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BRETT E. DELLINGER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. NO. 99-4073 CIVIL TERM
TANYA R. DELLINGER, CIVIL ACTION - LAW
Defendant IN CUSTODY
ORDER OF COURT
AMID NCW, this 3'l day of 04;V,4-? , 2000, upon
consideration of the attached Custody Conciliation Report, it is ordered
and directed as follows:
1. The prior Order of this Court dated January 26, 2000 is suspended
and replaced with this Order pending further Order of Court or agreement of
the parties.
2. The Father, Brett E. Dellinger, and the Mother, Tanya R.
Dellinger, shall have shared legal custody of Morgan Aylissa Dellinger,
born June 27, 1997. 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.
3. The Father shall have primary physical custody of the Child.
4. The Father shall cooperate in scheduling periods of supervised
visitation with the mother if appropriate during the Mother's period of
treatment.
5. 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
cc: Mary Kollas Kennedy, Esquire - Counsel for Father
Steven J. Fishman, Esquire - Counsel for Mother p p
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BRETT E. DELLINGER,
Plaintiff
VS.
TANYA R. DELLINGER,
Defendant
PRIOR JUDGE: Edward E. Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-9073 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
cusrow CONCILIATION SUMMARY REPORT
IN ACCORDANCE NITH 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
Morgan Aylissa Dellinger June 27, 1997 Father
2. A Conciliation Conference was held on September 27, 2000, with the
following individuals in attendance: The Father, Brett E. Dellinger, with
his counsel, Mary Kollas Kennedy, Esquire, and the Mother's counsel, Steven
J. Fishman, Esquire. The Mother, Tanya R. Dellinger, who is currently
incarcerated in the Cumberland County Prison, consulted with her counsel
during the Conference by telephone.
3. The parties agreed to entry of an Order in the form as attached.
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Date Dawn S. Sunday, Esquir
Custody Conciliator
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BRETT E. DELLINGER,
Plaintiff
V.
TANYA R. DELLINGER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4073 Civil
CIVIL ACTION - LAW
IN DIVORCE
AGREEMENT
This Agreement is made this 5 day of 5411.
2000 , by and
between Tanya R. Dellinger of Cumberland County, Pennsylvania ("Wife") and Brett E. Dellinger
of Cumberland County, Pennsylvania ("Husband".).
WITNESSETH
WHEREAS, the parties hereto are Husband and Wife, having been married on
December 3, 1994, in Lewisberry, Pennsylvania;
WHEREAS, certain unhappy differences, disputes, misunderstandings and difficulties have
arisen between the parties and the parties have decided that their marriage is irretrievably broken,
that it is their intention to live separate and apart for the rest of their natural lives, that they are
desirous of settling fully and finally their respective financial and property rights and obligations as
between each other including, without limitation by specification:
1. The settling of all matters between them relating to the ownership of real and
personal property including property heretofore or subsequently acquired by either party;
2. The settling of all disputes, rights and/or interests between them arising out of or
by reason of their marriage including but not limited to the past, present and future support,
alimony, counsel fees, costs or maintenance of Wife by Husband or of Husband by Wife;
3. In general, the settling of any and all actual and possible claims by each party
against the other or against their respective estates.
NOW THEREFORE, in consideration of the premises and of the mutual promises,
covenants and undertakings set forth in this Agreement and for other good and valuable
consideration, the receipt and adequacy of which is hereby acknowledged by each of the parties
hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as
follows:
1. Advice of CounseL The provisions of this Agreement and their legal effect have
been fully explained to Husband by his counsel, Mary Kollas Kennedy, Esquire, of Kollas and
Kennedy in Camp Hill, Pennsylvania. Wife has been advised of her right to review this
Agreement with counsel of her choice. The parties acknowledge that each has had the
opportunity to receive independent legal advice from counsel of his or her own selection, that
each has fully disclosed his or her respective financial situations to the other including his or her
property, estate, assets, liabilities, income and expenses, that each is familiar with and fully
understands the facts, including the property, estate, assets, earnings and income of the other, and
that each has been fully informed as to his or her legal rights and obligations. Each of the parties
acknowledges and agrees that, after having received such advice and with such knowledge, the
Agreement is, in the circumstances, fair reasonable and equitable, that it is being entered into
freely, voluntarily, and in good faith and that the execution of the Agreement is not the result of
any duress, undue influence, coercion, collusion and/or improper or illegal Agreement. The
parties further acknowledge that they have each made to the other a full and complete disclosure
of their respective assets, estate, liabilities, and sources of income and that they waive any specific
enumeration thereof for the purposes of this Agreement.
2. Definitions.
(a) Divorce Code. The phrase "Divorce Code" shall be defined as Act No.
1990-206, 23 Pa.C.S.A. § 3101 et seq.
(b) Dcrle of Execution of this Agreement. The phrase "date of execution" or
"execution date" of this Agreement shall be defined as the date of execution by the parties if they
have each executed the Agreement on the same date. Otherwise, the "date of execution" or
"execution date" of this Agreement shall be defined as the date of execution by the party last
executing this Agreement.
3. Effective Dule of Agreenrenl. This Agreement will become effective and binding
upon both parties upon execution of this Agreement by both of them.
4. Effect of Divorce Decree--Incorporation, No Merger. The parties agree that
unless otherwise specifically provided herein this Agreement shall continue in full force and effect
after such time as a final decision in divorce may be entered with respect to the parties. Husband
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and Wife agree that the terms of this Agreement shall be incorporated but not merged into any
divorce decree which may be entered with respect to the parties and therefore Wife and Husband
agree and each of the parties does hereby warrant and represent to the other that should either of
them obtain a decree, judgment or order of separation or divorce in any state, country or
jurisdiction, that party will take all reasonable steps to have this Agreement incorporated as part
of any such decree, judgment or order. The parties further agree that the Court of Common Pleas
which may enter such divorce decree shall retain continuing jurisdiction over the parties and the
subject matter of the Agreement for the purpose of enforcement of any of the provisions thereof.
Nevertheless, it specifically is understood and agreed by and between the parties
hereto and each of the said parties does hereby warrant and represent to the other that should
either of the parties obtain a decree, judgement or order of separation or divorce in any state,
country orjurisdiction, each of the parties agrees that all of the provisions of this Agreement shall
not be affected in any way by any such separation or divorce, it being agreed by the parties that
this Agreement shall continue in full force and effect after such time as a final decree a divorce
may be entered and shall survive and not be merged into any such decree, judgment or order.
5. Effect on Divorce. The parties agree to take all legal steps (including timely and
prompt submission of all documents and the taking of all action including executing the
appropriate waivers of notice of the master's hearing, right to file exceptions, and right to file
appeal) necessary to assure that a divorce pursuant to Section 3301 of the Divorce Code is
entered as soon as possible, but in any event not later than three (3) weeks from the date of
execution of this Agreement. To that end, the parties have executed and agree to promptly file
the affidavits required to obtain a divorce pursuant to § 3301(c) of the Divorce Code.
If, after the execution of this Agreement, either party delays or contests the
obtaining of a final, unappealed divorce decree, that party shall be fully responsible for all
attorney's fees, costs and/or expenses incurred as a result of such delay in obtaining the decree.
6. Effect of No Divorce. This Agreement is predicated upon and made subject to the
attainment of a final decree in divorce under Sections 3301(c) of the Divorce Code and therefor,
except as otherwise provided for herein, this Agreement will be null and void if a final decree in
divorce is not obtained within six (6) months of the date of execution of this Agreement.
Warranty of Disclosure. Husband and Wife represent and warrant that they have
disclosed to each other the full extent of their assets, income and liabilities. Each party has had
ample opportunity to review the financial condition of the other and each party agrees not to
challenge the instant Agreement based on an allegation of lack of sufficient disclosure of assets or
income.
8. Equitable Distribution of Property.
(a) Preniise.v. Husband and Wife hold title as tenants by the entireties the
premises identified as 13 Brian Drive, Carlisle, Cumberland County, Pennsylvania 17013 (the
"Marital Residence"). The parties have agreed to a sale of the Marital Residence with the
proceeds to be distributed as follows together with these additional terms:
(1) The first $15,800.00 shall be paid to David Ling to satisfy a loan
made to the parties by Wife's father during the course of the
marriage.
(2) Any remaining proceeds will be divided equally between the parties
so that Wife shall receive Fifty Percent (50%) and Husband shall
receive Fifty Percent (50%.)
(3) The parties have previously agreed and herein affirm that Husband
shall remain the listing real estate agent of the Marital Residence
until it is sold. As such, the commission received by Husband is his
alone and shall not be considered as part of the proceeds from the
sale of the Marital Residence but shall be considered as an expense
of the sale.
(4) Husband is entitled to sole and exclusive possession of the Marital
Residence until it is sold.
(b) Persona! Properly. The parties agree that the personal property of the
marriage has been previously distributed. Upon execution of this Agreement, the property in
possession of Husband shall be his sole property and Wife forever waives any rights she may have
had to the personal property in possession of Husband. The property in possession of Wife, upon
execution of this Agreement, shall be the sole property of Wife and Husband forever waives any
rights he may have had to the personal property in possession of Wife.
(c) Liahililies. Husband shall assume payment of the mortgage on the Marital
Residence until it is sold and the mortgage is satisfied. Husband shall hold Wife harmless from the
mortgage. Any other liabilities remaining are the responsibility of the party incurring the debt.
Each agrees to hold the other harmless against any such liabilities.
(d) Automobile. The Wife shall receive title to the 1992 Mercury Sable vehicle
which Husband has already surrendered to her and the Husband shall execute the necessary
papers for transfer of the 1992 Mercury Sable to Wife.
(e) 401(k). The parties agree that Husband shall retain his 401(k) from Fry
Communications in its entirety. By this agreement, Wife hereby waives, releases and gives up any
right, title, interest or claim she has or may have had in the above referenced account.
9. Credit. Wife and Husband represent that they have taken all steps necessary to
make sure that no credit cards or similar accounts exist which provide forjoint liability. From the
date of execution of this Agreement, each party shall use only those cards and accounts for which
that party is individually liable.
10. Counsel T-ces. Husband and Wife agree each party shall be responsible for his or
her own legal fees and expenses, except that, in the event of a breach of this Agreement, fees shall
be recoverable by a non-breaching party in an action to enforce the provisions of this agreement.
11. Warranty as to Future Obligations. Wife and Husband each covenants,
represents, warrants, and agrees that, except as may be otherwise specifically provided for by the
terms of this Agreement, neither of them shall hereafter incur any liability whatsoever for which
the other or the estate of the other may be liable, and each now and at all times hereafter shall
indemnify and hold harmless the other party from and against any such liabilities, costs or
expenses, including attorney's fees, relating thereto incurred by the other party after the date of
execution of this Agreement.
12. Warranties as to Existing Obligations. During the course of the marriage,
Husband and Wife have incurred certain liabilities and it is hereby agreed, without the necessity of
ascertaining for what purpose and for whose use each of the bills was incurred, that of those
liabilities that were incurred prior to the date of execution of this Agreement, Wife and Husband
each covenants, represents, warrants and agrees that, except as may be otherwise specifically
provided for by the terms of this Agreement, as of the date of execution of this Agreement, no
unpaid liabilities remain which were incurred by him or her or on his or her behalf for which the
other party may be deemed liable; and, if any such debts or obligations should be determined to
have existed as of the date of execution of this Agreement, the party who incurred that debt shall
indemnify and hold the other party harmless for and against any loss or liability and costs or
expense, including attorney's fees, incurred as a result of those liabilities.
13. Mutual Releases. Except, and only except, for all rights, agreements and
obligations of whatsoever nature arising under or which may arise under this Agreement or for the
breach of any part of this Agreement, Wife and Husband each do hereby mutually remise, release,
quitclaim and forever discharge the other and the estate of the other, for all time to come, and for
all purposes whatsoever, of and from any and all rights, title and interest, or claim in or against the
property (including income, and gain from property hereafter accruing) of the other or against the
estate of the other, of whatever nature and wheresoever situate, which he or she now has or at
any time hereafter may have against the other, the estate of the other or any part thereof, whether
arising (a) out of any former acts, contracts, engagements or liabilities of such other, (b) by way
of dower or courtesy or claims in the nature of dower or courtesy or widow's or widower's rights,
(c) as family exemption or similar allowance, or (d) under the intestate laws, the right to take
against the spouse's will, the right to treat a lifetime conveyance by the other as testamentary, or
all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising
under the laws of (i) Pennsylvania, (ii) any other State, Commonwealth or territory of the United
States, or (iii) any other country. Except, and only except for all rights, agreements and
obligations of whatsoever nature arising under or which may arise under this Agreement or for the
breach of any part of this Agreement, the parties agree that this Agreement shall be and constitute
a full and final resolution of any and all claims which each of the parties may have against the
other for equitable distribution of property, alimony counsel fees and expenses, alimony pendente
lite or any other claim pursuant to the Pennsylvania Divorce Code or the divorce laws of any
other jurisdiction. The parties further release and waive any rights which either party may have
now or hereafter against the other including but not limited to claims for past, present or future
support or maintenance, alimony, alimony pendente lite, property division (including but not
necessarily limited to equitable distribution), counsel fees, costs or expenses, whether arising as a
result of the marital relation or otherwise, whether under the Divorce Code or otherwise. Except,
and only except, for all rights, agreements and obligations of whatsoever nature arising under or
which may arise under this Agreement or for the breach of any pert of this Agreement, it is the
intention of Wife and Husband to give to each other by the execution of this Agreement, and full,
complete and general release with respect to any and all property of any kind or nature, whether
real, personal or mixed, which the other now owns or may hereafter acquire.
14. Mutual Waivers. Except as provided for in this Agreement, Wife and Husband do
hereby waive, release, and give up any rights that they may respectively have, either at the present
or in the future, against the other for equitable distribution, alimony, support, maintenance, or for
any other right resulting from their status as Wife and Husband. Wife and Husband agree that
neither party may apply to any court for a modification of this Agreement, with respect to
alimony, distribution of property, or otherwise, whether pursuant to the Divorce Code or any
other present or future statute or authority. Except as provided for in this Agreement, it shall be
the sole responsibility of Wife and Husband to sustain herself or himself without seeking any
support from the other party from the date of execution of this Agreement. In the event that
either of the parties shall nevertheless seek such a modification, that party shall indemnify and
hold the other party harmless from and against any loss resulting therefore, including counsel fees
and costs.
15. Waiver or Modification to fie in Wi•itiitg. No modification or waiver orally of the
terms hereof shall be valid unless in writing and signed by both parties and no waiver of any
breach hereof or default hereunder shall be deemed a waiver of any subsequent def hilt of the
same or similar nature.
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16. Mutual Cooperation. Each party shall, at any time and from time to time
hereafter, take any and all steps to execute, acknowledge and deliver to the other party any and all
further instruments and/or (within at least fifteen days after demand therefore) documents that the
other party may reasonably require for the purpose of giving full force and effect to the provisions
of this Agreement.
17. Law of Pennsylvania Applicable. This Agreement shall be construed in
accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date
of execution of this Agreement.
18. Integration. This Agreement constitutes the entire understanding of the parties
and supersedes any and all prior agreements and negotiations between them. There are no other
representations, terms, covenants, conditions, agreements or warranties, express or implied, oral
or written of any nature whatsoever, other than those expressly set forth herein.
19. Severability. If any term, condition, clause or provision of this Agreement shall be
determined or declared to be void or invalid in law or otherwise, then only that term, condition,
clause or provision shall be stricken from this Agreement and in all other respects this Agreement
shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to
meet her or his obligations under any one or more of the Paragraphs herein, with the exception of
the satisfaction of the conditions precedent, shall in no way void or alter the remaining obligations
of the parties.
20. Cotmaci Interpretation. For purposes of interpretation and for the purpose of
resolving any ambiguity herein, Husband and Wife agree that this Agreement was prepared jointly
by their respective attorneys.
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21. Waiver of Liability. Husband and Wife each knowingly and understandingly waive
any and all possible claims that this Agreement is, for any reason, illegal or for any reason
whatsoever of public policy, unenforceable in whole or in part. Husband and Wife each does
hereby warrant, covenant and agree that, in any possible event, he or she is and shall forever be
estopped from asserting any illegality or unenforceability as to all or any part of this Agreement.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and
year first above written.
rte-
Brett E. Dellinger
tm?a R. De Ij i der
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COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CuMgl r?a9
On this _Mday of .TA14l/AV-Y , Z Brett E. Dellinger known to me (or
satisfactorily proven) to be the person whose name is subscribed to the within instrument, and
acknowledged that he executed the same for the purposes therein contained.
In witness whereof, I hereunto set my hand and official seal.
4 01Y *
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF CUl?d?9
tary Public
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My Commission Expires:
SS:
On this -5X day of ;JMOACY , ZGbO, Tanya R. Dellinger, known to me
(or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and
acknowledged that she executed the same for the purposes therein contained.
In witness whereof, I hereunto set my hand and official seal.
M4WK< -
otary Public
My Commission Expires: ', ' 4? J(P,miic
My Comm?sai?c,pr.cs Fib. 7.2000
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
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y ..$RETT..E....D !,LI.NGER,__.._.__.__.._....
Plai.n.tiff_ ............. .
Vcixus
...TANYA.R._DELLINGER,
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Defendant
No. .907.3.... ....Civil 19 99
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DECREE IN
DIVORCE
AND NOW,.... r?. G''"^ .... ??? it is ordered and
decreed that ... Brett. .E.. Dellinger ......................... plaintiff,
and ... Tanya. R.. De.liinger ................................. defendant,
are divorced from the bonds of matrimony.
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s The court retains jurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered; e
A .Marr.iage..&ettl.ement.Agreement . was executed by. -the. parties,
on• ,74npary, 5.,..200.0.,..and .is..inQorpora.ted. but. no.t.merged. into, this
Decree Divorce.
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j; Attest. J ii
.,..,._J...... Prothonotary J
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BRETT E. DELLINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 99-4073 Civil
TANYA R. DELLINGER, CIVIL ACTION -LAW
Defendant IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record together with the following information, to the Court for entry of a
divorce decree:
1. Ground for a divorce: irretrievable breakdown under Section 330l(c) of the Divorce
Code.
2. Date and manner of service of the Complaint: 07/8/99 Certified mail. restricted d livery
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by Section 3301(c) of the
Divorce Code: by the Plaintiff 01105100, by the Defendant 01105100.
(b) (1) Date of execution of the plaintiffs affidavit required by Section 3301(d) of
the Divorce Code:
(2) Date of service of the plaintiffs affidavit upon the Defendant:
4. Related claim pending: None.
5. Complete either (a) or (b)
(a) Date and manner of service of the notice of intention to file praecipe to
transmit record, a copy of which is attached, if the decree is to be entered under Section 3301 (d)
of the Divorce Code:
(b) Date Plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary 01/12/00. Date Defendant's Waiver of Notice in Section 3301(c) was filed with the
Prothonotary 0 1112/0 0, n
Mary Kollar Kennedy, Esquire
Date: 1 I 13 16Z) Attorney &o the Plaintiff
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BRETT E. DELLINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 99- ?10?3
TANYA R. DELLINGER, CIVIL ACTION -LAW
Defendant IN DIVORCE
ORDER OF COURT
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AND NOW, this day of , .?\-', 1999, in consideration of the
attached petition, it is hereby directed that the parties and their respective counsel appear before
15g) . the conciliator, at 3q W • K*1 ? 61
YJUC , on the 11) day of Aj(jtL {;
1999, atL? o'clock P.m. for a pre-hearing custody conference. At such conference, an
effort will be made to resolve the issues in dispute; if this cannot be accomplished, to define and
narrow the issues to be heard by the Court and to enter into a temporary order. Failure to appear
at this conference may provide grounds for entry of a temporary or permanent order.
By the Court:
fl M?`?ocu ?1 ,
Custody Conciliator i .,l
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
s9JUL 13 AfI11: IQ
PENNS1'LW VIA
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BRETT E. DELLINGER,
Plaintiff
V.
TANYA R. DELLINGER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 79• 5/073
CIVIL ACTION - LAW
IN DIVORCE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth
in the following pages, you must take prompt action. You are warned that if you fail to do so, the
case may proceed without you and a decree of divorce or annulment may be entered against you by
the Court. A judgment may also be entered against you for any other claim or relief requested in
these papers by the Plaintiff. You may lose money or property or other rights important to you,
including custody or visitation of your children.
When the ground for divorce is indignities or irretrievable breakdown of the marriage, you
may request that the court require you and your spouse to attend marriage counseling prior to a
divorce decree being handed down by the Court. A list of marriage counselors is available in the
Office of the Prothonotary at the Cumberland County Courthouse, Carlisle. You are advised that this
list is kept as a convenience to you and you are not bound to choose a counselor from the list. All
necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
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 WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
BRETT E. DELLINGER,
Plaintiff
V.
TANYA R. DELLINGER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99- V07J &,a -r,.,-
CIVIL ACTION - LAW
IN DIVORCE
AND NOW comes the Plaintiff, BRETT E. DELLINGER, by and through his counsel,
Kollas and Kennedy, and respectfully represents as follows in support of the within Complaint:
1. Plaintiff is Brett E. Dellinger, an adult individual currently residing at 13 Brian Drive,
Carlisle, Pennsylvania, 17013. Plaintiffs Social Security Number is 165-64-9081.
2. Defendant is Tanya R. Dellinger, an adult individual currently residing at 13 Brian
Drive, Carlisle, Pennsylvania, 17013. Defendant's Social Security Number is 204-52-6237.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on December 3, 1994, in Lewisberry,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. Plaintiff has been advised that counseling is available and that Plaintiff may have the
right to request that the Court require the parties to participate in counseling.
7. Plaintiff and Defendant are both citizens of the United States.
COUNT I - DIVORCE PURSUANT TO §3101(c) OR !d1
OF THE DIVORCE CODE
8. Paragraphs I through 7 of this Complaint are incorporated herein by reference as though
set forth in full.
9. The marriage of the parties is irretrievably broken.
C OUNT II
_REQUEST FOR FO ITAB E DIR T 1B UTION
PURSUANT TO SECTIO N 3502 O F TAE . DIV ORCE CODE.
10. Paragraphs 1 through 9 are incorporated herein by reference as though set forth
in full below.
11. The parties are owners of marital property subject to equitable distribution.
12. Plaintiff requests this Honorable Court to equitably divide, distribute or assign marital
property between the parties and to assign the marital debts of the parties without regard to
marital misconduct in such proportions as the Court deems just after consideration of all relevant
factors.
COUNT III - CUSTODY
13. Paragraphs I through 12 of this Complaint are incorporated herein by reference as
though set forth in full.
14. One minor child has been born to the marriage between Plaintiff and Defendant:
(a) A daughter, Morgan Aylissa Dellinger, was born on June 27, 1997.
15. The child is presently in the custody of both Plaintiff and Defendant.
16. In the past five years, Morgan Aylissa Dellinger has resided with the following
persons and at the following addresses:
Brett D. Dellinger and
Tanya R. Dellinger
13 Brian Drive
Carlisle, Pennsylvania 17013
17. Plaintiff is aware of no pending custody proceeding concerning the child in a court of
this Commonwealth.
18. Plaintiff seeks primary physical and shared legal custody with visitation of the child,
Morgan Aylissa Dellinger, to the Defendant.
19. The best interests and permanent welfare of the child will be served by granting the
relief requested because:
(a) Plaintiff has shared the role of primary care giver to the child.
(b) Plaintiff is more likely to facilitate a relationship between the other parent
and the child.
(c) Plaintiff can provide a nurturing, stable, and loving environment for the
child.
20. While no custody agreement has been reached as of the date of the filing of this
Complaint, Plaintiff is willing to negotiate a fair and reasonable agreement of all matters with
Defendant and is hopeful that Defendant may also be willing to enter into a custody agreement.
21. To the extent that a written custody agreement might be entered into between the
parties, Plaintiff desires that such written custody agreement be approved by the Court and
incorporated in any divorce decree which may be entered.
22. Paragraphs 1 through 21 of this Complaint are incorporated herein by reference as
though set forth in full.
23. The public policy of the Commonwealth of Pennsylvania encourages parties to a
marital dispute to negotiate a settlement of their differences.
24. While no settlement has been reached as of the date of the filing of this Complaint,
Plaintiff is willing to negotiate a fair and reasonable settlement of all matters with Defendant and
is hopeful that Defendant may also be willing to enter into a marital settlement agreement.
25. To the extent that a written settlement agreement might be entered into between the
parties, Plaintiff desires that such written agreement be approved by the Court and incorporated in
any divorce decree which may be entered dissolving the marriage between the parties.
WHEREFORE, the Plaintiff prays that Judgment and Decree be entered as follows:
(a) As to Count 1, that a decree be entered divorcing Plaintiff from the bonds
of matrimony with the Defendant pursuant to 23 Pa.C. S. Section 3301 (c)
or (d); and
(b) As to Count II, that an Order be entered equitably distributing property of
the marriage; and
4
(c) As to Count III, if a written custody agreement is reached between the
parties prior to the time of hearing, Plaintiff respectfully requests that this
Honorable Court approve and incorporate any agreement into the decree in
divorce; and
(d) As to Count IV, that any settlement agreement reached between the parties
be incorporated but not merged into the decree in divorce.
RESPECTFULLY SUBMITTED
Mary Koll Kennedy, Esquire U
KOLLASV,ND KENNEDY
I.D. No. 69246
1104 Femwood Avenue, Suite 104
Camp Hill, Pennsylvania 17011
Telephone: (717) 731-1600
ATTORNEY FOR PLAINTIFF
DATE: Q
BRETT E. DELLINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO.
TANYA R. DELLINGER, CIVIL ACTION -LAW
Defendant IN DIVORCE
I, BRETT E. DELLINGER, verify that the statements made in the foregoing
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.A. 4904,
relating to unworn falsification to authorities.
By: `6 ,emu
Brett E. Dellinger
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BRETT E. DELLINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 99-4073 Civil
TANYA R. DELLINGER, CIVIL ACTION -LAW
Defendant IN DIVORCE
AFFIDAVIT OF ONC NT
I . A Complaint in Divorce under §3301(c) or (d) of the Divorce Code was filed on
July 2, 1999, and was served upon the Defendant on or about July 8, 1999. The Acceptance of
Service was filed on July 13, 1999.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing the Complaint.
3. I consent to the entry of a final decree of divorce.
4. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not c.aim them before a divorce is granted.
I verify that the statements made in this affidavit are true and correct. 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: I S-OO-
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Plaintiff
V.
TANYA R. DELLINGER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4073 Civil
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
I . A Complaint in Divorce under §3301(c) or (d) of the Divorce Code was filed on
July 2, 1999, and was served upon the Defendant on or about July 8, 1999. The Acceptance of
Service was filed on July 13, 1999.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing the Complaint.
3. I consent to the entry of a final decree of divorce.
4. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
I verify that the statements made in this affidavit are true and correct. 1 understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn
falsification to authorities.
DATE: DU
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Plaintiff
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TANYA R. DELLINGER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4073 Civil
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO
REQUEST ENTRY OF A DIVORCE DECREE
UNDER §3301(c) OR (d) OF THE DIYORCE CODE
I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. 1 understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn
falsification to authorities.
BRETT E. DELL ER
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Plaintiff
V.
TANYA R. DELLINGER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4073 Civil
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO
REQUEST ENTRY OF A DIVORCE DECREE
UNDER §3301(c) OR (d) OF THE DIYORCE CODE
I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that 1 will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn
falsification to authorities.
TANY R. DE LINGER
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Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-4073 Civil
TANYA R. DELLINGER CIVIL ACTION - LAW
Defendant IN DIVORCE
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1104 Fernwood Avenue
Suite 102
Camp Hill, PA 17011
(717) 731-1600
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BRETT E. DELLINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - DIVORCE
NO.99 -4073 CIVIL TERM
TANYA R. DELLINGER, IN DIVORCE
Defendant/Petitioner DR# 28859
Pacses# 814101351
ORDER OF COURT
AND NOW, this 1 lo' day of August, 1999, upon consideration of the attached Petition for
Alimony Pcndente Lite and/or counsel fees, it is hereby directed that the parties and their respective
counsel appear before R.J. Slraddav on September 14, 1999 at 9:00 A.M. for a conference, at 13 N.
Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for
Alimony Pcndente Lite be entered.
YOU are further ordered to bring to the conference:
(1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed
(2) your pay stubs for the preceding six (6) months
(3) the Income and Expense Statement attached to this order, completed as required by Rule
1910.110
(4) verification of child care expenses
(5) proof of medical coverage which you may have, or may have available to you
IF you fail to appear for the conference or bring the required documents, the Court may issue a
warrant for your arrest.
BY THE COURT,
George E. Hoffer, President Judge
Mail copies on Petitioner
8-11-99 to: < Respondent
Dale Shughart, Esq.
Mary Kennedy, Esq. .,
Date of Order: August 11, 1999
R. J hadda . Conference Officer
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND
REPRESENT YOU. 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 MAY GET
LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVE.
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
r
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required
by law to comply with the Americans with Disabilities Act of
1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business
before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business
before the court. You must attend the scheduled conference or
hearing.
l
BRETT E. DELLLINGER,
Plaintiff
VS.
TANYA R. DELLINGER,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4073 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
ALIMONY PENDENTE LITE
AND NOW, comes the Petitioner, Tanya R. Dellinger, by her
Attorney, Dale F. Shughart, Jr., Esquire and respectfully
represents as follows:
1. Petitioner is Tanya R. Dellinger who is the Defendant in
the above captioned divorce action.
2. Respondent is Brett E. Dellinger, who is the Plaintiff
in the above captioned divorce action.
3. Petitioner hereby raises the claim for alimony pendente
lite (APL) in connection with the Divorce Complaint which was
filed by the Plaintiff on June 30, 1999.
4. Petitioner is currently without sufficient assets to
maintain herself during the pendency of the divorce action.
5. Attached to this Petition is the DRS Statement for APL
Proceedings with appropriate information.
WHEREFORE, Petitioner prays Your Honorable Court to
establish an Order of Alimony Pendente Lite in favor of the
Petitioner and against the Respondent.
Respectfully submitted, n
By:
Dale F. ShugKar ,
Supreme Court .D. 4119373
35 East High Street, Suite 203
Carlisle, PA 17013
(717) 241-4311
Y
Tanya R. Dellinger hereby verifies that the facts set forth
in the foregoing Petition are true and correct to the best of her
knowledge, information and belief, and understands that false
statements herein are made subject to the penalties of 18 Pa.
C.S. §4904 relating to unsworn falsifications.
DATE: July ,% 1 1999
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ADDRESS:-a zzal-2
PHONE:
ATTORNEY:
PCTIT'IONER'S EMPLOYMENT: N/ . Ilan
NET PA ti PCR:_ JOB
OTHER INCOME: (AMOUNT. SOU
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ATT'ORNEiY:
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NE'I'PAY: PER: JOBTITLC:?
OTHER INCOME (AMOUNT. SOURCE): v
WHEN MARRIED: :WHERE: fGLCJJS PirU
DATE SEPARATED:— A72
WIIERE LAST LIVED
FOR DRS INFORMATION ONLY
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
TONYA R. DELLINGER ) Docket Number 99-4073 CIVIL
Plaintiff )
VS. ) PACSESCaseNumber 524301351/:?qT `f
BRETT E. DELLINGER )
Defendant ) Other State ID Number
Order
AND NOW to Wit, this SEPTEMBER 14, 1999 it is hereby Ordered
that:
THE ABOVE CAPTIONED COMPLAINT FOR ALIMONY PENDENTE LITE IS DISMISSED, WITHOUT
PREJUDICE, PURSUANT TO AN ORDER OF SPOUSAL SUPPORT DOCKETED AT
625 SUPPORT 1999 UNDER PACSES C#803101321.
blv.
DRO: RJ Shadday
xc: petltLoner
respondent
D. Shughart, Esq.
M. Kennedy, Esq.
Service Type M
Nab:e. troS.? h? Oco q/17r99
BY THE COURT:
Edward E. GuLdo JUDGE
Form OE-001
Worker ID 21005
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BRETT E. DELLINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 99-4073 Civil
TANYA R. DELLINGER, CIVIL ACTION - LAW
Defendant IN DIVORCE
ORDER OF COURT
AND NOW, this Q9 day of jkr?(_ , 1999, in consideration of the
attached petition, it is hereby directed that the parties and their respective counsel appear before
bowtl 5 the conciliator, at 39 Q, Mnu-i
f'UChn\C 5b M on the ?QL day of f?l
6 , at o'clock Q .m. for a pre-hearing custody conference. At such
conference, an effort will be made to resolve the issues in dispute; if this cannot be accomplished,
to define and narrow the issues to be heard by the Court and to enter into a temporary order.
Failure to appear at this conference may provide grounds for entry of a temporary or permanent
order.
By the Court:
r1a
Custody Conciliator ° C l
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17011
717-249-1)[66
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BRETT E. DELLINGER,
Plaintiff
V.
TANYA R. DELLINGER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
NO. 99-4073 Civil
CIVIL ACTION - LAW
IN DIVORCE
PETITION FOR MODIFICATION OF A CUSTODY OR
VISITATION ORDER AND FOR FINDING OF CIVIL CONTEMPT
The Petitioner, Brett E. Dellinger, through his attorneys, Kollas and Kennedy, files this
Petition for Modification of a Custody or Visitation Order and for Finding of Civil Contempt for
disobedience of a custody order, against the Respondent, Tanya R. Dellinger, and in support thereof,
avers the following:
The petition of Brett E. Dellinger, respectfully represents that on August 20, 1999,
an Order of Court was entered for Custody, a true and correct copy of which is attached.
2. The Respondent has wilfully failed to abide by the Order in that:
a. The Respondent has failed to submit to a custody evaluation to be performed
by Guidance Associates as agreed by the parties. Guidance Associates has
scheduled three separate appointments with Respondent. Each and every time
Respondent has tailed to appear at Guidance Associates.
b. Respondent has failed to demonstrate appropriate care for the minor child in
that Respondent was seen riding in an automobile with the minor child riding
unrestrained in the front seat of the car. This event occurred on or about
November 15, 1999.
3. This Order should be modified because:
a. The conduct of Respondent as outlined in Paragraph 2(b) above has directly
and adversely impacted the best interests of the minor child. Respondents
failure to appropriately restrain her daughter has placed the minor child in
serious, imminent danger.
b. The relationship between the parties continues to be strained, and Petitioner
requests a more specific custody schedule to address the upcoming holiday
season.
WHEREFORE, Petitioner requests that the Court (1) adjudge the Respondent, Tanya R.
Dellinger, to be in contempt of this Court and (2) to enter an Order directing respondent to submit
to a full custody evaluation with Guidance Associates within a specified period of time, and (3)
modify the existing Order for Custody to address the safety of the minor child as the Court deems
appropriate.
Date: II `6
RESPECTFULLY SUBMITTED,
Mary Koll s Kennedy, Esquire
KOLLAS D KENNEDY
I.D. No. 69246
1 104 Fernwood Avenue, Suite 104
Camp Hill, Pennsylvania 17011
Telephone: (717) 731-1600
ATTORNEY FOR PLAINTIFF
1)
BRETT E. DELLINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 99-4073 Civil
TANYA R. DELLINGER, CIVIL ACTION -LAW
Defendant IN DIVORCE
VERIFICATION
1, BRETT E. DELLINGER, verify that the statements made in the foregoing PETITION
FOR MODIFICATION OF A CUSTODY OR VISITATION ORDER AND FOR FINDING
OF CIVIL CONTEMPT 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.A. 4904,
relating to unsworn falsification to authorities.
By:
Brett E. Dellinger
DATE:
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BRETT E. DELLINGER IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
TANYA R. DELLINGER : NO. 99-4073 CIVIL TERM
CIVIL ACTION - LAW
AND NOW, this ZQ2 day of DECEMBER, 1999, a Rule is issued upon the
Defendant to Show Cause, if any she has, why her attorney should not be granted leave to
withdraw his appearance of record on her behalf.
Rule returnable on Monday, January 3, 2000.
Tanya R. Dellinger, Defendant
Mary Kollas Kennedy, Esquire
Attorney for Plaintiff, Brett E. Dellinger
Dawn S. Sunday, Esquire, Conciliator
:sld
By the urt,
Edward E. Guido, J. ,
12%.W-99
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DEC 17 1999
BRETT E. DELLINGER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99-4073 CIVIL
TANYA R. DELLINGER, CIVIL ACTION - LAW
Defendant IN DIVORCE
ORDER OF COURT
ON THIS, day of , 1999, upon
review of the attached Motion, Dale F. Shughart, Jr., Esquire is
hereby granted Leave of Court to Withdraw as Attorney of Record
for the Defendant, Tanya R. Dellinger.
By the Court,
CC:
Tanya R. Dellinger, Defendant
Mary Kollas Kennedy, Esquire,
Attorney for Plaintiff, Brett E. Dellinger
Dawn S. Sunday, Esquire, Conciliator
.!
BRETT E. DELLINGER,
Plaintiff
VS.
TANYA R. DELLINGER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4073 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
MOTION FOR LEAVE OF COURT OF WITHDRAW
PURSUANT TO PA.R.C.P. 1012(b)
TO THE HONORABLE, THE JUDGES OF SAID COURT:
AND NOW, comes Dale F. Shughart, Jr., Esquire, attorney of
record for Tanya R. Dellinger and requests Leave of Court to
Withdraw as attorney for defendant, Tanya R. Dellinger, as
follows:
1. The undersigned, Dale F. Shughart, Jr., Esquire agreed
to represent the defendant Tanya R. Dellinger in the above
captioned divorce action and entered his appearance on July 29,
1999.
2. The undersigned represented the defendant at a custody
conciliation conference held before Don S. Sunday, Esquire on
August 10, 1999 and at a support conference before R.J. Shadday,
Conference Officer, on August 14, 1999.
3. The undersigned entered a Fee Agreement with the
defendant obligating her to pay certain attorney fees on a
certain schedule. The defendant has failed to make any payment
of legal fees other than a $10 cash payment which was forwarded
to the Cumberland County Bar Association.
4. The defendant has had no contact whatsoever with the
undersigned since the support conference on September 14, 1999.
5. The undersigned wrote to the defendant on October 1,
1999, November 4, 1999 and November 17, 1999 requesting the
defendant to contact him to proceed with the case and in regard
to fulfilling her obligations under the Custody order entered by
Agreement with the plaintiff.
6. Many of the foregoing correspondences were also requests
for information or response to inquiries from counsel from the
plaintiff. Defendant never responded.
7. On December 8, 1999 the undersigned received an order of
Court scheduling a further conciliation before Dawn S. Sunday,
Esquire on January 18, 2000. The undersigned immediately sent a
copy to the defendant together with a Consent to his Withdrawal
as her attorney. The undersigned has received no response to his
letter of December 8 either.
8. The undersigned cannot effectively represent a client
who refuses to communicate with him.
9. The undersigned withdrawing as attorney for defendant
will not delay the litigation.
WHEREFORE, for all ui the foregoing reasons, the undersigned
requests Leave of Court to withdraw as counsel for defendant,
Tanya R. Delllinger.
Respectfully submitted,
Eye,'
Dale F. ughart, J .
Attorney I.D. 19373
35 East High Street, Suite 203
Carlisle, PA 17013
(717) 241-4311
VERIFICATION
Dale F. Shughart, Jr. hereby verifies that the facts set
forth in the foregoing Motion are true and correct to the best of
his knowledge, information and belief, and understands that false
statements herein are made subject to the penalties of 18 Pa.
C.S. §4904 relating to unsworn falsifications.
DATE: December ) ? , 1999
I
JAN ° 7 20001
BRETT E. DELLLINGER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99-4073 CIVIL
TANYA R. DELLINGER, CIVIL ACTION - LAW
Defendant IN DIVORCE
ORDER OF COURT
On this, the / day of // 2000, upon
review of the attached Petition for Rule Absolute, Dale F.
Shughart, Jr., Esquire is hereby granted leave of Court to
withdraw as attorney of record for the Defendant, Tanya R.
Dellinger.
CC:
By the Cou
J.
Tanya R. Dellinger
Mary Kollas Kennedy, Esquire, attorney for Plaintiff,
Brett E. Dellinger
Dawn S. Sunday, Esquire, Conciliator
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BRETT E. DELLLINGER,
Plaintiff
VS.
TANYA R. DELLINGER,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4073 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
PETITION FOR RULE ABSOLUTE
AND NOW, comes the Petitioner, Dale F. Shughart, Jr.,
Esquire and respectfully represents as follows:
1. On December 17, 1999, Your Petitioner filed a Motion for
Leave to Withdraw as Counsel for the Defendant, Tanya R.
Dellinger.
2. On December 20, 1999, Honorable Edward E. Guido issued a
Rule to Show Cause upon the Defendant with the Rule returnable on
January 3, 2000.
3. On December 20, 1999, the Prothonotary mailed the Motion
and Order of Court entered by Judge Guido to the undersigned
Petitioner, the Defendant, Tanya R. Dellinger, the Plaintiff's
attorney, Mary Kollas Kennedy, and the Custody Conciliator,
Dawn S. Sunday, Esquire. Confirmation of the mailing of the
Order and Motion by RKS (Renee Simpson) of the Prothonotary's
office is attached hereto, made a part hereof, and marked
Exhibit "A"
4. The Defendant, Tanya R. Dellinger, has not responded to
the Rule.
WHEREFORE, the undersigned, Dale F. Shughart, Jr.,
respectfully prays Your Honorable Court to grant him leave to
withdraw as counsel for the Defendant Tanya R. Dellinger.
Respectfully submitted,
By: ? K GRII
Dale F. S ughart, J
Supreme Court I.D. 19373
35 East High Street, Suite 203
Carlisle, PA 17013
(717) 241-4311
VERIFICATION
Dale F. Shughart,
forth in the foregoing
correct to the best of
understands that false
penalties of 18 Pa. C.:
falsifications.
Jr. hereby verifies that the facts set
Petition for Rule Absolute are true and
his knowledge, information and belief, and
statements herein are made subject to the
i. §4904 relating to unsworn
2/ ZI
DATE: January 7 , 2000
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BRETT E. DELLINGER : IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
TANYA R. DELLINGER NO. 99-4073 CIVIL TERM
CIVIL ACTION -LAW
AND NOW, this 2E day of DECEMBER, 1999, a Rule is issued upon the
Defendant to Show Cause, if any she has, why her attorney should not be granted leave to
withdraw his appearance of record on her behalf.
Rule returnable on Monday, January 3, 2000.
Tanya R. Dellinger, Defendant
Mary Kollas Kennedy, Esquire
Attorney for Plaintiff, Brett E. Dellinger
Dawn S. Sunday, Esquire, Conciliator
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BRETT E. DELLINGER,
Plaintiff
Vs.
TANYA R. DELLINGER,
Defendant
Dear Sir:
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4073 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
WITHDRAWAL
Pursuant to Leave of Court granted in the above captioned
matter, I hereby withdraw as counsel for the Defendant, Tanya R.
Dellinger.
TO: Curtis Long, Prothonotary
January 7 , 2000
Attorney I.D. 19 3
35 East High Street, Suite 203
Carlisle, PA 17013
(717) 241-4311
CC:
Tanya R. Dellinger, Defendant
Mary Kollas Kennedy, Esquire,
Attorney for Plaintiff, Brett E. Dellinger
Dawn S. Sunday, Esquire, Conciliator
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BRETT E. DELLINGER IN TIIE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
TANYA R. DELLINGER 1999-4073 CIVIL ACTION LAW
DEFENDANT IN CUSTODY
ORDER OF
AND NOW, this 22nd day of June , 2000, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. _,the conciliator,
at 39 West Main Street, Mechanicsburg PA 17055 on the 30th day of August , 2000, at1:00 PM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
FOR THE COURT,
By: /s/ Dawn S. Sunday. Esq. bp
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
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BRETT E. DELLINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 99-4073 Civil
TANYA R. DELLINGER CIVIL ACTION - LAW
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this day of
2000, in consideration of the
attached petition, it is hereby directed that the parties and their respective counsel appear before
the conciliator, at
,on the
day of
2000, at o'clock --m- for a pre-hearing custody conference. At such conference, an
effort will be made to resolve the issues in dispute; if this cannot be accomplished, to define and
narrow the issues to be heard by the Court and to enter into a temporary order. Failure to appear
at this conference may provide grounds for entry of a temporary or permanent order.
By the Court:
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, PA 17013
717-249-3166
BRETT E. DELLINGER,
Plaintiff/Petitioner
V.
TANYA R. DELLINGER,
Defendant/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 994073 Civil
CIVIL ACTION - LAW
IN CUSTODY
PETITION OF PLAINTIFF FOR ADJUDICATION OF
CONTEMPT AND MODIFICATION OF CUSTODY ORDER
Petitioner is Brett E. Dellinger, who resides at 32 Longstreet Drive, Carlisle, PA.
2. Respondent is Tanya R. Dellinger, who currently resides as an inmate at the
Cumberland County Prison.
3. On January 26, 2000, this Honorable Court entered an order for the custody of the
minor child of the parties.
4. Since the entry of said Order, there has been a significant change in circumstances
in that:
a. Respondent has failed to exercise more than half the periods of custody
awarded to her.
b. Over the weekend of May 6, Respondent took the minor child to
Allentown to visit the maternal grandparents and failed to return the child
pursuant to the Court Order. The child was returned to the custody of the
Petitioner on the evening of May 8, 2000.
C. On or about May 15, 2000, Respondent informed Petitioner that she had
moved from her residence at 204 Erford Road, Camp Hill, PA.
Respondent refused to give Petitioner her new address and telephone
number. Said refusal is a direct violation of 23 Pa C.S. § 5309 (a).
5. The conduct of Defendant in each circumstance above violated the Custody Order
of January 26, 2000, or violated some law of the Commonwealth. As a result,
Defendant is in contempt of the Court Order of January 26, 2000.
6. The best interest of the minor child will be served by granting the relief requested
herein.
WHEREFORE, Plaintiff Brett E. Dellinger respectfully requests this Court order the
following relief.
a. Find the Defendant in contempt of the Order of January 26, 2000, and
impose such appropriate penalties on the Defendant as the Court deems
appropriate,
b. Plaintiff prays for a modification of the Custody Order to impose an
express requirement that the Defendant provide Plaintiff with the proper
address and telephone number for the Defendant at all times when she has
custody of the minor child;
2 of 3
C. Plaintiff prays for a modification of the Custody Order eliminating
Defendant's midweek periods of partial custody.
RESPECTFULLY SUBMITTED,
MaryKol s ennedy, Esquire
KOLLAS\AND KENNEDY
I.D. No. 69246
1104 Fernwood Avenue, Suite 104
Camp Hill, Pennsylvania 17011
Telephone: (717) 731-1600
ATTORNEY FOR PLAINTIFF/PETITIONER
DATE: G 19 00
3 of 3
BRETT E. DELLINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-4073 Civil
TANYA R. DELLINGER, CIVIL ACTION -LAW
Defendant IN DIVORCE
VERIFICATION
1, BRETT E. DELLINGER, verify that the statements made in the foregoing PETITION
OF PLAINTIFF FOR ADJUDICATION OF CONTEMPT AND MODIFICATION OF
CUSTODY ORDER 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.A. 4904,
relating to unsworn falsification to authorities.
By: 7/ 2 _
Brett E. Dellinger
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BRETT E. DELLINGER,
Plaintiff/Petitioner
V.
TANYA R. DELLINGER,
Defendant/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4073 Civil
CIVIL ACTION - LAW
IN CUSTODY
CERTIFICATE OF SERVICE
I, Carole A. Rose, of the Law Offices of Kollas and Kennedy, hereby certify that I
have this 23rd day of June, 2000, served a true and correct copy of PETITION OF PLAINTIFF
FOR ADJUDICATION OF CONTEMPT AND MODIFICATION OF CUSTODY ORDER
and an ORDER OF COURT signed on June 22, 2000, by depositing same in the United States
mail, first class, postage prepaid, addressed to the following:
Ms. Tanya R. Dellinger
Cumberland County Prison
1101 Claremont Road
Carlisle, PA 17013
Defendant
LAW OFFICES OF KOLLAS AND KENNEDY
BY:Ookj/lX a- &/
Carole A. Rose
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BRETT E. DELLINGER, . IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99-4073 CIVIL TERM
TANYA R. DELLINGER, CIVIL ACTION - LAW
Defendant IN CUSTODY
ORDER OF ODUR'P
AND NOW, this a(r day of 2000, upon
consideration of the attached Custody C iciliation Report, it is ordered
and directed as follows:
1. The prior order of this Court dated August 20, 1999 is vacated and
replaced with this order.
2. The Father, Brett E. Dellinger, and the Mother, Tanya R.
Dellinger, shall have shared legal custody of Morgan Aylissa Dellinger,
born June 27, 1997. 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.
3. The parties shall have physical custody of the Child in accordance
with the following schedule:
A. The Mother shall have custody of the Child on alternating
weekends from Friday at 4:30 p.m. through Sunday at 4:30 p.m.,
beginning January 28, 2000. The mother shall also have
custody of the Child on the interim Sundays from 12:00 noon
through 4:30 p.m. The Mother shall have custody of the Child
every week on Mondays and Wednesdays from 4:30 p.m. until 8:00
p.m. In the event the Father has to work on a Monday or
Wednesday evening and is not available to provide care for the
Child overnight, the Father shall first contact the Mother to
offer her the opportunity to have custody of the Child
overnight before contacting third party caregivers. When the
Mother has custody of the Child overnight on a weekday, the
Mother shall transport the Child to day care the following
morning by 8:00 a.m. The parties shall cooperate in adjusting
the weekday custody schedule if the Mother begins taking
classes which conflict with her custody time to ensure that
the Mother has custody of the Child on 2 weekday evenings per
week.
B. The Father shall have custody of the Child at all times not
otherwise specified for the Mother under this provision.
C. In the event the Child is sick and unable to go to day care,
it shall be the Mother's responsibility to provide the care or
make alternative care arrangements for the Child on Mondays
and Wednesdays and it shall be the Father's responsibility to
provide the care or make alternate arrangements for the
Child's care on Tuesdays, Thursdays and Fridays. Recognizing
that the Father has a more flexible work schedule than the
Mother, the Father agrees to make a reasonable effort to
provide the care for the Child when she is sick on Mondays and
Wednesdays.
4. The parties shall alternate having custody of the Child on
holidays as follows:
A. CHRISTMAS: The Christmas holiday shall be divided into
Segment A, which shall run from Christmas Eve at 12:00 noon
through Christmas Day at 12:00 noon, and Segment B, which
shall run from Christmas Day at 12:00 noon through December
26 at 12:00 noon. The Father shall have custody of the Child
during Segment A in even numbered years and during Segment B
in odd numbered years. The Mother shall have custody of the
Child during Segment A in odd numbered years and during
Segment B in even numbered years.
B. THANKSGIVING: The Thanksgiving holiday shall run from the
Wednesday before Thanksgiving at 4:30 p.m. through
Thanksgiving Day at 8:00 p.m. The Mother shall have custody
of the Child on Thanksgiving in even numbered years and the
Father shall have custody of the Child on Thanksgiving in odd
numbered years.
C. FASTER: The Easter holiday shall run from the Saturday before
Easter at 4:30 p.m. through Easter Sunday at 8:00 p.m. The
Father shall have custody of the Child over Easter in even
numbered years and the Mother shall have custody of the Child
over Easter in odd numbered years.
D. MEMORIAL DAY/JULY 4TH/LABOR DAY: The parties shall share
having custody rf the Child on Memorial Day, July 4th and
Labor Day as arranged by agreement between the parties.
E. MOTHER'S DAY/FATHER'S DAY: The Mother shall have custody of
the Child every year on Mother's Day from 10:00 a.m. until
8:00 p.m. and the Father shall have custody of the Child every
year on Father's Day from 10:00 a.m. until 8:00 p.m..
F. The holiday custody schedule shall supersede and take
precedence over the regular custody schedule.
5. Each party shall be entitled to have custody of the-Child for 2
non-consecutive weeks during each summer upon providing 30 days advance
notice to the other party. Each party shall schedule his or her vacation
periods of custody under this provision to include his or her own regular
weekend periods of custody.
6. 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.
cc: Mary Kollas Kennedy, Esquire -
Tanya R. Dellinger, Pro Se
BY THE COURT,
Edward E. Guido) J.
Counsel for Father
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BRETT E. DELLINGER,
Plaintiff
VS.
TANYA R. DELLINGER,
Defendant
PRIM JUDGE: Edward E. Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-9073 CIVIL TERM
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 information concerning the Child who is the subject
of this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Morgan Aylissa Dellinger June 27, 1997 Father/Mother
2. A Conciliation Conference was held on January 18, 2000, with the
following individuals in attendance: The Father, Brett E. Dellinger, with
his counsel, Mary Kollas Kennedy, Esquire, and the Mother, Tanya R.
Dellinger, who is not represented by counsel in this matter.
3. The parties agreed to entry of an Order in the form as attached.
a r
Date Dawn S. Sunday, Esqui
Custody Conciliator
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BRETT E. DELLINGER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : NO. 99-4073 CIVIL TERM
TANYA R. DELLINGER, : CIVIL ACTION - LAW
Defendant CUSTODY
PER OF CGURT
AND NOW, this 90AA day of 1999, upon
consideration of the attached Custody Conciliation Report, it is ordered
and directed as follows:
1. The parties shall submit themselves, their minor child and
any other individuals deemed necessary by the evaluator to a custody
evaluation to be performed by Guidance Associates or other professionals
selected by agreement of the parties and counsel. The purpose of the
evaluation shall be to obtain independent professional recommendations
concerning custody arrangements which will best serve the Child's
interests. The parties shall equally share all costs of the evaluation.
2. The parties shall have shared legal custody of Morgan Aylissa
Dellinger, born June 27, 1997. 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.
3. Pending the outcome of the evaluation and further Order of
Court or agreement of the parties, the parties shall share having physical
custody of the Child in accordance with the following schedule: The Father
shall have custody of the Child overnight on Tuesdays and Thursdays every
week and the Mother shall have custody of the Child overnight on Mondays
and Wednesdays every week. The parties shall alternate having custody of
the Child on Friday and Saturday. The Mother shall have custody every
Sunday during the day and the Father shall have custody every Sunday
overnight. The specific times for exchanges of custody under this schedule
shall be arranged by agreement between the parties.
4. Upon completion of the evaluation and in the event the
parties are not at that time able to resolve all custody issues by
agreement, counsel for either party may contact the Conciliator to schedule
an additional Custody Conciliation conference.
5. 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
J.
cc: Mary Kollas Kennedy, Esquire and James Kollas, Esquire - Counsel for
Dale F. Shughart, Jr., Esquire - Counsel for Mother Father
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Cur.:ad?u•;u Cuu\RY
PENNSYLMMI A
BRETT E. DELLINGER,
Plaintiff
Vs.
TANYA R. DELLINGER,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-9073 CIVIL TERM
CIVIL ACTION - LAW
CUSTODY
CUSTODY CONCILIATICN s[mW REPCRT
IN ACOORDANCE WITH CE14BERLAND 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
Morgan Aylissa Dellinger June 27, 1997 Father/Mother
2. A Conciliation Conference was held on August 10, 1999, with the
following individuals in attendance: The Father, Brett E. Dellinger, with
his counsel, Mary Kollas Kennedy, Esquire and James Kollas, Esquire, and
the Mother, Tanya R. Dellinger, with her counsel, Dale F. Shughart, Jr.,
Esquire.
3. The parties agreed to entry of an order in the form as attached.
Date Dawn S. Sunday, Esquire
Custody Conciliator
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BRETT E. DELLINGER,
Plaintiff
vs.
TANYA R. DELLINGER,
Defendant
ORDER OF COURT
AMID NOW, this ? day of C CO u e R , 2000, upon
consideration of the attached Custody Conciliation Report, it is ordered
and directed as follows:
1. The prior Order of this Court dated January 26, 2000 is suspended
and replaced with this Order pending further Order of Court or agreement of
the parties.
2. The Father, Brett E. .Dellinger, and the Mother, Tanya R.
Dellinger, shall have shared legal custody of Morgan Aylissa Dellinger,
born June 27, 1997. 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.
3. The Father shall have primary physical custody of the Child.
4. The Father shall cooperate in scheduling periods of supervised
visitation with the Mother if appropriate during the Mother's period of
treatment.
5. 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.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4073 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
BY THE HURT,
/5/ C?i J e. llr/lii?
Edward E. Guido, J.
cc: Mary Kollas Kennedy, Esquire - Counsel for Father
Steven J. Fishman, Esquire - Counsel for Mother
TRUE COPY FROM RECORD
In Testimony whereof, I here unto set my hand
and t seal of sai Court at Carljsle, Pa.
Thi ............ a f.Q.? ?...,
rothonet ry
I
Richard J. Pierce
COURT ADMINISTRATOR
ONE COURTHOUSE SQUARE
CARLISLE, PA 17013
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7i58334 U.S. POSTAGE
teven J. Fishman, Esquire
F1514017 170132020 IN 13 10/11/00
RETURN TO SENDER
NO FORWARD ORDER ON FILE
I INAEII.E TO FORWARD
RETURN TO SENDER
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BRETT E. DELLINGER,
Plaintiff
VS.
TANYA R. DELLINGER,
Defendant
PRIOR JUDGE: Edward E. Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4073 CIVIL TERM
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 information concerning the Child who is the subject
of this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Morgan Aylissa Dellinger June 27, 1997 Father
2. A Conciliation Conference was held on September 27, 2000, with the
following individuals in attendance: The Father, Brett E. Dellinger, with
his counsel, Mary Kollas Kennedy, Esquire, and the mother's counsel, Steven
J. Fishman, Esquire. The Mother, Tanya R. Dellinger, who is currently
incarcerated in the Cumberland County Prison, consulted with her counsel
during the Conference by telephone.
3. The parties agreed to entry of an Order in the form as attached.
Dawn S. Sunday, Esquir
Custody Conciliator
Date
BRETT E. DELLINGER
Plaintiff
V.
TANYA R. DELLINGER
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.99-4073
CIVIL ACTION - CUSTODY
PRAECIPE FOR WITHDRAWAL OF APPEARANCE
TO THE PROTHONOTARY OF SAID COURT:
Please withdrawal the appearance of Mary Kollas Kennedy, Esquire on behalf of
the Plaintiff in the above-captioned case.
Please enter the appearance of Lisa M. Greason, Esquire, on behalf of the
Plaintiff in the above-captioned case.
"Z- L vl
Date
Respectfully Submitted,
GREASON LAW OFFICE
,Lisa M. reason, Esquire
155 S. Hanover Street
Carlisle, PA 17013
(717) 241-3030
ID #78269
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BRETT E. DELLINGER IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
99-4073 CIVIL ACTION LAW
TANYA R. DELLINGER
DEFENDANT IN CUSTODY
ORDER OF COURT
AND NOW, Monday, October 01, 2001 , 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 Thursday, October 25, 2001 at 12:30 PM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/ Dawn S. Sunday Esq. 1
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the
scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR A'1-FORNEY 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
i
BRETT E. DELLINGER,
Plaintiff
VS.
TANYA R. DELLINGER,
Defendant
ORDER OF COURT
COURT ADMINISTRATOR, FOURTH FLOOR
CUMBERLAND COUNTY COURTHOUSE
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
TELEPHONE: (717) 240-6200
FOR THE COURT,
AND NOW, this
day of
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-4073 CIVIL TERM
IN DIVORCE
2001, upon consideration
of the Complaint filed in this matter, it is hereby directed that the parties and their
respective counsel appear before , the Conciliator,
at
the day of
Pennsylvania, on
2001, at o'clock .m. for
a Pre-Hearing Custody Conference. At such Conference, an effort will be made to resolve
the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to
be heard by the Court, and to enter a temporary Order. All children aged 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.
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.
BY
CUSTODY CONCILIATOR
BRETT E. DELLINGER, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
1
VS. ) CIVIL ACTION - LAW
TANYA R. DELLINGER, 1 NO. 99-4073 CIVIL TERM
Defendant ? IN CUSTODY
PETITION TO MODIFY
AND NOW comes the above-named Defendant, Tanya R. Dellinger, by her attorney,
Samuel L. Andes, and petitions the Court to modify its custody order of 3 October 2000,
based upon the following:
1. The Petitioner herein is the Defendant, Tanya R. Dellinger, an adult individual who
resides at 23 Irene Street, Johnstown, Pennsylvania, 15901. The Respondent is the
Plaintiff, Brett E. Dellinger, an adult individual who resides at 32 Long Street, Carlisle,
Cumberland County, Pennsylvania, 17013.
2. The Plaintiff and Defendant are formerly husband and wife and are the parents
of one child, Morgan Alyssa Dellinger, born 26 June 1997. That child is the subject of
several orders previously entered in this matter. A copy of the most recent of those orders,
dated 3 October 2000, is attached hereto and marked as Exhibit A.
3. Defendant wishes to modify the prior order for the following reasons:
i
A. The conditions that existed at the time of the prior order which
prevented her from having primary physical custody, shared physical custody,
or substantial periods of temporary physical custody no longer exist.
B. The conditions that resulted in Defendant agreeing to have
supervised visitation with the child no longer exist.
C. Defendant has recovered from the drug dependence and other
problems which complicated her life at the time of the last order and
prevented her from having more normal and meaningful time with her child.
As a result of the above, Plaintiff wishes to have more reasonable and generous periods of
temporary custody of the child, without supervision.
4. Defendant believes that the expansion of her time with the child, without
supervision by third parties, will be beneficial to all parties and will serve the best interests
of the cF.ild.
WHEREFORE, Defendant prays this Court to modify its order of 3 October 2000 to
give her more substantial periods of custody with the parties' child, without supervision.
C -Q??
SSam-trel L. Andes
Attorney for Defendant
Supreme Court ID 17225
525 North 12th Street
Lemoyne, PA 17043
(717) 761-5361
I verify that the statements made in this document are true and correct. I understand
that any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904
(unsworn falsification to authorities).
DATE: (1J C?
U
TANYA . DELLINGER
3
BRETT E. DELLINGER, . IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99-4073 CIVIL TERM
TANYA R. DELLINGER, CIVIL ACTION - LAW
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this day of 0 &"' ' ' , 2000r upon
consideration of the attached Custody Conciliation Report, it is ordered
and directed as follows:
1. The prior Order of this Court dated January 26, 2000 is suspended
and replaced with this Order pending further order of Court or agreement of
the parties.
2. The Father, Brett E. Dellinger, and the Mother, Tanya R.
Dellinger, shall have shared legal custody of Morgan Aylissa Dellinger,
born June 27, 1997. Each parent shall have an equal right, to be exercised
jointly with the other parentr 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.
3. The Father shall have primary physical custody of the Child.
4. The Father shall cooperate in scheduling periods of supervised
visitation with the Mother if appropriate during the Mother's period of
treatment.
5. 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
cc: Mary Kollas Kennedy, Esquire - Counsel for Father
\v
Steven J. Fishman, Esquire - Counsel for Mother
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BRETT E. DELLINGER,
Plaintiff
vs.
TANYA R. DELLINGER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-4073
CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this Iq ^ day of /1 , 2001,
upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The prior Order of this Court dated October 3, 2000 is vacated and replaced with this Order.
2. The Father, Brett E. Dellinger, and the Mother, Tanya R. Dellinger shall have shared legal
custody of Morgan Alyssa Dellinger, born June 27, 1997. 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. Both parties shall have equal access to all records pertaining to the Child, including
medical and school records.
3. The Father shall have primary physical custody of the Child.
4. The Mother shall have partial physical custody of the Child, using her grandparents' home
in the Mechanicsburg area as her residence during periods of custody, on a gradually increasing basis
in accordance with the following schedule:
A. The Mother shall have custody of the Child from 9:00 a.m. until 4:00 p.m. on Thursday,
November 15, 2001, Friday, November 23, 2001, Thursday, November 29, 2001 and
Thursday, December 6, 2001. The Mother shall transport the Child to and from the paternal
grandparents' home for periods of custody under this provision.
B. The Mother shall have overnight periods of custody with the Child from Thursday,
December 13, 2001 at 9:00 a.m. through Friday, December 14 at 8:45 a.m., when the
Mother shall transport the Child to preschool and from Thursday, December 27, 2001 at
9:00 a.m. through Friday, December 28 at 11:00 a.m., when the Mother shall transport the
Child to the Father's residence. The mother shall pick up the Child at the paternal
grandparents' residence.
C. The Mother shall have periods of custody with the Child on alternating weekends,
beginning January 11, 2002, from Friday at 4:00 p.m., when the Mother shall pick up the
Child at the paternal grandparents' home through Sunday at 5:00 p.m., when the Mother
shall transport the Child to the Father's residence.
5. The parties and counsel shall attend an additional Custody Conciliation Conference in the
office of the Conciliator, Dawn S. Sunday, at 9:00 a.m., on the 3rd day of January. 2002, for the
purpose of reviewing the Child's adjustment to the partial custody schedule, making necessary
adjustments and establishing ongoing regular, holiday and summer custody arrangements as
appropriate.
b. Neither parent 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.
7. 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
Edward E. Guido,
cc: Lisa M. Greason, Esquire - Counsel for Father
Samuel L. Andes, Esquire - Counsel for Mother
J.
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C'Jivil.' n ;a•i? COUNITY
PLNNSYLMA
BRETT E. DELLINGER,
Plaintiff
VS.
TANYA R. DELLINGER,
Defendant
PRIOR JUDGE: Edward E. Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-4073 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 information concerning the Child who is the subject of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Morgan Alyssa Dellinger June 27, 1997 Father
2. A Conciliation Conference was held on November 6, 2001, with the following individuals in
attendance: The Father, Brett E. Dellinger, with his counsel, Lisa M. Greason, Esquire, and the
Mother, Tanya R. Dellinger, with her counsel, Samuel L. Andes, Esquire.
3. The parties agreed to entry of an Order in the form as attached. 4 )rlb,?' rm bea 7 .2 coo/
Date Dawn S. Sunday, Esquire
Custody Conciliator
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BRETT E. DELLINGER,
Plaintiff
vs.
TANYA R. DELLINGER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-4073
CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 17 ^ day of 4X 2002,
upon consideration of the attached Custody Conciliation R pow rt, it is ordered and directed as follows:
Order. 1. The prior Order of this Court dated November 14, 2001, is vacated and replaced with this
2. The Father, Brett E. Dellinger, and the Mother, Tanya R. Dellinger shall have shared legal
custody of Morgan Alyssa Dellinger, bom June 27, 1997. 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. Both parties shall have equal access to all records pertaining to the Child, including
medical and school records.
3. The Father shall have primary physical custody of the Child.
4. The Mother shall have partial physical custody of the Child, on alternating weekends,
beginning January 11, 2002, from Friday at 2:00 p.m., when the Mother shall pick up the Child at the
Carlisle Y.M.C.A. (or other location agreed upon by the parties), through Sunday at 5:00 p.m., when
the Mother shall transport the Child to the Father's residence. The parties agree that the Mother's
parents may provide transportation for exchanges of custody when they are visiting the Mother in
Johnstown.
5. The parties shall share or alternate having custody of the Child on holidays as follows:
A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which shall
run from December 21 at 2:00 p.m. (or at the end of the last day of school before the
Christmas vacation) through December 24 at 2:00 p.m., and Segment B, which shall run
from December 24 at 2:00 p.m. through December 27 at 2:00 p.m. In even numbered
years, the Father shall have custody of the Child during Segment A and the Mother shall
have custody during Segment B. In odd numbered years, the Mother shall have custody of
the Child during Segment A and the Father shall have custody during Segment B.
B. THANKSGIVING: The party who has custody of the Child under the alternating
weekend schedule shall have custody from the Friday after Thanksgiving at 5:00 p.m.
through Sunday, and the other party shall have custody from after school on the Wednesday
before Thanksgiving through Friday at 5:00 p.m.
C. EASTER/SPRING BREAK: In 2002, the party who has custody of the Child under
the alternating weekend schedule over Easter shall have custody from the Friday before
Easter at 5:00 p.m. through Easter Sunday. The other party shall have custody from the
Wednesday before Easter at 2:00 p.m. through Friday at 5:00 p.m. In subsequent years
when the Child is attending school, the parties shall equally divide the Easter vacation
break and any extended spring break. In even numbered years (beginning 2004), the Father
shall have custody of the Child during the first half of the Easter and spring break and the
Mother shall have custody during the second half. In odd numbered years, the Mother shall
have custody of the Child during the first half of the Easter and spring break and the Father
shall have custody during the second half.
D. MEMORIAL DAY/LABOR DAY: The party who otherwise has custody of the
Child under the alternating weekend schedule during the weekend immediately preceding
Memorial Day and Labor Day shall retain custody of the Child through the Monday holiday
at a time to be arranged by agreement.
E. MOTHER'S DAY/FATHER'S DAY: The Mother may have a period of custody on
Mother's Day and the Father may have a period of custody on Father's Day, with the
specific arrangements to be made by agreement of the parties.
F. The holiday custody schedule shall supersede and take precedence over the regular
custody schedule.
6. The Mother shall be entitled to have extended periods of custody with the Child each
summer for two non-consecutive weeks upon providing notice to the Father by May I of each year of
her selection of weeks under this provision.
7. The non-custodial parent shall be entitled to have liberal and reasonable telephone contact
with the Child.
8. Neither parent 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.
9. 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 T OURT,
Edward E. Guido, J.
cc: Lisa M. Grcason, Esquire - Counsel for Father
Samuel L. Andes, Esquire - Counsel for Mothers a ( 11- 1-7, 0 z-
i
BRETT E. DELLINGER,
Plaintiff
Vs.
TANYA R. DELLINGER,
Defendant
PRIOR JUDGE: Edward E. Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-4073 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:
follows: 1. The pertinent information concerning the Child who is the subject of this litigation is as
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Morgan Alyssa Dellinger June 27, 1997 Father
2. A Conciliation Conference was held on January 3, 2002, with the following individuals in
attendance: The Father, Brett E. Dellinger, with his counsel, Lisa M. Greason, Esquire, and the
Mother, Tanya R. Dellinger, with her counsel, Samuel L. Andes, Esquire.
3. The parties agreed to entry of an Order in the, form as attached. Date Dawn. Sunday, Esquire
Custody Conciliator
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