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FROM : MONT COUNTY HERD START PHONE NO. : 215 887 0916 Rug. 30 2000 10:20AM P20
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215 887-0916
530 TWINING ROAD
DRESHER, AP 19025
MONTGOMERY COUNTY HEAD START
610 326-1050
555 HIGH STREET
POTTSTOWN, PA 19464
COMPREHENSIVE EVALUATION REPORT
J-Inltlal Evaluation
_Reovaluatlon
CHILD'S NAME: G DATE OF BIRTH: l f j? 9/a
??)) CRIS'
Parents: r O'00tn "t 0Phone: (h)d54a- lAS?(w)
Address 3a!7 :SWete4 D-r.
f-n111o.,ce,:11n -P, _ 1cL1-7.0
School District: -,46bUde1(+ay,, Other Information (as needed):.
Date Permission to Evaluate/Reevaluate Received: q -1:5--j .7
Date of Completion of Multidisciplinary Evaluation: m "
Date of Comprehensive Evaluation Report: 9?
1. Reason f r Referral:
re ? f O KC aW I d -'O 717U- UTCU,66-Q CCXOMAIL4
ins OBI IYLC? ltn t fic?,l ?Sc.Ir e e v? i yr 5 tic i Ca?2d
Ii. History:
A. Early Intervention History NC)NIE
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B. Education, Soci and Physleal History
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??3i/oo Cvey
FROM : MONT COUNTY HERD STRRT PHONE NO. : 215 807 0916 Aug. 30 2000 10:21RM P21
DATE: CHILD'S NAME: C-vP?C C)f (,,) M 1 I IC' I I ?S
III. Information from the family (parents or other persons with whom the child lives)
A. Child's strengths and needs Including physical condition, cultural and language
confiderations, an adaptive behavior
B.
the?chil
Y?
_fV strengths and needs w ch n hance the 7elipment of
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IV. Summary of Findings
A.
B.
lr vt_ i Vla c ?ecl J ?'
Review of current IEP (for reevaluation only)
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Screening results (initial evaluation only)
FROM : MONT COUNTY HERD START PHONE NO. : 215 887 0916 Aug. 30 2000 10:2
A? 1RM P22
DATE: //- ? - e, eJ _ CHILD'S NAME: C",yr-c of, 'N i I Ie-h4S
III. Information from the family (parents or other persons with whom the child lives)
N.
A.
B.
Child's strengths and needs including physical condition, cultural and language
con ideratlons, an adaptlvv ehavlo
J `
Family- erceived strengths and needs w ch It enhance the d elopment of
the child
WL
Ma*&4
Summary of Findings A. Screening results (Initial evaluation only)
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B. Review of current IEP (!or reevaluation only)
*am
MCIU 7A6
3
FROM : MONT COUNTY HEAD START PHONE NO. : 215 887 0916 Aug. 30 2000 10:22AM P23
DATE' CHILD'S NAME: vey rq f l
e (,c
C. Developmental Assessment
Assessment Instruments and Procedures:
Date: I®- q q
Procedure/Assessment:_•LG.S? Rresdcool La ,,?I,,Ua4 z
Result: Rwk+a( CO VVkpfeblew's?, -
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Date: 16 _& -4
Procedure/Assessment: EXprE'SSi v-e 0"-Wb(di4' c -uw- Voc&b_
Result: -F?a.,ut bec>(v_- ?4o.
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Date: 9 - 141-C.C
Procedure/Assessment: qo (c1mcj- t - V I STD E'7E s+ J t y}? L
Result: OuD?I.bev- ??- &rors-
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2. Narrative (including, but not limited to physical development, cognitive
.and sensory development, hearing problems, teaming strengths and
educational needs, language and speech development, social and
e otionat develop ?nt, self-help skills, health onssider on
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FROM : MONT COUNTY HERD START PHONE NO. : 215 887 0916
Aug. 30 2000 10:22API P24
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FROM : MONT COUNTY HEAD START PHONE NO. : 215 887 0916 Aug. 30 2000 10:23AM P25
DATE: V CHILD'S NAME: G re?Cjp rci (vl,l t ?,e-hC S
D. Observations: (information from observations during daily activities such as
play with other children and interaction with family members and/or other
ad t8)
AVLM&
E. Area(s) of Delay:
Lc-v-tuCLT - xw(e.ulog ALI 0+ 69eeec'k-
F. Skills needed by the child to function successfully in variety of settings,
including the home, school, and community
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FROM : MONT COUNTY HEAD START PHONE NO. : 215 887 0916 Aug. 30 2000 10:23AM P26
DATE: 1 t -'S 41y CHILD'S NAME: Ll reoO #-4 %l < <e-h C S
V. Recommendations i
A. Recommendations of Eligibility for Early Intervention Services and Programs
t • Team recommends eligibility for early intervention services.
The following services or programs should be considered by
the IEP team:
2• Team recommends continued eligibility (Attach IEP)
3. Team does not recommend eligibility for early Intervention
services. Recommendations for follow-up activities (if any)
are:
B. Recommended Services to meet the family's needs to enhance the child's
development ,
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POCadD 04LB
MCPJ 7/90
7
FROM : MONT COUNTY HERD START PHONE NO. : 215 887 0916 Aug. 30 2000 10:24AM P27
DATE: CHILD'S NAME:
MULTIDISCIPLINARY EVALUATION TEAM St ATURES
Please Indicate your agreement or disagreement with the conclusion or content of this report.
If you disagree, please write the reasons for disagreement and attach them to this report.
SIGNATURE TITLE DATE AGREE DISAGREE
9z L - 43W A 4 L ki
This report Is a draft until all MDT members (Including parents) have reviewed
and signed the report. Any dissenting opinions must be Included.
Mcw WN
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Date CER sent to parents.
17
FROM : MONT COUNTY HERD START PHONE NO. : 315 887 0915 Aug. 30 2000 10:24AM P28
M 987.-,0916 MONTGOMERY COUNTY HEAD START
610 32
530 TWINING ROAD 6-lo5u
555 HIGH srREIET
nr1FF.l4F9, PA 1902
INVITATION TO PARTICIPATE IN THE IEP MEETINpOTTSrOMN,PA 19464
Date: /4 a7-re5 1 ?1I1/,_1If?. /?
Child's Name:c vec f 1
Name and Address of Parent; u
3a 7
Dear kQ/ti?
a -f 5Y52
We would like you to participate In an indivklualized education program team meeting. The purpose Of this
meeting is to: (C1NCk8n1haf4A*)
Z Discuss the results and recommendations of the multidisciplinary evaluation and make a determination if
Your Child Is In need of special education. If K Is detemtined that your child Is eligible for Early Intervention,
an Individualized Education Program (IEP) will be developed at the meeting
I 1 Olactuss your child's current IEP to review and revise it as needed,..
The team meeting has been scheduled for this location: _t/ )h.
at the following data and timo:-I??o V time, location is riot conventions, please contact me as soon as If this dice, or
mutually corwenient. Possible so we can arrange a time and place ace which are
and
Phone Number Dale
The folbwing Is are a ad to attend the meeting for your child:
NAME AOLE' (r. - -4 NAME ROLE'
77
NAME ROLE'
NAME ROLE'
NAME
ROLE'
NAME ROLE'
NAME
ROLE'
MIS fl0tes this person's Involvement in your child s IEP development. Examples: Regular education teacher,
MAWA Agency representative, etc.
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FROM MONT COUNTY HERD START PHONE NO. : 215 887 0916 Aug. 30 2000 10:13AM P7
IEP Dev Dote of
Child's narnsG
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1. Special Considerations the IEP Team Must Address Before Developing the IEP
(Each question must be answered)
A. Is the child blind or visually impaired? -NO
VES•Tsam mutt address the need for Braill*/Braille
instruction based on the child's current and future
reading and wdling skills and needs and will be
Included In the development of the IEP.
YES-Team doss not need to addrass the need
for BralllwSrallle Instruction based on the
student's current and future reading and
nmg skills and needs.
B. Is the child deaf or hearing impakad? No
YES-Team must address the child's language and
communication needs, opponunklss for direct
communication with paors and professionals in the
child's language and communication mode, academic
level, and full range of needs, including opportunities
for direct instruction in the child's language and
communication mode in the development of the IEP.
C. Does the child exhibit behaviors that impede NO
his/her learning or that of others? YES-Team must develop strategies including Positive
behavior intervention supports in the IEP.
D. Does the child have limited English NO
proficiency? YE$-Team must address the language needs of the
child in the development of the IEP,
i- Does the child have communication heeds? NO
YES-Team must address the communication needs of
the child in the development of the IEP.
F. Does the child require assistivs NO
technology devices and/or services? YES-Team must address the child's assistive
technology needs in the development of the IER
G. Does the child have any health No
concerns? Yes-Team must address intervention strategies
necessary to support the child's participation in
programs/service.
H. Does the child require transition to
schoo4ge services? --LNO
Yes-The child is within one year of transition. Team
must discuss ft transition process and develop
transition goals and objectives.
MCIU•7/98
Z
FROM MONT COUNTY HEAD START
PHONE N0. 215 B87 0916
Aug. 30 2000 10:14gM P8
IEP Dev Date ?? " S-?1 ?nl?
--,_, ?,L_ _ Child's name Ivl
11. Present Levels of Performance
A. Describe the eligible young child's present levels of performance, Including
functional Information regarding educational strengths and needs.
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0. With pare at consent, describe what the family perceives as their strengths and
needs as they relate td the goals of the child. What are the family's priorities for the
child?
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C. Now as th aliglbl
general education curriculum Ahkild-s d appropriate activities? child's participation In the
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MCIU•7/9a
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FROM : MONT COUNTY HERD START PHONE NO. : 215 887 051E Aug. 30 2000 10I:14RM P?
IEP Dev Date_ Chlld's name
{?l- arc
III• GOALS AND OBJECTIVES: (Use as many copies of this page as needed)
A. MEASUREABLE ANNUAL GOAL
?. ? ?B.r ?SHORT-TERM INSTRUCTIONAL OBJECTIVES OR BENCHMARKS
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MCIU•7/98
FROM : MONT COUNTY HERD START PHONE NO. : 215 887 0916
Aug. 30 2000 10:15gM P10
Child's netreC-
lgp DYV Date f?
Ill. GOALS AND OBJECTIVES: (Use as many copies of this page as needed)
A. MEASURHAf3LE ANNUAL GOAL
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FROM MONT COUNTY HEAD START
PHONE NO. :215 B87 0916
Aug. 30 2000 10:16AM P11
IEP Dev Date_ ?I JS 7 _ Child's nnme
.a4.cj
111. GOALS AND OBJECTIVES: (Use as many Copies of this page as needed)
A. MEASUREABLE ANNUAL GOAL
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FROM : MONT COUNTY HEAD START PHONE NO. : 215 887 0916 Aug. 30 2000 10:16AM P12
IEP Dev Date Child's name
111, GOALS AND OBJECTIVES: (Use as many copies of this Page as needed)
A. MEASUREABLE ANNUAL GOAL
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MCIU•7198
FROM : MONT COUNTY HEAD START PHONE NO. : 215 e67 0916
Aug. 30 2000 10:17AM P13
IEP Dev Date S'`Child's name
IV. Specially Designed Instruction, Special Adaptations, and Strategies
(Needed to advance toward attaining goals and to be involved and progress In the
general cunkulum andror appropriate activities)
A.
to most
Lt: How are Content, method and materials being
child's needs?
B. -jrited
young child to
transportation?
What Yuppditlve service* to required to assist the eligible
n or gain access to spacial education, e.g.,OT,PT,
C. Syjlglsmentary Aids and servlpas: What aide, services and supports are
required to ensure the eligible young child meaningful participation to the maximum
extent appropriate with non-eligible children?
D. supports: What training and/or materials will be provided for program personnel
In order to allow the child to participate or progress In the general curriculum or
appropriate activities?
E. Least Restrictive Environment: Explain to what extent, If any, the ellglble
young Ild will not participate with'noh-slipble children. n A , /?j p ?2
A?j
N l/`?.. D r
P. ftograss Reporting: Explain how the program will report progrsae toward
annual goals to parents, qnd ho often.
emouf/Iu@ -x ?v
i? MCIU-7/98 /
1`
FROM : MONT COUNTY HEAD START PHONE NO. : 215 eel 0916 Aug. 30 2000 10:17AM P14
MONTGOMERY COUNTY HEAD START
530 TWINING ROAD
555 HIGH STREET i
DRESHER, PA 19025 POTTSTOWN, PA 19464
215 887-0916 610 326-1050
OPTIONS CONSIDERED
Child's Name ??,/A
The following options were considered in descending order when recommending placement for your child,
except for the alternative relating to services and programs provided In the tame. Services in the home may be
the least restrictive early Intervention program for an etigbte youno child.
• Regular preschool program or class for all or most of the program ervention.
• Specialized selling for most or all of the program day, with noneligible young children.
• Specialized setting for pan of the day, with some programming provided in the regular preschool program
or class and opponunkfes for participation with none0grde young children in play or other activities.
• Supplemental Intervention, nordassroom setting.
• specialized setting Jor most or all of the program day.
• Services and programs provided in the fame, Including services which are provided in conjurxtion with
services provided in another setting.
• Specialized setting, Including the following:
Approved Private School.
Residential school facility.
Approved out-cf•stats program.
Reasons for the recommendations (Include evaluation procedures, reports, and other factors used in making the
recommendations.):
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Reasons why the above recommendation is appropriate and why it represents the least restrictive environment in
which your child's needs can be met:
_ ,ed t l&. j Age. 4n-r--j in -,?l?z? IPc.._<? Ii PG???c??u.t t°lilyi?'+oN K-•.7?'
0-0 C6- 9,e CLASS w9f0'1 S-4QO -t)
Reasons why the options that were considered, but not recommended, are Inappropriate or do not represent the
least restrictive environment In which your child's needs can be met:
Form: 7/198
7
FROM : MONT COUNTY HEAD START PHONE NO. : 215 887 0916 Aug. 30 2000 10:18AM P15
530 THINING ROAD
DRESHER, PA 19025
215 887-0916
MONTGOMERY COUNTY HEAD START
555 HIGH STREET
POTTSTOWN, PA 19464
610 326-1050 '
NOTICE OF RECOMME 1DED ASSIGNMENT (NORA)
CHILD'S NAME: DATE: /I'
This notice describe recommandatbns or proposed changes regarding your child's educational program
as a result of the recent Individualized Education Program (IEP) meeting or your request. The assignment
roWrrlmended for your Chill Ise
I v v
This assignment was recommended after a review of the attaohe options, which were used to assist in
Identifying the services that will meet your child's needs.
t. ? Your child should begin to receive early Intervention services. The MAWA Agency will not
p(004 without your approval of this recommendation (the IEP Is attached).
2. ( I Your child's early intervention placement or services should be Changed as noted In the IEP. The
MAWA Agency will proceed with this change unless you nouy us, within ten days. of your written disapproval (the
IEP Is attached).
3, [ I Your child Is no longer In need of early intervention services because (s)he has met exit criteria .
We recommend current early Intervention services be discontinued. The MAWA Agency will proceed with this
charge unless you notify us, within ton days, of your written disapproval.
4. [I All early Intervention services provided by the MAWA Agency will be discontinued by the
beginning of the coming school term. Education services will become the responsibility of the school district. You
will be provided assistance with this ftwilion.
5. I I Your child Is not eligible to receive early Intervention services.
6. I 1 The MAWA Agency Is refusing your request to Initiate or ctWV@ your d1Dd's:
(] Identification ( I Evaluation I I rational placement
I 1 Provision of a Free Appropriate Public Education
The reason and basis for this refusal are'
I I Other;
Agency Chief
c?l'1Ig?
Dale
FROM : MONT COUNTY HEAD START PHONE NO. : 215 887 0916 Aug. 30 2000 10:18AM PIS
4•
CHILD'S NAME: J?f e k 64?7,j?f _ / yf (? ?.D DATE:
You have certain rights which are described in the attached Procedural Safeguards Notice. Please carefully read
the Information. If you need more Information, you may contact:
Early Intervention Supervisor - Phone (610) 538.8330
DIRECTIONS FOR PARENTS: Please chock one of the options below, sign this form, and return it within
10 days to the person listed above.
j I approve this recommendation.
( `] I do not approve this recommendation. (Please request an option listed below.)
My reason for disapproval is:
I request:
1 1 A Prehearing Conference 1 1 Mediation- 1 1 Due-process Hearing"
-The attached Procedural Safeguards Notice provides information on these options. I have received a
copy and t understand the content of the Procedural Safeguards Notice. Parert's Initials
PareftCa Signature iJeEe Daythr Poore
MCIU NORA:711M
FROM : MONT COUNTY HEAD START PHONE NO. : 215 887 0916
MONTGOMERY COUNTY HEAD START
215 887-0916
Aug. 30 2000 10:19AN P18
610 326-1050
S55 HIGH'STREET
530 TWINING ROAD POTTSTOWN, PA 19464
DRESHER, PA 19025
// PERMISSION TO EVALUATE/REEVALUATE
I i1 rOrj0r U 1' I? 1 DATE: Q ?? Y f
CHILD'S NAME:
NAMPJADDRESS OF PARENT(S): '° iA AL i ? P 4-r S
_ Your child has been referred for an inhlal evaluation for the following reason(s): `
V. -4
o1-S ?t ve in RC7'?- . bra 7: -(k, 1 w SO VO-W-9- _ I uLd cci- C,
-Fb v,fUv' `}e s+?vt vu-.LdLd .
The MAWA agency requests your consent to conduct a Multidisciplinary Evaluation (MOE). We must have your
written consent before we can begin. As a parent, you are a member of the multidisciplinary team. You are entitled
to participate in all meetings concerning this evaluation. outing the evaluation process You may also provide
written comments. The team will review your child's educational reeds and strengths as shown by performance
levels. assessment results, observations and information from you. Fallowing is a list of specific types of tests and
procedures that will be used and a description of each:
The evaluation is proposed for the following date(s):
The MAWA agency is planning a reevaluation of your child for the following reason(s):
The MAWA agency requests your consent to Conduct this reevaluation. We must have your written consent
before the reevaluation can begin. However, pteaze baware h the after rban As le attempts,
You area ave n mernbOr
received your response, we are permitted by law to p in as meetings concerning this reevaluation. Outing
of the multidisciplinary team. You ou are are entitled to participate
the reevaluation process, you may also provide written comments. The team will review your child's current IEP
and educational needs and strengths, as shown by educational performance levels, assessment results,
observations, and information from you. Following is a iist of the specific types of tests and procedures that will be
used and a description of each:
The reevaluation is proposed for the following date(s):
)2.
FROM : MONT COUNTY HERD START PHONE NO. : 215 887 0916 Aug. 30 2000 10:20AM P19
The multidisciplinary team will prepare recommendations regarding your drib's educational program and whether your child is
eligible, or continues to be eligible. for special education and related services. The findings from the MOE will be contained in a
Comprehensive Evaluation Report ICES) and will be the basis for devebpng the IEP. The CER a to to delivered to you within
tic days of receipt of your written Consent to evaluate or reavaluate.
Please read the enclosed Procedural Safeguards Notice, which includes parent resources such as state or local advocacy
organi'Astions. You may contact me y you have any questions Or concerns about the evaluation or if you need the services of
a translator or an interpra / ,•?
Contact Person 11 Position Phona 26J L?6 7-0 4C
DIRECTIONS FOR PARENTS: Please cheek the appropriate Item(s), sign end return this form to the
parson named above.
/' S I give consent to begin the proposed initial evaluation.
[ 1 1 give mnsenl to begin the proposed reevaluation.
(1 Pleass cent= me. 1 am not ready to give consent at this time and would lace to ta& about this,
[ 1 I do not give consent to the proposed lnkW evaluation or reevaluation. Please do not begin the process.
[ ) I object to the proposed initial evaluation or reevaluation; however, I would tike to schedule;
[ J An informal meeting.
[ J A prehearing confaranoe•
[ 1 Mediation'
[ j A Due Process Hearing'
The enclosed Procedural Safeguards Notice provides Information on those options. I have received a copy and I
understand the content of the Procedural Safeguards Notice. (Parent's Inklals)
Your family may have strengths and needs which would be helpful to consider as part of the multidisefplinary evaluation In
older to enhance the development of your child.
Yes. I wish to share such Information. (Parem's Mugs)
No, I do not wish to share such information. (Puanes initials)
The CER may Include a statement of your lamkys strengths and needs and services recommended to most those needs.
Yss, l give permission for the CER to include such information. (Psvenrs Initiate)
No, I do not wish the CER to include such Information. (Parenrs Initials)
?Slonature of Parent(#).`ZQ? [l p veto l ?
Daytime Telephone. aLci aS6- 6
MAWA Agency Contact
DATE SIGNED PERMISSION RECEIVED BY PROGRAM:
MCIU: 7/1x98
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SCOTT R. MILLETICS,
Plaintiff
V.
KAREN E. KAMPIA,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN CUSTODY
NO. qq - Sa3lo
ORDER OF COURT
AND NOW, upon consideration of the attached
that the parties and their respective cou sel appear be
Custod Conference Officer, on the da of
it is hereby directed
. at d luau, a[
a
a Pre-Hearing Custody Conference. ON for
At such Con erencd, an -effort will be made to
resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the
issues to be heard by the Court, and to enter into a Temporary Order. All children age
five or older may, at the request of either attorney or party, be present at the Conference.
Failure to appear at the Conference may provide grounds for the entry of a temporary or
permanent Order.
FOR THE COURT,
Date of
Order: 910911 By: I U?P?II011
Custody Conference O i r
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.
The Cumberland County Lawyer Referral Service
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
Telephone No. (717) 240-6200
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SCOTT R. MILLETICS, : IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
KAREN E. KAMPIA, IN CUSTODY
Defendant NO. y q. fd y4
COMPLAINT FOR CUSTODY
1. The Plaintiff is Scott A. Milletics, residing at 1009 Brookwood Drive,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. The Defendant is Karen E. Kampia, residing at 327 Shirley Drive,
Lower Salford, Pennsylvania 19438.
3. Plaintiff seeks custody of the following child:
Name Present Residences Age
Gregory Scott Milletics 327 Shirley Drive 3
Lower Salford, PA 19438
and DOB 1/18/96
1009 Brookwood Drive
Mechanicsburg, PA 17055
The child was born out of wedlock.
The parties alternate custody of the child on an alternating two week basis.
Since birth, the child has resided with the following persons and at the
following addresses:
Karen E. Kampia 26 Falcon Court 1/18/96 through 6/96
Scott R. Milletics Mechanicsburg, PA 17055
From 6/96 through the present, the parties have been sharing custody of Gregory and he
has lived with Father at 1009 Brookwood Drive, Mechanicsburg, PA 17055 and Mother at
327 Shirley Drive, Lower Salford, PA 19438.
There was a brief period of time when the parties separated that Ms. Kampia continued to
live at the Falcon Court address and Father lived at the 1009 Brookwood Drive address.
The mother of the child is Karen E. Kampia currently residing at 327 Shirley
Drive, Lower Salford, Pennsylvania 19438.
She is single.
The father of the child is Scott R. Milletics, currently residing at 1009
Brookwood Drive, Mechanicsburg, Pennsylvania 17055.
He is single.
4. The relationship of Plaintiff to the child is that of father. The Plaintiff
currently resides with the following persons:
Name Relationship
Sandra L. Milietics Plaintiffs mother
Kendrick Jones Plaintiffs mother's boyfriend
Gregory Scott Milletics son
5. The relationship of Defendant to the child is that of mother. The
Defendant currently resides with the following persons:
Name Relationship
Robert Kampia Defendant's father
Kenneth Kampia Defendant's brother
Michael Defendant's son (Gregory's half-brother)
Gregory Scott Milletics son
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 has no information of a custody proceeding concerning the child pending in a
court of this Commonwealth.
Plaintiff does not know of a person not a party to the proceedings
who has physical custody of the 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 because: the parties have had a shared custodial
arrangement since June of 1996. Gregory is now 3 % years old and Father would like to
enroll him in a pre-school program no later than September 2000. Plaintiff believes that
he can provide a more stable environment for his son and will take all steps necessary to
ensure that Gregory has frequent, meaningful contact with Mother.
8. Each parent whose parental rights to the child have not been
terminated and the person who has physical custody of the child have been named as
parties to this action.
WHEREFORE, Plaintiff requests the court to grant primary physical
custody of the child to him.
Sandra L. Meilton, Esquire
TUCKER ARENSBERG $ SWARTZ
111 North Front Street
P.O. Box 889
Harrisburg, PA 17108-0889
(717) 2344121
ATTORNEYS FOR PLAINTIFF
20589.1
I, the undersigned, Scott Milletics, acknowledge that the facts stated in the
foregoing document are true and correct to the best of my knowledge, information and
belief.
I understand that any false statements herein are made subject to the
penalties of 18 Pa. C.S.A. Section 4904 relating to unswom falsification to authorities.
S ott illetics
Dated: 8/24/99
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SCOTT R. MILLETICS,
Plaintiff
V.
KAREN E. KAMPIA,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN CUSTODY
NO. 99-5236 Civil
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA )
SS:
COUNTY OF DAUPHIN )
AND NOW, this day of f*1 , 1999, personally
appeared before me, a Notary Public in and for the aforesaid Commonwealth and
County, Gloria M. Rine, legal assistant to Sandra L. Meilton, who being duly sworn
according to law, deposes and says that on September 9, 1999, she mailed a certified
copy of a Complaint for Custody with attached Court Order setting a custody
conference, by certified mail no. Z 187 542 979, return receipt requested, to Karen E.
Kampia, 327 Shirley Drive, Harleysville, PA 19348, and the same was received by her
on September 11, 1999 as indicated by the return receipt card which is attached hereto.
Gloria M. Rine
Sworn to and subs i ed
before me this J =day
of September, 1999.
ra"'e?7-? wall
Notary Public
Public
b. 7.2000
(SEAL) HarrisWsociat ounty
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MONTGOMERY COUNTY INTERMEDIATE UNIT
SERVING THE SCHOOLS OF MONTGOMERY COUNTY
1605-B WEST MAIN ST. - NORRISTOWN PA 19403 - 610/539.8550 - FAX 610/539-7411
SPEECH AND LANGUAGE EVALUATION AND PRESENT LEVELS OF
NAME:
DATE OF BIRTH:
DATE OF EVALUATION
C.A..
EVALUATOR:
PARENT:
ADDRESS:
PHONE:
COMMUNICATION
GREGORY MILLETICS
1-18-96
8-10-99
3 YEARS, 6 MONTHS
KATHLEEN WERTLEY,
KAREN KAMPIA
327 SHIRLEY DRIVE
HARLEYSVILLE, PA.
215-256-6954
BEHAVIORAL OBSERVATIONS/HISTORY
M.A., CCC/SLP
DEFENDANT'S EXHIBIT
19438
Gregory is a 3 year, 6 month old child who was referred to the Montgomery County
Intermediate Unit by his mother due to concerns with his overall development.
Following a developmental screening on 5-20-99, he was referred for a
Speech/Language Evaluation and Audiologic Evaluation. He was accompanied to
today's Speech/Language Evaluation by his mother who acted as informant. Ms.
Kambia reported that Gregory has difficulty pronouncing words.
Reportedly, Gregory is the product of an uncomplicated 39 week pregnancy with a
birth weight of 6 lbs., 5 oz. Ms. Kambia reported that there was a slowing of his
heartbeat during the delivery but there were no problems at birth other than mild
jaundice. There is no reported history of serious accidentlillness; hospitalization;
feeding/swallowing difficulty or chronic ear infections. Ms. Kambia reported that she
suspects Gregory may have seasonal allergies but he has not been formally
diagnosed. His hearing was tested on 5-20-99. Results indicated that hearing is
adequate for speech/language development. Emergence of developmental
milestones was reported as follows: sifting unsupported at 6 months; walking at 14
months; first words at 18 months. Gregory has not participated in an educational
preschool program to date. His mother is exploring the possibility of enrolling him in a
Head Start Program for the fall. He currently lives with his mother and younger brother
half of the time and his father the other half.
While in the playroom, Gregory was observed playing primarily with toy dinosaurs. He
primarily gathered them and carried them around the room but he did at times pretend
that they were fighting or growling at each other. He played briefly in the kitchen area
MCIU is an equal opportunity employment, educational, and service organization.
Speech and Language Evaluation - Gregory Milletics Page 2
and brought a cupcake to the evaluator and said, "Here a cupcake.". He transitioned
to the evaluation room with his mother and younger brother but he was able to
separate from them upon entering the room. He took the toy dinosaurs with him and
refused to separate from them but placed them on the table. He was generally
cooperative for labeling pictures and answering questions about pictures. He followed
one step directions involving object manipulation. He joined with the evaluator in a
spontaneous play activity using a Fischer Price Farm.
TESTS/PROCEDURES ADMINISTERED
Parent Interview
The Communication Screen (3-Year Form)
Goldman-Fristoe Test of Articplation (EFTA)
Structured Photographic Expressive Language Test-Preschool (SPELT-P)
Informal Language Sample
EVALUATION RESULTS
Receptive/expressive language content and use were assessed using AGS Early
Screening Profiles, administered 5-20-99; The Communication Screen and informal
language sampling. Gregory appeared to be functioning within age expectations on
these measures. He was able to identify actions in pictures. He could follow one step
directions using the spatial concepts in, upside down, under, on. He could label
pictures of common objects. He responded to what, where, yes/no questions.
Expressive language skills were further assessed using the PELT-P. He correctly
used prepositional phrases when given a choice (ex. When asked, "Is the dog under
the chair or on the chair?", he correctly responded, "under chair"). He did not use
plural noun endings; present progressive (is/are verbing); possessive noun endings;
pronouns he/she; past/present verb tense endings; copula (is/are) or negation. During
spontaneous language sampling sentence length averaged 2.3 words with one 4
word combination recorded. He used sentences to locate (ex. "Sheep in there."); to
negate (ex. "No, you don't."); to direct (ex. "Go in there."); to label (ex. "That a mommy.)
and to describe (ex. "Here a big sheep.").
Gregory's sentence length/complexity and grammar skills were below age
expectations.
The GFTA was administered to assess speech sound production at the single word
level. The following results were obtained. Overall speech intelligibility in connected
speech was judged to be poor.
Speech and Language Evaluation - Gregory Milletics
Target Initial
Sound Position
P
m
n
b
9 d glottal stop/g
k t glottal stop/k
f t glottal stop/f
ng
Y
t
sh
ch
j
th(voiceless)
V
s
z
th(voiced)
1/y
Medial
Position
t/p
omission
d/n
d/b
d/g
w/k
t/f
omission
d/sh d/sh
t glottal stop/ch d/ch
w/r Ur
d/j
of glottal stop/th omission
w/v d/v
d glottal stop/s d/s
I/z d/z
I/th d/th
Final
Position
omission
omission
omission
omission
omission
omission
omission
omission
omission
omission
omission
distortion
omission
omission
omission
omission
omission
Page 3
Gregory also produced the following consonant blend substitutions in the initial
position of words: b/bl, b/br, d/dr, t glottal stop/kr, p glottal stop/pl, t glottal stop/skw, t
glottal stop/sl, t glottal stop/st, t/tr.
In the initial position of words, Gregory frequently followed production of a stop plosive
/t,d,p/ with a glottal stop. He demonstrated vowel distortions (ex. heh/house; ne/knife).
He also demonstrated the following phonologic processing errors which are expected
to be eliminated in the 3rd and 4th years.
- final consonant deletion (3rd year): omission of final sounds from words/syllables
(ex. heh/house)
- stopping (3rd year): stopping air on production of continuous air sounds (ex.
didah/scissors)
- velar fronting (4th year): use of front sounds /d,t/ for back sounds /k,g/ (ex. du/gun)
- cluster reduction (4th year): omission of one sound from consonant blends (ex.
boo/blue)
Gregory was not cooperative for sound stimulability testing or for an oral peripheral
examination. He did imitate single word productions, when he did not know the label
Speech and Language Evaluation - Gregory Milletics Page 4
for a picture. His word imitations were generally close approximations of the word
given. Verbal imitation skills appeared to be good.
Vocal quality and fluency skills were judged to be within normal limits.
SUMMARY
Gregory is a 3 year, 6 month old child who displayed an expressive language delay
and poor speech intelligibility. The following communication strengths and needs
were identified.
Strenaths
- average receptive languag? skills
- average expressive language content/use
- verbal imitation skills ,
- age appropriate vocal quality and fluency skills
Needs:
- develop sound facilitating oral postures
- associate sound production with sound facilitating postures
- develop sound production in CV combinations; CVCV combinations; words and
sentences
- develop ability to identify correct/incorrect sound production,
- develop 3-5 word combinations for a variety of communicative intentions
- parent training to facilitate carry over of therapy targets to all settings
RECOMMENDATIONS
It is recommended that Gregory receive speech/language therapy 2 times per week.
This should be part of his Head Start Program if he is accepted into the program.
Parent training to facilitate carry over of speech/language goals to the home setting is
also recommended.
?I ?\J
Kathleen Wertley, M.A., CC C/SL-
Speech and Language Pathologist
1605-B West Main Street
Norristown, Pa. 19403
Montgomery County Intermediate Unit
Early Intervention Program
Phone: (610) 539-8550
Fax: (610) 539-3893
COMPREHENSIVE EVALUATION REPORT
_J___ Initial Evaluation
____Reevaluation
CHILD'S NAME: GREGORY MILLETICS DATE OF BIRTH: 1/18/96
Guardian: Karen Kambia Phone: (h) 215-256-6954
Address: 327 Shirley Drive
Harleysville, Pa. 19438
School District: Souderton Other Information (as needed):N/A
Date Permission to Evaluate/Reevaluate Received: 5/20/99
Date of Completion of Multidisciplinary Evaluation: 8/10/99
Date of Comprehensive Evaluation Report: 8/11/99
1. Reason for Referral:
Gregory was referred for multidisciplinary assessment to assist in determining
eligibility for services as his mother had concerns about his overall development.
II. History:
A. Early Intervention History
VY
Gregory has no known diagnosis. He has not received Early Intervention
services to date.
B. Education, Social, and Physical History
Reportedly, Gregory is the product of an uncomplicated 39 week pregnancy
with a birth weight of 6 lbs., 5 oz. Ms. Kambia reported that there was a slowing of his
heartbeat during the delivery but there were no problems at birth other than mild jaundice.
There is no reported history of serious accidentlillness; hospitalization; feeding/swallowing
difficulty or chronic ear infections. Ms. Kambia reported that she suspects Gregory may have
seasonal allergies but he has not been formally diagnosed. His hearing was tested on 5-20-
99. Results indicated that hearing is adequate for speech/language development.
Emergence of developmental milestones was reported as follows: sifting unsupported at 6
months; walking at 14 months; first words at 18 months. Gregory has not participated in an
educational preschool program to date. His mother is exploring the possibility of enrolling
him in a Head Start Program for the fall. He currently lives with his mother and younger
brother half of the time and his father the other half.
DATE: 8/11/99 CHILD'S NAME: GREGORY MILLETICS
III. Information from the family (parents or other persons with whom the child lives)
A. Child's strengths and needs including physical condition, cultural and language
considerations, and adaptive behavior
Gregory reportedly lives with his mother and younger brother half of the time and his
father half of the time. English is the primary language spoken in the home. Ms. Kambia
reported that Gregory gets along well with others; is well liked, considerate and sweet. She
reported that he has pretty good motor skills; is intelligent and tries to figure out the way
things work. She also reported that he needs to learn to share; feed himself; go to the
bathroom on the toilet and finish his words. He also needs to not cry at simple requests and
to listen and comply better.
B. Family-perceived strengths and needs which will enhance the development of
the child
Ms. Kambia reported that Gregory goes back and forth between his father's and her
house about every two weeks. She reported that he has supportive grandparents and
relatives at both houses. She reported'that his father works full time and she was going to
school and working full time. She also has a younger son.
IV. Summary of Findings
A. Screening results (initial evaluation only)
AGS EARLY SCREENING PROFILES - 5/20/99- MCIU results reveal the
need for further Speech and Language Evaluation.
Cognitive/Language Profile - standard score 100 (average)
Cognitive Subscale - standard score 101 (average)
Language Subscale - standard score 100 (average)
Motor Profile - standard score 81 (mildly delayed)
Articuiation Survey - below average with poor speech intelligibility
B. Review of current IEP (for reevaluation only)
Not applicable
C. Developmental Assessment
Assessment Instruments and Procedures:
Procedure/Assessment: Speech and Language Evaluation
Date: 8/10/99
MCIU 7198
DATE: 8/11/99
Result:
Assessment
The QQmmunication Screen
Goldman-Fristoe Test of 8nir iar QM)
Structured Photocraohic ore ive L anqllage Test
Informal sampling
CHILD'S NAME: GREGORY MILLETICS
Scores/
Percentile Rank/
kill Area Standard Score
Language/articulation/fluency articulation; expressive
Speech Sound Production language delay
severe delay
Grammar below age norms
Language/Fluency expressive language
Noice/Articulation delay; poor speech
intelligibility
Test results indicate that Gregory is a 3 year, 6 month old child who displayed an expressive
language delay and poor speech intelligibility.
Procedure/Assessment: Audioloiical Evaluation
Date: 5/20i99
Result: Hearing is adequate for speech/language development
2. Narrative (including, but not limited to physical development, cognitive
and sensory development, hearing problems, learning strengths and
educational needs, language and speech development, social and
emotional development, self-help skills, health considerations)
This information is based on the screening results and evaluation noted
in section IV A and C
ocial
Gregory presented as a child who appeared comfortable in these surroundings. He
was not observed initiating interaction with other children. His mother reported that he gets
along well with other children.
Motor
During fine motor tasks, Gregory was able to string 5 beads. Gross motor portions of
the flGS were performed within age expectations. General observation revealed that he
exhibits functional gross motor skills with adequate ability to sit, stand and walk with
coordination.
Communication
Gregory's poor speech intelligibility inhibits his ability to be understood by others. He
combines primarily 2-3 words to make his needs known and make comments.
MCIU 7/98
DATE: 8/11/99 CHILD'S NAME: GREGORY MILLETICS
Categories of Play
Gregory was observed engaging in exploratory, representational and interactive play.
He used toys appropriately and was able to functionally manipulate toys. He did not readily
initiate play with other children including his brother during the evaluation.
Attention Swan
Gregory demonstrated an adequate attention span. However, he was unwilling to
engage in activities that he did not enjoy.
Functional Vision
Gregory's vision appeared adequate for the performance of the visual tasks presented.
There are no reported vision cortcerns.
I
Self HeI12.
Gregory is reportedly beginning to feed
assistance for dressing.
himself. He is not toilet trained and requires
Cognitive/Language Abilities
Gregory demonstrated receptive language skills and expressive contentluse which
were within the average range. Cognitive abilities as measured by developmental screening
were also within age expectations.
D. Observations: (information from observations during daily activities such as
play with other children and interaction with family members and/or other
adults)
While in the playroom, Gregory was observed playing primarily.with toy dinosaurs. He
primarily gathered them and carried them around the room but he did at times pretend that
they were fighting or growling at each other. He played briefly in the kitchen area and
brought a cupcake to the evaluator and said, "Here a cupcake.". He transitioned to the
evaluation room with his mother and younger brother but he was able to separate from-them
upon entering the room. He took the toy dinosaurs with him and refused to separate from
them but placed them on the table. He was generally cooperative for labeling pictures and
answering questions about pictures. He followed one step directions involving object
manipulation. He joined with the evaluator in a spontaneous play activity using a Fischer
Price Farm.
E. Area(s) of Delay:
Expressive language and articulation delay
MCIU 7/98
DATE: 8/11/99 CHILD'S NAME: GREGORY MILLETICS
F. Skills needed by the child to function successfully in variety of settings,
including the home, school, and community
- develop sound facilitating oral postures
- associate sound production with sound facilitating postures
- develop sound production in CV combinations; CVCV combinations; words and
sentences
- develop ability to identify correct/incorrect sound production
- develop 3-5 word combinations for a variety of communicative intentions
- parent training to facilitate carry over of therapy targets to all settings
V. Recommendations
A. Recommendations of Eligibility for Early Intervention Services and Programs
1. Team recommends eligibility for early intervention services.
The following, services or programs should be considered by
the IEP team:'
An Early Intervention Program to address Gregory's need in the area of speech
and language. It is recommended that he receive direct speech/language
therapy 2 times per week. This should be part of his Head Start Program if he is
accepted into the program.
2. Team recommends continued eligibility (Attach IEP)
3. Team does not recommend eligibility for early intervention
services. Recommendations for follow-up activities (if any)
are:
B. Recommended Services to meet the family's needs to enhance the child's
development
The Speech/Language Pathologist working with Gregory will provide strategies
to the family to facilitate carry over of therapy goals
MCIU 7/98
DATE: 8/11/99
CHILD'S NAME: GREGORY MILLETICS
MULTIDISCIPLINARY EVALUATION TEAM SIGNATURES
Please indicate your agreement or disagreement with the conclusion or content of this report.
If you disagree, please write the reasons for disagreement and attach them to this report.
SIGNATURE TITLE DATE AGREE DISAGREE
d•C?t/U ?z cne rc Q
This report is a draft until all MDT members (including parents) have reviewed
and signed the report. Any dissenting opinions must be Included.
g-1)--gq
Date CER sent to parents
MCIU 7/98
I . °_J P.7E? P; r 717
Y _
KATHLEEN WERTLEY
1127 Byron Court 215-368-3192 (home)
Lansdale, Pa. 19446 610-539.6550 (office)
EXPERIENCE: Monig_omet C, o. Intgrrnodilto Unn R _, September 1971 - present
Currently, Speech Clinician providing diagnostic )valuations and
therapeutic intervention for preschool children.
Previously, Speech Clinician serving a caseload of 60.75 Students
consisting of regular education, learning disabled, emotionally
disturbed, language learning disordered and developmentally
delayed students in a public school setting
fast co-chair of staff Committee on Mental Retardalion. participant
in Committee for Classroom Language Stimulation, Language
Committee, Materials Committee. Diagnostic Cvnvmittea,
Committee for Staff Development and Staff Advisory Council.
Member of Preschool Assistive Technology Core Team
Field supervisor for students-in-training from area universities.
Clinical Fellowship Year Supervisor for ASHA Certification.
Developed and presented parent and teacher workshops in local
school districts.
Contributed to the development of staff manuals and checklists.
Criteria for as2 Spleetion and ismiss,all (regular education
population, LD/EMR population, TMR/SPMR population and
preschool population); In-Service Workshons for Teachers an
Parents: MQU I.n[grmal Soeech and Language Checklist For Early
Interven
Supervision of a paraprofessional throughout a three year Federal
Project exploring the use of paraprofessrunals in a public school
speech/language program.
EDUCATION
Tgm it Universi Phdadol?hia _PA,
M. A in Speech Pathology, 1971
B. A in Speech Pathology. 1969
RECEIVED t1AlE
?- 1
10/12/99 07:44 fRorl
610+539+J893
DEFENDANT'S
EXHIBIT
c?.GL. II."I'EP"P Tli
KATHLEEN WERTLEY Page Two
FDl1CATION. PAR&Y_Ivania State University
Completed Supervisory Cerdtleation Program in Special
Education (21 credits). 1990
Participant in Assistive Technology Training related to Core
Team Membership
Participant in continuing education short courses and
workshops.
PROFESSIONAL Certiticato of Clinical Cornnr'tencn in.$J).f?ech F'athol=
CERTIFICATES.
awarded 1/1/73
Pennsylvania TeachinCertiticate=lInstructional II_In S eF h
Correction
awarded 5/74
PeDingy]y ania.Lic for,Speech Lan auagLPathologist
awarded 5/86
Per Lsvlvania SupgrvisOr Gertificate in SpecL Education
awarded 8/90
PROFESSIONAL Americdn S ee h Lan ua a HeaQD Association
AFFILIATIONS:
member 1971 - present
Speech Lanauaoe AMs_ociation of Mcntgome Count
member 1996 - present
RECEIVED UAIE : 10/12/99 07:44 I-Mi :610+539+3893
SCOTT R. MILLETICS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
KAREN E. KAMPIA,
Defendant NO. 99-5236 CIVIL TERM
ORDER OF COURT
AND NOW, this 361 day of September, 1999, upon consideration of Plaintiff's
Petition for Emergency Relief, a hearing is scheduled for Tuesday, October 12, 1999, at
9:00 a.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania.
BY THE COURT,
J/ esley Oler, J /
Sandra L. Meilton, Esq.
P.O. Box 889
Harrisburg, PA 17108
Attorney for Plaintiff
Karen Kampia
327 Shirley Drive
Harleysville, PA 19438
Defendant, Pro Se
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0
SCOTT R. MILLETICS,
Plaintiff
V.
KAREN E. KAMPIA,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN CUSTODY
NO. 99-5236 Civil
ORDER
AND NOW, this day of
the within petition, it is
1999, upon consideration of
HEREBY ORDERED AND DECREED that present physical custody schedule being
observed by the parents of Gregory Scott Milletics shall be maintained, i.e. alternating custody on
a two week schedule (September 19, 1999 through October 3, 1999 with Father; October 3, 1999
through October 17, 1999 with Mother, and continuing on the same schedule thereafter), until final
resolution either through a custody conciliation conference or Court hearing, if necessary.
BY THE COURT:
21532.1
J.
d'`i
SCOTT R. MILLETICS, : IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
KAREN E. KAMPIA, IN CUSTODY
Defendant NO. 99-5236 Civil
PETITION FOR EMERGENCY RELIEF
AND NOW, comes Scott R. Milletics, Plaintiff, by and through his attorney, Sandra L.
Meilton, of Tucker Arensberg & Swartz, and petitions this Honorable Court as follows:
1. Plaintiff and Defendant are the parents of a minor son, Gregory Scott Milletics, I
born January 18, 1996.
2. The parties have been operating on a shared arrangement of physical custody of
their son, Gregory, alternating custody of him every two weeks.
3. A Complaint for Custody was filed with the Court on August 26, 1999 to have the
custody situation reviewed so that a primary custody location may be established prior to the
beginning of school in September, 2000.
4. A custody conference has been set before Michael L. Bangs, Custody
Conference Officer, to be held on October 28, 1999.
5. Defendant has subsequently advised Plaintiff that she has enrolled Gregory in
school even though he is only presently 3 % years old.
6. The current custodial arrangement is that Plaintiff has custody of Gregory from
September 19, 1999 through October 3, 1999 and Mother has custody of Gregory from
October 3, 1999 through October 17, 1999, alternating thereafter on said two week schedule.
7. Plaintiff desires to assure that Gregory continues to have good meaningful
contact with both parents and that the status quo is maintained until this matter is resolved
either at the custody conciliation conference level or through hearing with the Court.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Interim
Order confirming the current arrangement of the alternating two week schedule of custody of
Gregory until the matter is ultimately resolved through a conciliation conference or Court
hearing.
TUCKER ARENSBERG & SWARTZ
By: - ;°
Sandra L. Meil n, No. 32551 `
P.O. Box 889, Harrisburg, PA 17108
(717) 234-4121
Dated:/ - Gl ?/ Attorneys for Plaintiff, Scott R. Milletics
VERIFICATION
I, Scott R. Milletics, acknowledge that the facts stated in
the within document are true and correct to the best of my knowledge,
information and belief.
I understand that any false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn
falsification to authorities.
cot R. Mi letics
DATED:
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SCOTT R. MILLETICS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
Y ;2EN E. KAMPIA,
Defendant No. 99-5236 CIVIL TERM
ORDER OF COURT
AND NOW, this 12th day of October, 1999,
upon consideration of Plaintiff's Petition for Emergency
Relief, and following a hearing, the petition is granted to
the extent that the alternating two-week periods of
custody, which have been the custom of the parties, shall
continue pending the custody conciliation conference on
October 28, 1999, and further order of Court.
The parties are encouraged to communicate
with each other with respect to speech therapy for the
parties' child.
By the Court,
Sandra L. Meilton, Esquire
For the Plaintiff
Michael Pykosh, Esquire
For the Defendant
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J •Wesley Olejkl Jr.,
(/ .A. P.
* ScoN 2? NCI\C?i CS
Plaintiff
V.
* K.a?,? E , ?C,otv\P t a
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
: CIVIL ACTION LAW
NO. Sc)3b CIVIL 19C(9
CUSTODY VISITATION
And now, this IN U) I D , upon consideration of the attached complaint, it is hereby directed
that the above parties and their respective counssell appear before Mt(h0 r L, ?S1G5
Esquire, the conciliator, at 3
Pennsylvania, on the \ f-?, day of .Y3ti n cal ,)=.at IV, 00 4gD/ P.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 into a temporary order. All children age five or older maybe 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: 1d
Custody Conciliator t 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.
THE CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
1-800-990-9108
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SCOTT R. MILLETICS, : IN THE COURT OF COMMON
Plaintiff : PLEAS, CUMBERLAND COUNTY,
: PENNSYLVANIA
V.
CIVIL ACTION-LAW
KAREN E. KAMPIA,
Defendant : IN CUSTODY
: NO. 99-5236
AND NOW this _ day of 1999, it is hereby ordered
that primary Physical custody of the subject minor, Gregory Scott Milletics, shall be with
his mother, Karen E. Kampia until final resolution; either through a custody conciliation
conference or a court hearing if necessary.
By The Court:
J.
SCOTT R. MILLETICS, : IN THE COURT OF COMMON
Plaintiff : PLEAS, CUMBERLAND COUNTY,
: PENNSYLVANIA
V.
KAREN E. KAMPIA,
: CIVIL ACTION -LAW
Defendant : IN CUSTODY
: NO. 99-5236
RESPONSE TO PLAINTIFF'S PETITION FOR EMERGENCY RVIRE
AND NOW comes Karen E. Kampia, Defendant, by and through her attorney the
Law Office of Darrell C. Dethlefs, and in answer to Plaintiffs Petition avers as follows:
1. Admitted.
2. Admitted in part and denied in part. It is admitted that the parties have been
operating on a shared arrangement of physical custody of their son, Gregory. It is
denied that the alternating times for custody were exacting two week periods.
3. Admitted. It is admitted that a complaint for custody was filed with the Court
on August 26, 1999. The complaint is a written document of which the content
speaks for itself.
4. Admitted.
5. Admitted in part and denied in part. It is admitted that Defendant enrolled
Gregory in the Head Start Program. It is denied that Defendant knew anything
about the filing of the custody complaint at the time when Gregory was enrolled in
Head Start. It is further denied that Gregory is too young to be enrolled in the
Head Start Program.
6. Admitted in part and denied in part. It is admitted that Plaintiff and Defendant
have been working on a shared schedule of physical custody with respect to
Gregory. It is denied that said shared arrangement was always for a two week
period.
7. The allegation as set forth in Paragraph 7 constitutes a Conclusion of Law to
which no response is required. If the court should require a response, it is denied
that Plaintiff desires to assure that Gregory continues to have good meaningful
contact with both parents and that the status quo is maintained until this matter is
resolved either by a custody conciliation conference or through a hearing with the
court.
WHEREFORE, Defendant respectfully requests that this Honorable Court enter
an Interim Order awarding primary physical custody of Gregory to Defendant mother so
that he may remain in the Head Start Program and receive the necessary therapy that he
requires.
AND NOW comes Defendant, Karen Kampia, who in further support of her
answer to Plaintiff's Petition pleads the following new matter:
1. Gregory Milletics was evaluated by the Montgomery County Intermediate Unit
and was found to have a need for speech therapy.
2. The minor child obtains this needed therapy through the Head Start Program.
2. The Head Start Program in which Gregory is presently enrolled has helped the
aibresaid child with his self esteem and confidence.
4. The best interest of the minor child, Gregory Milletics, would be best served by
awarding primary physical custody to Defendant and allowing Gregory to remain
in the Head Start Program.
WHEREFORE, Defendant respectfully requests that primary physical custody of
Gregory Milletics be awarded to Defendant and the child remain in the Head Start
Program.
Michael J. Pyko
Attorney I.D. 851
3805 Market Street
P.O. Box 368
Camp Hill, Pa 17001-0368
(717)975-9446
SCOTT R. MILLETICS, IN THE COURT OF COMMON
Plaintiff PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
V.
No. 99-5236
KAREN E. KAMPIA,
Defendant IN CUS'DDY
I hereby verify that the statements of fact made in the foregoing DOCUMENTS,
are true and correct to the best of my knowledge, information and belief. I understand
that any false statements therein are subject to the criminal penalties contained in 18 Pa C.
S. Section 4904, relating to unworn fasification to authorities.
Date: r2 rl
Karen E. Kampia
SCOTT R. MILLETICS, : IN THE COURT OF COMMON
Plaintiff : PLEAS, CUMBERLAND COUNTY,
: PENNSYLVANIA
v. •
CIVIL ACTION -LAW
KAREN E. KAMPIA,
Defendant : IN CUSTODY
: NO. 99-5236
I hereby certify that the foregoing Petition and New Matter in the above captioned
matter was served upon the following by United States First Class Mail
Sandra L. Meilton, Esquire
P.O. Box 889
Harrisburg, Pa 17108
Respectfully Submitted by:
2-ic ael J. Pykosh
Date: lC4(Qp I Attorney I.D. 58851
P.O. Box 368
Camp Hill, Pa 17001-0368
(717)975-9446
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SCOTT R. MILLETICS,
Plaintiff
vs.
BY THE COURT,
KARENE. KAMPIA,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 99-5236 CIVIL TERM
CIVIL ACTION-LAW
ORDER
AND NOW, this 2 0?? day of .T.t-y? C 2000, upon receipt of the
Conciliator's Report, it appearing that a hearing is necessary, it is hereby ordered and directed as
follows:
1. A hearing is scheduled for the 1 day of?
2000, at / . 30 o'clock P.M., in Court Room Number / of the
Cumberland County Court House, Carlisle, Pennsylvania. Both parties, through
counsel, will provide each other and the court with a list of witnesses ten (10)
days prior to the date of the hearing along with a statement as to their expected
testimony. Additionally, both parties will submit their proposal for a resolution of
the matter.
Sandra L. Meilton, Esquire
Michael Pykosh, Esquire
mlb
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-SLEY OLE R. J.
40?) V
SCOTT R. MILLETICS,
Plaintiff
VS.
KAREN E. KAMPIA,
Defendant
JUDGE PREVIOUSLY ASSIGNED:
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 99-5236 CIVIL TERM
CIVIL ACTION-LAW
The Honorable J. Wesley Oler, Jr.
CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the child(ren) who is(are) the subject of this
litigation is as follows:
NAME BIRTHDATE CURRENTLYIN
CUSTODY OF
Gregory Scott Milletics January 18, 1996
2. A Conciliation Conference was held on May 25, 2000, and the following individuals
were present: the Plaintiff and his attorney, Sandra L. Meilton, Esquire; the Defendant and her
attorney, Michael Pykosh, Esquire.
3. Items resolved by agreement: See attached Order.
4. Issues yet to be resolved: See attached Order.
5. The Plaintiffs position on custody is as follows: Father, as well as Mother, have been
working on a two week on, two week off schedule with the child since the child was six months
old. Father lives in Mechanicsburg and Mother lives near Philadelphia. Since the child is
approaching school (apparently the child is in K4 or pre-kindergarten this fall), the parties want
to modify the existing schedule because it will not work. Father's position is that he is better
suited to have the child here during the school year. Father works locally for Bell and lives with
his mother and father. His mother provides the daycare for the child. He notes that the parties
resided together here and it is the Mother who removed herself from the area. He does not have
any complaints with the Mother but he feels that he is better suited to be the primary custodial
parent during the school year.
6. The Defendant's position on custody is as follows: Mother reiterates the position of
the Father in that they need a change of the existing Order. She lives with her father, sister, and
a special-needs brother. She works at the International House of Pancakes. Mother also has
another child who was born on December 25, 1997. She has a shared custodial arrangement with
that child's natural father. Apparently, the natural father lives close to the Mother near
Philadelphia. This child was, of course, bom after the parties split up.
Mother believes that she should have the child during the school year and that she is
better able to care for the child during the school year.
7. Need for separate counsel to represent child(ren): Neither party requested.
8. Need for independent psychological evaluation or counseling: None requested and the
Conciliator does not believe any is necessary.
9. A hearing in this matter will take four hours.
10. Other matters or comments: This is a case where there are two caring parents who
really have nothing negative to say about each other. Unfortunately, however, the parties live
some distance apart and as school approaches, someone needs to be the custodial parent during
the school year. The Conciliator explained to counsel (who have also apparently explained to
their clients) that the Court in all likelihood will maintain a shared arrangement but simply will
modify it so that someone has primary custody during the school year and the other parent will
have primary custody during the holidays and summer months. Additionally, since the parties
live so close, it is the perfect situation whereby the parent who is the non-custodial parent during
the school year should have more regular weekend visitation, perhaps rotating on a three on, one
off basis, so that the parties still have a pure shared arrangement as they are operating under now.
The parties have been working on a two week on, two week off schedule since the child
was six months old. The Mother did remove herself from Mechanicsburg to Philadelphia so the
Court will have to inquire as to why that occurred and if that should be a factor in its
determination as to who should have primary custody of the child during the school year.
Unfortunately, because of the Father's job and because of Mother's other child, neither one has
the ability to move and the Court simply has to make a decision as to who is going to be the
primary custodian of the child while the child is in school.
Given the fact that there is not any fitness issues or other unusual issues, the Court should
not have to take a lot of testimony in this case.
Date: June 13, 2000 6? Z
Micha I L. Bangs
Custody Conciliator
JUN 19 2CO12
SCOTT R. MILLETICS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
KAREN E. KAMPIA,
Defendant No. 99-5236 CIVIL TERM
IN RE: PLAINTIFF'S COMPLAINT FOR CUSTODY
BEFORE OLER. J
ORDER OF COURT
AND NOW, this 1st day of September, 2000,
upon consideration of Plaintiff's complaint for custody
with respect to the parties' child, Gregory Scott Milletics
(date of birth, January 18, 1996), and following a hearing
held on August 31, 2000, it is ordered and directed as
follows:
1. Legal custody of the child shall be
shared by the parties.
2. Primary physical custody of the child
shall be in the mother.
3. Temporary or partial physical custody of
the child shall be in the father at the following times:
a. On alternating weekends, from
Friday at 7:00 p.m. until Sunday at
5:00 p.m.; provided, that when a
federal holiday falls on a Monday
on such a weekend, the period of
partial or temporary physical
custody shall extend to Monday at
5:00 P.M.
b. During Christmas vacation, from
December 26 at 5:00 p.m. until
January 2 at 3:00 p.m.
4. Notwithstanding the foregoing, during the
summer, the father shall have custody of the child for five
consecutive weeks at the beginning of the summer and five
consecutive weeks at the end of the summer; the mother
shall have custody of the child for one week between the
said five-week periods.
5. Transportation of the child shall be the
responsibility of the parent receiving custody.
6. Nothing herein is intended to preclude the
parties from varying the terms of this order by mutual
agreement.
By the court,
ley Oler, J,
Sandra L. Meilton, Esquire V
P.O. Box 889
Harrisburg, PA 17108
For the Plaintiff
Michael Pykosh, Esquire /-"-
3805 Market Street
Camp Hill, PA 17011
For the Defendant R?5
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