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HomeMy WebLinkAbout99-06098 (2) Y s y p x sxf r.a x'Y t t K ?r?E v? ? I s i f°' axe 4 i cz j>3 +r ??. ??1 n f ? ST ??? ?4 at 1 f s. i r ???fil ?? t to 14 i .a 'f?'^xs?y r s ? ? - x. ei?YS``.' v, hP W lj f +t pl ?nYf4?n1P t 5Z. ?" Wpb{ : - e ?4 ?!'lj`° ate i r to t7 t# tx '_1 14% Xl 1 $. ?pdZPt .? ? S t a!? . 9 ?ix1Y5 "4r 1 ? i#<<. a`f?4 t 5 _ . i d Y1 !` Ar^ ti.c w y ? _ A apt e R 1 15- L t ?i Ri r Y fi: n,5 y x A F3 l !k r ?4Fiht w.,.yl 'r r, FEB 2 8 2003 ?I!J.?CNA?,I._-(hf?Tt?SKY. !?NTNF_Cou? oF?oMn?o?1s - --- I'LlI 'ns ts? ;CSFW/Y7BFI JA nR-MR, O F ZOUR 7 42A fCA , aog3 USN 6.F ?-MEy?-?Eti?- -----M-,,..,?-?u,-you 3---.,?- g: 3d--?•.M-.,___------ `` .?Ilfgt!77, MIAMI a2T J.. (Y1z4H9?1?.('nHT??sk?? ---- SN TH£_(1»OF Com noo _.?IAiN?i? i0F ?t?M3 LAND LDUti1TY __ __.__._..___ ____ _ _? P?NNSYLVAN=A_.._ -------------------- SON OR EmERG.ENCL MielvAf_I _n?a-f{eskJ__l?ho_efsI pA ?. ??A__ 11 P?? ? _k?ssa?__ w S+ ?_Cum?cl2?gr.1?_?Q?N7IJ_) 'CFNNS?)??A?vifti?CS ?R??/ns'?'NN_cr5._ ?''lil?" .1_._I?f??fvE--_wAr?e????_?t;s ?4???? ---- -- f?_?il? hffn?__UNt_jG T6? £x?FN?_f???_i.?. ?f?s_. c so b?v --- _ _ -__ {'tlE?t} c?/ENFJfa2._.ZI1-u5 ceca+o_ AN U.?S><AdIF S?vvii2G?T7ri?? fire hdA Ai L1); W At,)ci 41,- c - ----------- ?1o-?l?frZ ?r3_ ?fsklcss__.f?c?a!vc?F,?,,.E,v? __Ir? _c?I.i?. CF??f?2__??x,ti?s AAC I /L'O (:.tit Ll OU ?! ??E ??r?^_? ?D £7 J hr b-11 _?UU C .1? /??.iss _CO6.``. LRFAjjNq pN vN_: N TUB. f't_4?±??y ?J--;ZOU? _-!'R`??If?2.WA5 _hoMc_.J CifU.£ C?At?`?+tr2 A'? _y.3G ?r? -} 4 CJAuc?I1 f CYIS?RESS NN? ???-nl'?'ivn±A' .q?5??? 1?! ?1 . -- - - CR?_.__4N_r'aII C?Ar ??}eit_yN _AOCAV -8N( t 34 r '. 1"???CI'??I.[?1j?CS?c.?,._ _- _ ____.. ;?1?.?t1? Cc?l;,Ct_O? CC:?,m?'Y?c2YU rJ1EC?._._._.._ . f, . CC??tt?,_(??Y1?'Yl(,vi. EganC4 ' lveS -U.? L -A).L1- w wuq 1aLO..eP L* MICHAEL E. MATTESKY, Plaintiff V. TINA MARIE KASSAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 99-6098 CIVIL TERM ORDER OF COURT AND NOW, this let day of November, 2002, after hearing, it is hereby ordered and directed as follows: 1. All prior custody orders are vacated. 2. The parties shall have shared legal custody of their daughter, Brianna Marie Mattesky, born June 28, 1998. 3. Mother shall have primary physical custody of the child subject to periods of partial of custody in father as follows: (a) From today after daycare or school until the commencement of daycare on, \ Tuesday, November 5, 2002. \f (b) Every other weekend from Thursday at 4:30 p.m. until the commencement of daycare or school the following Monday. Said periods to begin Thursday, November 7, 2002. Provided, however, if said visitation occurs on Mother's Day :weekend, father shall return the child by 9:00 a.m. on Sunday, rather than on Monday. (c) Every Tuesday, from 4:30 p.m. until 8:00 p.m. (d) At such other times as the parties agree. 4. Father shall have partial custody of the child on the following holidays: (a) Thanksgiving in even numbered years from 4:00 p.m. on Thanksgiving Day until 8:00 a.m. the morning after. (b) Thanksgiving in odd numbered years from 4:30 p.m. the day before Thanksgiving until 4:00 p.m. on Thanksgiving Day. (c) Christmas in even numbered years from 4:00 p.m. on Christmas Eve until noon on Christmas Day. (d) Christmas in odd numbered years from noon on Christmas Day until 8:00 a.m. the day after Christmas. (e) Every Father's Day weekend from Saturday before Father's Day at 5:00 p.m. until Monday after Father's Day at 8:00 a.m. (f) From 9:00 a.m. to 8:00 p.m. on the following holidays on an alternating basis: New Year's Day, Easter, Memorial Day, July 4 and Labor Day. 5. Father is not to drink any alcohol or use any drugs whatsoever at any time during the period he has partial physical custody of the child, nor is he to allow anyone in his home to use drugs or alcohol during said times. 6. Neither parties shall disparage the other in front of the child, nor shall either party discuss this case in front of the child. By the Edward E. Guido, J. Michael E. Mattesky, Pro se Karl Rominger, Esquire For the Defendant It I hor' >.°t my ::end n d It I3 v; ...,.: t' i .: r?!; ?C, C-a. Th)a G - . Wy ( `L-21 dl? -HBO t minairitari r a ? \ 7 ?. ? r? t : y- t, `1 `? ? ( ?= C?`??'l N ,y. ...)tf t)4 1 ? 7 E;{? ? x: ?;? .r M r ??; ? ?.. 1 r , ? {'rI? N 1!_ ? ?i ? _? >. ?,. ?V i ?41 ,L,? ?, V C 1 1 .. ??? 1 1 v rid 6?? V ? t f . .??h+?. {+r ?i ak }'y'?i r? 5 e ? i N?'? `X?{{. }!{° ??.y r ? • /i JAN. 30. 100 3:26PM CUMBERLAND CNTY 911 Ca r I i sl e, Pa N0.4955 P. 1 #Prina acreenicumu i3) for "cacl9" on "NPCNWS64" at 30Jan2OO3 03:21:17 PM PAGE 1 OF CUM213-58515 - CHR 01/30/03 15:21:07 - 01/30/03 15:21:07'BTi R1ABXD5MW 1 *** RESPONSE FROM PA COMPUTERIZED CRIMINAL HISTORY FILE •++ ORI/PA021CYS1.NAM/MATTESKY,MICHAEL E DOB/19690426.ANG/ . SOC/187649035.OTN/ FBI/ SID/ FUR/C.ATN/LAMMEY OPR/. *** RESPONSE FROM PA CCHRI - BASED ON IDENTIFIERS ABOVE •++ NAM/MATTESKY,MICHAEL EDWARD DOB/04261969. SEX/M. RAC/W. DNA/N. SID/210-87-08-4. FBI/338624KA3. III/M. RAP STATUS/AUTOMATED HGT/509. WGT/175. HAI/BLN. EYE/BRO. PRO-PAR MAX/06302004. CPIN PHOTO ON FILE SOC/187649035. OTN/E383687-3:E679595-O:E679669-4:E016572-3:F138135-4tP271887-O:LO45310-6: H424927-6:L101547-5. OTHER NAMES/MATTESKY,MICHAEL E :MATTESKY,MIKE THIS CCHRI RECORD LAST UPDATED : 01072003 FINGERPRINTS REQUIRED FOR POSITIVE ID -Print: JAN. 30, fi003r:a3:26P or CUUQul" u:CNT:vrainnoa- a,- SOJan2003 03: Nj':4955PMP 3 CUM213-58516 - CHR PAGE 1 OF 7 01/30/03 15:23:15 - 01/30/03 15:23:1S BTJR2ABXD6M4 SP4-1378 PENNSYLVANIA STATE POLICE CENTRAL REPOSITORY 1800 ELMERTON AVENUE HARRISBURG, PENNSYLVANIA 17110 717-757-9092 ATTN: LAMMEY ORI: PA021CYSI CUMBERLAND CO.CHILDREN & YOUTH -- w w -r M _ USE OF THE FOLLOWING CRIMINAL HISTORY RECORD FOR *** SID/210187-08-4 +•+ REGULATED BY ACT 47, AS AMENDED. *** III - MULTIPLE STATE OFFENDER *** --------------------- ------w---- DOB: 04/26/1969 SEX: M RAC: W SOC: 187-64-9035 FBI: 338624KA3 --------------------------------------------------------------- --------------- NAME: MATTESKY,MICHAEL EDWARD OTN: 2383687-3 ARRESTED: 06/27/1992 PAPSPS100 SOMERSET PSP TURNPIKE OCA: T6639 DISPOSITION DATE: 12/28/1992 COMMON PLEAS DOCKET: 521 1992 06/27/1992 CS13A16 VIO CS/DRUG/DEV & COSMETIC ACT NOLLE PROiSED/WITHDRAWN 002 CTS - M -Print JOuLee kk um 1j) or t,caav,, onNTiar?NwnbdV at PjoJan2003 03:;d 4;dv PM P' 4 SAN: BTJRIABXD6M4 PAGE 2 OF 7 06/27/1992 CS13A16 VIO CS/DRUG/DEV & COSMETIC ACT PLEAD GUILTY M COUNTY PROBATION COSTS 06/27/1992 CS13A16 VIO CS/DRUG/DEV & COSMETIC ACT PLNEAD GUILTYWITH CS13A16 M COUNTY PROBATION 01 YR COSTS 06/27/1992 CS13A16 VIO CS/DRUG/DEV & COSMETIC ACT PLEAD GUILTYWITH CS13A16 - M COUNTY PRISON 26 DYS - 12 DYS FINES AND'COSTS 06/27/1992 CS13A31 VIO CS/DRUG/DEV & COSMETIC ACT NOLLE PROSSED/WITHDRAWN M 06/27/1992 CS13A32 VIO CS/DRUG/DEV & COSMETIC ACT NOLLE PROSSED/WITHDRAWN - M PAROLE INFORMATIONt CUMBERLAND COUNTY PROBATION iOCAt 29,80 EFFECTIVE: 06/11/1993 MAXIMUM: 06/11/1994 NAMEt MATTESKY,MICHAEL E OTNt E679595-0 ARRESTEDt 04/11/1994 PA0210200 CARLISLE PD ! OCA: 940508 PrintJacreen0k?UMtijjP or "camp-NonN"f4eC WSb4" at Pj0Jen2003 03;41:Jj5PMP 5 SAN; BTJRIABRD6M4 PAGE 3 OF 7 DISPOSITION DATE, 05/31/1994 COMMON PLEAS DOCKET: 94722 01/31/1994 CS13A30 VIO CS/DRUG/DEV & COSMETIC ACT QUASHED/DVSMIS/DEMUR SUS - F 01/31/1994 CS13A30 VIO CS/DRUG/DEV & COSMETIC ACT PLEAD GUITiTY - F COUNTY PRISON 09 MOS - 18 MOS COSTS RESTITUTION +++++++++»++++++++++++++»+++++++++++++++++++++++++++++++++++++.H+++++++++++.+»»+ NAME: MATTESKY,MICHAEL E OTN: E679669-4 ARRESTED: 04/28/1994 PA0210200 CARLISLE PD 4 OCA: 9406007 DISPOSITION DATE: 08/30/1994 COMMON PLEAS DOCKET: 941027 04/28/1994 CS13A31 VIO CS/DRUG/DEV & COSMETIC ACT QUASHED/DISMIS/DEMUR SUS M 04/28/1994 CS13A32 VIO CS/DRUG/DEV & COSMETIC ACT PLEAD GUILTY M COUNTY PROBATION COSTS NAME: MATTESKY,MICHAEL E OTN: 8016572-3 ARRESTED: 11/23/1995 PA0362600 MOUNT JOY TWP PD OCA; 951993 : r'u ? z Print JAA i 0, J00`ur, 3:27Fmfor CUMnu:011 Ui1N %mv1-awaoyl•? sad Pi0J&n2003 03N 4955 PMP' 6 SAN: BTJRIA13XD6M4 PAGE 4 OF 7 DISPOSITION DATE: 09/18/1996 COMMON PLEAS DOCKET: 0723-1996 11/23/1995 VC1543A DRIVING WHILE SUSP OR REVOKED - S 11/23/1995 VC3731A1 DUI OF ALCOHOL OR CONTLR SUBST - M2 11/23/1995 VC3731A4 DUI OF ALCOHOL OR CONTLR SUBST - M2 11/23/1995 VC3731AS DUI OF ALCOHOL OR CONTLR SUBST - M2 PAROLE INFORMATION: LANCASTER COUNTY PROBATION EFFECTIVE: 09/18/1996 +++++++++++?++++++++++++++++++++++++++f++++++++++++. NAME: MATTESKY,MICHAEL EDWARD OTN: P138135-4 ARRESTED: 06/02/1998 PA0210200 CARLISLE PD 06/02/1998 CS13A31 VIO CS/DRUG/DEV & COSMETIC ACT 06/02/1998 CS13A32 VIO CS/DRUG/DEV & COSMETIC ACT 06/02/1998 CS13A16 VIO CS/DRUG/DEV & COSMETIC ACT 06/02/1998 CS13A30 VIO CS/DRUG/DEV & COSMETIC ACT PLEAD GUILTY FINES AND!:COSTS PLEAD GUILTY COUNTY PRISON 02 DYS - dl YR 11 MOS FINES ANDjCOSTS PLEAD GUILTY I NOLLE PROiSED/WITHDRAWN =A: 1361 MAXIMUM: 08/18/1998 OCA: 199806057 i DISPOSITION NOT RECEIVED • PrintJycreenwume1j)P or?-camv, onN--f4v Nwnbylisa aaoJan2o03 o3:N0.i49S5PMP.7 SAN: BTJRIABXD6M4 PAGE 5 OF 7 PAROLE INFORMATION: CUMBERLAND COUNTY PROBATION OCA: 357811 EFFECTIVE: 04/13/1999 MAXIMUM: 07/02/2003 ++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++#++++++++++++++++ NAME: MATTESKY,MICHAEL EDWARD OTN: F271887-0 ARRESTED: 11/20/1998 PA0210200 CARLISLE PD OCA: 199811821 DISPOSITION DATE: 07/08/1999 DISTRICT JUSTICE: 09201 11/20/1998 CS13A31 VIO CS/DRUG/DEV & COSMETIC ACT PLEAD GUILY M FINES ANDICOSTS 11/20/1998 CS13A32 VIO CS/DRUG/DEV & COSMETIC ACT QUASHED/DFSMIS/DEMUR SUS M 11/20/1998 VC3731AL DUI OF ALCOHOL OR CONTLR SUBST PLEAD GUILTY - M2 COUNTY PRISON FINES AND;COSTS 11/20/1998 VC1543A DRIVING WHILE SUSP OR REVOKED PLEAD GUILTY - S FINES ANDiCOSTS PAROLE INFORMATION: CUMBERLAND COUNTY PROBATION iOCA: 753731A EFFECTIVE: 10/12/1999 MAXIMUM: 44/16/2002 +++++++++++++++*+++++++i•++++++++++++++++++++++++++++++++++++++}++++++++++++++++ NAME: MATTESKY,MICHAEL EDWARD OTN: L045310-6 ARRESTED: 09/22/1999 PA0210200 CARLISLE PD OCA: UNKNOWN DISPOSITION DATE: 11/22/1999 DISTRICT JUSTICE: 09201 I i i. ? •Print bULtfell%,-wa 314j mfor CllvctEu:p" UCNTY?ri?lDo.&.. a`, P;OJan20O3 03:&5.v 5 PMP. 8 SANS BTJRIABXD6M4 PAGE 6 OF 7 09/22/1999 CC2701AI SIMPLE ASSAULT QUASHED/DISMIS/DEMUR SUS 09/22/1999 CC2701A3 SIMPLE ASSAULT QUASHED/DISMIS/DEMUR SUS 09/22/1999 CCO908A PROHIBITED OFFENSIVE WEAPONS NOLLE PR+ED/WITHDRAWN - Ml 09/22/1999 CC2706 TERRORISTIC THREATS - Ml QUASHED/DISMIS/DEMUR SUS NAMES MATTESKY,MICHAEL EDWARD OTNt H424927-6 ARRESTED: 08/30/2001 PA0210200 CARLISLE PD OCA: UNKNOWN DISPOSITION DATE: 12/05/2001 DISTRICT JUSTICE: 09201 08/29/2001 CC2701Al SIMPLE ASSAULT QUASHED/DI SMIS/DEMUR SUS - 08/29/2001 CC5503A1 DISORDERLY CONDUCT QUASHED/DI SMIS/DEMUR SUS 08/29/2001 CC2709AI HARASSMENT - S QUASHED/D ISMIS/DEMUR SUS ++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++ +.++++++++++++++ NAME: MATTESKY,MICHAEL EDWARD OTN: L101547-5 ARRESTED: 09/21/2001 PA0210200 CARLISLE PD ! OCA: UNKNOWN 09/21/2001 VC3731A1 DUI OF ALCOHOL OR CONTLR SUBST DISPOSIT16N UNREPORTED - M2 09/21/2001 VC1543 DRIVING WHILE SUSP OR REVOKED PAROLE INFORMATION: CUMBERLAND COUNTY PROBATION COCA: 753731A 'PrintJScre n?((CUM213)PforCucaEd9m onNTNPCNWSb4I"Sa°ePj10Jan2003 03:x. 49 5PMP.9 SAN: BTJRIABXD6M4 PAGE 7 OF 7 EFFECTIVE: 01/30/2002 MAXIMUM: 06/30/2004 +++++++++++++++++ittrt+++++++tt+++++++++++++++++++++++++++++++t+++++++++t++++Y+ . « «« «< ADDITIONAL IDENTIFIERS >>>>>>»»h AKA'S: MATTESKY,MIKE *** CPIN PHOTO ON FILE *** I F = FELONY, M - MISDEMEANOR, S - SUMMARY AND THE NUMERIC - THEIDEGREE. THIS RESPONSE IS BASED ON REQUESTER FURNISHED INFORMATION AND INCLUDES FINGERPRINT SUPPORTED DATA EXCLUSIVELY FROM THE FILES OF THE PENNSYLVANIA STATE POLICE REPOSITORY. IT DOES NOT PRECLUDE THE EXISTENCE OF OTHER CRIMINAL RECORDS CONTAINED IN THE REPOSITORIES OF OTHER LOCAL,' STATE OR FEDERAL CRIMINAL JUSTICE AGENCIES. i *+* END OF CRIMINAL HISTORY RECORD FOR SID 210-87-08-4 ++* i,. l.. j' i . : I Y' }i Z ..iA .PrintJAN. 30 20033:27PMForCUMBERLAND CNTYV911l?,CarrIisIt P;OJan2003 03::0 4955PMP.10 NO. VA& IF ow-A t: PAGE 1 OF 1 ;' CUM213-58517 - PFA1 01/30/03 15:25:34 - 01/30/03 15:2504 PCIRIABXD7P3 .`•aaaAaaaaaaaaaaaaaaaaaaAaAAAAAAAAAaAAAAAAAAAAA}AAAA}AaAAAAAa}a,}AAa}aaaaaA o''A NEGATIVE RESPONSE DOES NOT MEAN A PROTECTION ORDER HAS NOT B*EN ISSUED, ** A PFA RECORD MAY EXIST BY USING AN "FS QPO" QUERY BY NAM4 ONLY.** UNTIL NOTIFIED, A SECONDARY CHECK SHOULD BE MADE WITH THE COUNTY REGISTRY :?:AAAaaAAaAAA AkAAAA}}AAkAAAAAAAAAAAA}}#AA}}}A}AAAA}}}*}}A}}}}AAA?AAAAAAA1aA NO RECORD SOC/ 187649035 NO RECORD NAM/ MATTESKY,MICHAEL EDWARD DOB/ 19690426. , 1 i t t , i e 0 CUMBERLAND COUNTY, PENNSYLVANIA ADULT PROBATION AND PAROLE DEPARTMENT 1 couaTHOusa sauAAE cAAUSLE. PA 17017 FAX TRANSMISSION SHEET DATE: I • I Y-03 TO: ecC VS FAU FROM: ,ADDRESS: Cumberland County Adult Probation I Courthouse Square Carlisle, PA 17013 FAX 0; (717) 240.6480 Number of Pages: $ (Including Transmission Sheet) If you experience any difficulty in receiving this fax, please call: (717) 240-625$ ##?AA#HH#}Aw}#•#NH•H•H#A#wwA•Hw•NAH}M#A?}wAA•A wA}#•}Aw RA##}Aw##}•AAAA ME.NIO This message is intended only for the use of the individual or entity to which it is addressed and may contain information that is privileged. confidential and exempt from disclosure under applicable law. If the reader of this message is not the intended recipient. you are hereby notified that any dissemination. distribution or copying of this communication is strictly prohibited. If you have received this communication in error. please notify us immediately by telephone (collect), and return the original message to us at the address above via the U.S. Postal Service. (We will reimburse postage.) Thank you. TNApneno A*A Proha6pn ce4wMA4r Tog Rise SNPPWWWrI E00/100'41 66ZZ6 171711404236 FAX 6 Td1AphaM DUO ProOrmw (717) 2406100 (71711400173 140.4410 The rr» West Shoro (717) 6010771 1717) W4164 r?17T fnn7 %T-kWA • • UMBERLAND COUNTY ADULT PROBATION AND PAROLE DEPAR'T'MENT C 1 ITIONS OF? PROBATION, PAROLE AND INTERMEDIATE PUNISHMENT r Uk- { ` Address: -ion CA-A{ ,St_ Ile III 3 Docket # 73--('587 1-1013 he Court has conditionally placed you under the supervision of the Cumberland County Adult Probation and Parole )cpartment. You are required to comply with the conditions set forth below. If you violate any of these conditions, this icpartment his the authority to temporarily detain you in prison, and/or return you to Court for further action. A violation may result in the revocation of your probation, parole, or intermediate punishment and a sentence of imprisonment. 1. You must comply with the laws of the United States, the Commonwealth of Pennsylvania and the community in which you reside. You are required to report any arrests or police contacts, to your supervising officer during the next working day. 1. You are required to maintain regular employment. You must report any changes in your employment status to your supervising officer during the next working day. 3. You must remain on good behavior and refrain from any behavior which presents a danger to yourself or others. You are prohibited from furnishing false statements, written or oral, to your Probation / Parole Officer and must follow your Probation / Parole Officer'& instructions. 4. You may not use or possess any illegal drugs, drug paraphernalia, solvents, or controlled substances without a valid prescription. You are required to submit to testing for substance abuse if directed by this department, and you must pay for any and all testing expenses should you test positive for drug use. Any attempts to adulterate or substitute a urine specimen will constitute a violation of this section and may subject you to arrest on new charges under Title 18, Section 1, Subsection 7509 of the PA Consolidated Statutes. S. You are required to obtain approval from the Adult Probation Department before changing your place of residence, or before leaving the jurisdiction of the Court for longer than A hours. If you are planning on leaving Pennsylvania for any length of time, you must secure a "Travel Permit" before you leave Pennsylvania. 6. You are required to pay all costs, fines and restitution as directed by the Court, Probation / Parole Officer or Collections Officer. All payments must be made to the Clerk of Courts Office. A $25.00 per month supervision fee will be assessed to every defendant unless physically or mentally incapable of maintaining employment or financially overburdened due to factors beyond their control. 7. You agree to a search of your present or future residence, your person, and / or your vehicle, with or without warrant, by any member of this department as deemed necessary for the enforcement of your probation / parole / intermediate punishment conditions. 8. You must report promptly to your supervising officer as follows hdukw 1 r' . 9. You may not have any weapons, Including but not limited to, rifles, handguns or shotguns in your residence or vehicle, while under the supervision of this department. NOTEt If you are convicted of a crime that could have carried a maximum penalty of more thnn 2 years, or involved a firearm or explosive, you are forbidden to own or possess any firearm(s) under the provisions of the Federal Gun Control Act of 1968 and 1986. 10. You will waive extradition to Pennsylvania from any jurisdiction in or outside the United States and will not contest any effort by any jurisdiction to return you to Pennsylvania. ran/700•d 66778 r%:7r rnn7 %T.kwp A • 0 You are required to comply with the following special conditions of your probation, parole or intermediate punishment. ( ) Complete hours of Community Service () Enter Into and/or complete counseling at () Comply with the Electronic Monitoring special conditions (attached) () Abide by set curfews. Weekdays Weekends Until (Date) (.1, Oth H NOTE: The Court may, at anytime, revoke or modify any or all of these conditions. r' Probatloaer Parolee D e Starting Date •Z -0 Expiratlon Date -z- 03 Rev. 6.01 Obtain Drug/Alcoholevaltation," a V.1 U /1.6cu+ti.u () Comply with the Sexual Offenders special conditions (attached) () Comply with the D.U.I. special conditions (attached) () File monthly reports by the S° day of each month. () Comply with Intensive Supervision special conditions (attachedl Coo/Coo'd 66ZZe W Z1 000Z'?t'NVr x CUMBERLAND COUNTY ADULT PROBATION AND PAROLE DEPARTMENT CONDITIONS OF PROBATION, PAROLE AND INTERMEDIATE PUNISHMENT To: M, t'_ "& t tylek S'k , Address: 'Y&-3 N r 3£eJ P? 1 S File A ?_ Std 7 Docket 4 d /--ZrIJ Ate F f?E >?a 1'Zvf The Court has conditionally placed you under the supervision of the Cumberland County Adult Probation and Parole Department. You are required to comply with the conditions set forth below. If you violate any of these conditions, this department has the authority to temporarily detain you in prison, and/or return you to Court for further action. A violation may result in the revocation of your probation, parole, or intermediate punishment and a sentence of imprisonment. You must comply with the laws of the United States, the Commonwealth of Pennsylvania and the community in which you reside. You are required to report any arrests or police contacts, to your supervising officer during the next working day. 2. You are required to maintain regular employment. You must report any changes In your employment status to your supervising officer during the next working day. 3. You must remain on good behavior and refrain from any behavior which presents a danger to yourself or others. You are prohibited from furnishing false statements, written or oral, to your Probation / Parole Officer and must follow your Probation / Parole Officer's instructions. 4. You may not use or possess any illegal drugs, drug paraphernalia, solvents, or controlled substances without a valid prescription. You are required to submit to testing for substance abuse if directed by this department, and you must pay for any and all testing expenses should you test positive for drug use. Any attempts to adulterate or substitute a urine specimen will constitute a violation of this section and may subject you to arrest on new charges under Title 18, Section 1, Subsection 7509 of the PA Consolidated Statutes. 5. You are required to obtain approval from the Adult Probation Department bAfm changing your place of residence, or before leaving the jurisdiction of the Court for longer than -/Z hours. If you are planning on leaving Pennsylvania for any length of time, you must secure a "Travel Pertnlt" before you leave Pennsylvania. 6. You are required to pay all costs, fines and restitution as directed by the Court, Probation / Parole Officer or Collections Officer. All payments must be made to the Clerk of Courts Office. A $25.00 per month supervision fee will be assessed to every defendant unless physically or mentally incapable of maintaining employment or financially overburdened due to factors beyond their control. 7. You agree to a search of your present or fative residence, your person, and / or your vehicle, with or without warrant, by any member of this department as deemed necessary for the enforcement of your probation / parole / intermediate punishment conditions. S. You must report promptly to your supervising officer as follows Qz1&j-,Wty gMtT.S As D1C-9(: h r 9, You may not have any weapons, including but not limited to, rifles, handguns or shotguns in your residence or vehicle, while under the supervision of this department. NOTE: If you are convicted of a crime that could have carried a maximum penalty of more than 2 vears, or involved a firearm or explosive, you are forbidden to own or possess any firearm(s) under the provisions of the Federal Gun Control Act of 1968 and 1986. 10. You will waive extradition to Pennsylvania from any jurisdiction in or outside the United States and will not contest any effort by any jurisdiction to return you to Pennsylvania. ftell L-? on II) yi0-O Coo/100'd Z6ZZs ir:r7 onn7 ?' ??'" SPECIAL CONDITIONS You are required to comply with the following special conditions of your probation, parole or intermediate punishment () Complete hours of Community Service (vl"*Obtain a Drug/Alcohol evaluation () Enter Into and / or complete counseling at () Comply with the Sexual Offenders special conditions (attached) () Comply with the Electronic Monitoring special conditions (attached) () Abide by set curfews, Weekdays Weekends Until (Date) ( ) Other (Wo"Ceomply with the D.U.I. special conditions (attached) (v)'Tile monthly reports by the Sw day of each month. () Comply with Intensive Supa, vision special conditions (attached) NOTE, The Court may, at anytime, revoke or modify any or all of these conditions. 0 0 J?rOntlon Probationer / Parolee Starting Date /r Z j o'L Expiration Date 6'-.; p -oy Rev. 6.01 coo/Uo'd d6ZZa oc:TT Pnne •T-k6A CUMBERLAND COUNTY ADULT PROBATION AND PAROLE DEPARTMENT DRIVING UNDER THE INFLUENCE OFFENSES - SPECIAL CONDITIONS As a condition of your sentence, you are required to comply with the following special conditions of your probation / parole. Note that your signature on the preceding CONDITIONS OF PROBATION, PAROLE AND INTERMEDIATE PUNISHMENT page applies to these conditions as well. You grant your permission for any treatment agency and the Cumberland County Adult Probation and Parole Department to exchange information, written or oral, regarding your case for the duration of your sentence. 2. You must attend, pay for and successfully complete D.U,I. school when directed. 3. You may not consume or possess any alcoholic beverages or illegal drugs. 4. You may not operate a motor vehicle while under suspension from the Pennsylvania Department of Transportation. 5. , You must obtain and pay for an alcohol evaluation and successfully comply with,the recommendations of that evaluation, within three (3) months of your parole date. It is you r responsibility to provide written verification of the completion of these requirements to your Probation / Parole Officer. If all of the D.U.I. requirements are not completed prior to the expiration of your license suspension, your suspension will continue as outlined in Act 122 of 1990. Rev. 3.31.99 nnw lnwn•) ,r„r W s± -_GR-Dk , _OF_COuR i mA ._______:.:d?????1 -f?1A`1" '}\1`c__{??$?NC?£N'?".Lc?Op42A-?_ w'???1_?_?_.:. --W- ioN4pz GJi7h __??%S7C`Ck/ .ss(Cllf}?.g?s .RS dradEr?ECl _Ixj 4he_.. .. _ ?.:.f-i LiN? LL'Sf? '?'ii'?')ti. IGSS o? C?OC2K? AI?Cf -?j??E _?PR45f'?_?iV??'___: ISE, x^ 'WiE\_ _111AA-Lsk?,. I?N '1? CDCJf? . _ ''m _Ti IR i t4i FF CF &tgt3 pjpoD__ (ogtJ.% -%A R - ---- ..Tiro n!KC _Y-ASStarv\, ------ ---/?Na. cup tG?7)Es m,?,?l h'IAAb);j {}Nd it-\0SQ3 of his mAioN Fog Com-6,hpi- OF Gush _.__.. ._ ._.._?• Three IoR5 i _eosTdDY aRD?e, pN t?-bv_Er? .._ _. _.___._ _.,Z04.Z) Rrc?192C(i' J .ll?E MiN4R C?1i ICl) ??`iRNNA .. (Ylrl?$?CCJ. _• __.. _ oZ. N/i kRSSgN? -IS t, l giviAg 1/71< C61 /? CO. 1 _ 1't ..1 -t 54id ?in)45 CR(NQE8 by ko5fiM /tti cl h i , /?'7o F y kAR ? RCVS i /? E K h? ..#Mtjdc. uQ 42 c(.,,wN iEQ_ v\s C)F LvSTG D? a_ 14Z r rls.;''?^ w } , v r h FD?_--- ?:C.ON_T?n'IP .... ?bJ h?Nd d?l???,?y ? Ac?Ja.?ss?C? As_Follows•. - _ _. _--------- t yY. "At ('li?he?l__Yna-ti sky,- _Ros ,.s-FA s ? _h?. rs...9,? 44 ?hir??F'I"_1N AACN_;_4W-.h£ (i hh5 );i /?XAAkA:' . op, ._-_-- _ UNsUuc7" rRISi 'LAON - 40 -_-- -- November 19, 2002 In order to make it easy for all of us 1 think we should make pick ups and drop offs the same for every day except for Tuesday, since Deb is willing to drop Brianna off for me as long as the weather is good. Tuesday Brianna will be dropped off at your house between 4:00 and 4:30 and I will meet you at the red light at the corner of North and East streets at 8:00 Tuesday nights. Friday and Monday mornings of your weekend 1 will meet you at the red light at 6:30 to pick Brianna up for day care and I will meet you at the red light to drop Brianna off at 6:30 Thursday and Friday evenings I do not get into town before this time. If you have a way to pick Brianno up at day care at 4:30 on these days then just leave me a message, in the morning so that I don't waste a trip. On the Holidays that your are to get Brianna we can meet at the red light at the scheduled times for pick up and drop offs. Thursday 11-21-02 1 will have Brianna at the red light at 6.30 unless I get a message that you were able to pick her up at 4:30 from day care. Thanks Tina L.AW OFFICES law®romingerlaw.com 155 SOUTH HANOVER STREET www.romingedaw.com CARLISLE, PENNSYLVANIA 17013 KARL E. ROMINGER, Esq. TEL: 717.241.6070 MARK F. BAYLEY, ESQ. FAX: 717.241.6878 November 6. 2002 Michael Edward Mattesky 103 *:nrth 13ed1'nrd Street Carlisle. PA 17013 Dear Mr. btattesky: This letter is to simply put into writing the visitation arrangements between you and my client. Tina Kassam. As you will have every other weekend visitation, you may pick up Brianna on Thursday evening at the red light at the intersection of East North Street and North East Street at 6:30 p.m., you must be there no later than 6:35 p.m. You will return the child on Monday mornings at 6:30 a.m. no later than 6:35 a.m. to the same red light and intersection, A$ you also have visitation on Tuesdays. Debra Baer will drop the child off at your house no later than 4:00 p.m. and you will return I3rianna no later than 8:00 p.m at the aforementioned red light. If there needs to be a deviation from this arrangement, you will need to give my client .1 twenty- four hours notice and she will try to accommodate you. At no time are you to be on Ms. Kassam's property and she in turn gill not he on your property. At this time, my client chooses to follow the Court Order entered by Judge Ciuido at the Custody I -fearing and does not wish to deviate from it. Thank you for your time and attention. Sincerely. Karl E.. Rominger. Esquite KER:ljj cc. Tina Kassam ADVOCACY - ADVICE - ANSWERS .,.::..;.?:.....: I MICHAEL E. MATTESKY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V TINA MARIE KASSAM, Defendant 99-6098 CIVIL TERM ORDER OF COURT AND NOW, this 1st day of November, 2002, after I I hearing, it is hereby ordered and directed as follows: 1. All prior custody orders are vacated. 2. The parties shall have shared legal custody of their daughter, Brianna Marie Mattesky, born June 28, 1998. 3. Mother shall have primary physical custody of the child subject to periods of partial of custody in father as follows: (a) From today after daycare or school until the commencement of daycare on, Tuesday, November 5, 2002. V (b) Every other weekend from Thursday at 4:30 p.m. until the commencement of daycare or school the following Monday. Said eriods to be in Thursda p g y, ' November 7, 2002. • KX? i Provided, however, if said visitation occurs or. Mother's Day weekend, father ,n shall return the child by 9:00 a.m7 on Sunday, rather than on Monday. (c) Every Tuesday, from 4:30 p.m. until 8:00 p.m. (d) At such other times as the parties agree. `. 4. Father shall have partial custody of the child on ' f`au a' the following holidays: ,.s "'+ (a) Thanksgiving in even numbered years from 4:00 p.m. on Thanksgiving Day until 8:00 a.m. the morning after. (b) Thanksgiving in odd numbered years from 4:30 p.m. the day before Thanksgiving until 4:00 p.m. on Thanksgiving Day. (c) Christmas in even numbered years from 4:00 p.m. on Christmas Eve until noon on Christmas Day. (d) Christmas in odd numbered years from noon on Christmas Day until 8:00 a.m. the day after Christmas. (e) Every Father's Day weekend from Saturday before Father's Day at 5:00 p.m. until Monday after Father's Day at 8:00 a.m. (f) From 9:00 a.m. to 8:00 p.m. on the following holidays on an alternating basis: New Year's Day, Easter, Memorial Day, July 4 and Labor Day. 5. Father is not to drink any alcohol or use any drugs whatsoever at any time during the period he has partial physical custody of the child, nor is he to allow anyone in his home to use drugs or alcohol during said times. 6. Neither parties shall disparage the other in front of the child, nor shall either party discuss this case in front of the child. By the . Guido, J. Michael E. Mattesky, Pro se Karl Rominger, Esquire For the Defendant it frIU2 C :. Y FRG1119 REC^;ID m i a.(;r;tcn, ;: ;?; :,t, I her +.:aa set any hand and (ha ?v,: Ui J t:.: u C r?;?a, Pa rills, G uay ,100.4 Prothano(a i N a J Cf :1 } f. lrr . . O ? V Q?c x r? E 4 i{': Ak k Z h?? r F,.x a? v {'Y4 . FEB 2 5 1003 I / M (Cur- F' c? M -Ac, tit PLIA5 i? l? l?? PNR 6F CAM ,? T by 7 £F£ - ????L -? CF r- .T'1`c ,?;•?-1-t,„` .? „mow ?-- // ?5 h5 c rcl<kF cl bcj Af- ?d?? ?tSLr? 1 ES ?,c3?n2?f-f}NC?. ??7'il?•Cn:F?2 /5 A(`:4 . _ . .. •m? 1c 5.5 c?? NCr2K? h?..?) ,.f-intt ?? RES??%'?i?s? .. _...sar- ?e. Inw)A, I r n1;?h?rl ma-fit?sky, ??.?? `1i? ?a.:r,T ?F CGn?r????; ???5 ???;??fi? l?F ; CF CUr7??RIA?D C???7`i'???5?'S?ILtJAl?-1 i TWO MAeie YP65i4 r--\, cr*?c?n F cR Ccn lr 1 ,F Cc: ? UV A.&Uj ezoj s m;d)Al filA isky, lx?j AA:ct ;N 5,;ppreT OF h•,5 ,mc,+ItN r fica's A5 rtk(( 5 1.. Thfee, ti C usTc> ?Y c•9 07 ,Z i5,..-h'2fcJ c -'uvE? R l/ a.c•z) ntigAPdinc? 1I,t m;ncR C?t?l 1) ?f;'ia^+N?? n?att£-;l<y. ...?.. ?N? ka?sA??? '.s ? ? c??u;nc? -f (ice cl,; lc? •{e ?,? ??4tZ . /4t Sf}ic? y-in)4.5 c??£2?d U ?? LcUti?• b?.X??bil? J 'k?s5rirt f-N cl h f l: 14-11C&N?y lod rRalt N?E K- U? `I1t41+2 cc.?ti '1?.?2i??S OF GvsTa?`? G?c14.(?. . mRA I1? i I?? C4c:2i aF CoMn1??? PLUS r r DAVj/*jf 7W 3 -N,,s Jily S'zp:tefJ A /-L-P?j c%F4)er- /a?G7icti' For, L/-c&,T?-mP 1 of C.c;sc-o` u;m ..b? ? ,,,; d dd ,? AC,6455?Cl As F0)ICLIZ5. kno-I Acl%\Tti?v.- j? 7A cc,; ter c i= ??1mcti t.?,a5 ;Gl= (6-3AAND Z6CMi Vj EWNsyl4'A 1 V5. ?Nc. cl I - <G?rtB C-TQ L.. Tf 2n\ +1.t-1ni _..h;,y?s??? ;?. -i?l,:S ?C`t'IGN ? ?ti?}f ht mPk?? ?71,,s ?F???,a..??- AS f? S?. C hA?£J vpGn, J?iS 1ti?•`fs'?cc6 41,1? (?rll?r2S RuER?2 Jr, _... ..GR.?fNi4.C? iN ?h? jG•t2CtciNc?. UGC..uihtiut? /?n:d 7?ir?T"?h?5 f v?.' F- 4tj c S• RfrATff,;9 C_UNswuRn.' YR?Sir7?A cN. _ .._.__- FIC.'7?2i?'IfS. C. 3 iL ? . /fib/L£S I / . Tom. SE, November 19, 2002 In order to make it easy for all of us I think we should make pick ups and drop offs the same for every day except for Tuesday, since Deb is willing to drop Brianna off for me as long as the weather Is good. Tuesday Brianna will be dropped off at your house between 4:00 and 4:30 and I will meet you at the red light at the corner of North and East streets at 8:00 Tuesday nights. Friday and Monday mornings of your weekend I will meet you at the red light at 8:30 to pick Brianna up for day care and I will meet you at the red light to drop Brlanna off at 8:30 Thursday and Friday evenings I do not got Into town before this time. If you have a way to pick Brianna up at day care at 4:30 on these days then just leave me a message, in the morning so that I don't waste a trip. On the Holidays that your are to get Brianna we can meet at the red light at the scheduled times for pick up and drop offs. Thursday 11.21.02 1 will have Brlanne at the red light at 8.30 unless I get a message that you were able to pick her up at 4:30 from day care. Thanks Tina zxh;b' 4 (A) . f A"WP69 &AY46e- LAW OFFICES law@romingerlaw.com 155 SOUTH HANOVER STREET www.romingedaw.com CARLISLE, PENNSYLVANIA 17013 KARL E. ROMINGER, ESQ. MARK F. BAYLEY, ESQ. November 6, 2002 Michael Edward Mattesky 403 North 13edford Street Carlisle, I'A 11013 Dear Mr. titatteskv: TEL: 717.241.6070 FAX: 717.241.6878 'fhis letter is to simply put into writing the visitation arrangements between you and my client.'fina Kassam. As you will have every other weekend visitation, you may pick up Brianna on Thursday evening at the red light at the intersection of Gast North Street and North East Street at 6:30 p.m.. you must be there no later than 6:35 p.m. You will return the child on Monday mornings at 6:30 a.m. no later than 6:35 a.m. to the same red light and intersection. As you also have visitation on Tuesdays, Debra Baer will drop the child off at your house no later than 4:00 p.m. and you will return Brianna no later than 8:00 p.m at the aforementioned red light. If there needs to be a deviation from this arrangement, you will need to give my client a twenty- four hours notice and she will try to accommodate you. At no time arc you to be on Ms. Kassam's property and she in turn will not be on your property. At this time, my client chooses to follow the Court Order entered by Judge Guido at the Custody I fearing and does not wish to deviate from it. Thank you for your time and attention. Sincerely. Karl 1:. Romingcr, lisyuire KER:IJ cc. Tina Kassam L ??'l1 L I I ADVOCACY - ADVICE - ANSWERS MICHAEL E. MATTESKY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. TINA MARIE KASSAM, Defendant 99-6098 CIVIL TERM AND NOW, this let day of November, 2002, after hearing, it is hereby ordered and directed as follows: 1. All prior custody orders are vacated. 2. The parties shall have shared legal custody of their daughter, Brianna Marie Mattesky, born June 28, 1998. 3. Mother shall have primary physical custody of the child subject to periods of partial of custody in father as follows: (a) From today after daycare or school until the commencement of daycare on, Tuesday, November 5, 2002. \, V (b) Every other weekend from Thursday at J? 4:30 p.m. until the commencement of daycare or school the following Monday. Said periods to begin Thursday , November 7, 2002. Provided, however, if said visitation occurs on Mother's Day weekend, father shall return the child by 9:00 a.m. on Sunday, rather than on Monday. (c) Every Tuesday, from 4:30 p.m. until 8:00 P.M. (d) At such other times as the parties agree. 4. Father shall have partial custody of the child on the following holidays: (a) Thanksgiving in even numbered years from 4:00 p.m. on Thanksgiving Day until 8:00 a.m. the morning after. k (b) Thanksgiving in odd numbered years from 4:30 p.m. the day before Thanksgiving until 4:00 p.m. on Thanksgiving Day. (c) Christmas in even numbered years from 4:00 p.m. on Christmas Eve until noon on Christmas Day. (d) Christmas in odd numbered years from noon on Christmas Day until 8:00 a.m. the day after Christmas. (e) Every Father's Day weekend from Saturday before Father's Day at 5:00 p.m. until Monday after Father's Day at 8:00 a.m. (f) From 9:00 a.m. to 8:00 p.m. on the following holidays on an alternating basis: New Year's Day, Easter, Memorial Day, July 4 and Labor Day. 5. Father is not to drink any alcohol or use any drugs whatsoever at any time during the period he has partial physical custody of the child, nor is he to allow anyone in his home to use drugs or alcohol during said times. 6. Neither parties shall disparage the other in front of the child, nor shall either party discuss this case in front of the child. Michael E. Mattesky, Pro se Karl Rominger, Esquire For the Defendant It I iWE COPY FROM RECOM nt T frr:.n, vaiif"f, I here wita set my I13nd xid 10 wl v '....:? l;; a tt C.:fdsO, Pa. ?his,_4 b tlay u ltov? ? - ,cro,t Prnthonotafl r FEB 2 5 2003 N ?2 r C F Cc A?r?C' ?`1 PLiA5 1 , j) e n?C?1r •? , Z ti' C c) S TG D 4' r AtoJ y- ?N Ccn:S?c?E«A?'iC`ti C 71`;. C?.I pe 'lZll* .._ A ?. Cd?.?Ern p?" O? LUS7"Cdy _. 1 usf?c? ?aC??v} sr5 RS or<rlE?Ecl bcj AIL «sf? l i N.S J. DA ' bu fTO CF CcANMal ?!?P6 ?I??I?fi?FF ;CfCC'r1i?RIq?1D C?u?7?;??;?:S?CVru?r? Ii TiO MML Y4k5Sla?v\i ?}?Ua ? c'cui cta}tEs In, n?A-lt s k?, )?cj tic! • ????6?C,+.? +.,; .?.S+ IF ?}IL:IJ iN ???ik?T CF r11S t?1G'{'IZN ?? Ca:,•e?:?hpL GI' ?,US10'L\C? t??ftZ fiu E'5 A5 Fc(C?w 5 r ? Thiee, em6 ? CusTv ?Y G? ??? -g-,..4t,2fc! } ICS . i?qqAqctlt •{?,t m"Nor, Ct,t ?) ?RiAtit:,A (1'1A uZ . 'N?+ kA?SAM ',S do I gicliAXI -1114- Ce'1dd Tc '1?1? ?A??42 . l?''t SR?? 7 i?'?4..5 CF?f('??C? ??, i??? LCu?.? ? ` )t IT` ,• kw rim lqN C) h f t: A7fzNk / kil RCn1 i ti R"L up 44zoLzo,.? :? _ ... --- .. _. l?I???-?i?? . ?CFCu?+?713F(ZIA?iD Lo?:?Ut y, ?Nti5YL.V ?'' I I ?Ro ss. , do h£,2e,-b? r w-4--, C-, -?h l- .3. -N,;s JAY 5rwLEJ A 40Pc3 /110ctij FGr ..b3 h??:c1 d?,??.`J" r?t?I?ayS?Cl RS F?IIG??s, 7A Cc? k'r c ?= C?n1m?ti_ PI,S FIniN?i F?- 'CIF (WMIAhD L?cw? ?'? F?£tiNS4'Uf , V5, :NO. a 1 -l?G?l`d CT??. TERM r . , I,t IIAS 5?.(-7 c,.•? f k??t?.:l?r`g? cR br,6rcl. vlcn, h;s. i 7I?r?7-7??5 -•GR._Cl£N.if-6 iN Ih? `CiZqaIN9 CICLu0\109f /4tic( __. .t R7Fn?f?uT f5 MAcrti soA-)F-t-+7r-? 4-L,vctA if.5 OF. C, S, .. ........ . November 79, 2002 In order to make It easy for all of us I think we should make pick ups and drop offs the some for r every day except for Tuesday, since Deb Is willing to drop Brianna off for me as long as the weather Is good. • Tuesday Brlanne will be dropped off at your house between 4:00 and 4:30 and I will meet you at the red light at the corner of North and East streets at 8:00 Tuesday nights. Friday and Monday mornings of your weekend I will meet you at the red light at 6:30 to pick Brlanne up for day care and I will meet you at the red light to drop Brianna off at 6:30 Thursday and Friday evenings I do not got Into town before this time. If you have a way to pick Brlanne up at day care at 4:30 on these days then dust leave me a message, in the morning so that I don't waste a trip, On the Holidays that your are to get Brianna we can meet at the red light at the scheduled times for pick up and drop offs. Thursday 11.21.02 1 will have Brlanne at the red light at 6.30 unless I get a message that you were able to pick her up at 4:30 from day care. Thanks Tina LAW OFFICES lawmromingerlaw.com www.romingtrtaw.com KARL E. ROMINGER, Esq. MARK F. BAYLEY, ESQ. Michael I'dward Mattesky u01 North Bedford Street Carlisle. PA 17013 Dear Mr. Mattesky: November 6. 2002 ISS SOUTH HANOVER STREET CARLISLE, PENNSYLVANIA 17013 TEL: 717.241.6070 FAX: 717.241.6878 This letter is to simply put into %%Titing the visitation arrangements between you and my client. Tina Kassam. As you will have every other weekend visitation, you may pick up Brianna on Thursday evening at the red light at the intersection of East North Street and North East Street at 6:30 p.m., you must be there no later than 6:35 p.m. You will return the child on Monday mornings at 6:30 a.m. no later than 6:35 a.m. to the same red light and intersection. As you also have visitation on Tuesdays. Debra Bacr will drop the child ol7at your house no later than 4:00 p.m. and you will return Brianna no later than 8:00 p.nt at the aforementioned red light. If there needs to be a deviation from this arrangement. you will need to gi%c nt%, client a twenty. four hours notice and she will try to accommodate you. At no time arc you to be on Ms. Kassam's property and she in turn will not be on your property. At this time. my client chooses to follow the Court Order entered by Judge Guido at the Custody Hearing and does not wish to deviate from it. 'Thank you for your time and attention. Sincerely. Karl E. Rominger. I-squire KER:Ijj cc. Tina Kassam ADVOCACY - ADVICE ANSWERS i MICHAEL E. MATTESKY, Plaintiff V. TINA MARIE KASSAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 99-6098 CIVIL TERM AND NOW, this 1st day of November, 2002, after hearing, it is hereby ordered and directed as follows: 1. All prior custody orders are vacated. 2. The parties shall have shared legal custody of their daughter, Brianna Marie Mattesky, born June 28, 1998. 3. Mother shall have primary physical custody of the child subject to periods of partial of custody in father as follows: (a) From today after daycare or school until the commencement of daycare on, rr? Tuesday, November 5, 2002. V (b) Every other weekend from Thursday at 4:30 p.m. until the commencement of daycare or school the following Monday. Said periods to begin Thursday, November 7, 2002. Provided, however, if said visitation occurs on Mother's Day weekend, father shall return the child by 9:00 a.m. on Sunday, rather than on Monday. (c) Every Tuesday, from 4:30 p.m. until 8:00 P.M. (d) At such other times as the parties agree. 4. Father shall have partial custody of the child on s.: the following holidays- (a) Thanksgiving in even numbered years from 4:00 p.m. on Thanksgiving Day until 8:00 a.m. the morning after. I. . (b) Thanksgiving in odd numbered years from 4:30 p.m. the day before Thanksgiving until 4:00 p.m. on Thanksgiving Day. (c) Christmas in even numbered years from 4:00 p.m. on Christmas Eve until noon on Christmas Day. (d) Christmas in odd numbered years from noon on Christmas Day until 8:00 a.m. the day after Christmas. (e) Every Father's Day weekend from Saturday before Father's Day at 5:00 p.m. until Monday after Father's Day at 8:00 a.m. (f) From 9:00 a.m. to 8:00 p.m. on the following holidays on an alternating basis: New Year's Day, Easter, Memorial Day, July 4 and Labor Day. 5. Father is not to drink any alcohol or use any drugs whatsoever at any time during the period he has partial physical custody of the child, nor is he to allow anyone in his home to use drugs or alcohol during said times. 6. Neither parties shall disparage the other in front of the child, nor shall either party discuss this case in front of the child. Hy Edward E. Guido, J. Michael E. Mattesky, Pro se Karl Rominger, Esquire For the Defendant It MUSE c-.3rY FRCf:9 ;r:C.^. RO In T;,s(!r:i .r!, ur?r : I cM my !:and .Ind I h a r". f: c i :filSh), Pa. tills 4 - Ury o 71oc.? ti 'r -2004 Prothooota r MICHAEL E. MATTESKY, Plaintiff V. TINA MARIE KASSAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 99-6098 CIVIL TERM AND NOW, this 1st day of November, 2002, after hearing, it is hereby ordered and directed as follows: 1. All prior custody orders are vacated. :. The parties shall have shared legal custody of their daughter, Brianna Marie Mattesky, born June 28, 1998. 3. Mother shall have primary physical custody of the child subject to periods of partial of custody in father as follows: (a) From today after daycare or school until the commencement of daycare on, Tuesday, November 5, 2002. (b) Every other weekend from Thursday at 4:30 p.m. until the commencement of daycare or school the following Monday. Said periods to begin Thursday, November 7, 2002. Provided, however, if said visitation occurs on Mother's Day weekend, father shall return the child by 9:00 a.m. on Sunday, rather than on Monday. (c) Every Tuesday, from 4:30 p.m. until 8:00 P.M. (d) At such other times as the parties agree. 4. Father shall have partial custody of the child on the following holidays: (a) Thanksgiving in even numbered years from 4:00 p.m. on Thanksgiving Day until 8:00 a.m. the morning after. (b) Thanksgiving in odd numbered years from 4:30 p.m. the day before Thanksgiving until 4:00 p.m. on Thanksgiving Day. (c) Christmas in even numbered years from 4:00 p.m. on Christmas Eve until noon on Christmas Day. (d) Christmas in odd numbered years from noon on Christmas Day until 8:00 a.m. the day after Christmas. (e) Every Father's Day weekend from Saturday before Father's Day at 5:00 p.m. until Monday after Father's Day at 8:00 a.m. (f) From 9:00 a.m. to 8:00 p.m. on the following holidays on an alternating basis: New Year's Day, Easter, Memorial Day, July 4 and Labor Day. 5. Father is not to drink any alcohol or use any drugs whatsoever at any time during the period he has partial physical custody of the child, nor is he to allow anyone in his home to use drugs or alcohol during said times. 6. Neither parties shall disparage the other in front of the child, nor shall either party discuss this case in front of the child. By Edward E. Guido, J. Michael E. Mattesky, Pro se Karl Rominger, Esquire 44, U.i For the Defendant it ? `. i ????? '? > u ?U0 Ll $ Pei N s MICHAEL MA*ITESKY, Plaintiff VS. 'T'INA MARIE KASSAM. Defendant f+YB Y 11003 IN '1'I Ili COURT' OF COMMON PLEAS OP CUMBERLAND COUNTY. PENNSYLVANIA NO. 99-6098 CIVIL TERM IN CUS'T'ODY CUSTODY MEMORANDUM Defendant, Tina Marie Kassam, by and through her attorney. Karl E. Rominger, Esquire, hereby submits her Custody Memorandum pursuant to Rule 39.1915 (b)(8) of the Local Rules of Civil Procedure. 1. FACTUAI, RACKCROUND: The parties in this matter are Tina Maric Kassam (hereinafter referenced as "Mother'), who resides at 248 East North Street. Cumberland County. Pennsylvania. 17013 and Michael Mattesky (hereinafter referenced as "Father'"), who resides at 403 North Bedford Street, Cumberland County. Pennsylvania. Father and Mother arc the natural parents of one child, Brianna Maucsky, born June 28. 1998. 'there %%as an Order of Court dated January 31. 2001. which gave the parties shared physical custody. ']'here was a Custody Order entered in this case on November 1, 2002, granting Mother primary physical custody with partial custody in the Father. Father has since ignored the Court Order in regards to the designated meeting places and times. Father does not drive and Mother has arranged an elaborate series of rides but Mr. Mattesky does not show up at the designated places and tines. Asa result. the minor child has not been taken to the day care program. Father does not gi%c Mother ad%ance notice of his "change in plans". Mother filed a Motion tiff Contempt which has led to this hearing. I1 NAMES AND ACES OF THE. CHILDREN: Brianna Mattcsky, age 4 III. PROPOSED ORDER FOR RESOLUTION: Mother would have primary physical custody of the child, with shared legal custody in both parents. Father would have partial periods ofvisitation on Saturdays from 9:00 a.m. to 5:00 p.m. and Sundays from 9:00 a.m. to 7:00 p.m. with advance notice given to Mother if he is unable to keep the schedule as outlined on the Custody Order. IV NAN1Fti AND ADDRFSSFS OF FACTUAL WITNFSSFS• 1. Tina Kassam - Mother- She will testify to the her caregiving abihitics. to her interactions with Brianna, and her observations about Brianna's interactions with the Father and the Father's bhmily. 2. Michael Mattcsky - Father. will be called as if on cross to go through his criminal history, Ile will be called to testify as to the home environment he keeps the child in, his interactions with the child and the child's tinnily, and the like. tr 3, Debra E. Bear - Maternal Aunt of Michael Mattcsky will be called to testify about concerns about Mr. Maucsky's caregiving abilities, his alcohol problem, and her observations of ..4 .. the interactions between Mother and Father. ; a 4. Cindy L. White will testily to threats made by Michael Mattcsky, drunken episodes `s she has w itnessed by Mr. Mattcsky. and comment on the child care giving by both parents. Cindy L. White is it child care professional. V NAMES AND ADDRESSES OF EXPERT WITNESSES: At this time. Mother does not propose to call any expert witnesses. She does reserve the right to supplement this list of witnesses as necessary. VII, LEGAL AND FACTUAL ISSUES FOR RESOLUTION: There arc no unique legal issues, and the Court will be called upon to determine which parent would be best suited to provide the primary physical care for the child. VIL ESTIMATED LENGTH OF TRIAL: One halfday. VIII, NEED FOR A HOME STUDY: Mother does not request a home study at this time but does reserve the right to request one if the need fur one becomes apparent. IN, NEED FOR A PSYCHOLOGICAL EVALUATION: Mother does not request one at this time but reserves the right to request one if the need for one becomes apparent. Further, should this Court after hearing determine that such a evaluation is required to make it final determination. Mother would be ready, willing and able to coopcrale 1611%. Date: February 21. 2003 Respectfully submitted. ROMINGER & IIAVLEY Karl E. Romingcr. Esquire 155 South I lanover Street Carlisle. PA 17013 (717) 241-6070 Supreme Court ID 0 81924 Attorney tier Plaintiff MICHAEL MA'17ESKY. Plaintiff' Vs. TINA MARIE KASSAM. Defendant : IN TI IE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA NO. 99.6098 IN CUSTODY CIVIL TERM CERTIFICATE. OF SERVICE 1. Karl E. Romingcr. Esquire, attorney for Plaintiff. do hereby certify that I this day served a copy ol'the Cuslndp Alemoraadum upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle. Pennsylvania, addressed as follows: Michael Mattesky. Pro Se 403 North Bedford Street Carlisle. PA 17013 Karl E. Romingcr, Esquire Attorney for Defendant Dated: February 21. 2003 FEB 212003 MICHAEL MATTESKY. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. TINA MARIE KASSAM. Defendant NO. 99-6098 : IN CUSTODY CUSTODY MEMORANDUM CIVIL TERM Defendant. Tina Marie Kassam, by and through her attorney. Karl E. Rominger, Esquire, hereby submits her Custody Memorandum pursuant to Rule 39-1915 (b)(8) of the Local Rules of Civil Procedure, 1. FACTUAL BACKGROUND: The panics in this matter are Tina Maric Kassam (hereinafter referenced as "Mother"), who resides at 248 East North Street, Cumberland County, Pennsylvania, 17013 and Michael Mattesky (hereinafter referenced as "Father'), who resides at 403 North Bedford Street, Cumberland County. Pennsylvania. Father and Mother are the natural parents of one child, Brianna Mattesky, bom June 28, 1998. There was an Order of Court dated January 31, 2001, which gave the parties shared physical custody. There was a Custody Order entered in this case on November 1. 2002. granting Mother primary physical custody with partial custody in the Father. Father has since ignored the Court Order in regards to the designated meeting places and times. Father does not drive and Mother has arranged an elaborate series of rides but Mr. Mattesky does not show up at the designated places and times. As a result, the minor child has not been taken to the day care program. Father does not give Mother advance notice of his "change in plans". Mother filed a Motion for Contempt which has led to this hearing. 11, NAMES AND ACES OF THE CHILDREN: Brionnu Maucsky, age 4 Ill, PROPOSED ORDER FOR RESOLUTION: Mother would have primary physical custody of the child, with shared legal custody in both parents. Father would have partial periods of visitation on Saturdays from 9:00 a.m. to 5:00 p.m. and Sundays from 9:00 a.m. to 7:00 p.m. with advance notice given to Mother if he is unable to keep the schedule as outlined on the Custody Order. IV, NAMES AND ADDRESSES OF FACTUAL WITNESSES: 1. Tina Kassam - Mother- She will testify to the her caregiving abiltitics, to her interactions %%ith Drianna. and her observations about Drianna's interactions with the Father and the Father's tnmily. Michacl Mattesky - Father, will be called as if on cross to go through his criminal history. I le %k ill be called to testify as to the home environment he keeps the child in, his interactions with the child and the child's family, and the like. 3. Debra E. Dear - Maternal Aunt of Michael Mattesky will be called to testify about concerns about Mr. Mattcsky's caregiving abilities. his alcohol problem, and her observations of the interactions between Mother and Father. 4. Cindy L. White will testify to threats made by Michael Mattesky, drunken episodes she has witnessed by Mr. Mattesky, and comment on the child care giving by both parents. Cindy L. White is a child care professional. V._ NAMES AND ADDRESSES OF EXPERT WITNESSES: At this time, Mother does not propose to call any expert witnesses. She dots reserve the right to supplement this list of witnesses as necessary. VI. LEGAL AND FACTUAL ISSUES FOR RESOLUTION: There are no unique legal issues, and the Court will be called upon to determine which parent %%ottld be best suited to provide the primary physical care for the child. VII, ESTIMATED LENGTH OF TRIAL: One half day. Vlll, NEED FOR A HOME STUDY: Mother does not request a home study at this time but does reserve the right to request one it'the need for one becomes apparent. IX, NEED FOR A PSYCHOLOGICAL EVALUATION: Mother does not request one at this time but reserves the right to request one if the need for one becomes apparent. Further, should this Court after hearing determine that such a evaluation is required to make a final determination, Mother would be ready, willing and able to cooperate lidly. Date: February 21.2003 Respectfully submitted, ROMINGER & BAYLEY Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717)241.6070 Supreme Court ID N 81924 Attorney fitr Plaintiff MICHAEL MATTESKY, Plaintiff VS. TINA MARIE KASSAM, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6098 CIVIL TERM : IN CUSTODY 1. Karl E. Romingcr, Esquire, attorney for Plaintiff, do hereby certify that 1 this day served a copy of the Custody bfemorandum upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Michael Mattesky, Pro Sc 403 North Bedford Street Carlisle, PA 17013 Karl E. Romingcr, Esquire Attorney for Defendant Datcd: February 21, 2003 JAN 2 4 M3)) MICHAEL MATTESKY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW TINA MARIE KASSAM, : NO.99-6098 CIVIL Defendant : IN CUSTODY COURT ORDER AND NOW, this.74 y of January, 2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Courtroom o 5 of the C mberland Count Courthouse on the,ocy of , 2003, at AO :3Q ,&.M. At this hearing the Mother, Tina Marle Kasmin, shall be the moving party and shall proceed initially with testimony. Counsel for the parties, or the parties if they do not have legal counsel, shall file with the court a memorandum setting forth the history of custody in this case, the Issues currently before the court, each parties position on these Issues, a list of witnesses who will be called to testify at the hearing and the summary of the anticipated testimony of each witness. Ills memorandum shall be Bled at least five (5) days prior to the mentioned hearing date. In the event Father desires to litigate any Issues of contempt at the hearing scheduled in this matter, Father shall also file a supplemental petition with the court raising these issues. 2. Pending further order of this court, this Court's prior Order of November 1, 2002 shall remain in effect. THE Edward E. cc: sari E. Romminger, Esquire ,,Alichael Mattesky 403 North Bedford Street Carlisle, PA 17013 TRXs 01-30-03 J. 03 [MY CQxac + , jj, ` Fr??vsni ,f+ r yh i r r 1 MICHAEL MATTESKV, Plaintiff v TINA MARIE KASSAM, Defendant Prior Judge: Edward E. Guido IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.99-6098 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The conciliator met with the parties and Attorney Michael J. Whare who was representing the Plaintiff and pinch-hitting for Mr. Rominger. After the conciliator spoke with the parties, it Is the conciliator's view that it would be fortunate if these two people could even agree upon the day of the week. Father is asserting that Mother is in contempt In the petition, and Mother has filed a petition to hold Father in contempt. Even though the court recently had a hearing on this case, the conciliator suggests this matter needs to come before the court again in order to address these Issues and, possibly, modify the November 1, 2002 Order. 2. The conciliator recommends the entry of an order In the form as attached. 1 Ua 6;)1/ DATE Hubert X. Gilroy, Es ire Custody Conclllat ?g£IF h??t?`py_s'?bn,,?-s--my.c?sl?ly, r1Cir0!?PNc1un'?_?JuR?? RUIN 39 /91S (b) (8? c5P 4?t Ier-vN\ RU1f S c5F_6jv; ------ -- - --- If ...f Ais_4m Aii mA p, IfRE /11;cA I Luho R S s _w± a3__t?1_ ed.( r. t_s . _Cvr_???Ee?ra??c? Ctlu,u><y , C"£NN.sC???/}N'?A?. 1??13_..r4,Jcl ?N_R__/YI!}?i?__?< REr42Er?c?c1 tc? /}s ?%i'la???ErE' Why _(2£S.r.d S _.f}' I _?._NG!??I, .5 f CC?M??F?' ? 'FlnSCi (Gun17'??r QfNN$,?V_/ /.ill?r 17613 .. FkKl? loici IV6' A' k ARC "1?4 r??t?2A?, ???a??titJ'?S O? CGN?c chi?l?_1 ?f??r11 ,r:1? 19AJ aooO . 1??7`t:?lt_. Rik ?A ?t,2 ?A?:?;,?1 ?Us?crl?.l. i-rl ??tE?? hA5 1=? £ElJt_. ._.-._?._____...__'._/. L^r.ra..._.I v.-.._. Ur J?!?\_. _1. L/? • - • 1 1-1•'R.:V rv r..Vl r...?. WIJ . • 9.c?{ r2_:C1f?E_fo -At 1,04- of coinPf???,c? WA .sard__Cecr? __Oh ?ANNA__MAf 6 t yb ?- y 'ML_ pRomsy-c4 o"e. Fog, R?so?u ?o _ -- __J ?. - ...__ . _rR??£?2_?9N? IneAfZ ul7ulcl _EN?jO(J, _S?1A12rcc?._ S cry, ----- - -.._c?s??y mar= +1,? ???; Id, w;+l, s?,A?.Ed l?A\ ??s-bd5. FoR_._._ pnRw s _ cgs _ws//. 6A; ld Noulc/ c%RNqE __...,QNd- -fop locgl Sckoo) 4000 XIAVC G)AL Jk f, FROM Y CVJC1q J '-JQ f4+ .Sc"<ol YlNLNC)AX (;"' hh"- hfti LY-601-;I ??E ????Cul?'? /,?r,r??? ???,n:i/.r) c?,li?.v ?1C Cvc'TU?? d(•v?. I h?e_oFF p-I-sZI , fy? ?s RAa !_8dP 5st5 of f=A? uA1 f Lj ; ----- _ _. ?, l InOksktj - F417'C--R - H-"r- Will - _ 1- _ shcU l c? Nod- b? :a d t ?., coti4-,vv\ 0- o F, 6_us-b_d.9 - ?R r w,?i.r??T1ifg mcQE skow 46f I'n? QAQ TN c __ _ -.?a._'T,NR_ kASS!`?m. -_Mo?l???-.w, l l 6?_c?IlEd- fls iC a?? c _" T ?1Fy_AS__ 4T r__ )met- 5114 d?? ?R?hNNA a? /tNCI_ ?oNc??+jonf$ ?E ????? 15 Qua iiu -z be picked vP--At3' _..._---::.LvifN_FSS£S. Nf doES R?sf,??F. ??? c +0 Suf l,'sf oF_w;Ae,ssFs- f+5 NEcissAmJ. _-- _ 'Th ?-?c?R i SS C:ti AI -TSSULS rcZ R?sal u`Fior? : - - rFA- 1 Agcl I s (foto-?rnp+ hk3d +4 )r:. Oft-pkip- r: I f 5 (. £VAI?JP bA5 S),owrz. 1R2A4ioNAr 6?{?avio?2_c,11?3?4, - :.1.1? T?14,_.,?Q?E?V« GF GRc,c?`1't£? ANcI why l? a?? --?.??_???av??...._.... 64i' A _A_._b-u:5itocs5 _ ?re?e. SANc?c? ? eef o zo/cj' _. _ca??PIE E. s ??? ?2 Ao Vv- is ply -this !s t,:*T +I,_,- kIocl of +I)fA+ -5kou Id t1.? . LA2? _ C3F Llii Icl 'it's 4z n At'&JS . T?- ___t______.______..._ m?cheal rY(Mesky, :Tn7he (?vort'o? Common?le450? 'rr..iv?hirir,v-wI /1i?r%4,i V MtneI1111/i?Iv vS. ? YJQ?e YY?PV1t '_ ?Cr?_Clf??nC'??I -??lc. 1?t1 YYtG1?¢5k?1 JQ?fe.Se?ll?tvC?. C?Ov Salc, __-fie CUS l?t?lc?Rd?111??m uOoN.2h.e - .c?--(bs??-epc9,-??_r..l.??te,?.n.??s?1u.?n?, rth- St , November 19, 2002 In order to make it easy for all of us I think we should make pick ups and drop offs the same for r every day except for Tuesday, since Deb is willing to drop Brlanno off for me as long as the weather is good. Tuesday Brianna will be dropped off at your house between 4:00 and 4:30 and I will meet you at the red light at the corner of North and East streets at 8:00 Tuesday nights. Friday and Monday mornings of your weekend I will meet you at the red light at 8:30 to pick Brianna up for day care and I will meet you at the rod light to drop Brianna off at 8:30 Thursday and Friday evenings I do not got Into town before this time. If you have a way to pick Brianna up at day care at 4:30 on these days then just leave me a message, in the morning so that I don't waste a trip. On the Holidays that your are to get Brianna we can meet at the red light at the scheduled times for pick up and drop offs. Thursday 11 -21-02 1 will have Brianna at the red light at 8.30 unless I get a message that you were able to pick her up at 4:30 from day care. Thanks Tina i= , a fiW MA_7w?-_ &A?4 LAW OFFICES law@romingerlaw.com 155 SOUTH HANOVER STREET www.fomingerlaw.com CARLISLE, PENNSYLVANIA 17013 KARL E. ROMINGER, Esq. TEL: 717.241.6070 MARK F. BAYLEY, Esq. FAX: 717.241.6878 November 6. 2002 Michael Edward Mattesky u03 North Bedford Street Carlisle. PA 17013 Dear Mr. Mattesky: This letter is to simply put into writing the visitation arrangements between you and my client. Tina Kassam. As you will have every other weekend visitation, you may pick up Brianna on Thursday evening at the red light at the intersection of East North Street and North East Street at 6:30 p.m.. you must be there no later than 6:35 p.m. You will return the child on Monday momings at 6:30 a.m. no later than 6:35 a.m. to the same red light and intersection. As you also have visitation on Tuesdays. Debra Baer will drop the child off at your house no later than 1:00 p.m. and you will return 13rianna no later than 8:00 p.tn at the aforementioned red light. If there needs to be a deviation from this arrangement. you will need to give my client a t%%cnty- f'our hours notice and she will try to accommodate you. At no time are you to be on Ms. Kassam's property and she in turn will not be on your property. At this time, my client chooses to follow the Court Order entered by Judge Guido at the Custody I fearing and does not wish to deviate from it. 'thank you for your time and attention. Sincerely. Karl E. Romingcr, layuirc KERJ j cc. Tina Kassam ADVOCACY - ADVICE - ANSWERS MICHAEL E. MATTESKY, Plaintiff V. TINA MARIE KASSAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 99-6098 CIVIL TERM AND NOW, this let day of November, 2002, after hearing, it is hereby ordered and directed as follows: 1. All prior custody orders are vacated. 2. The parties shall have shared legal custody of their daughter, Brianna Marie Mattesky, born June 28, 1998. 3. Mother shall have primary physical custody of the child subject to periods of partial of custody in father as follows: (a) Fzom today after daycare or school until the commencement of daycare on, iI\ Tuesday, November 5, 2002. \, V \f (b) Every other weekend from Thursday at J? 4:30 p.m. until the commencement of \ daycare or school the following Monday. Said periods to begin Thursday, November 7, 2002. Provided, however, if said visitation occurs on Mother's Day weekend, father shall return the child by 9:00 a.m. on Sunday, rather than on Monday. (c) Every Tuesday, from 4:30 p.m. until 8:00 P.M. (d) At such other times as the parties agree. 4. Father shall have partial custody of the child on the following holidays: (a) Thanksgiving in even numbered years from 4:00 p.m. on Thanksgiving Day until 8:00 a.m. the morning after. i. (b) Thanksgiving in odd numbered years from 4:30 p.m. the day before Thanksgiving until 4:00 p.m. on Thanksgiving Day. (c) Christmas in even numbered years from 4:00 p.m. on Christmas Eve until noon on Christmas Day. (d) Christmas in odd numbered years from noon on Christmas Day until 8:00 a.m. the day after Christmas. (e) Every Father's Day weekend from Saturday before Father's Day at 5:00 p.m. until Monday after Father's Day at 8:00 a.m. (f) From 9:00 a.m. to 8:00 p.m. on the following holidays on an alternating basis: New Year's Day, Easter, Memorial Day, July 4 and Labor Day. 5. Father is not to drink any alcohol or use any drugs whatsoever at any time during the period he has partial physical custody of the child, nor is he to allow anyone in his home to use drugs or alcohol during said times. 6. Neither parties shall disparage the other in front of the child, nor shall either party discuss this case in front of the child. By Edward E. Guido, J. Michael E. Mattesky, Pro se Karl Rominger, Esquire For the Defendant it EVE r n In,I1%AlF::Q? +,t:f, j0t m 1131d fflf?? ? fJt?y? G1 ?W UCfW?a. 100.2.. AtIf Protho:uta(f gegi my k' Q MICI IAEI. MA'ITESKY. Plaintiff VS. 'TINA MARIE KASSAM. Defendant IN TI IE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA : NO. 99-6098 IN CUSTODY CUSTODY MEMORANDUM CIVIL. TERM Ocfcndant. Tina Marie Kassam, by and through her attorney, Karl E. Romingcr. Esquire, hereby submits her Custody Memorandum pursuant to Rule 39.1915 (b)(8) of the local Rules of Civil Procedure. 1. FACTUAL [BACKGROUND: The panics in this matter are Tina Marie Kassam (hereinafter referenced as "Mother'), who resides at 248 East North Street. Cumberland County. Pennsylvania. 17013 and Michael Mattcsky (hereinafter referenced as "Father"), who is believed to he incarcerated at the Cumberland County Prison. Father and Mother are the natural parents of one child, lBrianna Mattcsky, horn June 28. 1998. '['here was an Order of Court dated January 31. which gave the parties shared physical custody. Mother had petitioned the Court fir Emergency Relief on July 19, 2002 because of Father's smoking marijuana in Isom of the child and not rollowing the Custody Order in place, by keeping the child from Defendant. The Petition ?VUS denied and conciliation was held on September 26. 2002. Which has led to the hearing now scheduled for November 1, 2002. 11. NAMES AND ACES OF THE CHILDREN: lirianna Mattcsky. age 4 111, PROPOSED ORDER FOR RESOLUTION: Mother would have primary physical custody of the child, with shared legal custody in both parents. Father would have partial periods of visitation on Saturdays from 9:00 a.m. to 5:00 p.m. and Sundays from 9:00 a,m. to 7:00 p.m. IV, NAi11F.S AND ADDRESSES OF FACTUAL. WITNESSES: 1. 'T'ina hassam - Mother- She will testify to the her caregiving abiltitics, to her interactions with Drianna, and her observations about Brianna's interactions with the Father and the Father's family. 2. Michael Mattcsky - Father, will be called as iron cross to go through his criminal history. I le will be called to testify as to the home environment he keeps the child in. his interactions with the child and the child's family. and the like. 3. Debra L. Bear - Maternal Aunt of Michael Mattcsky will be called to testify about concerns about Mr. Mattesky's caregiving abilities, his alcohol problem, and her observations of the interactions between Mother and Father. 4. Cindy L. White will testify to threats made by Michael Mattcsky, drunken episodes she has witnessed by Mr. Mattcsky, and comment on the child care giving by both parents. Cindy L. White is a child care professional. V. NAMF,S AND ADDRESSES OF EXPERT WITNESSES: At this time. Mother does not propose to call any expert witnesses. She does reserve the right 10 supplement this list of witnesses us necessary. VI. LEGAL AND FACTUAL ISSUES FOR RESOLUTION: There are no unique legal issues, and the Court will be called upon to determine which parent would be best suited to provide the primary physical care for the child. VIL ESTIMATED LENGTH OFTRIAL: One half day. VI11. NEED FOR A HOME. STUDY: Mother does not request a home study at this time but does reserve the right to request one if the need I'ar one becomes apparent. a IN, NEED FOR A PSYCHOLOGICAL EVALUATION: Mother does not request one at this time but reserves the right to request one if the need for one becomes apparent. Further, should this Court alter hearing determine that such a evaluation is required to make a final determination. Mother would be ready, willing and able to cooperate fully. Date: October 28, 2002 Respectfully submitted, ROMINGER & BAYLEY Karl E. Rominger, Esquire 155 South I lanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID 4 81924 Attorney for Plaintiff {?F x. 6v i. t `?µ hD. MICI IAEL MATTE-SKY, Plaintiff Vs. TINA MARIE KASSAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99.6098 CIVIL TERM IN CUSTODY CERTIFICATE OF SERVICE. 1. Karl E. Romingcr, Esquire. attorney for Plaintiff, do hereby certify that 1 this day served a copy of the Custody AJemorandunt upon the following by depositing some in the United States Mail. first class postage prepaid, at Carlisle. Pennsylvania. addressed as follows: Michael Mattesky, Pro Sc 1101 Claremont Road Cumberland County Prison Carlisle, PA 17013 Karl E. Romingcr, Esquire Attorney for Defendant Dated: October 28, 2002 O DEFENDANT'S EXHIBIT 11.1-oz MKT f',01i A -51-101 ''UESdRc R 'ERNOOQ iAKOUOd 41-.30, =rm oFF wov-k 'Sick ul? t II _ wed. ?->,f. IcV' W4)%O +V\ doc. ,look .A me .t?gfalr.)... i .E OV41 b08l -YV\'000O N\- .T wAS 3 bX1 v4c1- uvh nl . z S R1 z w As 3ic;k . z WIGS \cS S..?aoulc? b? -%ow"a.1of ,+1?? b\ock., IOUt. .GR-h IN, O? J1d\ ?fZdn` fvcRgoNi:,- goads ?wd iNm#q-Jis. -z: 9uas yoUa: 'Hof .?la?d ?? 9s4- s%ck cihmi Voud Rf-._oN..A s: 'block'. T.- cwou movEal._Faafn . onlc.. 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Because when it conics to a 1' 11 It I N A S C I I N 1' I proves that tPc n( Pl ton can make all '"e ! fference. Not . ' s a°n'?r II Il 1 1-?--1 ... .. r. rn[I 1 ifr. WWW.PUNINA. CUM Tough Kids, Tougher Calls When your child is picked oil, your urge is to pholle the bully's parents. Should you do it? By Jeffrey Zaslow OT I/)NG Arrlat TI l r. N telephone w•;n invented, I asunne, it call seas pl:ucil. 71ic caller svgs a parent saying, ")'our child is bullying my child, and I avant it stopped!" The bully's parent replied, ")'Oil must have the wrong number. My child is it little angel." A trillion phone calls later, the conversation is the same. Mein children are leased or lyrinnimil, lire parental inipuke is to grab the phone uncl rant. Ilut these days, as studies show bullying on the risearal parental tile decline. researchers _.Vwr? svhn stud)' bullying say that calling mums and dads is more futile than ever. Such calk often lead to playground recriminations and don't rcxlly teach our kids any lessons about hose to navigate the world and resols'e conflicts. Still, tn•my of In v.111 1 resist. "\ly fantasy is to Pick on Parents the same sv.w their kids lave picked on Illy daughter," says I)autdi Dates Mac•kull of Cinmunoo Like. olio, %% hose daughter. 18, has been teased Maul her spcuch impairments. Mackall has called paren(s but found them defcnsm, or in denial. %%lien you Ball Parents. you scant them to **extract the cruel- ty" from their bullying children, stns 1. ura Kmesh, it child py- chologtsl in Evanston. Ill." Hill many parents arc bl(ssvti assay Its. the tile's of their child lacing c•ntel. They won't Iselioce it." In it recent pxwlice-department sung-• in o:tk 1 hill is r. ..a. ,. ,.-...r had eng.igcvl in bulking 1whanior. Yet only IS'; of parents thought Ihcir children would act as bullies. In a new national vv% survey. •1.i'i of patents suplwrt Cool's cUng other patents to deal sail bullying. But ntury educatun sc,rn that tho,e convenatiuns e.ut be nusinter- I n•ted, causing tempters it, Ilatu. Instead. thuv say, patents should get objectoil outsulot,. Re principals. In mediate. Meanwhile. if you get it call from it parent who is angry alxtut pair child's bullying. listen w'illoul getting defcnshe. 'Iliat's what I: aura Mel lugh of Castro Palley, Calif., did schen it caller told her that her (lien 11-year-old son had spit in another Boy's food. I Ice sun lmd undesseli. but the cictini s mall "wanted to make sure Illy son hadn't given her stn it nasty' disease'"sa)s Mel lugh, who apologized and promi etl to get her stn tested for AI Os and other diseases. Site knew the ch.uur of contracting any dis- case Ibis way was remote, but her promise calmed the mother And slim till Met lugli s still that Ilk bad h • i.Mor was living LIL- en eery seriously. \lei high. founder of parents Coach Kids, n group that bestirs P,runting skills, sent the inotn the lest results. All score negithe. If you fuel you must call n Parent, there arc strategics. Keep in mind thatpanyts viuss' criticism of their kids as critic•i+ni of their pauunling. Rather than call their child ..sour little monster., s.w. "I'[ swrriud about the rcLdirinibiP hchceen (stir kith." And bas open-ntioded. Recess cam somclnnes be 20 minutes of %%lu% Wring, Iltinticknig. ,avert I I g. MIs I sLrtel l w hal I'eth'sp, )our cIidd is leas itin(st'ent III.(st het, ontends. Ilumembcr: ( Inca you make a call, con might not like \11lat %Uu hear. If you 11.1\t. an itchy. dialing linger, resist lrniplatwn. Put it in Nmr Pocket. E /.•trlt 114 PLAINTIFFS (sr Itulh° EXHIBIT ELDER DISCOUNTSAsbaby boomers age, senior citizen . discounts may become a thing of the past. Della and American Airlines recently eliminated their senior clubs, and the Newyork Mats have put o stop to their senior dollar days. With I In 5 Americans current. ly over 55, other corporations are also beginning to think about the cost-effectiveness of offering discounts. And experts wonder whether the reduced prices are necos- sary-today people in their 50s are wealthier than any other age group In the U.S. SHARED CUSTODY According to a study published in the Journal of Family Psychology. kids are more likely to be better adjusted after divorce If parents share custody. Researchers found that children who spent substantial time with both parents had fewer behavioral and emotional problems and higher self-esteem and grades than kids in sole-custody arrangements. DAD-ENHANCED LEARNING Researchers at the University of Illinois have determined that the involvement of a father or father figure can help Improve • a child's grades. When dads ask kids daily about their class- work and school relationships, reading and math scores on achievement tests are higher. -By Llu Mclauihlln ar! I ifi Iltl f. 11'1111.]' : x?= Vt MICHAEL MATTESKY : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. TINA MARIE KASSAM : NO. 99-6098 CIVIL TERM ORDER OF COURT AND NOW, this 20T0 day of NOVEMBER, 2002, a Rule is issued upon plaintiff to Show Cause why he should not be held in contempt. Rule returnable on MONDAY, DECEMBER 16, at 3.00 P.m. in Courtroom # 5 of the Cumberland County Courthouse, Carlisle. By Edward E. Guido, /Michael Mattcsky Pro Se /Karl Rominger, Esquire For the Defendant - // Z:)0 -O a :sld W03-mi liEUIWOJ'MMM Wtb'Mttpaulwojomwl hZOOZ 6 t AON SWAMSW - 7DIAGV - ADVD(AGV 8L89'l4Z'Llz :XVd 0 Zf l '6fL'009 •OLOTIK'LlL s7DIdilo-Awl lgOVCq,1VAW 4W s? NN C,.') C) tv l i ' " Itj. rl 11OLI VINVAIASKN3d'31SI1aV3 133H S 113AONVH HinOS SSl MICI IAEI, MATTESKY, Plaintiff VS. TINA MARIE KASSAM, Defendant : IN 7'l IE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99.6098 IN CUSTODY ORDF,R OF COURT AND NOW, this day of CIVIL TERM 2002, in consideration of the within Motion for Contempt of Custody Order, it is hereby ordered and directed that Respondent cooperate with Petitioner with custody exchanges and facilitating the child's attendance at day care and Petitioner is awarded reasonable attorney's fees. J. Distribution: Karl E. Romingcr. Esquire Michael Mattesky Pro Sc MICIIAEL MATTESKY, Plaintiff Vs. TINA MARIE KASSAM, Defendant : IN TI IE COURT OI' COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99.6098 CIVIL TERM : IN CUSTODY MOTION FOR CONTEMPT OF CUSTODY ORDER AND NOW, comes Tina M. Kassam, by and through her privately retained counsel, Karl E. Rominger. Esquire and in support of her Motion for Contempt of Custody Order avers as follows: 1. There was a Custody Order entered on November 1. 2002. regarding the minor child, Brianna Mattcsky. (Exhibit "A") 2. Michael Mattesky is not taking the child to the day care program. 2. Mother, Tina Kassam has arranged an elaborate series of rides since Mr. Mattcsky cannot drive and is willing to do so but keeps getting stood up. 3. Further. Mr. Mattcsky gives no advance notice of his "change in plans". WI IEREFORE, Petitioner respectfully requests that this I lonomble Court enter an Order directing Father to cooperate with custody exchanges and facilitating the child's attendance at day care plus reasonable attorney ties. Respectfully submitted, ROMINCF.R & BAYLEY Karl E. Rominger, Esquire 155 South I lanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court 11) N 81924 Attorney for Petitioner MICHAEL MATTESKY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-6098 CIVIL TERM TINA MARIE KASSAM, Defendant : IN CUSTODY CERTIFICATE OF SERVICE 1, Karl E. Rominger, Esquire, attorney for Petitioner, do hereby certify that 1 this day served a copy of the Motion for Contempt of Custody Order upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Michael Mattcsky 403 N. Bedford Street Carlisle, PA 17013 Dated. I l 0 - 02, 'x z{ ? h h ? Karl E. Rominger, Esquire Attorney for Petitioner ."' St yc z,i.(SF t MICHAEL MATIT'sSKY. Plaintiff VS. 'TINA MARIE: KASSAM, Defendant IN 'I'I Ili COURTOF COMMON PLUAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6098 CIVIL TERM : IN CUSTODY VyftIFICATION KART. E. ROMINGER. I-SQUIRE. states that he is the attorney for. Petitioner in this action: that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document: and that this statement is made subject to the penalties of 18 Pa. C.S. Pa.C.S. §4904. relating to unsworn falsification to authorities. Date://-/ 3- (J 'Z VERIFICATION i t; ;i } } I verify that I am the petitioner and that the statements made in the foregoing Petition are true and correct. I understand that false statements herein arc made subject to the penalties of 18 Ila. ('. S. § 4904, relating to unswom falsification to authorities. Date: Tina M. Kassam Karl E. Rominger, Esquire Attorney for Petitioner MICHAEL E. MATTESKY, Plaintiff V. TINA MARIE KASSAM, Defendant / l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 99-6098 CIVIL TERM AND NOW, this 1st day of November, 2002, after hearing, it is hereby ordered and directed as follows: 1. All prior custody orders are vacated. 2. The parties shall have shared legal custody of their daughter, Brianna Marie Mattesky, born June 28, 1998. 3. Mother shall have primary physical custody of the child subject to periods of partial of custody in father as follows: (a) From today after daycare or school until the commencement of daycare on, Tuesday, November 5, 2002. (b) Every other weekend from Thursday at 4:30 p.m. until the commencement of daycare or school the following Monday. Said periods to begin Thursday, November 7, 2002. Provided, however, if said visitation occurs on Mother's Day weekend, father shall return the child by 9:00 a.m. on Sunday, rather than on Monday. (c) Every Tuesday, from 4:30 p.m. until 8:00 P.M. (d) At such other times as the parties agree. 4. Father shall have partial custody of the child on the following holidays: (a) Thanksgiving in even numbered years from 4:00 p.m. on Thanksgiving Day until 8:00 a.m. the morning after. ,/ t 0", - (b) Thanksgiving in odd numbered years from 4:30 p.m. the day before Thanksgiving until 4:00 p.m. on Thanksgiving Day. (c) Christmas in even numbered years from 4:00 p.m. on Christmas Eve until noon on Christmas Day. (d) Christmas in odd numbered years from noon on Christmas Day until 8:00 a.m. the day after Christmas. (e) Every Father's Day weekend from Saturday before Father's Day at 5:00 p.m. until Monday after Father's Day at 8:00 a.m. (f) From 9:00 a.m. to 8:00 p.m. on the following holidays on an alternating basis: New Year's Day, Easter, Memorial Day, July 4 and Labor Day. 5. Father is not to drink any alcohol or use any drugs whatsoever at any time during the period he has partial physical custody of the child, nor is he to allow anyone in his home to use drugs or alcohol during said times. 6. Neither parties shall disparage the other in front of the child, nor shall either party discuss this case in front of the child. Michael E. Mattesky, Pro se Karl Rominger, Esquire For the Defendant it ;:?' COPY FROM RECORD 4'• ?G t vU'I c': (:pdi1?LM;, E'tl, (irr.!hnnrA?rO ;? ?, _ ti ? . ??, ? _ ? i ?iS ,.; • . ?i: -? C7 iiL .. r: ? i. t? u V ? M ?? ? 4. v 5EP 1 0 20[1 1!/ MICHAEL E. MATTESKY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW TINA KASSAM. : NO. 99-6098 CIVIL Defendant : IN CUSTODY COURT ORDER AND NOW, this // r day of September. 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: All prior custody orders entered in this case are vacated. 2. The Father, Michael E. Mattesky, and the Mother, Tina Kassam, shall enjoy shared legal and shared physical custody of Brianna Marie Mattesky, bom June 28, 1998. 3. Physical custody shall be handled, for purposes of this order, such that it is interred that the panics arc sharing equally physical custody of the minor child. This shared arrangement shall control for purposes of calculation of any support obligation, with the understanding that each puny has an obligation to share in daycare costs. 4. In the event rather would be unable to take care of the child because of any incarceration, such incarceration shall result in Mother assuming primary physical and legal custody of the minor child until such time as Father was released from prison. cc: Karl Rominger, Esquire Michael Mattesky 403 North Bedford Street Carlisle, PA 17013 c y"i 'rO4. cr( 9. /.)•0l 9-1 1 BY 1*1IE COURT. o? s?-e COO if h. ". f[ .1... .,, VI MICHAEL E. MATTESKY, Plaintiff v TINA KASSAM, Defendant Prior Judge: Kevin A. I-Icss IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 99-6098 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITII THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3.8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Brianna Marie Mattesky, born June 28, 1998. 2. A Conciliation Conference was held on September 7, 2001, with the following individuals in attendance: The Mother, Tina Kassam, with her counsel, Karl R. Romingcr, Esquire; and the Father, Michael E. Mattasky, who appeared without counsel. 3. The parties agree to the entry of an order in the form as attached. ATE Hubert X. Custody ( ti -'% . JAN 3 0 ypl? MICHAEL E. MATTESKY. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW TINA KASSAM, : NO. 99-6098 CIVIL Defendant : IN CUSTODY COURT ORDER AND NOW, this e day of January, 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I. This Court's prior Order of November 23, 1999 is vacated. 2. The Father, Michael E. Mattesky, and the Mother, Tina Kassam, shall enjoy shared legal and shared physical custody of Brianna Marie Mattesky, bom June 28, 1998. 3. Physical custody shall be arranged pursuant to agreement of the parties. 4. This Order is entered with recognition that both parties are currently unemployed and they each expect to obtain some type of employment in the future that may merit a reevaluation of this custody arrangement. The Conciliator shall conduct a telephone conference call with the attorneys for the parties on Thursday, March 8, 2001 at 8:30 a.m. The purpose of this telephone custody conciliation conference shall be to update the Conciliator on the status of the case and determine whether another formal conciliation conference needs to be scheduled or determine whether a hearing needs to be scheduled. B r, J. Edward E. Guido cc: Karl E. Rominger. Esquire Matthew J. Eshelman. Esquire ?0?!w 4YAjI oz-o,-o1 "/) If Y 0' 0: 01 PI 3 f P/t1 4: I CUa;cti,.raL)J 1„UUIVTy PcNNISYLVANIA `. .0 . MICHAEL E. MATTESKY, Plaintiff v TINA KASSAM, Defendant Prior Judge: Edward E. Guido : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-6098 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: I. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Brianna Marie Mattesky, bom June 28,1998. 2. A Conciliation Conference was held on January 25, 2001, with the following individuals in attendance: The Father, Michael E. Mattesky, with his counsel, Matthew J. Eshelman, Esquire; and the Mother, Tina Kassam, with her counsel, Karl E. Rominger, Esquire. 3. The parties agree to the entry of an order in the forth as attached. 119'ell UI D TE Custody Conciliator ? A OCT O 3 2002V MICHAEL E. MATTESKV, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW TINA MARIE KASSAM, : NO.99-6098 CIVIL Defendant : IN CUSTODY COURT ORDER AND NOW, this q01 day of 0 Vy` , 2002, upon consideration of the attached Custody Conciliation Report, It is ordered and directed as follows: 1. Ills Court's Order of August 20, 2002 Is modified such that the Father's visitation at the Cumberland County Prison with the minor child shall start every Sunday with Mother delivering the child to the prison at 9:45 a.m. for arrangements of the paternal grandmother to take the child in to the Prison to have a contact visit with the Father. Mother shall leave the prison after she delivers the child to the paternal grandmother and ensures the paternal grandmother can enter the prison with the child for visitation. The child shall then remain with the paternal grandmother after the visit with the Father at the prison for the paternal grandmother to enjoy some time with the minor child. The paternal grandmother shall deliver the minor child to the Mother's home on Sunday at 5:00 p.m. 2. Father's petition for contempt is deemed withdrawn with the understanding that Father can reinstitute the petition if there are any further alleged violations of the order. 3. The hearing scheduled for November 1, 2002 at 8:30 a.m. shall remain as scheduled. BY TA COURT, Edward E. Guido cc: Dirk E. Bem-, Esquire Karl E. Rominger, Esquire ID q 6 RL(C? '?r1 iGc Cc r. .,. ; .,`;4A9Y 020CT-i, ,," Ikn2 wuwy ro" I ISYLVA4;tA MICHAEL E. MATTESKV, Plaintiff v TINA MARIE. KASSAM, Defendant IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-6098 CIVIL IN CUSTODY Prior Judge: Edward E. Guido CONCIi.1ATiOV CONFF_._RF_NCF SUMMARY REPORT AT ndersigned Ct stodv Cncciltal for submits the following PROCEDURE 1915.3-8(b), the wing report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Brianna Marie Mattesky, born June 28, 1998. 2. A Conciliation Conference was held on September 26, 2002, with the following individuals in attendance: The Father, Michael E. Mattesky, with his counsel, Dirk E. Berry, Esquire; and the Mother, Tina M. Kassam, with her counsel, Karl E. Rominger, Esquire. 3. The conciliator just held n conference with three folks about a month ago, and the existing order needs to be tweaked to address an issue with respect to visitation at the prison. Upon the agreement of the parties, the conciliator recommends the entry of an order in the form as attached. r /0 DATE. Hubert X,G o)•, Esquire ; Custoth nciliator = i I ?, ^++; tT SiJr: ? t-1 ?ilC il?Ei t.. vla'i't1.Stn'. IV TIIF r0U9T0F C0N1 l0N ll1,FoooS OF i'i,rintiff (t *,iRFRt tivn rotrvTY. PFVNS INANIA T\'i}, tf rION - 1,,>Nv 71'x.1 41-AfilF KASS,1?i, Itrfendnnt I v r• I ?TnnY Cnl'RT ORi)P.R :t;VD ,NMv, this _ Anti' of Au;urf. 2 MI tinnn ronc}rto ntion of thw;tttnrhat Cusnwlg f'on6fla0nn Wrpeirt, it id Ord?rrA end+firrrt?d ac fnllmvs A hearing is chednled in t"nnrfrnnm NO. Of the f itmhertarwY County c'nurthntxc On Nnvemher i. Z M! se' R-.30 n.m. v this hearint,.-the Mother. rina Nfarir Kassam, shall Ito the mtr-ing party and shall prnreett inmalty with testimony. File anent, :hall he whether this rnnrf`a print- nrdvrof,lamtary 3t.- 2AA1 shall remain in effect upon the Fathers release fmm prlenn atrh that the parties have shared physleal cnmfnrfi, of the tnintor child. Rrianna Marie klatlesky, horn .line 29, MR. Conmetfnr the parties shall rile with the. cnnrr :md Opp(p,,inse mismo l a memnr;mfitm ?etilna fnrth the hkinry of cnstrwty in this c tse, the itvie,; cnrrentlc hefnre thernnrt• each parties PO"offkwt on thane iwiv , it lint of .citnetscs uhn !'ill ter,#16- at the hearing and a summary of the :+nficipntcd testimony of each ?sifnecs. 'this memnrandum shall he Med on or hefnre 1londsrv, f?etnher 29, M12, 1. PendinK farther Order Of Ihle, rnnrt end in rcrO2nitinn of the fact that the l;ttht•r is currenfly intarcerafed, the Nether shall enjoy vNitation with the minor chair) One day a u eek flurlnti Nether',; normnl visitation times at the t.utnhcrland Comd•v Prison, rhk visitation shnil he arranged with the Nlrrther delivering cn-Ifodv Of the child to the Peternsrl Grandmother sn that lit(- palt•cnal 1,randmrdher can take the minor child to the Cumhertand f't,unly Prison for ron}nct visits with her Mather. 'rhis 00tatinn shall he once it nvtrk r•llltet on Wetlnoalay evening err nn Saturday or Sttnday, with rrrtsrrt}tenu•rtle Ito he rnnde hetween IheJftrthrt'skind the paternal flrandmnther. 1h r nilti V, i;ttititr r r. ?t}u i I:, lbtndtt?-rrt 1-etinh t, 1 tr ?l t ? r? ? }?,??,i t? i itnntns i?irlsi, i?,t,tth ., g . 1011 fir. J. FILED Cr 11ic F; DTI.CmC1 02 bUG 20 PM 3145 CUy'K tNISYLVMIA U -t SS 4t S yq?a}? , ,.f Ca f i yt xt t ?y4 t tt_j Y•ti? t i MICHAEL E. NIATTESKY, Plaintiff v TINA MARIE, KASSAM, Defendant Prior Judge: Edward E. Guido : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA : CIVIL ACTION - LAW : NO.99-6098 CIVIL : IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-80)), the undersigned Custody Conciliator submits the following report: 1. The pertinent Information pertaining to the child who is the subject of this litigation is as follows: Brianna Marle Mattesky, born June 28, 1998. 2. A Conciliation Conference was held on August 8, 2002, with the following individuals in attendance: The Father, Michael E. Mattesky, with his counsel, Thomas S. Diehl, Esquire; and the Mother, Tina M. Kassam, with her counsel, Karl E. Rominger, Esquire. 3. The prior order in this case is from January, 2001 at which time the parties entered into an agreement to have shared legal and shared physical custody with this minor child. The parties worked with that order and, essentially, carried out a 50/50 physical custody arrangement. In the Fail of 2001, Father was arrested for his third DUi. lie was Incarcerated July 30, 2002 on a 90-day jail sentence for DUI. The child has been with the Mother while the Father is incarcerated. 4. The Mother's position at this lime is that she wants primary physical custody to continue even when Father is released from prison, and she suggested that supervised visitation may also be necessary upon Father's release from prison. Father suggests that the 50/50 custody arrangement should continue once he is out of jail, and Father is also suggesting that he should have some visitation with his minor child while he is in prison during the normal visitation times in prison. Mother is resistant to taking the child to the prison, and suggests It would not be In the child's best Interests. S. A hearing is necessary to address what happens once the Father is released from prison. In the meantime, the conciliator is of the opinion that this 4 year old child will not be dramatically harmed by visiting the Father in prison. In fact, since the Father has been active in the child's life prior to his incarceration and since the conciliator anticipates the Father will also be involved in the child's life after he is out of jail, it appears to be prudent to continue the 4 year old seeing her father even while in prison. 6. The conciliator recommends the entry of an order in the form as attached. g 4 ea DATE r?> x: MICHAEL MATTESKY IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. TINA MARIE KASSAM DEFENDANT • 99-6098 CIVIL ACTION LAW . IN CUSTODY AND NOW, Tuesday, July 23, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, August 08, 2002 at 9:30 AM 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/ Hubert X. Gilroy, Esq. rnv Custody Conciliator The Court of Common Plcas 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 L'',!.. I, .;i12: PcN?„Y?!411?'Ys i UMMep62UIWOJ-#A%M BVZ"NV - 23tAC3V - ADVDOAOr EIOLI VINYAIASNN7d'il$IIMVJ um-MvInsulwommel OL99'I4Z'LIZ:XYA@ZEIZ'4EL'OOB•OL09'I4Z'LIL MULSp7AONVHHMOS611 0201,1A0 MV11 ? zooz s z inr i rl ^gg > I E 6 h MICHAEL MATTESKY, Plaintiff VS. TINA MARIE KASSAM, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 99.6098 CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW, 20_, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before the conciliator, at on the day of , 200_, 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 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: Custody Conciliator 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. 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 WIIERE YOU CAN GET LEGAL HELP. Office of the Court Administrator Cumberland County Court I louse, Fourth Floor Carlisle, PA 17013 (717)240.6200 MICHAEL MATTESKY, Plaintiff VS. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA NO. 99.6098 TINA MARIE KASSAM, Defendant : IN CUSTODY 2. 3. 4. 5. CIVIL TERM Petitioner is Tina Maric Kassam who resides at 248 Fast North Street, Carlisle, Pennsylvania 17013. Respondent is Michael E. Mattesky who resides at 403 North lledlbrd Street Carlisle, PA 17013. On January 31, 2001, the Honorable Edward F. (h6do, entered Ilse Custody Order attached as Exhibit "A". Since the entry of said order. there has been it significant change in circumstances in that: (a) Father is becoming intoxicated tst the rinses lie is supposed ht have his daughter. (b) Father is continuing to become and renushs enumgled lit Ilse criminal justice system. (c) Upon information and helief Father skits physically ossouhed by others in his home and his home is not a safe place. (d) Father has inappropriately punished Ilse child by stril%ing tier on tier face and head. The best interest of the child %%ill he served by the Court lit modilying said Order. WHEREFORE, Petitioner prays this Court lu gauu the modification with physical custody in the mother with pattiul yishollon in the lidher by agreement of the parties. Respectfully submitted, ROMINCER At IIAVLEY `Karl E. Rominger, Esquire I SS South I lanover Street Carlisle, PA 17013 17171241.6070 Supreme Court ID N 81924 Attorney fior Defendant , LR 3Ar ?R IN I verify that the statements made in this petition are true and correct.' I understand that false statements herein are made subject to the penalties of 18 Pa. cons. Stat. § 4904 relating to unswom falsification to authorities. Date: I ?/U aZ Tina Maric Kassam MICHAEL MATfESKY, Plaintiff VS. TINA MARIE KASSAM, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99.6098 CIVIL TERM : IN CUSTODY CERTIFICATE OF SERVICE 1, Karl E. Romingcr, Esquire, attorney for Defendant, do hereby certify that I this day served a copy of the Petition to Modify Custody upon the following by depositing same in the United Slates Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Michael Mattcsky 403 North Bedford Street Carlisle, PA 17013 Dated: -? /% Z OUQ Karl E. Romingcr, Esquire Attorney for Defendant MICHAEL E. MATTESKY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW TINA KASSAM, NO.99 - 6098 CIVIL Defendant IN CUSTODY COURT ORDER AND NOW, this 3P' day of January, 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. This Court's prior Order of November 23,1999 is vacated. 2. The Father, Michael E. Mattcsky, and the Mother, Tina Kassam, shall enjoy shared legal and shared physical custody of Brianna Marie Mattesky, bom June 28,1998. 3. Physical custody shall be arranged pursuant to agreement of the parties. 4. This Order is entered with recognition that both parties am currently unemployed and they each expect to obtain some type of employment in the futum that may merit a reevaluation of this custody arrangement. The Conciliator shall conduct a telephone conference call with the attorneys for the parties on Thursday. March 8, 2001 at 8:30 a.m. The purpose of this telephone custody conciliation confemtce shall be to update the Conciliator on the status of the case and determine whether another formal conciliation conference needs to be scheduled or determine whether a hearing needs to be scheduled. B CO T, ':? P J. Edward E. Guido cc: Kul E. Rominger, Esquire Matthew J. Eshelman, Esquire zj -P1a&j W-01-0i Res Z)-ekk-e "AN I F MICHAEL E. MATTESKY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 99 - 6098 CIVIL TERM TINA KASSAM, CIVIL ACTION - AT LAW - CUSTODY Defendant PREVIOUSLY ASSIGNED TO: J.GUIDO PRAECIPE FOR WITHDRAWAL AND ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw the appearance of Matthew J. Eshelman, 1 i Esquire, on behalf of the Plaintiff, Michael E. Mattesky, in the above-captioned action. Respectfu ly submitted, Law Offices of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building 3 23 o r Camp Hill, Pennsylvania 17011-4706 Date: IDA 72655 Tel. (717) 763-1800 Kindly enter the appearance of Michael E. Mattesky, pro se, in the above-captioned action. Respectfully submitted: LAL 403 N. Bedford Street Carlisle, PA 17013 (717) 241-9283 ..-.. .?.-n -.,.- n+wx..•vw??'Kre.?w,iw5+f?weW's4. ru.?feyyywya; Wi..iom ` y A F Y k 1u? n _ kM. Tay LLGHL 5LRVICE$, IIIL. 14400]6 P'02-. ` ?11 C ?l ?? 1, l: ti\a 1l??Kv ' _ r Plaintiff IN THE CUIIR I' ()I• COMMON PLEAS OF ?t* CUMBERLAND COUNTY. PENNSYLVANIA . V. ' 'L ?ZNn KA`aSpN\ NO. 9_- CIVIL I'I'RR ?C% L q 9 i ' t. 1 y Defendant l v i !E ' `5' 7- rxAECIP '1'Qj!j?Cj;j;ll.rN 1:(Z({??_PAtiPFRiC ' o the Prothonotary: " y ,;. Kindly allow, Mnn h y to proceul hi fttrgta paupcm. :'" Ric. h f1t10 ; ? ' ?•. "At„y , attorney for the party proceeding ill Louth pauper, certify that 1 believe the party.ts to pay the costs and that I am providing free legal services It, the party. The party's affidavlt'shi to pay the costs of litigation is altached hereto. Name Pu?+Fll?p?Ivr% , MOAR14j17R, Attorney for PL, ns N > zdcre Andress ?le6 G , K1NC 57, S1l.Z Uy?„s8p1K6? PJ? I l'?.h'? g?' WV H AL L L, N1A116yKr I't N 1 vs a. i 1 r r . :NQ. 99- VIVILTERNI 7?.N f, KhSSAM Defendant ©LTlDAaCjLU UUjjjlj.U-l, t 'r'; MLC),9 U1R-I J:AW To PR=-E-D 1N I:OMA PAUPERIS tr I. I an? the l ' f in the above matter and because of my financial condition am unable to pay `i- i -the fees and costs of ptosecumng, defending, or appeilinL the action or proceeding. 2. I am unable to obtain funds from anyone, including illy thmily and associates, to pay the costs of SK :4idgadon . ti. 3. I represent that the information below relating fn illy ;ability to pay the fees and costs ik true and it"': k COlreel. (a) Name: Address: r dS + (b) Social Security Number: ",.,,If you are presently employed, state ., ` Employer: y, 1 Address: --- :' . Salary or waves per month: Type of work: ;you are presently unemployed, state -i. ' Date of last employment: £5 i. 4-j s.dr J. X1 Salary or wages per month rNwoiNrt2?LL. ft f cK 3??ks Type of work: NY_ ' u1 a,?r? ' LL'.GHL SEhV 14115. 1110. (c) Other income within the bast twelve months Business or profession: Other self-employinum: Interest: Dividends: Pension and annuities: < Social Security bcnef?ts: Support payments: r. _ Disability payments: Unemployment compensation and t. supplemental benefits: _ L4 ° %;. Workman's cornpciisation: t. Public Assistance: Other: _ (d) Other contributions to household support ' Y(Wife)(Iiusband) Name: ?P If your (husband) (wife) is employed, state Employer: _ Salary or wages per month: s Type of work: 1 Fp „y.• ; Contributions from children:. (e) Property owned Cash: Checking Account:__ _`. o e _ -_- - Savings Account:__2 S. o ° Certificates of Deposit: ?- 2436u2e P.03, r ,j p}, :i f J? fYOJA ji? pt irlR:l=': < i f ,? Y Py r Y4 t Zt(R; ?.r r" , ?as , p p y><! 1 ? N ry ,? h Iyy,,y w. § °t:1, 11 LL'GHL SLNVICF4. Mi.- 243 0026 P'04, Real Estate (including home): Motor vehicle: Make YL.lr are .' Cost Aniounl o%vi.1 ._ ? .µ ? j,:- Stocks; bonds: Other: _ ~ , , (Q Debts and obligations Mortgage: Rcnt: Loans: P(l1uX 26) 000 r .5 „ Monthly Expenses: - --- -- -- ---- ki (g) Persons dependent upon you for suplxwrt (Wife) (Husband) Name: _ --•--- ` •}` Children, if any: Name: Age: 4, 1 understand that I have a continuing obligation to inform the court of improvement to my' financial circumstances which would )xrmit me to pay the cods incurred herein. M;:f± ry}?. 5. I verify that the statements made in this affidavit arc true and correct. A understand that falsa #`a# statements herein are made subject to the penalties of lti Pa. C.S. 4904, relating to unsworn falsifieatioA to +"S"° ".'•.:5 Date: ?'! - ??$ n' t• - 1l1 f t C7 t:? It M'. L'7 -"fin 1 t" V :7)11 \ ? a ..., - MICHAEL E. MATTESKY IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. TINA KASSAM DEFENDANT 99-6098 CIVIL ACTION LAW IN CUSTODY AND NOW, this 20TH day of October , 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their rcspcctivc counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor Cumberland County Courthouse, Carlisle on the lit day of December , 2000, at 9:30 a.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 ?o 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: Id Hitlzea-M-Glcoxynb 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 1*0 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 KELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 jp /to -'n IOOWd-e I 4 9j E ?s ma sc a PATRICK F. VAUER, JR. Attorney at Law 2108 Mar1d Sum ' Azlcd Bmldin8 ' Camp hill, PA 17011 17171763.1800 DOT ] H 100p? MICHAEL E. MATTESKY, s IN THE COURT OF COMMON PLEAS OF Plaintiff s CUMBERLAND COUNTY, PENNSYLVANIA i vs. s No. 99 - 6098 CIVIL TERM i TINA KASSAM, s CIVIL ACTION - AT LAW - CUSTODY Defendant s PREVIOUSLY ASSIGNED TOs J.GUIDO AND NOW, this , upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before the conciliator, at the day of , on 2000, at .M., for a Prehearing 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. Either party may bring the child who is the subject of this custody action to the , but the child/children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: By: Custody Conciliator SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 MICHAEL E. MATTESKY, Plaintiff vs. TINA KASSAM, Defendant s IN THE COURT OF COMMON PLEAS OF s CUMBERLAND COUNTY, PENNSYLVANIA s s No. 99 - 6098 CIVIL TERM s s CIVIL ACTION - AT LAW - CUSTODY s PREVIOUSLY ASSIGNED TO: J.GUIDO 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. J .A*e MICHAEL E. MATTESKY, Plaintiff vs. TINA KASSAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 99 - 6098 CIVIL TERM CIVIL ACTION - AT LAW - CUSTODY PREVIOUSLY ASSIGNED TO: J.GUIDO PETITION FOR MODIFICATION OF A PARTIAL CUSTODY OR VISITATION ORDER The Petitioner, Michael E. Mattesky, through his attorneys, The Law Offices of Patrick F. Lauer, Jr., files this Petition for Modification of a Partial Custody or Visitation order against the Respondent, and in support thereof, avers the following: 1. The petition of Michael E. Mattesky respectfully represents that on November 23, 1999, an Order of Court was entered for Partial Custody, a true and correct copy of which is attached. 2. This Order should be modified because: a. The parties reconciled subsequent to the Order and lived together for a period of approximately three months; b. The parties' work schedules, living arrangements, and domestic situations have changed; C. The child has resided primarily with Father since June; d. The Order should be modified to reflect the actual circumstances of the parties and the child's schedule. WHEREFORE, Petitioner requests that the Court modify the existing Order for Partial Custody because it will be in the best interest of the child. tted, Matthew J. Eshelman, Esquire 2108 Marks Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 Date: IU ?Q ID/ 72655 Tel. (717) 763-1800 VERIFICATION it /UtCwwc /4rdwy , state that I am the PlA14714F in above-captioned case and that the facts set forth in the above '?MIou*p MW(Fy are true and correct to the beet of my knowledge information, and belief. I realize that false statements herein ar subject to the penalties for unsworn falsification to under 18 Pa. C.S. S 4904. Date: ?? 7 dC? EXHIBIT A -s MICHAEL E. MATTESKY, Plaintiff V. TINA KASSAM, Defendant IN TI-1f: COURT OF COMMON PLEAS OF CUMOI:7%t AND COUNTY, PENNSYLVANIA :CIVIL ACTION LAW t NO. C!,-C00R CIVILTERM CUST(,I.• ` ORDER Cl ' OURT r' NUV 2., 19 v . r # r' ?J„"iCtf? V r\ ,t A) NOW, this •d3 AA day of 1000, Narsuant to an agrecmaM a'K, t'., of the pridior, !t Is ordered that: 1. Mlcirie! E. Matlosky ond'Tina SGv-nrl n •:dl exrrrlsojoint Io;Tal custody of Brianna 2 Ti^ K ssam shall exerciso prinrrny I•uy• .al cu::tudy of Dlianna Mario Mattesky and .. a Michael E. Matlesky shall exercise Parllat Physil:al :ustady as follows: a. Every other weekend from Frid: ; G:00 P.M, until Sunday at 6:00 P.M. { b. Custody shall alternate on the fl Sowing holidays such that Michael shall have ;t A custody as folloym (•I) In even numbered train 0:00 P.M. the day before the holiday until 0:00 P.M. on I;w 1' d the holiday on 1.1amodal Day and Labor r Day" (2) In odd numbered yen 'tom 0:00 P.M. cr• the day before the holiday `'' until axto P.M. on tim da; if ilia holiday on Indepondance Day and ; ThnM?411vint! '': (s) For a pallod of live, ("O'•ouls on Christman as may be agreed upon by the parties from limo I. .ono. Every Wednosday oval lin0 frr-l. !,:ri0 P.Ivt. Wool 0:(10 P.lA, C : . 1. I • ` d. Every uummor for six (R) r.rora: which works shall be desigratcd by fnlhor 1 revs 4AU1 Il n.h / ylll ll 1j. o. Al such other limes us the paihus may mutually agree. 3. Th^ party recolving custody shall ho m! l.•msihle for transportation. } i fly ilia Coull, ; p i • Prolhonoldry I ;R MICHAEL MATTESKY, : IN THE COURT OF COMMON PLEAS OF PETITIONER : CUMBERLAND COUNTY, PENNSYLVANIA V. TINA KASSAM, RESPONDENT : 99-8098 CIVIL TERM ORDER OF COURT AND NOW, this 2/Y day of February, 2001, IT IS ORDERED that Tina Kassam shall not move Brianna Mattesky from the State of Pennsylvania without an order of court, which she may seek. Michael Mattesky, Pro se Karl E. Rominger, Esquire For Respondent :saa By the Court, Edgar `13. Bayr, J. x?i. ? ( ? r C?3 y? t-.; a. U.t __ ..rh??1.?E1 rn???.sk`t ?N AL LOUR?.Q .(wr1 oN_ c AA"ia l ii NA ?<ASS1) r\ _ ND.. _ 199°? - loo q g_ L; ?; ? tam__ v4ioO_FoR_5pf? a1.R?ItE _ __ _. _. __ _...(?O/?1fI5_/UdGe?? / ;GlJRE? / ? eSr`Y?-GtJ!?O Oats A&-.by 4.vv?-A ?. cI Iwoz s Cvvcc ptf 1 _ mmlhfs fk a8 0li SI w is va -------._ ._wha pL-5%AfS kN. yo3 ?. B ?Ra _4, _C.jel.sl £ PAT )i5 --- -d..???NdFN? ,S ? R r?RS?4/?'?, A?? Aa??+_?Na??,a??.l _w? no ofpcsomwc- .Ake Rd L14911'611F _ PA, _T14_I -- -TkL inoT cq "Ti,oi) KP?ssAr? 1 +6*A'}cA.>tJ -fo IeAVE 7 Ac- 7,44f 4,wA o?oe dAullr(vr2 SRIANNtq -7hc mo %p- ANA s - ... kA15AM 6.3 r?l x rN -At PN5?-&V S?NkL w;A_c 4-._.. ... d,4C?-fK lZiFWNA ?O PVTVCA, y "S /WVA/Aif Lo ill) /Vo ?rPiHNNA//,, /f?l??fS?cY11""?1A5 .SfA?FCI ? A _ __. Aolgllz Tiu? ?Si SHi? hP%6 SAI'a 1?f_hf.;sfL?F;-B??1AoeJA!ANcl /7 40412 5 4741 lf&%J5 17ou5E rAFA?e ?rwA_y_,_ ??y OF Ndv/(/-f" AAjci wE I bitN?j caF M?..dgc?j?ift3?is _hnj?d_RNd woL,,IJ 6i MoRc -s£cu?e? - - _ /i?/If1Gl-._. ig/(£5 ?(1_ R?n .ASKiN? U (' , -____._.__?RiA??NA._.I?'IJ?sky-bc qiu; bii-tie owE?l bNl y -s?c?.e??l uis;}s eiNJ+; -- W f?E.2.Fdkt- AL P?l?ia?vf?Z REgvEs?". T11i5 TF?"'OQA? 5e fYI,LhAE?__IM&3 y03 N aFd(:?,/ad zAdl5 h PP, 11613 (-71?)-?VI `q ZgS3 PA POP 1 , } 3 i I n , 7 .?x i I?2r.?zeal0??c'c1?? 103 RJ /? /?o?dS ?C??J,?, ?G I DUI ? t:. 4r . ? 1. 4 Y s rA? Ha r? fi?? • M?chUe\ C.Mo1?e5?? Plaintiff V. Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, : PENNSYLVANIA CIVIL ACTION LAW NO. (0073 CIVIL 1999 CUSTODY VISITATION And now, this i0haO L-{?, upon consideration of the attached com taint, it is hereby directed that the above parties and their respective counsel appear before lk X r-j rn Esquire, the conciliator, at 0% Pennsylvania, on the _W- day of '1919' at. R-xn_ 4?/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 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: -? 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. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (i 17) 249-3166 1-800.990-9108 OCT 0 6 lgglq , MICHAEL E. MATTESKY, Plaintiff V. TINA KASSAM, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ?- :NO. qQ-(oor/?? ?IC?r? 1E211 IN CUSTODY ORDER OF COURT AND NOW, this day of 1999, upon consideration of the attached Complaint, It Is hereby directed that the parties and their respective counsel appear before Esq., the conciliator, at . _ t Cumberland County, Pennsylvania, on the _day of 1999, at _ O'Clock for a Pre-Hearing Custody Conference. At such conference an effort vdil be made to resolve the Issues in dispute, or If this cannot be accomplished, to define and nanow the Issues to be heard by the Court and to enter Into a temporary Order. Either party may bring the child or children who are the subject of this custody action to the conference, but the child's attendance Is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent Order. BY THE COURT; BY: Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 liberty Ave. Carlisle, PA 17013 (717) 240 - 3160 MICHAEL E. MATTESKY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION • LAW :NO. (?q- TINA IVt If 2Nl KASSAM, Defendant : IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff Is Michael E. Mattesky, an adult individual who resides at 403 N. Bedford St., Carlisle, PA 17013. 2. The Defendant Is Tina Kassam, an adult Individual who was last known to reside at an unknown location in San Diego, CA. Jurisdiction Is established because she and the child lived In Cumberland County, Pennsylvania within the last six (8) months. 3. Plaintiff seeks partial physical custody of the following children: NAME PRESENT ADDRESS DATE OF BIRTH Bdanna Marie Mattesky San Diego, CA June 28,1988 The child was born out of wedlock. The children presently are In the custody of Tina Kassam who was last known to reside In San Diego, California. During the past five years, the children have resided with the following persons and at the following addresses: DATES PERSONS ADDRESS 08/12/99 TO CURRENTTina Kassam San Diego, CA BIRTH TO 118112/99 Michael E. Mattesky 8 403 N. Bedford St. Tina Kassam Carlisle, PA 17013 The mother of the child Is Tina Kassam who resides In San Diego, CA She Is married. She resides with the child and her daughter Sabrina Kassam. The father of the child Michael E. Mattesky. He resides at 403 N. Bedford St., Carlisle, PA 17013. He Is not married. He resides with his roommate Joe Hunt. He Is temporarily Incarcerated. The relationship of Plaintiff to the child is that of father. He resides with his roomate Joe Hunt. 5. The relationship of Defendant to the child is the mother. She lives with the child and her daughter Sabrina Kassam. 8. Plaintiff has not participated In any custody action regarding the custody of Bdanna Marie Mattesky, In this or any other Commonwealth. Plaintiff does not know of any other 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 relief requested Is in the best Interests of the child in that: A. Plaintiff can provide as much stability as Defendant; 8. Plaintiff can provide the same quality of mental, emotional and physical care as Defendant; C. The child's paternal and maternal grandparents reside In Cumberland County and are available to provide further mental and emotional support for the child; Each parent whose parental rights have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or vlsItatlon of the child will be given notice of the pendency of this action and right to Intervene: NONE. 9. To the beat of the Plalntlfrs knowledge the Defendant is not represented by counsel In this matter. WHEREFORE, Plaintiff respectfully requests that your Honorable Court enter an Order granting joint physical and legal custody of the child. R ly su fitted, I Attorney for Plaint 318 E. Iang St. Shippensburg, PA 17257 (717)530.8879 ID # 74454 DATE: 1 \ 1 I verify that the statements made In this Complaint are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Sec. 4904, relating to unswom falsification to authorities. '/? <7,4 _ MICHAEL E. MATTESKY' ?t rn a cr% m '1 u - .. \ MICHAEL E. MATTESKY, Plaintiff V. TINA KASSAM, Defendant AND NOW, this day of 1999, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before . Esq., the conciliator, at Cumberland County, Pennsylvania, on the _ day of 1989, at _ O'Clock 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 nanow the Issues to be heard by the Court and to enter Into a temporary Order. Either party may bring the child or children who are the subject of this custody action to the conference, but the child's attendance Is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent Order. BY THE COURT; BY: Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Ave. Carlisle, PA 17013 (717) 240 - 3166 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW etc; : NO. 99 _ Z 07P ( /Ert11 IN CUSTODY ORDER OF COURT - y ` MICHAEL E. MATTESKY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : NO. n TINA KASSAM, :., ..., Defendant : IN CUSTODY COMPLAINT FOR CUSTODY ?• f 1. The Plaintiff Is Michael E. Mattesky, an adualndlvidual who resides at 403 N. Bedford St., Carlisle, PA 17013. 2. The Defendant Is Tina Kassam, an adult Individual who was last known to reside at an unknown location in San Diego, CA. Jurisdiction Is established because she and the child lived in Cumberland County. Pennsylvania within the last six (8) months. 3. Plaintiff seeks partial physical custody of the following children: NAME PRESENT ADDRESS DATE OF BIRTH Bdanna Marie Mattesky San Diego, CA June 28,1088 The child was bom out of wedlock. The children presently are in the custody of Tina Kassam who was last known to reside In San Diego, Califomia. During the past five years, the children have resided with the following persons and at the following addresses: DATES PERSONS ADDRESS 00112!89 TO CURRENTTIna Kassam San Diego, CA BIRTH T008/12/99 Michael E. Mattesky & 403 N. Bedford St. Tina Kassam Carlisle, PA 17013 The mother of the child is Tina Kassam who resides in San Diego, CA She is married. She resides with the child and her daughter Sabrina Ka m. The father of the child Michael E. Mattesky. He resides at 403 N. Bedford SL, Carlisle, PA 17013. He Is not married. He resides with his roommate Joe Hunt. He Is temporarily Incarcerated. The relationship of Plaintiff to the child Is that of father. He resides with his roomate Joe Hunt. 5. The relationship of Defendant to the child Is the mother. She lives with the child and her daughter Sabrina Kassam. 6. Plaintiff has not participated In any custody action regarding the custody of Bdanna Marie Mattesky, In this or any other Commonwealth. -i ? Plaintiff does not know of any other 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 relief requested is in the hest Interests of the child in that: A. PlalnUff can provide as much stability as Defendant; B. Plaintiff can provide the same quality of mental, emotional and physical care as Defendant; C. The chlids paternal and maternal grandparents reside In Cumbedand oL`Wunty and are available to provide further mental and emotional support for the child; Each parent whose parental rights have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and right to Intervene: NONE. 9. To the best of the Plaintiffs knowledge the Defendant is not represented by counsel In this matter. WHEREFORE, Plaintiff respectfully requests that your Honorable Court enter an Order granting joint physical and legal custody of the child. R Ily su fitted, I ? 1 Attorney for Plaint 318 E. Idng St. Shippensbu , PA 17257 _ _P9 Y5 q (717) 5304B ID # 74454 DATE: 1 lJ \ CJ- 19 q I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Sec. 4904, relating to unworn falsification to authorities. MICHAEL E. MATTES .. 4 OCT 0 5 1990 MICHAEL E. MATTESKY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW :NO. 97-(cvgP Cluj( s2h7 TINA KASSAM, Defendant : IN CUSTODY ORDER OF COURT NOW this day of 1999, upon the petition of plaintiff, defendant Is hereby ordered not to remove the child from the Commonwealth, pending further hearing in this matter. Further, a hearing is set for the day of . 1999, at O' Clock, in Courtroom _, of the Cumberland County Courthouse, Carlisle, PA, 17013, to determine If an order prohibiting the removal of the child from the Commonwealth should remain In effect until further order of this Court. J. 318 E. King St. Shiooensbura. PA I verify that the statements made In this Complaint are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Sec. 4904, relating to unswom falsification to authorities. MICHAEL E. MATTESKY MICHAEL E. MATTESKY, Plaintiff V. TINA KASSAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. : IN CUSTODY PETITION FOR EMERGENCY ORDER PREVENTING THE REMOVAL OF THE CHILD FROM THE COMMONWEALTH NOW, comes Michael E. Mattesky, by and through his attorney Richard M. Mortis, Jr. and petitions the court as follows: WHEREAS: 1. The mother left the Commonwealth with the child in June of 1999. This was done with no notice to the father. The father has not been allowed access to the child or even been told where mother and child were located. 2. The mother has returned to the Commonwealth with the child. 3. It Is the understanding of the father that the mother Intends to leave the Commonwealth again with the child inhibiting plaintiffs ability to exercise custody or even serve process in this case. WHEREFORE, plaintiffs respectfully request that the court grant an emergency order prohibiting the removal of the child from the Commonwealth. I\ fry C- ` Ei"?',. to fir CA I I 3??F r x4??3 f I F. 91? R` ? V k s ..v Fn`s ri ii OCT 0 5 19990 MICHAEL E. MATTESKY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION • LAW :NO. 9(2, 6c)gp TINA KASSAM, Defendant : IN CUSTODY ORDER OF COURT NOW this day of 1999, upon the petition of plaintiff, defendant is hereby ordered not to remove the child from the Commonwealth, pending further hearing In this matter. Further, a hearing is set for the day of ? 1999, at a Clock, In Courtroom . of the Cumberland County Courthouse, Carlisle, PA, 17013, to determine if an order prohibiting the removal of the child from the Commormwith should remain In effect until further order of this Court. J. 1 MICHAEL E. MATTESKY, Plaintiff V. TINA KASSAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. : IN CUSTODY PETITION FOR EMERGENCY ORDER PREVENTING THE REMOVAL OF THE CHILD FROM THE COMMONWEALTH NOW, comes Michael E. Mattesky, by and through his attorney Richard M. Morris, Jr. and petitions the court as follows: WHEREAS: 1. The mother left the Commonwealth with the child in June of 1999. This was done with no notice to the father. The father has not been allowed access to the child or even been told where mother and child were located. 2. The mother has returned to the Commonwealth with the child. 3. It is the understanding of the father that the mother Intends to leave the Commonwealth again with the child Inhibiting plaintiff s ability to exercise custody or even serve process In this case. WHEREFORE, plaintiffs respectfully request that the court grant an emergency order prohibiting the removal of the child from the Commonwealth. n 318 E. Icing St. v Shippensburg, PA 1 I verity that the statements made In this Complaint are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Sec. 4904, relating to unswom falsification to authorities. MICHAEL E. MATTESKY - OCT 0 5 1990 MICHAEL E. MATTESKY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LA?W+ /} ?-7'? ?1 :NO. Q9^6,Oldp (Suit (E l TINA KASSAM, Defendant : IN CUSTODY ORDER OF COURT NOW this day of 1999, upon the petition of plaintiff, defendant Is hereby ordered not to remove the child from the Commormealth, pending further hearing In this matter. Further, a hearing is set for the day of ? 1989, at a Clods, In Courtroom _, of the Cumberland County Courthouse, Carlisle, PA, 17013, to determine If an order prohibiting the removal of the child from the Commormealth should remain In effect until further order of this Court. J. MICHAEL E. MATTESKY, Plaintiff V. TINA KASSAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN CUSTODY PETITION FOR EMERGENCY ORDER PREVENTING THE REMOVAL OF THE CHILD FROM THE COMMONWEALTH NOW, comes Michael E. Mattesky, by and through his attorney Richard M, Monts, Jr. and petitions the court as follows: WHEREAS: 1. The mother left the Commonwealth with the child In June of 1999. This was done with no notice to the father. The father has not been allowed access to the child or even been told where mother and child were located. 2. The mother has returned to the Commonwealth with the child. 3. It Is the understanding of the father that the mother Intends to leave the Commonwealth again with the child Inhibiting plaintiffs ability to exercise custody or even serve process In this case. WHEREFORE, plaintiffs respectfully request that the court grant an emergency order prohibiting the removal of the child from the Commonwealth. P. 318 E. King St. Shippensburg, PA (717) 530 - 8579 ID # 74454 I verify that the statements made In this Complaint are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Sec. 4904, relating to unswom falsification to authorities. M? MA IIESKY ?. MICHAEL E. MATTESKY, Plaintiff V. TINA KASSAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVILACTION LAW NO. 99 - 8098 CIVIL TERM :CUSTODY dayo ORDER OF C; LRT P?ln??'? NOW, this 1999 persuant to an agreement of the parties, it is ordered that: 1. Michael E. Mattesky and Tina Kassam shall exercise joint legal custody of Brlanna Marie Mattesky. 2. Tina Kassam shall exercise primary physical custody of Bdanna Marie Mattesky and Michael E. Mattesky shall exercise partial physical custody as follows: a. Every other weekend from Friday 8:00 P.M. until Sunday at 8:00 P.M. b. Custody shall alternate on the following holidays such that Michael shall have custody as follows: (1) In even numbered years, from 8:00 P.M. the day before the holiday until 8:00 P.M. on the day of the holiday on Memorial Day and Labor Day. (2) In odd numbered years, from 8:00 P.M. on the day before the holiday until 8:00 P.M. on the day of the holiday on Independence Day and Thanksgiving. (3) For a period of five (5) hours on Christmas as may be agreed upon by the parties from time to time. c. Every Wednesday evening from 5:00 P.M. until 8:00 P.M. d. Every summer for six (8) weeks, which weeks shall be designated by father not later than April 15. e. At such other times as the parties may mutually agree. Nov22 vs?? 3. The party receiving custody shall be responsible for transportation. By the Court, J. , % MICHAEL E. MATTESKY, Plaintiff V. TINA KASSAM, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION LAW NO. 99 - 8098 CIVIL TERM :CUSTODY PETITION FOR ENTRY OF CUSTODY AGREEMENT 17013. 1. Plaintiff Is Michael E. Mattesky, who resides at 403 N. Bedford St., Carlisle, PA 2. Defendant is Tina Kassam, who resides at 170 Opposum Lake Rd., Carlisle, PA 17013. 3. The parties are the natural parents of Bdanna Marie Mattesky, Age 1, Date of Birth June 28, 1998. 4. On N 1VEMIM 19 1999, the parties entered Into an agreement regarding the custody of the child, which Agreement is attached hereto and Incorporated herein as Exhibit "A". 5. The best Interests of the child will be served by this Court entering said custody Agreement, set forth as Exhibit "A", as an Order of Court. WHEREFORE, petitioner requests this court approve the foregoing Agreement and enter it as an order of court. Respectfully su tied, Riche . tid Attorney for Plain 318 E. King St. Shippensburg, PA 17257 (717) 530-8579 ID #74454 MICHAEL E. MATTESKY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION LAW V. NO. 99 - 8098 CIVIL TERM TINA KASSAM, Defendant :CUSTODY EXHIBIT "A", CUSTODY AGREEMENT AND NOW, this ? day of N 0%M (;9 1999, it is agreed by and between Michael E. Mattesky, Plaintiff, and Tina Kassam, Defendant, that the Court enter a custody order regarding Brlanna Marie Mattesky, as follows: 1. Michael E. Mattesky and Tina Kassam shall exercise joint legal custody of Bdanna Marie Mattesky. 2. Tina Kamm shall exercise primary physical custody of Brlanna Marie Mattesky and Michael E. Mattesky shall have partial physical custody as follows: a. Every weekend from Friday at 8;00 P,M. until Sunday at 8:00 P.M. b. Custody shall alternate on the following holidays such that Michael shall have partial custody as follows: (1) In even numbered yearn, from 8:00 P.M. the day before the holiday until 8:00 P.M. on the day of the holiday on Memorial Day and Labor Day. (2) In odd numbered years, from 8:00 P.M. the day before the holiday until 8:00 P.M. on the day of the holiday on Independence Day and Thanksgiving. (3) For a period of Ove (5) hours on Christmas as may be agreed upon by the parties from time to time. c. Every Wednesday evening from 5:00 P.M. until 8:00 P.M. d. Every summer for six (8) weeks, which weeks shall be designated by father not later than April IS. e. At such other times as the parties may mutually agree. 3. The party receiving custody shall be responsible for transportation. WITNESS 'MICHAEL E. MATTESKY WITNESS TINA KASSAM ?we?a.w.r?. M. iw.?i.. i.:?.?.? .. "..........:.a .:e.?... . ... ....?auw.a.•....w?. N?a?'e..sunw- .wtiti...?. V i r .? la ! 1. 1 Ulf ?, cli DEC 2 2 19998) MICHAEL E. MATTESKY, Plaintiff v TINA KASSAM, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-6098 CIVIL IN CUSTODY COURT ORDER AND NOW, this a day of December, 1999, the Conciliator being advised that the parties have reached an agreement, the Conciliator relinquishes jurisdiction. BY THE COURT, cc: Richard M. Moms, Esquire Tina Kassam 170 Oppossum Lake Road Carlisle, PA 17013 Hubert X. Gi y, Esquire Custody C nciliatoor / ?,?,,. A>z?(1 or AK-5 (J r' tf) ?.i liii;. :7 :.? r? v ,, n i ?: ?,, ; •T, S ? ?_ "-c-. .._ ?? %i ? _? ? (T RICHARD MORRIS, JR. A=)?"YATLAW 318 E. King St. Abippuneburg.PA 17287 (717) 63P6678 4 4w ?y `I 1 .. .}fit z .x^.`-; ` F;?. TINA MARIE KASSAM IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. MICHAEL E. MATTESKY • 99-6098 CIVIL ACTION LAW DEFENDANT IN CUSTODY AND NOW, Thursday, August 09, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Erg. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday. September 07, 2001 0l 9:30 a.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 may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: , Is/ Hubert X• Gilroy. Esq& Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATfORNEY 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 01 Al1G I 0 Prl 2' 30 CUI'p-EMSYL`INTANiY 4 " of Alm io H., ?:3e CUt PEP NSYNN A NiY ego Ma-t? a %V I Area I North Maln Street 165 South Hanover Street ? !i CarW, Pen*lvanl6 17013 717.241.6070 • 1100.734.0490 • FAX* 7p.a.a7s Chamberaburg, Pennrylvanla -17201 .. : IN THE. COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-6098 CIVIL TERM Michael E. Matteaky, Defendant : IN CUSTODY ORDER OF COURT AND NOW, , 2001, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before the conciliator, at on the day of 2001_, nt o'clock, _.M.. for a Pre-I fearing 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 or a temporary or permanent order, FOR TI Ili COURT: By:. Custody Conciliator The Court of Common fleas 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 he 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: TI IIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT I IAV E A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPI ZONE THE OFFICE: SET FORTII BELOW TO FIND OUT WHERE YOU CAN GET LEGAL IIELP. Office of the Court Administrator Cumberland County Court I louse, Fourth Floor Carlisle. PA 17013 (717) 240.6200 MICHAEL MAT'ITSKY, Plaintiff VS. TINA MARIE KASSAM, Defendant : IN TI IE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99.6098 CIVIL. TERM : IN CUS'T'ODY PETITION TO MODIFY CUSTODY 1. Petitioner is Tina Marie Kussam who resides at 170 Opossum Lake Road Carlisle, PA 17013. 2. Respondent is Michael E. Mattesky who resides at 403 North Bcdford Street Carlisle, PA 17013. 3. On January 31, 2001, the I lonomble Edward E. Guido, entered the Custody Order attached as Exhibit "A". 4. Since the entry of said Order, there has been a significant change in circumstances in that: (a) Father continues to fail to make the equal exchange. 5. The best interest of the child will be served by the Court in modifying said Order. WHEREFORE, Petitioner prays this Court to grant the modification with physical custody in the mother with partial visitation in the father by agreement of the panics. Date: -Q 1 ??V-1.6?e KG2121& 7 Tina Marie Kussam, Petitioner t 1 verify that the statements made in this petition arc true and correct. I understand that false statements herein are made subject to the penalties of 18 1'a. cons. Slat. § 4904 relating to unswom falsification to authorities. Date: !i? 11L),- r-, Tina Marie Kassam MICHAEL MATI'ESKY, Plaintiff VS. TINA MARIE KASSAM, Defendant : IN 7'111: COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6098 CIVIL TERM IN CUSTODY CERTIFICATE OF SERVICE 1. Karl E. Romingcr, Esquire, attorney for Defendant, do hereby certify that 1 this day served a copy of the Petition to bfodify Custody upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle. Pennsylvania, addressed as follows: Michael Mattesky 403 North Bedford Street Carlisle, PA 17013 Datcd: QUa c(j X001 Karl E. Romingcr, Esquire Attorney for Plaintiff JAN 3 0 MICHAEL E. MATTESKY, Plaintiff TINA KASSAM, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO.99-6098 CIVIL IN CUSTODY AND NOW, this 3A7 day of January, 2001, upon consideration of the attached Custody Conciliation Report, it Is ordered and directed u follows: 1. This Court's prior Order of November 23, 1999 is vacated. 2. The Father, Michael E. Manesky, and the Mother, Tina Kassam, shall enjoy shared legal and shared physical custody of Brianna Marie Manesky, bom June 28,1998. 3. Physical custody shall be arranged pursuant to agreement of the parties. 4. This Order is entered with recognition that both parties are cur=tly unemployed and they each expect to obtain some type of employment in the futum that may merit a reevaluation of this custody arrangement. The Conciliator shall conduct a telephone conference call with the attorneys for the parties on Thursday, March 8, 2001 at 8:30 a.m. The purpose of this telephone custody conciliation conferee shall be to update the Conciliator on the status of the case and determine whether another formal conciliation conference needs to be scheduled or determine whether a hearing needs to be scheduled. B CO T, Edward E. Guido cc: Karl E. Rominger, Esquire Matthew J. Eshelman, Esquire zap'?In&&J 0. -O/-01 R?.s ti c? J r? N Cy T l [L ?; J dl? f ?T Y f: •. 3i. X`I p)F L Law Office of James K. Jones, Esquire Y`rtvine Row Cadisle, PA 17013.3019 (717) 240-0296 AUG 0 6 20V MICHAEL MATTESKY : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99-6098 CIVIL ACTION LAW TINA MARIE KASSAM : IN CUSTODY Defendant AND NOW, this day of August, 2002, it is hereby ordered and directed that the Clerk of Court of Common Pleas of Cumberland County, Pennsylvania issue a Writ of Habeas Corpus Ad Procequedum directing the Warden of Cumberland County Prison to deliver the body of Michael Mattesky to the Sheriff of Cumberland County, Pennsylvania for the purpose of transportation to Cumberland County Courthouse to attend a Pre-Hearing Custody Conference scheduled for August 8, 2002 at 9:30 a.m. The Sheriff of Cumberland County is hereby directed to serve the Writ upon the Warden of the Cumberland County Prison. This Writ shall be for the purpose of his release from said institution and his return thereto following the conclusion of said hearing unless otherwise ordered by the Court. This Order is to constitute sufficient warrant by the Court. BY THE COURT, J. cc: Dirk E. Berry, Esquire Counsel for Petitioner MICHAEL MATTESKY Plaintiff V. TINA MARIE KASSAM Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6098 CIVIL ACTION LAW : IN CUSTODY 1. Petitioner is incarcerated at Cumberland County Prison in the work release program. 2. A Pre-Hearing Custody Conference (Conciliation Conference) is scheduled for August 8, 2002 at 9:30 a.m. at Cumberland County Courthouse. WHEREFORE, Petitioner requests this Court to direct that a Writ of Habeas Corpus Ad Procequedum directing the Warden of Cumberland County Prison to deliver Michael Mattesky to the Sheriff of Cumberland County, Pennsylvania for transport to Cumberland County Courthouse so he may attend the Pre-Hearing Custody Conference scheduled for August 8, 2002. Respectfully submitted, Dirk E. Berry, Esquire Attorney for Defendant 7 Irvine Row Carlisle, PA 17013 (717) 240-0296 MICHAEL E. MATTESKY IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. TINA MARIE KASSAM DEFENDANT 99-6098 CIVIL ACTION LAW IN CUS'T'ODY AND NOW, Friday, September 06, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 41h Floor, Cumberland County Courthouse, Carlisle on Thursday, September 26, 2002 at 10:30 AM for a Prc-licaring 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 rive 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/ Hrtbert X Gitroy. Esq, try Custody Conciliator The Court of Common Picas of Cumberland County is required by law to comply with the Americans with Disabilitcs 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 liar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 -CE 02 VP I D A 112: 90 cut 11, - ,::? CGUNTY HNNSYLVANIA /pad Q ?D 42 n, , o p , Law Office of James K: Jones', Esquire SEP 0 $ 2002 7 Irvine Row Carlisic, Pt I7o13-3019 (717) 240-0296 tJ IN THE COURT OF COMMON PLEAS OF MICHAEL E. MATTESKY, Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. TINA MARIE KASSAM, Defendant NO. 99-6098 CIVIL ACTION - LAW IN CUSTODY AND NOW, this day of , 2001, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at on the day of , 2001, at 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 may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. BY THE COURT: By: Custody Conciliator 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. 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 MICHAEL E. MATTESKY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99-6098 : CIVIL ACTION - LAW TINA MARIE KASSAM, g a) c Defendant : IN CUSTODY r - ?? te '•?? C F icy 1 iV PETITION FOR CLVIL CON E PT T M FOR DISOBEDIENCE OF ORDER OF CURT The Petition of Michael E. Mattesky, by and through his counsel, Dirk E. Berry, Esquire, respectfully represents: 1. The Petitioner if MICHAEL E. MATTESKY, father of the subject child. 2. Respondent is TINA MARIE KASSAM, mother of the subject child. 3. That on August 20, 2002, the Honorable Edward E. Guido, Judge, entered an Order awarding Petitioner, Michael Mattesky, father, visitation with the minor child one day a week during father's normal visitation times at the Cumberland County Prison. 4. This visitation was directed to be arranged with the mother delivering custody of the child to the paternal grandmother so that the lwternal grandmother can take the minor child to the Cumberland County prison for contact visits will; her father. The visitation was directed to be once a week either on Wednesday evening or on Saturday or Sunday (emphasis added). 5. Respondent, Tina Kassam, willfully failed to abide by the order in that she utilized a lack of cooperation to deliberately prevent Petitioner from enjoying his first period of visitation with the subject child. Subsequently, she has refused to allow any make-up of that lost visitation period. 6. Moreover, Respondent deliberately remained uncooperative and willfully prevented Petitioner from exercising the second week's visitation by refusing to deliver custody of the child to the paternal grandmother a second time. Subsequently, she has refused to allow any make-up of that lost visitation period. 7. Furthermore, despite verbal assurances from mother's counsel, and despite the fact that mother's attorney had by then received a written copy of the August 20, 2002 order, Respondent, mother, continued to willfully disregard the order of this Honorable Court for the third week in a row by refusing to deliver custody of the child to the paternal grandmother and instead taking the child to the prison herself thereby deliberately creating the precise confrontation that mother, at conciliation, had agreed to cooperate in avoiding. 8. As a result of the Respondent's deliberate, and willful actions, Petitioner has been unable to enjoy the visitation periods that were provided to him by the Court and has entailed significant costs procuring the services of an attorney in order to pursue compliance with the August 20, 2002 order. WHEREFORE, Petitioner respectfully requests this Honorable Court to find Respondent, Tina Kassam, in Contempt of Court, and thereafter order her to deliver custody of the child to the paternal grandmother, at the paternal grandmother's home, no later than one-half hour prior to the visitation time, selected each week by father (with mother being notified by either father or paternal grandmother) so that the paternal grandmother can take the minor child to the Cumberland County Prison for contact visits with her father and with the child to be delivered to the mother no later than one hour after the official ending time of the contact visit period. Additionally, that mother be Ordered to abide by father's request, with one weeks advance notice, for three make-up visits to be conducted with the same procedures and to constitute a second visit during each of the three weeks requested by father. Further, to Order mother to pay father's reasonable attorneys fees necessitated by mother's actions in defiance of the Order of this Honorable Court. Respectfully submitted, /-U;?; ??? Dirk E. Berry, Esquire Attorney for Plaintiff/Petitioner 7 Irvine Row Carlisle, PA 17013 (717) 240-0296 I verify that the statements made in this Defendant's Answer to Petition for Emergency Order are true and correct to the best of my knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. _??' Ae,' -4, oe V7 Michael E. Mattesky MICHAEL E. MATTESKY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99-6098 CIVIL ACTION - LAW TINA MARIE KASSAM, Defendant : IN CUSTODY I, Dirk E. Berry, Esquire, do hereby certify that on this day the within Petition for Civil Contempt for Disobedience of Custody Order was served by First Class Mail, postage pre-paid upon the following persons: Karl E. Rominger, Esquire 55 S. Hanover Street Carlisle, PA 17013 Date: -3a-02 - Dirk E. Berry, Esquire Attorney for Plaintiff/Petitioner 7 Irvine Row Carlisle, PA 17013 (717) 240-0296 0 n v C w r? ? O IQL Q U N Cz N v RS Y?, Law Office of James K. Jones, Esquire 7 Irvine Row Carlisle, PA 17013-3019 (717) 240-0296 OCT Z4 0Z - MICHAEL MATTESKY : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99-6098 CIVIL ACTION - LAW TINA MARIE KASSAM : IN CUSTODY Defendant AND NOW, this a day of v ` 2002, upon consideration of the within petition and request by Plaintiff, the request by Plaintiffs counsel, Dirk E. Berry, Esquire, for Leave to Withdraw is GRANTED. J. Karl E. Rominger, Esquire 155 S. Hanover Street Carlisle, PA 17013 Dirk E. Berry, Esquire 7 Irvine Row Carlisle, PA 17013 I 02 0CT 2Q l ;i 12: nQ CUPici( C.-'It TY PC- SYllr,N-A MICHAEL MATTESKY Plaintiff V. TINA MARIE KASSAM Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6098 CIVIL ACTION - LAW : IN CUSTODY AND NOW, comes Dirk E. Berry, Esquire, attorney for Michael E. Mattesky, Plaintiff in the above captioned matter, and respectfully avers as follows: 1. Plaintiff notified undersigned counsel, through his mother, that he does not desire any further legal representation. 2. Plaintiff confirmed his desire to proceed pro se by executing the attached request to this Honorable Court. 3. Plaintiff owes $551.45 for legal services already rendered and is not expected to pay for any additional services. 4. Accordingly, undersigned counsel respectfully requests this Honorable Court to grant counsel Leave to Withdraw. WHEREFORE, Petitioner, Dirk E. Berry, Esquire, undersigned counsel to Plaintiff Michael E. Mattesky, respectfully requests this Honorable Court to grant Petitioner Leave to Withdraw. Dirk E. Berry, Esquire Attorney for Plaintiff 7 Irvine Row Carlisle, PA 17013 (717) 240-0296 TO THE HONORABLE EDWARD E. GUIDO Please allow my privately retained counsel to withdraw his appearance in my case; Mattesky v. Kassam, Docket No. 99-6098. I have decided to proceed pro se until such time as I have retained other counsel. W' I acknowledge that I have received a copy of the Order of this Honorable Court dated August 20, 2002 that schedules a hearing in my case for November 1, 2002 at 8:30 a.m. vx%H I acknowledge the requirement to file a memorandum in this matter on or before Monday, October 28, 2002 as set forth in paragraph one of the Order of this Honorable Court dated August 20, 2002. I acknowledge that I owe Attorney Dirk E. Berry, Esquire, of the Law Office of James K. Jones, Esquire the amount of Ski 45_for legal representation and services previously performed. tti`"^ It is my. desire to proceed pro se. Date: r o`? / Michael E. ttes ry MICHAEL MATTESKY ; IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99-6098 CIVIL ACTION - LAW TINA MARIE KASSAM : IN CUSTODY Defendant I, Dirk E. Berry, Esquire, do hereby certify that on this day Petitioner's Petition for Leave to Withdraw was served by Certified First Class Mail, postage pre- paid upon the following person: Karl E. Rominger, Esquire 155 S. Hanover Street Carlisle, PA 17013 Date: to -23-o2- Dirk E. Berry, Esquire Attorney for Plaintiff 7 Irvine Row Carlisle, PA 17013 (717) 240-0296 fy N o I Law Office of James K. Jories, Esquire r. 7 Irvine Row r. Cafte PA 17013.3019 (717) 240-0296 MICHAEL MATTESKY Plaintiff V. TINA MARIE KASSAM Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6098 CIVIL ACTION - LAW IN CUSTODY Please withdraw my appearance on behalf of Plaintiff Michael E. Mattesky in accordance with the attached order. Di k E. Berry, Esquire MICHAEL MATTESKY Plaintiff V. TINA MARIE KASSAM Defendant Law Office or James K. Jones, Esquire .7 Iine Row '4 Carlisle. PA 17013.3019 Q(;T (717) 240-0296 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6098 CIVIL ACTION - LAW : IN CUSTODY AND NOW, this Z P L- day of (Drt,-L. . 2002, upon consideration of the within petition and request by Plaintiff, the request by Plaintiffs counsel, Dirk E. Berry, Esquire, for Leave to Withdraw is GRANTED. BY THE COURT: Karl E. Rominger, Esquire 155 S. Hanover Street Carlisle, PA 17013 Dirk E. Berry, Esquire 7 Irvine Row Carlisle, PA 17013 c J. c .T (I 1?uet?+4s- fr,:,p?nrtarr' MICHAEL MATTESKY : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99-6098 CIVIL ACTION - LAW TINA MARIE KASSAM : IN CUSTODY n o r, Defendant ' nit -4 T PETITION FOR LEAVE TO WITHDRAW AND NOW, comes Dirk E. Berry, Esquire, attorney for Michael E. NrittesK Plaintiff in the above captioned matter, and respectfully avers as follows: 1. Plaintiff notified undersigned counsel, through his mother, that he does not desire any further legal representation. 2. Plaintiff confirmed his desire to proceed pro se by executing the attached request to this Honorable Court. 3. Plaintiff owes $551.45 for legal services already rendered and is not expected to pay for any additional services. 4. Accordingly, undersigned counsel respectfully requests this Honorable Court to grant counsel Leave to Withdraw. WHEREFORE, Petitioner, Dirk E. Berry, Esquire, undersigned counsel to Plaintiff Michael E. Mattesky, respectfully requests this Honorable Court to grant Petitioner Leave to Withdraw. Dirk E. Berry, Esquire Attorney for Plaintiff 7 Irvine Row Carlisle, PA 17013 (717) 240-0296 TO THE HONORABLE EDWARD E. GUIDO Please allow my privately retained counsel to withdraw his appearance in my case; Mattesky v. Kassam, Docket No. 99-6098. I have decided to proceed pro se until such time as I have retained other counsel. I acknowledge that I have received a copy of the Order of this Honorable Court dated August 20, 2002 that schedules a hearing in my case for November I, 2002 at 8:30 a, m. Vx"V% I acknowledge the requirement to file a memorandum in this matter on or before Monday, October 28, 2002 as set forth in paragraph one of the Order of this Honorable Court dated August 20, 2002. I acknowledge that I owe Attorney Dirk E. Berry, Esquire, of the Law Office of James K. Jones, Esquire the amount of 555145_ for legal representation and services previously performed. tw"'. It is my desire to proceed pro se. Date: O r o Michael E. Mllitesky MICHAEL MATTESKY Plaintiff V. TINA MARIE KASSAM Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6098 CIVIL ACTION - LAW IN CUSTODY I, Dirk E. Berry, Esquire, do hereby certify that on this day Petitioner's Petition for Leave to Withdraw was served by Certified First Class Mail, postage pre- paid upon the following person: Karl E. Rominger, Esquire 155 S. Hanover Street Carlisle, PA 17013 Date: to - 2?- 0 2 Dirk E. Berry, Esquire Attorney for Plaintiff 7 Irvine Row Carlisle, PA 17013 (717) 240-0296 w ldJ?' C:. ?: J r by 1` C. ,a lip 'U v MICHAEL MATTESKY, Plaintiff s V. TINA MARIE KASSAM, s Defendant s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 99-6098 CIVIL TERM ORDER OF COURT AND NOW, this 16th day of December, 2002, it appearing that this is a petition for contempt, the Court Administrator is directed to refor this matter to the conciliator forthwith, in accordance with Local Rule 1915.12-1. Pending conciliation, our order of November 1, 2002, shall remain in full force and effect. By the Co Edward E. Guido, J. s/ Michael Mattesky, Pro no ? Karl Rominger, Esquire For the Defendant Court Administrator's Office it e?o ' L RKs )2.27-oa ?'Y)T (iY 28 38 vrY rsrrr?snVM? MICHAEL MATTESKY IN '1'1IIi COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 99.6098 CIVIL ACTION LAW TINA MARIE KASSAM = IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, __, Frldayr January 03, 2003 upon consideration of the attached Complaint, it is hereby directed that patlics and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator, at /Ih Floor, Cumberland Countyy Courthouse, Carlisle on Thursday, January 16, 2003 at 10:30 AM for a Pre•1lcaring Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot lie accomplished, to tic ['ilia and marrow the issues to be heard by the court, and to enter into a temporary order. All children age IAr 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 11u parties to furnish any and all existing Protection from Abuse orders, Special Rellef orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR TI 11: COUR'T'. Fly: Is/ blhf LXS &QY.D EsEsq. C: Custody Conciliator 'Ilia Court ol'C'onunon Pleas of Cumbcrland County is required by law to comply with the Anmetieans with DisobiIhas Act of 1990. For information about accessible facilities and reasonable uccol unodalions available Ut disabled individuals having business before the court, please contact our office. All arrangements must he made at (cast 72 hours prior to any hearing or business before the court. You must uncnd the scheduled conference or hearing. YOU SI IOULD TAKE TIIIS PAPER TO YOUR A'ITORNEY AT ONCE. H. YOU DO NOT HAVE AN A'1'1'OI(NI?Y Olt CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET FOR'l 11 1111OWTO FIND OUT Will-RE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 'telephone (717)249.3166 PG`JNSl'LViLVIA / G ?? ? ? A MICHAEL MATTESKY, Plaintiff V. TINA MARIE KASSAM, Defendant DEC 2 7 2002 ? & IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 99-6098 CIVIL TERM ORDER OF COURT AND NOW, this 16th day of December, 2002, it appearing that this is a petition for contempt, the Court Administrator is directed to refer this matter to the conciliator forthwith, in accordance with Local Rule 1915.12-1. Pending conciliation, our order of November 1, 2002, shall remain in full force and effect. By the Co Edward E. Guido, J. Michael Mattesky, Pro se Karl Rominger, Esquire For the Defendant ,/Court Administrator's Office it • it a . OCT 3 o 2002 c /?iC?AE? 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ORC?.vZ. ?a?- R?cSOIu?'? oN i._ -t?-?k4?__R!?-?_?o??fcz__wdu?d 4'NJcx?--sha?cr_Phys ale. 4t1E?1CEN LA_??? ?r0 C S_???1?'lN?_ -wak 4d 4;4-e w6o /C/ b ytlj,-.FF;?Ay _N 9/,?5 _ s?oo P??Nd N S'LrAJAU ___-- __________?_N n??.s ANd_,4D?n?sscs ?? ?+??1_ w?ss??• -Ht t ;A d4wy/rke -B "m f±od X14 Plo fl tas Fou IY ---- -_--._ _..-^ __?7iN? KASSAM? ^/?'lo7/ttr2?--GU,:ll,?jc_c?}_??Ed _.AS ?C_v!v._G_•eo55__?0_ ss?.t?y_?.?z.?lz? .h?M?_??_v??za?F?r_s?i?k??p?_???._id <<y,_h?c_ 'rte ? 4{e. e ldAmJ 4 d i ,v EN'e_O?dRlx?S__?N LoA -, d ' J vd a -r- LL ------- --- --------- y(y* n = ,. bA oe-c 5_NOT _pr -Po. __-}(j_C.A_?\__I ?4?T_ C.?i?N.4ss.ES.. 1??. cbES RfsE2J? ?E ??-[al?? ?PPI£MfNT A;s t,s o F e4i?NtisSES ,4$ N?6. S_Sl ___. __f1Nd r?_?Nf?Lc•l b?„Aky -- - -vzu _ NOD ? ?Z ? h??_S??J?, . _ _ __ _------ _..._ - __ ...???E?z G?u?cf /tkc '/o R?ufst_R ?iv??,? S??c1Y ?t f?i%s 7?rrvt?. P, ' s F? I srn a• .. ?ll C? 1 t.. 1) __...C!+'f??f2__?ES ?t14T_.?£9GfS_fOivE_Af' ?hIS_TTME buf ??-E-- ?q?f f -l9 _,2?uFSTQnrF lF ? 4_NFS? ? o,?F F? N --- -- M ¦ 1;2 Micheal M(Ate5kq, : Tn-Me cvur? O? Common?l Ie45 O? 2t? elnn-941U ?_I(??ni??? - - ,.Afyj vS. to-corm-o pr-epd -3rl1c wn . w? YID7MO?Ib{?4{g1?M01 ? WOi'MOy?OyYpl'MMM IOLLI ONDA&UUOd'angWWO40 arw•usrlc J 06VOWCOa . 0109'ux•rlc IOeAS UIDW WON l 4 v r IOU E 9f1N ssxri ra ,c?Giviruu n f LOL l DiUD*WuGd 'GMPOO • 1"4S JOAOUGH 4PM 49 l 0 1 . t 1•f , MICHAEL MATTESKY, Plaintiff VS. TINA MARIE KASSAM, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99.6098 CIVIL TERM IN CUSTODY AND NOW, this _3o -, day of <w 2001, upon consideration of Petitioner's Petition for Emergency Rclicf, it is hereby ordered and dccrced that temporary primary physical custody of the parties' minor child, Brianna Mattesky shall be with Mnthcr pending scheduling of a conference, hearing, or trial on the matter. BY THE COURT: t.: A i±}: 'ii"3 Y MICHAEL MATTESKY, Plaintiff Vs. TINA MARIE KASSAM, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99.6098 CIVIL TERM IN CUSTODY PETITION FOR F.MERGFNCY RELIEF 1. Petitioner is Tina Marie Kassam who resides at 170 Opossum Lake Road Carlisle, PA 17013. 2. Respondent is Michael E. Mattesky who resides at 403 North Bedford Street Carlisle, PA 17013. 3. On January 31, 2001, the Honomble Edward E. Guido, entered the Custody Order attached as Exhibit "A". 4. Since the entry of said Order, there has been a significant change in circumstances in that: (a) Father has been incarcerated on drug charges (PWI). 5. The best interest of the child will he served by the Court granting the Mother full physical custody. WHEREFORE. Petitioner prays this Court to grant the Emergency Relief with full physical custody in the mother. Date: 00 ( Respectfully submitted, Karl E. Romingcr. Esquire 155 South HanoVcr Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID a 81924 Attorney for Petitioner MIC14AEL MATTESKY, Plaintiff VS. TINA MARIE KASSAM, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMOr:RLAND COUNTY, PENNSYLVANIA :NO. 99-6098 CIVIL TERM IN CUSTODY I, Karl E. Rominger, Esquire, attorney for Defendant, do hereby certify that I this day served a copy of the PeNlJon far Emergency Relief upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Michael Mattesky Cumberland County Prison 1100 Claremont Road Carlisle, PA 17013 Karl L'. Itominger, Esquire Attorney for Petitioner Datcd: August 30, 2001 j` 4.? Ftt? r MICHAEL E. MATTESKY, Plaintiff v TINA KASSAM, Defendant D 1.0 : M THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 99-6098 CIVIL : IN CUSTODY COURT ORDER AND NOW, this 3l Sk day of January, 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. This Court's prior Order of November 23, 1999 is vacated. 2. The Father, Michael E. Mattesky, and the Mother, Tina Kassam, shall enjoy shared legal and shared physical custody of Brianna Marie Mattesky, born June 28, 1998. 3. Physical custody shall be arranged pursuant to agreement of the parties. 4. This Order is entered with recognition that both parties are currently unemployed and they each expect to obtain some type of employment in the future that may merit a reevaluation of this custody arrangement. The Conciliator shall conduct a telephone conference call with the attorneys for the parties on Thursday, March 8, 2001 at 8:30 a.m. The purpose of this telephone custody conciliation conference shall be to update the Conciliator on the status of the case and determine whether another formal conciliation conference needs to be scheduled or determine whether a hearing needs to be scheduled. BY THE COURT, /?•. J_ IS J. Edward cc: Karl E. Rominger, Esquire Matthew J. Eshelman, Esquire : Exhibit "A" I 1 Li I • r• MICHAEL MATTESKY V. TINA MARIE KASSAM : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6098 CIVIL TERM : CUSTODY -CIVIL ACTION ORDER OF COURT AND NOW, this ]9T" day of JULY, 2002, there being no emergency alleged in Defendant's "Petition for Emergency Relief', it is DENIED. This matter shall be handled by a custody conciliator and scheduled for court, thereafter, if necessary. By the E. Guido, J. Karl E. Rominger, Esquire For the Petitioner .- 7/41/0.2. Michael Mattcsky 403 North Bedford Street Carlisle, Pa. 17013 Court Administrator - .5. v' :sld g1iA1CNV - 231AOV - AOVOOAaV CIOLI VINVMASNN3d'31snuy.) > BLA9'I'traz :XVd • ME'b£6'OO9 • OL091WLIL + 13lHIS a3AONVH HiMbS $$I 6701ibl0 MV7 Q n S 3O u V ry n yA MICHAEL MATTESKY, Plaintiff VS. TINA MARIE KASSAM, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99.6098 CIVIL TERM IN CUSTODY AND NOW, this day of , 2002, upon consideration of Petitioner's Petition for Emergency Relief, it is hereby ordered and decreed that temporary primary physical custody of the parties' minor child, Brianna Mattcsky shall be with Mother pending scheduling of a conference, hearing, or trial on the matter. BY T14E COURT: 1 MICHAEL MATTESKY, Plaintiff Vs. TINA MARIE KASSAM, Defendant : IN TI IL COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99.6098 CIVIL TERM : IN CUSTODY 1. Petitioner is Tina Marie Kassam who resides at 248 East North Street, Carlisle, PA 170i3. 2. Respondent is Michael E. Mattesky who resides at 403 North Bedford Street Carlisle, PA 17013. 3. On January 31, 2001, the I lonomble Edward E. Guido, entered the Custody Order attached as Exhibit "A". 4. Since the entry of said Order, there has been a significant change in circumstances in that: (a). Father has been smoking marijuana in front of the child. (b). Cindy White, cousin of the Plaintiff has seen the Plaintiff smoke marijuana in front of the child and will so testify in Court. (c). Father is withholding the child from Defendant and does not follow the Custody Order now in place. 5. The best interest of the child will be served by the Court granting the Mother full physical custody. WHEREFORE, Petitioner prays this Court to grant the limergcney Rclicf with full physical custody in the mother. l Date: 3-v/ f Respectfully submitted, Karl E. Romingcr, Esquire 155 South I Ianover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID 0 81924 Attorney for Petitioner VERIFICATION I verify that I am the petitioner and that the statements made in the foregoing Petition are true and correct. I understand that false statements herein arc made subject to the penalties of 18 Pa. C. S. § 4904, relating to unworn falsification to authorities. Date: Tina Marie Kassam MICHAEL MATTESKY, Plaintiff VS. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 99-6098 CIVIL TERM TINA MARIE KASSAM, Defendant : IN CUSTODY CERTIFICATE, OF SERVICE 1, Karl E. Romingcr, Esquire, attorney for Defendant, do hereby certify that 1 this day served a copy of the Pellllon for Emergency Relief upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle. Pennsylvania, addressed as follows: Michael Mattesky 403 North Bedford Street Carlisle, PA 17013 Kar E. Romingcr, Esquire Attorney for Petitioner Dated: July 19, 2002 Jn1H V . I - MICHAEL E. MATTESKY, Plaintiff v TINA KASSAM, Defendant M THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW N0.99 - 6098 CIVIL IN CUSTODY COURT ORDER AND NOW, this 3A7 day of January, 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. This Court's prior Order of November 23,1999 is vacated. 2. The Father, Michael E. Mattesky, and the Mother, Tina Kassam, shall enjoy shared legal and shared physical custody of Brianna Marie Mattesky, bom June 28,1998. 3. Physical custody shall be arranged pursuant to agreement of the parties. 4. This Order is entered with recognition that both parties ore currently unemployed and they each expect to obtain some type of employment in the future that may merit a reevaluation of this custody arrangement. The Conciliator shalt conduct a telephone conference call with the attorneys for the parties on Thursday, March 8, 2001 at 8:30 a.m. The purpose of this telephone custody conciliation conference shall be to update the Conciliator on the status of the case and determine whether another formal conciliation conference needs to be scheduled or determine whether a hearing needs to be scheduled. B CO T, J. Edward E. Guido cc: Karl E. Rominger, Esquire • ?? Matthew J. Eshelman. Esquire trfu'z O?td o?-oi-o? R?.s ?? t-? ? ? Cr a, ? ?h J' ,:? ? CJ• t_IK V ? ?T?i, _] rt ~` .J `?? ?i..: .. li. ?S' :'??? (J` U MICHAEL MATTESKY, Plaintiff V. TINA MARIE KASSAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 99-6098 CIVIL TERM IN CUSTODY IN RE: PETITION FOR CONTEMPT AND NOW, this 26th day of February, 2003, the Defendant having advised the Court that she withdraws her Petition for Contempt, the hearing scheduled in this matter has been rendered moot. It appearing the Defendant has filed a Petition of Contempt of his own with the Court, this matter is referred to the conciliator for disposition in accordance with the rules of court. Michael Mattesky 403 North Bedford Street Carlisle, PA 17013 Plaintiff, Pro se Karl E. Rominger, Esquire For the Defendant OVA (4,J 17&%A?tfd- srs a K w MICHAEL E. MATTESKY, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW TINA MARIE KASSAM, 99-6098 CIVIL TERM Defendant/Respondent IN CUSTODY IN RE: PETITION DISMISSED ORDER OF COURT AND NOW, this 10th day of March, 2003, the Petitioner having failed to attend the hearing scheduled on his Petition for Emergency Relief, it is DISMISSED. The Petitioner is directed to reimburse Respondent $125.00 towards her counsel fees. Michael Mattesky 403 North Bedford Street Carlisle, PA 17013 Plaintiff/Petitioner, Pro se Michael Where, Esquire For Defendant/Respondent srs 3" 11.0.3 Edward E. Guido, J. ;_ ?.: rup S Cx r.l i} j:??.:...,_ Yf .a !^ f Yi,?. ;.:. .... j:> y( ?` ??., J:? 1 ' ?.. ":f!i tY`,,' i? x. . MICHAEL E. MATTESKY, Plaintiff v. TINA M. KASSAM, MTV t.g 2005- : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW :NO.1999.6098 CIVILTERM : IN CUSTODY Defendant ORDER OF COURT NOW, this 2P dayof Ar•wt?. , 2005, upon presentation and consideration of the attached Stipulation and Agreement and upon agreement of the parties, it is hereby ordered and decreed that the attached agreement is made an Order of Court. Distribution: Stacy B. Wolf, Esquire For the Plaintiff Michael E. Mattesky (0-? Pro Sr Defendant BY THE COURT, OF 7N8 Pn n uu?? RY 10DSf10V 2? AMlO: 28 PCP1Ay,147u?h tV1y s'; i 199i- We ed ( -1 T p rl or to x STACY n. WOLF, ESQUIRE ATTORNEY ID NO. 88732 37 SOtrr111 MOVER STREIi r, SUITE 201 CARLISLE PA 17013 (717) 2144{36 ATTORNEY FOR DEFENDANT MICHAEL E. MATTESKY, Plaintiff V. TINA M. KASSAM, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW :NO.1999-6098 CIVILTERM : IN CUSTODY THIS STIPULATION AND AGREEMENT entered into this 15th day of November, 2005, by and between TINA M. KASSAM (hereinafter refemcd to as "Mother") and MICHAEL E. MATTESKY (hereinafter referred to as "Father"). NOW THIS AGREEMENT WITNESSETH THAT: WHEREAS, the Mother and rather are the parents of one minor child, namely, BRIANNA MARIE MATTESKY (age 7 years, born June 28,1998); and, WHEREAS, the parties wish to enter into an amended custody agreement relative to the custody of the parties' child. NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as follows: The panics shall retain shared legal custody of the child. 2. Fathershall have primaryphysical custodyof the child, effective November 16, 2005 through the end of the 1005.2006 school year. 3. Following the 2005.2006 school year. Mother shall be entitled to assume custody of the child for the summer vacation. 4. Prior to the end of the summer vacation, the parties shall agree as to the future custody arraignments for the child, absent the reaching of an agreement to the contrary, custody shall revert to Father for the 2006-2007 school year. 5. Nothing in this agreement shall preclude Mother from pursuing a petition for modification of custody should such circumstances arise necessitating such a filing. 6. The custodial parent shall ensure that the noncustodial parent has reasonable access to the child by telephone. The parties shall share custody of the child on holidays by mutual agreement. 8. Ile parties shall keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to insure that the health, welfare and well being of the child is protected. 9. The parties shall do nothing that mayestrange the child from either partyor hinder the natural development of the child's love or affection for the other party. 10. Any modification or waiver of any of the provisions of this agreement shall be effective only if trade in writing. 11. The patties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 12. In the event of the breach of the agreement of the parties by any party, the nonbreaching party shall have the right to file a petition for contempt of court and to seek specific performance of the terms of the agreement of the panics. 13. The patties desire that this agreement be made an order of Court through the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County has jurisdiction over the issue of custody of the parties' minor child. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound by the terms hereof, set forth their hands and seats the day and year herein set forth. WITNESSETH: (SEAL) T1 14-A M. IZASMM 517 oz , SEAL)_ . MICHAE E. MA SKY COMMONWEALTH OF PENNSYLVANIA : :SS: COUNTY OF CUMBERLAND On this, the /S dayof s,I 1,/1005, before, the undersigned officer, appeared TINA M. KASSAM (mown to me (or satisfactorily proven) to be the same person whose name is subscribed to the within instrument, and acknowledged that he executed this agreement for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA Notarial Seal f4nun r WNr NWtry Putk Gvficrb:.r„ 0-C"tanOC" My Co mustrnt Ea:Aroa Apr. 19, 20M Notary P?? Member, Penmpranln Afiodabon Of Notaln COMMONWEALTH OF PENNSYL :SS: COUNTY OF CUMBERLAND On this, the _ZL day of 2005, before, the undersigned officer, appeared MICHAEL E. MATT ESKY, kno to me (or satisfactorily proven) to be the same person whose name is subscribed to the within instrument, and acknowledged that she executed this agreement for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. [COMMONWEALTH OF PENNSYLVANIA NotAfLV Seat Nathvf C WM. Notary Pwc CaUn Bas rAgvWeanro County My Camvssar F "ms Apr. 19, 2ODj Member, PennSYr.ema 4somaecn Of NOWIie7 lb? 1! 1 r l ``lam ? /?? s s•<<? ? ct ?? e 1. a r•w e y f'ro /2- C -o / ?-cj 44-e Nnrct /\ 7°S I'd P14C -V- n i S ; s l-e H,L,,l 9 Y 0 CA I q vW i 12--e Ca L4 S'v I w;11 b-e 1-e7Vi?14? k" y cggdeo-ey 1. ijaW) 95- ;M g,LA u'? •??; 1 a ?P ('c Lf In g l3Yd d W r? c+ct? G? e? f Cc? / fro ?+? d c1 ?a l-?-G,.? ley a w 0?.t w-er? 0r? 7? Yb lQ?? d pt ri{?m J a l l vh -? u c c? d r LC 7`?r //, h y ? kM -P n d ocr t.er.e Ta D ?-P u?J iS 4k c:CC?'?7?4?1pJ C,t k) A c ? I-5T,4 3f L Yo L14 t (v 15 AO r-e 0 ccI/ (n.? V Occ e 0LIL/UPty d1 G V-e 17-e-e i,-%- '?' .c? ??-2 ?l ,???? ?j-P -PG r i L'1 Mvre Ct ? u t? -4i S l ct #-P ?o MAlEc ANNE E. IRU DEBUoCH 4711 Locust Lane Harrlsburg, PA 17109 James Freed, District Attorney Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 ATTORNEY AT LAW August 23, 2002 RE: COMMONWEALTH OF PA V. MORA DOCKET NO. 0666 (717)657.0632 Fax 657.1512 11 f?J Dear Attorney Freed: This office represent Bonnie Lorwey in a civil matter. Ms. Lorwey authorized me to notify you that she does not want to pursue the assault charges against Edwin Mora. If you have any questions concerning this matter, please contact Ms. Lorwey directly. Very truly yours, (? i= d??.n...oa(_ Marianne E. Rudebusch MER/kaf cc: Thomas C. 7x1Le, J:., Esquire Bonnie Lorwey MARRANN E E. RUDEBUb- CH 4711 Locust Lane Harrisburg, PA 17109 ATTORNEY AT LAW August 21,2(X)2 Thomas C. Zerbe, Jr., Esquire 806 Lisburn Road Camp Hill, PA 17011 RE: LORWEY V. MORA IN CUSTODY Dear Attorney Zerbe: (717) 657.0632 Fax 657.1512 As per our phone conversation on 8/21/02, I am enclosing a Custody Agreement for your client's review and signature. Once the agreement is signed by your client, I shall forward it to the court for the entry of a Modified Custody Order and cancel the hearing scheduled for 8/26/02. My client has given much thought to your client's request that she withdraw her criminal complaint against him. I will send a letter to the District Attorney's office in Cumberland County upon receipt of the fully executed custody agreement stating that she is no longer interested in pursuing the assault charges. Ms. Lorwey is hopeful that her willingness to do so will engender some good will on Mr. Mora's part and set the tone for a more civil cuttodial relationship for the future. Please be advised that this letter is written for purposes of negotiating a settlement and therefore, inadmissible as evidence in a court of law. Very truly yours, Marianne E. Rudebusch MER/kaf Enclosure cc: Bonnie A. Lorwey (w/ encl.) BONNIE A. LORWEY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 97.1750 EDWIN H. MORA, CIVIL LAW Defendant : IN CUSTODY AGREEMENT FOR THE MODIFICATION OF CUSTODY THIS AGREEMENT is made and entered between 13ONNIE A. LORWEY and EDWIN H. MORA, hereinafter referred tons Mother and Father. The parties are the natural parents of BROOKE ANNE LORWEY-MORA, born 7/8/91. The parties agree to modify the existing Custody Order issued by the Court on 5/9/96 and attached hereto as Exhibit A. 1. The parties shall share legal custody of the child. Educational decisions shall be made solely by Mother if an agreement cannot be reached between the parties. Major medical decisions concerning the child shall be made by Mother after consultation with Father giving rather the opportunity to have input into the final decision concerning major medical procedures. Father shall have the opportunity to consult with the child's physicians as well as physician's of his own choosing prior to the initiation of all major medical treatments for the child. It is understood that these provisions only apply to non-cmergency situationsand that each parent shall make decisions about medical treatment in an emergency when the child is in their respective physical custody. In the event that such an emergency arises and a parent has to make a unilateral decision concerning medical care for the child, that parent shall notify the non-custodial parent as soon as possible of the emergency. 2. Mother shall maintain primary physical custody of the child and Father shall have partial physical custody of the child under the following schedule: a. Every other weekend from Friday after school/work until Sunday at 6:00 p.m. b. During the school year, one evening during the week from after school/work until 7:30 p.m. The particular eveningshall be selected by the parties in writing within five (5) days from the execution of this Agreement. C. During the summer vacation, the child shall be with rather one weekday from 6:00 p.m. until 6:00 p.m. the following day during the week preceding his regularly scheduled weekend. The particular overnight shall be selected by the parties in writing no later then 5115 of each year. 3. The parties shall alternate the major holidays of Easter, Memorial Day, July 4', Labor Day and Thanksgiving. Christmas shall be divided into Segments A and B. Segment A shall be from 12/24 from after school/work until 12 noon on 12/25 and Segment B shall be from 12 noon on 12/25 until 10:00 p.m. on 12/25. Whoever has Thanksgiving in I t a given year shall have Segment B that same year. The child shall be with Father on Father's Day and with Mother on Mother's Day. A holiday is considered to be from 10:00 a.m. until 6:00 p.m. on the day of the holiday with the exception of Christmas. Holiday schedules supersede regularly scheduled visitations. 4. The parties shall each have two (2) non-consecutive weeks of summer vacation with the child and shall give each other a minimum of sixty (60) days written notice of their intention to exercise this option. Whichever party first notifies the other, shall have the vacation time as per their request. The vacation time shall either begin or end with a parties' regularly schedule weekend and shall not exceed seven (7) days. 5. The parties agree that they shall notify the other party in a timely manner if they travel with the child away from their primary residence overnight and provide the other party with an address and phone number where the child can be reached. 6. The parties shall give each other liberal phone access to the child while she is in their custody and facilitate the child's phone contact with the non-custodial parent. 7. The parties shall share transportation of the child such that the party beginning his/her period of physical custody shall provide transportation for the child. Custody exchanges shall take place at the police station in Enola unless otherwise agreed to by the parties. 8. The parties agree to transport the child to extracurricular activities during their respective periods of custody. Neither party shall enroll the child in activities which interfere 3 with the other parties custodial period without the other parties' consent. Such consent shall not be withheld capriciously keeping in mind the child's wishes and best interest. Extracurricular activities do not include CCD at the child's church which is required for the child to attend on a regular basis. Both parties will transport the child to CCD classes while she is in their custody. 9. The parties shall exert every reasonable effort to maintain free access and unhampered contact between the child and each of the parties, and to foster a feeling of affection between the child and the other party. Neither party shall do anything which may estrange the child from the other party, or injure the child's opinion as to his mother or father, or which may hamper the free and natural development of the child's love and respect for the other party. 10. In the event the parties have a dispute concerning custody of the child, they agree to attend mediation with a mutually agreed upon mediator prior to the initiation of legal proceedings. The out of pocket costs of such mediation shall be shared equally by the parties and shall not exceed eight (8) session unless agreed to by both parties. 11. The parties agree to a "Right of First Refusal" meaning that if one party cannot be with the child during their custodial period, they must give the other party the option to have the child if they are available. This does not include absences of less then three hours. 4 IN WITNESS WHEREOF, and intending to be bound hereby, the parties have C11 /' signed and scaled this Agreement on the._) day of 2002, at Harrisburg, Pennsylvania. ............. (SEAL) ONNIEA. LORWEY COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF DAUPHIN d On this the. U day of 21X12, before me the undersigned officer, personally appeared BONNIEA. LO EY, satisfactorily proven to be the person whose name is subscribed to the within document and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. Notary Public tutut? IFAJ Mity wER PMAXM lIIEI t [my COMMISSUM IT -- L nos c-L (SEAL) EDWIN H. MORA COMMONWEALTH OF PENNSYLVANIA . : SS COUNTY OF DAUPHIN ('t 14 On this the day of C b.4 , 2002, before me the undersigned officer, personally appeared EDWIN H. M , satisfactorily proven to be the person whose name is subscribed to the within document and acknowledge that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official scat i Notary Public I iiu& 6 r+ ±x TRANSCRIPT OF TAPED PHONE MESSAGES J FROM BONNIE LORWEY TO EDWIN MORA RE: INDIRECT CRIMINAL CONTEMPT AFFIANT: Detective Kristin Mertz, Cumberland County District Attorney's Office VOICES RECORDED TO INCLUDE, BUT NOT LIMITED TO: Edwin Mora. Transcribed by: Christine C. Pulgar at the request of Kristin Mertz Cumberland County District Attorney's Office and proof read by 12/16/02 DETECTIVE KRISTIN MERTZ: This is Detective Kristin Mertz. It is January 2nd, 2002. The time is 9:54 AM. I am here with Bonnie Lorwey and her daughter and the intern Steve and I am at 422 D, Duke Street Enola. I will be recording a message off her answering machine reference to a Domestic Violence case that I am currently investigating with East Pennsboro. FIRST MESSAGE EDWIN MORA: Hello, okay we've read over you're a little, course concert thing, you Bonnie can pick up Brooke at the dancing school whatever 6 o'clock just let us know what time you're gonna pick her up. She'll be having class, she can go, and as long as you're back to the school by 8:30 something happens you can't be back by 8:30 let us know and a we'll make sure somebody's here at the house. So a everyone can relax now. I appreciate you going off the handle and getting Brooke all excited before we had a chance to even talk about it. Goodbye. 0 _3 N Ci- ? a i p. '+ 0 ; 'S i EXHIBIT 12.16.02. UCT MldPenn Legal Services 8 Irvine Row Carlisle PA 17013 f17? 243.9400 800 822-5288 I2• IL•o2.. WT T .Kar?.,.?,. ?9-botig x(2*ol(pOZ p?-li3 ill -?1''? I 199 1 - x,0 9 ? e rg ( 'IT Prior fo STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR DEFENDANT MICHAEL E. MATTESKY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW TINA M. KASSAM, : NO. 1999-6098 CIVIL TERM Defendant : IN CUSTODY STIPULATIONAND AGREEMENT THIS STIPULATION AND AGREEMENT entered into this 15th day of November, 2005, by and between TINA M. KASSAM (hereinafter referred to as "Mother") and MICHAEL E. MATTESKY (hereinafter referred to as "Father"). NOW THIS AGREEMENT WITNESSETH THAT: WHEREAS, the Mother and Father are the parents of one minor child, namely, BRIANNA MARIE MATTESKY (age 7 years, born June 28, 1998); and, WHEREAS, the parties wish to enter into an amended custody agreement relative to the custody of the parties' child. NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as follows: The parties shall retain shared legal custody of the child. Father shall have primary physical custody of the child, effective November 16, 2005 through the end of the 2005-2006 school year. 3. Following the 2005-2006 school year, Mother shall be entitled to assume custody of the child for the summer vacation. 4. Prior to the end of the summer vacation, the parties shall agree as to the future custody arraignments for the child, absent the reaching of an agreement to the contrary, custody shall revert to Father for the 2006-2007 school year. 5. Nothing in this agreement shall preclude Mother from pursuing a petition for modification of custody should such circumstances arise necessitating such a filing. 6. The custodial parent shall ensure that the non-custodial parent has reasonable access to the child by telephone. The parties shall share custody of the child on holidays by mutual agreement. 8. The parties shall keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to insure that the health, welfare and well being of the child is protected. 9. The parties shall do nothing that may estrange the child from either party or hinder the natural development of the child's love or affection for the other party. 10. Any modification or waiver of any of the provisions of this agreement shall be effective only if made in writing. 11. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 12. In the event of the breach of the agreement of the parties by any party, the nonbreaching party shall have the right to file a petition for contempt of court and to seek specific performance of the terms of the agreement of the parties. 13. The patties desire that this agreement be made an order of Court through the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County has jurisdiction over the issue of custody of the parties' minor child. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound by the terms hereof, set forth their hands and seals the day and year herein set forth. WITNESSETH: COMMONWEALTH OF PENNSYLVANIA (SEAL) TIT A M. I S f EAL)- MICHAE E. SKY COUNTY OF CUMBERLAND :SS: On this, the (I day of 4,.l,,T,-,-2005, before, the undersigned officer, appeared TINA M. KASSAM known tome (or satisfactorily proven) to be the same person whose name is subscribed to the within instrument, and acknowledged that he executed this agreement for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal, LeUMMONWEALTH OF PENNSYLVANIA h,h an=I Sea! J a l 013fV ptlr?IIC ?-"-% "(SEAL) t Ceda;ib County PAY C,onrmi?,?; 7:5 ExPrros Apr. 99, 2008 Notary Public Member. 1'1o9S,I,,n(a 4_socml on Of Notaries COMMONWEALTH OF PENNSYLVANIA :SS: COUNTY OF CUMBERLAND . On this, the _, J day of erg`/E , 2005, before, the undersigned officer, appeared MICHAEL E. MATTESKY, known to me (or satisfactorily proven) to be the same person whose name is subscribed to the within instrument, and acknowledged that she executed this agreement for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ?O IklONWFAL fN of PENNSYLVANIA Notarial Seat "nerlarl'.i County h atn2 C Crr. Nota ,? P,ibliLMemb,, ry i,omrt?rs,,.o, t r_Xjmr..?s Apr. 19, 200$ . o pr,ryhema 4s9CCratio0 Of Notaries C) ?5 rr? lit n? t C.a f . .c MICHAEL E. MATTESKY, Plaintiff V. TINA M. KASSAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1999-6098 CIVIL TERM IN CUSTODY ORDER OF COURT NOW, this 21' day of Arovu &. 2005, upon presentation and consideration of the attached Stipulation and Agreement and upon agreement of the parties, it is hereby ordered and decreed that the attached agreement is made an Order of Court. Distribution: Stacy B. Wolf, Esquire For the Plaintiff Michael E. Mattesky Ptv Se Defendant ? BY THE COURT, t ? ?? ??? ?? r-n ? a? :I :?0 ?'; ? a r JUN 1 12010 MICHAEL E. MATTESKY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA c> ~.~~ vs. CIVIL ACTION -LAW ~__ ~ `- ~-; :-! _n TINA M. KASSAM, NO. 1999-6098 - , ~ _ = 'r'~ `-- Defendant IN CUSTODY - ~~ !" - S,. -- COURT ORDER - ~:. - _~_ ~:; ../ .. AND NOW, this rs~ day of June, 2010, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. A hearing is scheduled in Court Room No. 4 of the Cumberland County Courthouse on the 1 S` day of September, 2010 at 9:30 a.m. At this hearing, the father shall be the moving party and shall proceed initially with testimony. Counsel for the parties, or the parties themselves if they do not have an attorney, shall file with the Court and opposing counsel/party a memorandum setting forth the history of custody in this case, the issues currently before the Court, a summary of each parties position on these issues, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least five days prior to the mentioned hearing date. Father's Petition for Contempt will also be addressed at this hearing and should be further addressed in the memorandum filed by the parties or their attorneys. 2. Pending further order of Court, this Court's prior order of May 7, 2010 shall remain in effect which provides that the mother, Tina M. Kassam, shall enjoy primary physical custody of Brianna M. Mattesky, born June 28, 1998. Pending the hearing scheduled above and any further order of Court, father shall enjoy temporary physical custody with the minor child as follows: A. Father shall be entitled to have custody for a period of five weeks during the upcoming summer. Father is directed to consult with mother's attorney for purposes of selecting the five weeks in question and, after such consultation and assuming an agreement, mother's attorney shall confirm with the father in writing the schedule for father's visitation. Father shall purchase a plane ticket for a round trip flight for the minor child to fly by herself from Arizona to an airport where the father can pick her up. Father shall advance the costs for purchasing of this round trip ticket, with mother to reimburse father one half of the costs within fifteen days of father providing mother with written verification of the purchase of the ticket. If the parties are unable to reach an agreement with respect to father's period of temporary custody during the summer or the logistics relative to the minor child flying from Arizona back to Pennsylvania, either party or their attorney may contact the Custody Conciliator's office to schedule a telephone conference call during which those issues may be addressed and, as appropriate, the Conciliator may recommend a further order to this Court to address those issues. cc: .Michael E. Mattesky /Stacy B. Wolf, Esquire eon ~~ ,~.~~~. L~~s~rv ~~ BY THE COURT, Kevin .Hess, Judge MICHAEL E. MATTESKY, Plaintiff vs. TINA M. KASSAM, Defendant Prior Judge: The Honorable Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 1999-6098 : IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The Conciliator conducted a Conciliation Conference with the parties on June 3, 2010. Present were the mother, Tina M. Kassam, who appeared via telephone, and her counsel Stacy B. Wolf, along with the father, Michael E. Mattesky. 2. The history of this case is that mother filed a Petition for Special Relief and Judge Hess issued an Order dated May 7, 2010, transferring primary physical custody of the minor child, Brianna M. Mattesky, born June 28, 1998, to the mother. Judge Hess also authorized the mother to take the child back to Arizona with her. 3. Since the Order issued by Judge Hess, father has filed a Petition for Contempt suggesting that the mother did not abide by some visitation provisions included in Judge Hess's 2010 Order. Additionally, father indicated at the Custody Conciliation Conference that he felt that the Judge's Order was incorrect and that he was seeking primary physical custody of the minor child. 4. A hearing is necessary in this case and the Conciliator reserved September 1, 2010 as a hearing date. The Conciliator also spoke with Judge Hess in Chambers with respect to the feelings of Judge Hess regarding father's periods of temporary custody ,' during the upcoming summer months. Based upon those discussions, the Conciliator recommends an Order in the form as attached. Date: June ~~ , 2010 Hubert X. roy, Esquire Custody onciliator JUL 29 2010 MICHAEL E. MATTESKY, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW ~, : NO. 1999-6098 CIVIL TERM o C`' '~ r.~ '-, _~ c- TINA M. BASSAM, '= ~ ~ -~ Defendant : IN CUSTODY ~ ~::, `~; ?? _.. ,-;~, o c-, ORDER OF COURT ~ ~ _," ~ __ =~d_f~ n`a AND NOW this ~ day of , 2010, upon consideration of the attached Motion, it is hereby, ordered that the Custody Hearing scheduled for September 1, 2010 at 9:30 a.m. be continued to the .S "' day of 2010 at l 1 ~ ~.m. in Court Room No. 4 of the Cumberland County Courthouse. Distribution: Stacy B. Wolf, Esquire For the Defendant ~ Michael E. Mattesky Pro se ~1~o~~a BY THE COURT: Kevin ess, President Judge s~ ~~, l ~~~ n A11~ 12 X010 MICHAEL E. MATTESKY, : IN THE COURT OF COMMON ~LEAS~ -~ ~ a Plaintiff :CUMBERLAND COUNTY, - ~ ' ~" :PENNSYLVANIA ~ - - v. CASE NO. 1999-6098 =~ TINA M. KASSAM, . _ :~ Defendant :CUSTODY PLAINTIFF'S RESPONSE TO PETITION FOR MODIFICATION FILED BY DEFENDANT AND NOW, comes Plaintiff Michaet E. Mattesky, by and thmugh his attorney, Sheri D. Coover, Esquire and files the following PLAINTIFF'S RESPONSE TO PETITION FOR MODIFICATION FILED BY DEFENDANT and in support thereof avers as follows: 1.-3. Admitted. 4. Admitted. The Order in which the Plaintiff Michael E. Mattesky (hereinafter referred to as "Father") had primary physical custody of the minor child was in effect between November 21, 2005 and May 7, 2010. The May 7, 2010 Court Order which granted Defendant Tina M. Kassam (hereinafter referred to as "Mother's primary physical custody of the minor child pending further proceedings was entered by the Honorable Judge Hess as a result of the PETITION FOR SPECIAL RELIEF filed by Mother. During the period of time that Father had custody, the child was well taken care of by Father and Father denies that any circumstances were present that warranted the child being removed from his custody. 5. Admitted. By way of further explanation, the child lived with Father from the time she was seven years of age until she was twelve. During the time that Father had custody, the Mother only exercised visitation with the child on one occasion when the child went to visit with her in Arizona. 6. Denied. Father denies that an}+ circumstances exist which necessitate the removal of the child from his custody and the home in which they have shared for the last four and a half yeazs. 7. Admitted. 8. Denied. Father denies that he has ever been physically abusive to the child. He denies that he uses any physical discipline on the child of any fashion. He further denies that he is physically abusive toward his mother (the child's paternal grandmother) on any occasion. He admits that there was one occasion when he did raise his hands and made gestures as if he were choking his mother but denies that he actually places his hands on his mother or tried to harm her in any fashion. 9. Denied. Father denies that he has ever drunk excessively, used drugs or distributed drugs in the presence of the child. Father admits that he does drink beer on occasion, but limits himself to a few beers and does not drink to excess. He admits that he has used marijuana in the past, but denies that he has ever engaged in marijuana use in the presence of the child. Father denies any addiction to marijuana use and has made a commitment to cease mazijuana use altogether. 10. Admitted in part, denied in part. Father admits that he did take the child with him to the American Legion azound noon on April 17, 2010. The child liked to play some games at the American Legion and she was excited to go there that day, Father stayed with Brianna the entire time that she was playing games at the restaurant. They stayed a little over an hour and then left. Father was not intoxicated at the time that they left the restaurant. Father further denies that he ever told the child to lie to the police which is believable since he had no pending chazges and was not involved with the police at all on that occasion. 11. Admitted in part, denied in part. Father admitted that he had an automobile accident with the child and two other young children in the automobile. Father had two beers on that occasion and had one unopened beer in the car. Father denies that he had a case of beer in his possession and denies that he ever told the children to hide a case of beer. After the accident, Father checked the children out to see if they were injured and inquired as to whether they felt that they needed medical attention. Father did not see any injuries (no scratches or bruises whatsoever) on the children so he did not get medical Gaze for them. Father informed the father of the other two young children about the accident immediately after it happened. Police responded to the accident and Father was chazged with driving too fast for conditions. 12. Admitted in part, denied in part. .Father admits that the child told him around Mazch of 2010 that she wanted to go and stay with Mother. The child told him that she felt that she had lived with him for the last several years and wanted a chance to live with Mother. Father expressed to the child at that time that he did not feel that it was a good idea and that he did not agree with it because he did not feel that it was in the best interest of the child. Mother had a history of not supervising her other children and felt that Mother would not provide a safe environment for the child. 13. Denied. Father has no knowledge of the Mother's fears. Mother did not speak to Father about the issue of Brianna's custody either before or after the filing of the Petition for Special Relief. 14. Admitted. Father denies that Mother having physical custody of the child is in the child's best interest. Father claims that Mother's home has no structure and no rules. Mother has a history of not supervising her other children and having conflicts with her other children which have caused the children to constant move between Mother's home and their biological father's home. 1 S. Denied. Father has had custody of the child for several years prior to the entry of the May 7, 2010 Order. Father denies that Mother's home is stable and appropriate for the child. Mother does not discipline the child. While on the telephone with Father since being in her Mother's custody, the child will swear in Mother's presence. Mother does not do anything to correct this behavior although it is obvious that she must hear the child acting inappropriately. Mother also fails to supervise her children and lets them do whatever they want without imposing any rules for their safety. Mother has had conflicts with children from previous relationships which have resulted in those children moving in and out of her household without the establishment of any boundaries. Upon information and belief, Mother abuses alcohol and drugs in the presence of the child. Child has recently reported to Father, paternal grandmother and a family friend by telephone that Mother places alcohol in a coffee cup and consumes the alcohol while she drives with the child as a passenger in the vehicle. The child was well cared for in Father's home. Father believes that it is in the child's best interest to be in his Gaze and custody. Father claims that he is in the best situation to provide a stable home for the child as the child lived with him for a substantial period of her life and while in his custody Father had provided a safe and nurturing environment in which the child grew and thrived. 16. Denied. Father denies any physical or substance abuse which created a risk of harm for the child. 17. Denied. Father denies that the child was subjected to a negative environment in his home. He submits that he is in the best situation to provide a stable home for the child as the child lived with him for a substantial period of her life and while in his custody Father had provided a safe and nurturing environment in which the child grew and thrived. 18. Denied. submits that he is in the best situation to pmvide a stable home for the child as the child lived with him for a substantial period of her life and while in his custody Father had provided a safe and nurturing envimnunent in which the child grew and thrived. NEW MATTER 19. On ar around May 7, 2010, this Court issued an Order granting Mother primary physical custody of the minor child, but the Order provided that Father was to have two visits with the child prior to the child leaving the state of Pennsylvania to go to live with Mother in Arizona. 20. After the entry of the May 7, 2010 Order, Father got to see the child on occasion for about twenty minutes at the Carlisle Police station and for a few minutes later that afternoon at the Dairy Queen. 21. Mother and Mother's boyfriend were present on both occasions that Father saw the child after the entry of the May 7, 2010 Order. 22. A short time thereafter Father learned that Mother and the child had left for Arizona when he received a call from the child's school in Carlisle requesting that he retrieve the child's belongings at the school because she had already left for Arizona, 23. Father tried to contact Mother several times to learn if and when Mother and the child left for Arizona but Mother did not answer the telephone and she refused to return Father's calls. 24. After a conciliation conference held before Hubert Gilroy, Esquire on June 3, 2010, the Court issued an Order an June 1 S, 2010 which granted Mother primary physical custody of the minor child and granted Father five weeks of custody during the summer. 25. The Order directed that Father was to consult with Mother's lawyer regazding the five weeks of custody. 26. Father contacted Mother's lawyer prior to the end of June 20 i 0 with the dates that he would like custody and the arrangements for the flight that he had arranged. 27. Sometime thereafter, Father learned that Mother had contacted his mother (child's paternal grandmother) and demanded that she cancel the flight. 28. Father did not get to exercise his five weeks of partial custody that he was granted under the June i 5, 2010 Order. 24. Father has not been reimbursed by Mother one half of the costs of the airplane ticket as directed by the June 15, 2010 Order although such reimbursement was directed by the June 15, 2010 Order. 30. The Order provides that Father may request a telephone conference call to address problems that he encounters with the scheduling of his period of temporary physical custody or logistics of the child flying back from Arizona to Pennsylvania, although Father was acting pro se' until recently and did not have the legal background and experience to understand that he had this right. 31. On or around Monday, August 9, 2010, the child reported to Father by telephone that Mother had called her names including a "cunt", that Mother and Mother's boyfriend were threatening to put the child in juvenile detention and that the child wanted to return to live in Father's home. 32. The child told Father and Father's friend by telephone that an adult friend Marsha Castle helped the child to figure out how she could go to live with her Mother and that the child's allegations against Father were based upon advice that she got from Ms. Castle instead of being based on the truth. 33. Upon information and belief, the child is not properly cared for in Mother's home and that Mother is not able to provide a suitable environment for the child. 34. Father is in the best position to care for the child as he has done for the past four and a half years prior to the Mother's filing of her Petition for Special Relief. WHEREFORE, Father respectfully requests that this Court return primary physical custody of the minor child Brianna Mattesky to him. he ' D. Coover, ESQ. rney ID 93285 S. Hanover Street Cazlisle, PA 17013 MICHAEL E. MATTESKY, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vi. CASE NO. 1999-6098 TINA M. KASSAM, Defendant :CUSTODY VERIFICATION I, Michael Mattesky hereby certify that I have reviewed the foregoing RESPONSE TO DEFENDANT' S PETITION FOR MODIFICATION and verify that all of the facts contained therein are true and correct to the best of my knowledge, information and belief. I understand that I can be liable both civilly and criminally under Pennsylvania and U.S. law for any false statements contained therein. Michael Mattesky ~~ O ate MICHAEL E. MATTESKY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. TINA M. KASSAM, Defendant CASE NO. 1999-6098 CUSTODY CERTIFICATE OF SERVICE I, Sheri D. Coover, ESQ. hereby certify that on this ~Z~day of 2010, I caused the foregoing RESPONSE TO DEFENDANT' S PETITION FOR MODIFICATION to be served upon counsel for the Defendant via United States first class mail addressed as follows: Stacy Wolf, Esquire Wolf & Wolf 10 W. High Street Carlisle, PA 17013 then ll. Coover, ESQ. Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 i MICHAEL ~. MATTESKY, IN THE COURT OF COMMON PLEAS OF Plain#iff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW ~, NO.99-6098 CIVIL c ~ `r' TINA M. KASSAM, ,~~~ ~ ~-~ Defe~Adant IN CUSTODY ~~, --~ ~~" ~ ~ o ORDER r -~ ~ t~ Dn a ~ =-rr Q.-~.i AND'' NOW, this ~ 9 ~ day of October, 2010, after hearing, it is hereby ~~redmndar~,-,-, ~ ~, D directed as follows: ~ `~ The mother, Tina M. Kassam, shall have primary physical custody of Brianna M. Mattesky, barn June 28, 1998. 2. Tl~e father, Michael E. Mattesky, shall have visitation of the child for five weeks each summer durik~g the child's school break with the child, however, to stay at her paternal grandmother's home. 3. The father shall pay the entire cost of the child's plane ticket for his period of summer visitation if lie is not paying child support to mother; however, if father is paying child support to mother, father shall purchase the plane ticket and mother shall reimburse him for one-half of the cost within f~fteen days of father providing written verification of the purchase of the ticket. 4. The father shall have other periods of visitation by agreement of the parties. 5. Tl~e mother shall not interfere with liberal and reasonable telephone contact between father and child. BY THE COURT, Kevin A~. Hess. P. J. y ~D. Co ver, Esquire For the Plai~itiff tacy Wolf, Esquire For the Def~ndant :rlm 6~.S '/Yt~L ~~~~ /~ ~~ P MICHAEL A. MATTESKY, : IN THE COURT OF COMMON PLEA$3 Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYIIIA, rn vs. : = ; , : NO.: 99-6098 CIVIL TERM e TINA M. KASSAM, : IN CUSTODY < , ` Defendant/Respondent : �' =_c)Y ^^ ♦w �.,,.shy PETITION FOR MODIFICATION OF CUSTODY - wf 1. The Petitioner is Michael A. Mattesky, who resides at 52 East High Street, Carlisle, PA 17013. 2. The Respondent is Tina M. Kassam, who resides at 605 Juniper Street, Payson, AZ 85541. 3. Petitioner is requesting that he have full physical and legal custody of Brianna M. Mattesky, born June 28, 1998. 4. Previous allegations of child abuse by the Petitioner have been unfounded. (See Petitioner Exhibit "A"). 5. Respondent is currently under investigation by the Arizona Department of Economic Security for neglect of the child. (See Petitioner Exhibit "B"). WHEREFORE, the Petitioner requests a Modification of Custody. Respectful ub d, J Date: Li 111'34 13 By: a A Paul Bradford Orr, Esquire Attorney for Plaintiff/Petitioner 50 East High Street Carlisle, PA 17013 (717) 258-8558 v d /0"•t e4; PA Court ID # 71786 a� � s. COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF PUBLIC WELFARE OFFICE OF CHILDREN, YOUTH AND FAMILIES P.O. BOX. 2675 HARRISBURG, PENNSYLVANIA 17105-2675 Phone:(717)783-1964 FAX:(717)772-6857 MIKE MATTESKY Mailing Date 403 NORTH BEDFORD STREET June 25, 2012 CARLISLE PA 17013 Child: BRIANNA MATTESKY Report No 210008956 Status: Unfounded Agency: CUMBERLAND COUNTY CYA DEAR MR. MATTESKY : The above named child was reported as a victim of suspected child or student abuse. The agency listed above has investigated the report and determined it was Unfounded or Unfounded for School Employee because of one of the following : (1) the incident did not occur, (2) the injury was not of a serious nature, or (3) substantial evidence was not found. This is notification that the above-listed report will be expunged by this office as required by the Child Protective Services Law § 6337 section (a) that states, when a report of suspected child abuse is determined by the appropriate county agency to be an unfounded report the information concerning that report of suspected child abuse shall be maintained for a period of one year. The report shall be expunged from the pending complaint file, as soon as possible, but no later than 120 days after the one-year period from the date the report was received by the department. If the investigation reveals that the child and family are in need of social services provided or arranged by the investigating agency, their records will be retained by them. This letter is the only notice of expunction you will receive from our office, so please retain it for your records. If you have questions concerning this report, you may contact the investigating agency at (717) 240-6120. Sincerely, Terry L. Clark, Director Division of Operations Exp1 PS-045(5-11) ARIZONA DEPARTMENT OF ECONOMIC SECURITY Division of Children,Youth and Families CHILD PROTECTIVE SERVICES' NOTICE OF DUTY TO INFORM When Child Protective Services (CPS)receives an allegation of child abuse or neglect by a parent, guardian or custodian and a report is taken,Arizona law requires CPS to conduct an investigation and provide you with information about your rights both verbally and in writing. The following complaint or allegation concerning your family is currently under investigation: �e/e c f- • This notice is to inform you that: • CPS has no legal authority to compel or make you cooperate with the investigation or to accept services,but it is our hope that by working together we can find solutions to ensure that your child(or children)is safe and that your family has what it needs. • CPS has a duty to proceed with the investigation even if you decide not to cooperate to ensure that your child(or children)is safe,although we would prefer to carry on with the investigation with your support. • Your refusal to cooperate with the investigation or services offered does not in itself form a basis for CPS to take temporary custody of your child(or children),unless it is clearly necessary to protect your child(or children)from abuse or neglect. • CPS has the authority to petition the Juvenile Court for a determination that your child(or children)is dependent and in need of protection. • You have the right to provide written,telephonic or verbal responses to the allegation, including any documentation,and to have the information considered in determining whether your child(or children)is in need of protective services. • You need to know that anything you say or write can be used in a court proceeding. • You need to know that anything you say may be included in CPS' report of the investigation. • You need to know that any written response that you provide,including any documentation,will be included in the CPS case record. • You need to know that any information that you provide in response to the complaint or allegation(s)will be considered during the investigation. • You have the right to appeal determinations made by CPS about the results of the investigation and will be notified in writing of these results and how to appeal. • You have the right to: • Request and participate in a Mediation Program in the Attorney General's Office. The telephone number for the Mediation Program in Phoenix is(602)542-7767,and in Tucson,(520)628-6782. The Mediation Program may be used to settle disputes that arise among families, CPS,and others concerned with the welfare of children. • File a complaint with the Arizona Ombudsman-Citizens Aide. The telephone number in Phoenix is(602)277-7292,and statewide toll-free is 1-800-872-2879. The Ombudsman-Citizen Aide office is available to handle inquiries,concerns and complaints about agency actions,including CPS. More information about CPS and your parental rights are outlined in the pamphlet, "Guide to Child Protective Services"that I am leaving with you today. By signing this form,you are acknowledging that I have reviewed the information contained in this notice with you. PARENT,GUARDIAN OR CUSTODIAN'S SIGNATURE PARENT,GUARDIAN OR CUSTODIAN'S NAME(Please print) DATE m I chose.' MO-its Cove e pho At-64er P') 3/51/3 PARENT,GUARDIAN OR CUSTODIAN'S SI ATURE PARENT,GUARDIAN OR CUSTODIAN'S NAME(Please print) DATE ❑Yeso Parents were asked about Native American/American Indian heritage. Explain: pps CIALISTS SIGNATURE CPS SPECIALIST NAME(Please print) DATE aJ f-a-rJc,l Fred nek- 3/s/J 3. See reverse for EOE/ADALEP disclosure. VERIFICATION I verify that the statements made in the foregoing Petition 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: ‘7/—.2 /3 Michael Mattesky, Petitioner MICHAEL A.MATTESKY IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA C- C= tai O 1999-6098 CIVIL ACTION LAW TINA M. KASSAM k DEFENDANT IN CUSTODY ORDER OF COURT < AND NOW, Thursday, May 02,2013 -, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X.Gilroy,Esq. the conciliator, at 4th Floor,Cumberland County Courthouse,Carlisle on Friday,May 31,2013 9:30 AM for aPre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished,to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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/ Hubert X. Gilroy, Esq. jr Custody Conciliator r 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 32 South Bedford Street rq Carlisle, Pennsylvania 17013 0 a COWL. Telephone (717)249-3166 Tim M . 4'5:50-m 4A X E MIC:HAFL A.MXITESKY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V 1999-6098 CIVIL ACTION- LAW c ` rn� � TINA M. KASSAM, Defendant IN CUSTODY <n o PRIOR JUDGE: The Honorable Kevin A. Bless COURT ORDER -_ AND NOW, this rr7_day of tune, 2013, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I. This Court's prior Order of October 17,2010, is vacated. 2. This Court defers to the Arizona state officials, either in their Children's Services department or in an appropriate Judicial department, for purposes of making a determination as to the best interest of Briars M. Mattesky, born June 28, 1998, and for purposes of determining who should have custody of the minor child. 3. In the event the father, Michael A. Mattesky is awarded custody of the minor child and the child returns from Arizona to Cumberland County, Pennsylvania, this Court will assume jurisdiction at that time and either parent or any other appropriately interested party may bring this matter back before dtis Court for purposes of entry of a custody order. No party shall be permitted to relocate the residence of the child where said relocation will significantly impair the ability to exercise custody unless every individual who has custodial rights to the child consents to the proposed relocation or the court approves the proposed relocation.Any party proposing to relocate MUST comply with 23 Pa. O.S. §5337. BY THE COURT, Kevin ess, Judge i cc: I B. Orr, Esquire Ms. Tina M. Kas`s`aamm mw �?ptfS � t L/fo/i3 MICHAEL A.MATTESKY, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v 1999-6098 CIVIL ACTION- LAW TINA M. KASSAM, Defendant IN CUSTODY PRIOR JUDGE: The Honorable Kevin A. Hess CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: I. The pertinent information pertaining to the child who is die subject of this litigation is as follows: Brianna M. Mattesky, bom June 28, 1998. 2. A Conciliation Conference was held on May 31,2013,with the following individuals in attendance: The father,Michael A. Mattesky,with his counsel,Paul B.Orr,Esquire. The mother, Tina M. Kassam,appeared via telephone on her own without counsel. 3. This case has somewhat of a unique history. The Cumberland Court, after a hearing in October of 2010, issued an Order giving the mother primary physical custody and the father visitation during the summer subject to the visitation occurring at the paternal grandmother's home.For the past three years,the mother has lived in Arizona with the child. The father has not seen the child for approximately three years. The father has now filed a Petition for Modification seeking primary custody ol'the child. However, the child is currently involved in dependency proceedings in the state of Arizona and a hearing was held on May 30, 2013, before the appropriate officials in Arizona. Apparently, the child is hospitalized in Arizona and basically in the custody of the Arizona equivalency of children's services. There is another hearing scheduled in August. Father suggests that the Arizona officials maybe willing to send the child to be in the custody of the father, but that the existing custody Order in Cumberland, Pennsylvania,is an impediment to such a detentrination being made in Arizona. The mother does not believe the father should have custody. A. The Conciliator's view is that the Arizona officials have the more appropriate jurisdiction in this case and are in a better position to make a decision with respect to custody of this child. The Conciliator also is of the opinion that the existing Order may be an impediment to the Arizona officials delivering custody to the father even though they may feel that would be in the best interest of the minor child. The Conciliator recommends that the existing Order be vacated with an appropriate reference to deferring to Arizona in connection with a decision. Date: May 3f__, 201.3 Htfi<ert x Gil y,Esquire Custody C: ciliator