulation is adopted in its entirety and incorporated herein as an Order of Court. BY THE COURT: J. C~~ o$,,~o ~a ~~_,a~7 ,`~, rr ~f,x~ silk ~ i i _9_ ~ ... ~fiR~Ry~%C yf~~k'~3%"'.~ _ A4k..-i ?: e'.~ gyn. x'Li ve ~~..a,°f' S. rc~s _.arRl .:.b-vdm'1$`-'4 `m'A2k31~nf4' MAX SPIEGEL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-4680 AN1TA SPIEGEL, CIVIL ACTION -LAW Defendant IN CUSTODY STIPULATION FOR CUSTODY AND NOW, this day of 2004, the parties having the best interest of their minor child, Alexis Spiegel, born March 10, 1990, in mind, do hereby agree and stipulate as follows: 1. The parties agree to share legal custody of their minor child, Alexis Spiegel. All decisions effecting the child's growth and development including, but not limited to: medical and dental treatment; psycho-therapy, psychoanalysis, or like treatment; decisions relating to actual or potential litigation involving the child, directly or as a beneficiary, other than custody litigation; education, both secular and religious; choice of camp, if any; athletic pursuits and extracurricular activities shall be considered major decisions and shall be made by the parties jointly, after discussion and consultation with each other and with a view towards obtaining and following a harmonious policy in the child's best interest. 2. Primary physical custody of the minor child shall remain with Father until the end of the 2003-2004 school year. On the first Friday following the close of school for the 2003- 2004 school yeaz in June, 2004, primary physical custody of Alexis shall switch to Mother. 3. Beginning at the end of the 2003-2004 school year, Father shall have rights of partial physical custody from that point forwazd in accordance with the following schedule: a. Alternating weekends from Friday 7:00 PM until Sunday at 7:00 PM. In the event that Monday is a school holiday which coincides with Father's custodial weekend, Father shall have the option of extending his custodial weekend unti17:00 PM on Monday. b. The Thanksgiving holiday shall be Father's custodial time in 2004 and all even numbered years thereafter and Mother's custodial time in 2005 and all odd numbered years thereafter. c. The Christmas holiday shall be defined as the last day of school prior to the Christmas break through the evening before school resumes. Mother shall have the Christmas holiday in 2004 and all even numbered years thereafter. Father shall have the Christmas holiday in 2005 and all odd numbered years thereafter. d. The remainder of the holidays shall be shared by the parties as they can agree. e. The parties agree that the holiday schedule shall take precedence over the regularly scheduled custodial periods. 4. The party who is to receive custody shall provide transportation. 5. While in the presence of the child, neither pazent shall make any remarks or do anything which could in any way be construed as derogatory or uncomplimentary to the other parent. It shall be the express duty of each parent to uphold the other parent as one whom the child should respect and love. 6. The parties agree that this Stipulation shall be entered as an Order of Court and as such shall have the same full force and effect as if the matter had been tried and decided. 7. This Stipulation and Order of Court shall supersede any existing custody arrangements between the parties. This Stipulation and Order of Court shall continue in full force and effect until further Order of Court and/or amended agreement in writing between the parties. 8. The parties hereby waive the right to present this Stipulation in open court or to have this their case heard by the Court at this time. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the date and year first above written. Witness Date: Max Spiegel ~ , Date: .Ln .r~A ~-~ ~ t/ Anita Spiegel glg/ Date: O ~/ <~> t - ~' <~ - r~ -r, ~,^-, I li'~ .~: ,,„ .. T GI g7 ~ ~ ( 7 I - j} -+' „ ~, '" ~~ G7 "{ /~ l\/.V// \\A\\\ a*3aifc .~..a,ditRa~~sxrn~ ..... .. ... .. .....-.__ i. :..ii,: ma~irtNZ~F~, tia... OCT 19 20iJ4~ ' MAX SPIEGEL, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff N0.01-4680 CIVIL TERM v. ANITA SPIEGEL, Defendant CIVIL ACTION -LAW IN CUSTODY ORDER TO RELINQUISH JURISDICTION AND NOW, this 18~' day of October, 2004, the parties having reached an agreement which has been memorialized in a Stipulation and filed with this Court, the Conciliator hereby relinquishes jurisdiction of the above captioned matter. FORTH OU T: Y: Melissa Peel Greevy, Esquire Custody Conciliator :237600 ~~, .~_~ ._ c_~ , _ - -~~ ~> - --~ - ~, -~_~ i r'J i C.J ~ "g Q ~ ~ ~` C f(E 4: ~~ ~~ ,,® x~:eass~sas~~axsr~n ~ ' MAX SPIEGEL, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-4680 ANITA SPIEGEL, Defendant : CIVIL ACTION - LAW : IN CUSTODY PETITION TO MAKE RULE ABSOLUTE AND NOW, comes Sandra L. Meilton, Esquire, and the law firm of Tucker Arensberg & Swartz, and petitions this Honorable Court as follows: 1. The Petition to Withdraw as Counsel filed by the Petitioner on November 12, 2002, along with the Rule entered by the Honorable Edward E. Guido on November 14, 2002 was served on counsel for Plaintiff and on Defendant. Plaintiff's counsel received same by certified mail on November 19, 2002. Defendant was served by first class mail (mailing on November 18, 2002) and by fax to her work place where she received same on November 19, 2002. 2. A copy of Petitioner's letter to Plaintiff's counsel and to Defendant forwarding the said Petition and Rule, along with the certified mail receipt card are attached hereto as Exhibit "A". A copy of the fax confirmation sheet to Defendant's work place forwarding the Rule is attached hereto as Exhibit "B". 3. Said Rule was returnable in ten (10) days. 4. More than ten days has elapsed since service and neither Plaintiff's counsel nor the Defendant have responded to said Petition and Rule. WHEREFORE, Petitioner respectfully requests that this Honorable Court to make the Rule absolute and allow Petitioner to withdraw as counsel for Defendant in the above matter. TUCKER ARENSBERG & SWARTZ Sandra L. Meilton, No. 32551 P.O. Box 889 Harrisburg, PA 17108 (717) 234-4121 TUCKER ARENSBEF 5WARTZ CELEBRATING A CENTUt~.Y OF 5~:R. VICE November 18, 2002 Maria P. Cognetti, Esquire 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Mrs. Anita Spiegel 418 Boxwood Court Mechanicsburg, PA 17055 Dear Maria and Anita: Enclosed to each of you is a copy of the Petition to Withdraw as well as the Rule to Show Cause. Anita, this will also confirm the telephone conversation you had today with my paralegal, Gloria, wherein Gloria advised you that the Rule had bccn signed and we would sending it to you by .regular mail and not by certified mail and that the document should arrive at your home tomorrow. This was done to expedite your receipt of the document. Gloria advised you that, per the Judge's signed Rule attached to the Petition to Withdraw, you have ten days to respond to the Court if you desire to do so. Sincerely, TUCKER ARENSBERG & SWARTZ SLM:gmr Enclosure to each Sandra i. Meilton 111 NORTH FRONT STREET PO BOX 889 HARRISBURG, PA 17108-0889 717-234-4121 800-257-4121 FAX 717-232-6802 Pittsburgh · Pittsburgh AirportArea · Lewistown E-mail: tapc~tuckerlaw, com www.tuckerlaw, com ,, SENDER: [3 Complete items 1 and/or 2 for additional services. Ccmplete items 3, 4a, and 4b. [] Pdnt your name and address on the reverse of this form so that we can return this card to you. [] Attach this form to the front of the maitpiece, or on the beck if space does not [] Write 'Return Receipt Requested' on the maitpiece below the article number. [] The Retum Receipt will shew to whom the art/de was delivered and the date delivered. I also wish to receive the follow- ing sanhces (for an extra fee): 1. [] Addressee's Address 2 [] Restricted Delivery 3. Article Addressed to: Maria P. Cognetti, Esq. 210 Grandview Ave Suite 102 Camp Hill PA 17011 5. Received By: (Print Name) ll~'~J(:lnat ~lre (A Ago~t) PS~'r~ ~'I, ~)l~;~oer 19~4 4a. Article Number 7099 3400 0016 3623 6405 4b. Service Type [] Registered ~ertified I [] Express Mail [] Insured 1"1 Return Receipt for Merchandise I-JC.OD 7. Date of I~elivery 8. Addres~ee's Address (Only if requested and fee is pa/d) 102595-99-B~223 Domestic Return Receipt 13- I-1 Postage Certified Fee Postmark Return Receipt Fee Here (Endorsement Required) Restricted Delivery Fee (Endorsement Required) · o,., .o~s. & P... $ 11/18/02 aecipiellt% Name (P/ease Print C/ear/y) (to be completed by rnailer~, P. 1 x ~ x COMMUNICATION RESULT REPORT ( NOV. 19. 2002 ll:08AM ) TRANSMITTEDZSTORED NOV, 19. 2002 ll:07AM FILE MODE OPTION ADDRESS RESULT PAGE 2091 MEMORY TX 5314010 OK 2/2 TUCKER. AFLEN 5BEP,-G FACSIMILE COVER LEI ~ ER, DATE: ! /-- J THIS DOCUMENT SHOULD BE DELIVERED IMMEDIATELY TOTA~ PAGES (INCLUDING THI~ COVER L~ IF YOU DO NOT R~C~IV~ ALL ~ ,, PAGES, PL~ CALL OUR OFFICE FACSIMILE: (717) 232-6802 COMMENTS: .' THE INFORMATION CONTAINED IN THIS FACSIMILE MESSAGE IS A I'IORNEY PRIVILEGED AND CONFIDENTIAL INFORMATION INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPY OF THiS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLE~:kSE IMMEDIATELY NOTIFY US BY TELEPHONE AND RETURN THE ORIGINAL MESSAGE TO US AT THE ABOVE ADDRESS VIA THE U,S. POSTAL SERVICE. THANK YOU. MAX SPIEGEL, Plaintiff ANITA SPIEGEL, Defendant 111 NORTH FRO_NT STR.,F_,ET P.O. BOX 889 HARR SBURG, PENNSYLVANIA 17108-(1859 '(717) 234-:1121 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-4680 : CIVIL ACTION - LAW : IN CUSTODY RULE TO SHOW CAUSE AND NOW, this /d~II~ day of ~~~~_._, 2002, upon consideration of the Petition to Withdraw as Counsel; a Rule is issued upon Plaintiff, MaX Spiegel, to show cause why Sandra L. Meilton, and TUCKER ARENSBERG & SWARTZ, should not be granted leave to withdraw as counsel for Defendant in this case. RULE RETURNABLE I ~) DAYS FROM THE DATE OF SERVICE. CERTIFICATE OF SERVICE AND NOW, this ~ '~ ~ ~E' day of ~ ¢.'"-~.~-. ,2002, I, Gloria M. Rine, Paralegal to Sandra L. Meilton, Esquire, for the firm of Tucker Arensberg & Swartz, hereby certify that I have this day served a copy of the within document, by mailing same by first class mail, postage prepaid, addressed as follows: Maria P. Cognetti, Esquire 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Mrs. Anita Spiegel 418 Boxwood Court Mechanicsburg, PA 17055 Gloria M. Rine 54864.1 MAX SPIEGEL, Plaintiff · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA v. ' NO. 01-4680 ANITA SPIEGEL, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER AND NOW, this day of ,2002, upon consideration of the Petition to Make Rule Absolute, it is hereby ORDERED AND DECREED THAT Sandra L. Meilton, Esquire, and the law firm of Tucker Arensberg & Swartz shall be withdrawn as counsel for Defendant, Anita Speigel, in the above matter. VINVA-IASNN~d ~ 0~' ~ ~