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HomeMy WebLinkAbout99-04100 1t 1?. 15 eI b yi. i f M CAROLINE A. PICKING, PLAINTIFF V. FRANK S. GROTTOLA, III, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- c41 10C) CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT c AND NOW, upon consideration of the attached Petition, it is he by directed that , e parties and their respective counsel appear before, Esquire, the Conciliator, on the f2 day of r 191E at ,, : 00 P.M., at the 4th Floor, Cumberland County Courthouse, Carlisle, ennsylvania, 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 the entry of a temporary or permanent Order. Notification to the Defendant by the Prothonotary's Office is waived. For the Court, Date of Order: By: Q/ G % Z ?? 1W?1l? / yA Custody Conciliator v 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 iil C; _ ^r 99 J!!!_ I :? i';fi 3: 58 Az?wo CAROLINE A. PICKING, PLAINTIFF V. FRANK S. GROTTOLA, III, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 49. Y/Da CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT You, Frank S. Grottola, III, Defendant, have been sued in Court to obtain custody, partial custody or visitation of the child: Anthony T. Grottola You are ordered to appear in person at the Cumberland County Court House, Front and Market Streets, Harrisburg, Pennsylvania, on the day of 1999, at o'clock .m. You are further ordered to bring with you the child: Anthony T. Grottola. If you fail to appear as provided by this Order or to bring the child, an Order for custody, partial custody or visitation may be entered against you or the Court may issue a warrant for your arrest. 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 BY THE COURT: J. CAROLINE A. PICKING, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 9 J. y I Po Curl Tt. - FRANK S. GROTTOLA, III, : CIVIL ACTION -LAW DEFENDANT : IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Caroline A. Picking, residing at 807 North Walnut Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is Frank S. Grottola, III, residing at 503 Elmwood Avenue, Apt. 1, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff seeks primary custody of the following child: NAME PRESENT RESIDENCE D.O.B. Anthony T. Grottola 807 North Walnut Street 03/06/93 Mechanicsburg, Pennsylvania The child/children was not bom out of wedlock. The child is presently in the custody of Caroline A. Picking who resides at 807 North Walnut Street, Mechanicsburg, Pennsylvania. Since date of birth, the child has resided with the following persons and at the following addresses: NAME RESIDENCE DATE Caroline A. Picking (Mother) 642 Cedar Ridge Drive 03/06/93 -12/1996 Frank S. Grottola, III (Father) Mechanicsburg, Pennsylvania Matthew Picking (Step-Brother) NAME Caroline A. Picking Mathew Picking Joyce Werner (Maternal Grandmother) RESIDENCE DATE 807 North Walnut Street 12/1996 - Present Mechanicsburg, Pennsylvania The mother of the child is Caroline A. Picking, currently residing at 807 North Walnut Street, Mechanicsburg, Pennsylvania. She is single. The father of the child is Frank S. Grottola,1I1, currently residing at 503 Elmwood Avenue, Apt. 1, Mechanicsburg, Pennsylvania. He is single. 4. The relationship of Plaintiff to the child is that of mother. The Plaintiff currently resides with the following person/persons: NAME Anthony T. Grottola Matthew Picking Joyce Werner RELATIONSHIP Son Son Mother 5. The relationship of Defendant to the child is that of father. The Defendant currently resides with no other person/persons. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, the Plaintiff, Caroline A. Picking, requests the court to grant primary physical custody of the minor child, Anthony T. Grottola, to her. JAMES, SMITH, DURKIN & CONNELLY Date: LV -d T'99 By: Jqhn . onnelly, r., Esquire Pbst O Ace Box 6 0 (717) 533-3280 PA I.D. No. 15615 VERIFICATION I verify that the statements made in this Pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: & - A-tl -9g ?-' J'j ? 2° o. + Ukfottnc N -• (&in laintiff v. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW CIVIL 199ry CUSTODY VISITATION And now, this 7i H / 99, upon consideration of the attached complaint, it is hereby directed that the above parties and their respective counsel appear before L)2Nh l . Esquire, the conciliator, at 39 ! cLL tiz , Keckaebu `V''-xc) Pennsylvania, on the 1Z day of 1999, at _ A.M./ for a Pre-hearing Custody Conference. At uch 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 be present at the conference. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent order. FOR THE COURT: By; M )i 02dhn , Custody Conciliator C1_ ) 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. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 7 (p??C3 ? }aco ?+---- t >- L!, ,_, F? IL1 ?.? Cr ??')1? .1J ?., .' ? ? ? -• _ J_ ?_`i- fL?7 I_. ? "_1 [may L? ? OFFICE OF THE COURT ADMINISTRATOR CUMBERLAND COUNTY COURT OF COMMON PLEAS 1 Courthouse Square • Carlisle, PA 17013 Richard J. Pierce Court Administrator Phone (717)240.6200 (717) 697.0371 (717) 532.7286 (717) 240.6462 FAX Taryn N. Dixon Assistant Court Administrator Frank S. Grottola, III 503 Elmwood Avenue Apt. I Mechanicsburg, PA 17055 Dear Mr. Grottola, III: July 16, 1999 You have recently received a notice to appear before Dawn S. Sunday, Esq., custody conciliator, as a party to a custody dispute. Please note that the address of the conciliation was incorrect on the first notification. The correct address for the law office of Dawn S. Sunday, Esq., is 39 W. Main St., Mechanicsburg, 17055. Enclosed, you will find the correct version of the order. We would like to apologize for any inconvenience. If you have any questions, please do not hesitate to contact the Court Administrator's Office. Sincerely, 0,4? Christine Anthony Office Intern OFFICE OF THE COURT ADMINISTRATOR CUMBERLAND COUNTY COURT OF COMMON PLEAS Richard J. Pierce 1 Courthouse Square • Carlisle, PA 17013 Court Administrator Phone (717) 240.6200 Taryn N. Dixon (717) 697.0371 Assistant Court Administrator (717) 532-7286 (717) 240.6462 FAX July 16, 1999 John J. Connelly, Jr., Esq. James, Smith, Durkin, & Connelly P.O. Box 650 Hershey, PA 17033 Dear Mr. Connelly, Jr.: You have recently received a notice to appear before Dawn S. Sunday, Esq., custody conciliator, as a party to a custody dispute. Please note that the address of the conciliation was incorrect on the first notification. The correct address for the law office of Dawn S. Sunday, Esq., is 39 W. Main St., Mechanicsburg, 17055. Enclosed, you will find the correct version of the order. We would like to apologize for any inconvenience to you or your client. If you have any questions, please do not hesitate to contact the Court Administrator's Office. Sincerely, COffice Intern ti. • ?.D :ITS Cl- L CIA I I" I 1-l f. r CAROLINE A. PICKING, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-4100 CIVIL TERM FRANK S. GROTPOLA, III, CIVIL ACTION - LAW Defendant ' IN CUSTODY u: 6V ORDER OF COURT . AND NOW, this ? day of (A v,_,?, 1999, upon consideration of the attached Custody and dire Concail a'Eion Report, it is ordered 1. he cted as follows: iJ Grottola, III, shall e have shared legal custody of Anthony TthGro?ttola,,born March 6, 1993. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. The Mother shall have primary physical custody of the Child. 3. The Father shall have partial physical custody of the Child on alternating weekends from Friday at 6:00 p.m. through Sunday at 6:00 p.m. beginning Friday, August 20, 1999. The Father shall also have custody of the Child every Wednesday from after work through the following morning when the Father shall take the Child to school or to the child care provider if the Child does not have school. During weeks following the Mother's weekend periods of custody, the Father shall have custody of the Child on Tuesday from after work through 8:00 p.m. when the Child has school the following day or until Wednesday morning if the Child does not have school the following day. During weeks following the Father's weekend periods of custody, the Father shall have custody of the Child on Thursday from after work until 8:00 p.m. if the Child has school the following day or until Friday morning if the Child does not have school. 4. 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 At 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 Mother shall have custody of the Child during Segment A in odd numbered years and during Segment B in even numbered years. The Father shall have custody of the Child during Segment A in even numbered years and during Segment B in odd numbered years. B. THANKSGIVING: The Thanksgiving holiday shall be divided into Segment A, which shall run from 9:00 a.m. until 2:00 p.m. on Thanksgiving Day, and Segment B, which shall run from 2:00 p.m. until 9:00 p.m, on Thanksgiving Day. 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. C. ALTERNATING HOLIDAYS: The parties shall alternate having custody of the Child from 9:00 a.m. until 9:00 p.m. on the following holidays: Easter, Memorial Day, July 4th and Labor Day. The Father shall have custody of the Child in even numbered years on Easter and July 4th, and in odd numbered years on Memorial Day and Labor Day. The Mother shall have custody of the Child in even numbered years on Memorial Day and Labor Day, and in odd numbered years on Easter and July 4th. D. MOTHM'S DAY/FATEER'S DAY: The Mother shall have custody of the Child every year on Mother's Day from 9:00 a.m. until 9:00 P.m. and the Father shall have custody of the Child every year on Father's Day from 9:00 a.m. until 9:00 p.m. E. CHILD'S BIR'TW": The non-custodial parent shall have a period of custody on the Child's birthday each year, with the specific times to be arranged by agreement of the parties. 5. Each party shall be entitled to have custody of the Child for summer vacation each year for up to two uninterrupted weeks (consecutive or non-consecutive) upon providing 60 days advance notice to the other party. 6. In the event either party is unavailable to provide care for the Child during his or her period of custody for a period of three hours or longer, that party shall first contact the other party to offer the opportunity to provide the care for the Child before contacting third party care givers. 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. cc: John J. Connelly, Jr., Esquire - Counsel for Mother IF Barbara J. Patton, Esquire - Counsel for Father BY THE COURT, CAROLINE A. PICKING, . IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 99-4100 CIVIL TERM FRANK S. GROTTOLA, III, CIVIL ACTION - LAW Defendant IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACOMMANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCCWM 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 Anthony T. Grottola March 6, 1993 Mother 2. A Custody Conciliation Conference was held on August 17, 1999, with the following individuals in attendance: The Mother, Caroline A. Picking, with her counsel, John J. Connelly, Jr., Esquire, and the Father, Frank S. Grottola, III, with his counsel, Barbara J. Patton, Esquire. 3. The parties agreed to entry of an Order in the form as attached. ?CIA ? /8, /999 Date _ Dawn S. Sunday, Esquire Custody Conciliator ?,yy «7 W ? UZq C ?F A a?? ?o O ??tt ////??]]]]ii Ha xHx Ll ? E t? c ? r p ?' UUg g 2 N [-? .ti a U ? p Fi H a OH ?N ai hI w? ? u ? a E , H U ,? N y M aI 0 AUG 2 t°g`