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HomeMy WebLinkAbout03-3522 JOSEPH PHILIP GARZA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. NO. o3-j5'.2.~ CIVIL ACTION - LAW IN CUSTODY TIFFANY DENISE HOLLINGER, Defendant COMPLAINT FOR CUSTODY 1. The Plaintiff is Joseph Philip Garza, who currendy resides at 346 E. North Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Tiffany Denise Hollinger, who currendy resides at 217 Green Lane Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The Plaintiff seeks custody of the following children: a. Yuri Dylan Hollinger, born March 16, 1999, who currendy resides at 217 Green Lane Drive, Camp Hill, Cumberland County, Pennsylvania 17011; b. Cole Joseph Hollinger, born July 1, 2002, who currendy resides at 217 Green Lane Drive, Camp Hill, Cumberland County, Pennsylvania 17011; c. Nathaniel Rain Hollinger, born July 1, 2002, who currendy resides at 217 Green Lane Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 4. The children were born out of wedlock. 3 5. The children are presently in the custody of Tiffany Denise Hollinger, who resides at 217 Green Lane Drive, Camp Hill, Cumberland County, Pennsylvania. 6. During Yuri Dylan Hollinger's lifetime, he has resided with the following persons and at the following addresses: Plaintiff & Defendant; 3/1999 - 8/2000; East High Street, Elizabethtown, PA Plaintiff & Defendant; 8/2000 - 6/2001; 425 Haldeman Blvd., New Cumberland, P A Plaintiff & Defendant; 6/2001 - 10/2002; 4 Marshall Drive, Apt. K-19, Camp Hill, P A Defendant; 10/2002 -1/2003; 4 Marshall Drive, Apt. K-19, Camp Hill, PA Plaintiff & Defendant; 1/2003 - 3/9/2003; 4 Marshall Drive, Apt. K-19, Camp Hill P A , Defendant and Defendant's parents, Tanya & Dennis Hollinger; 3/9/2003 - present; 217 Green Lane Drive, Camp Hill, P A 7. During Nathaniel Rain Hollinger's and Cole Joseph Hollinger's lifetimes, they have resided with the following persons and at the following addresses: Plaintiff & Defendant; 7/2002 - 10/2002; 4 Marshall Drive, Apt. K-19, Camp Hill, P A Defendant; 10/2002 -1/2003; 4 Marshall Drive, Apt. K-19, Camp Hill, PA Plaintiff & Defendant; 1/2003 - 3/9/2003; 4 Marshall Drive, Apt. K-19, Camp Hill, P A 4 Defendant and Defendant's parents, Tanya & Dennis Hollinger; 3/9/2003 - present; 217 Green Lane Drive, Camp Hill, P A 8. The mother of the children is Tiffany Denise Hollinger, who currendy resides at 217 Green Lane Drive, Camp Hill, P A. 9. Mother of the children, Tiffany Denise Hollinger, is not married. 10. The father of the children is Joseph Philip Garza, who currendy resides at 346 E. North Street, Carlisle, PA. 11. Father of the children, Joseph Philip Garza, is not married. 12. The relationship of Plaintiff to the children is that of Father. 13. The relationship of Defendant to the children is that of Mother. 14. The Defendant currendy resides with the following persons: Tanya & Dennis Hollinger, Maternal Grandparents 15. The Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or any other court. 16. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 17. The Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 5 18. The best interest and permanent welfare of the children will be served by granting the relief requested for reasons including the following: a. The Father has been a caregiver of the minor children since their birth. He has: 1. Planned and prepared meals; 11. Bathed, groomed and dressed the children; 111. Purchased, cleaned and cared for the children's clothing; lV. Attended trips to physicians in order to provide medical care; v. Arranged alternative daycare; vi. Put the children to bed nighrly, attended the children in the middle of the night, and awakened the children in the morning. b. The Mother has restricted Father's time alone with the children. c. The Mother has not allowed the Father to see the children since their separation. d. The children have a psychological bond with the Father and access to the children is vital to maintaining the father! child relationship. e. Father is able to provide a stable environment for the child. 6 19. Each parent whose parental rights to the children have not been terminated has been named as parties to this action. WHEREFORE, the Plaintiff requests that this Court to grant pnmary physical custody of the children to the Plaintiff/Father. Respectfully submitted, MOM & KUTULAKIS, L.L.P. DATE '1- 2.'/ 0 oJ ~ Jas n P. Kutulakis ID No. 80411 36 South Hanover Street Carlisle, P A 17013 (717) 249-0900 Attorney for Plaintiff 7 CERTIFICATE OF SERVICE AND NOW, this /1.Lf#.. day of ~ 2003, I, Jason P. Kutulakis, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Custody Complaint, upon the Defendant by depositing, or causing to be deposited, same in the . United States Mail, First-class mail, postage prepaid addressed to the following: Joan Carey, Esquire MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 Glenn Zeider MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 Respectfully submitted, Abom & Kutulakis, L.L.P. ~l~ JasO<l P. Kutulakis ID No. 80411 36 South Hanover Street Carlisle, P A 17013 (717) 249-0900 Attorney for Plaintiff 7 VERIFICATION I, JOSEPH PHILIP GARZA, verify that the statements made in this Custody Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Date 7/~fl5 ~~ rcr JOSEPH PHILIP GARZA 9 ~ f! ~ ~..., ~ "- ' .. ~ -', , ~ ~ , , - ~ --C. ,. \.}.l ~ .. C) .~") ~ ~ -0 I' .. J'\ ~ .-C. <::- s:;--- ~ v. v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, P A NO. 0">:) S-;;r?- JOSEPH PHILIP GARZA, Plaintiff TIFFANY DENISE HOLLINGER, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW; this dL(Jl\ day of ~, 2003, upon consideration of the attached Stipulation and upon agreement of the parties, it is hereby Ordered and Directed as follows: 1. The parties are the natural parents of three minor children, Yuri Dylan Hollinger, born March 16, 1999; Cole Joseph Hollinger, born July 1, 2002; and Nathaniel Rain Hollinger, born July 1, 2002. 2. The parties shall share legal custody of the minor children. 3. Mother shall have primary physical custody of the parties' minor children. 4. Father shall have partial physical custody of the parties' minor children by way of supervised visitation to occur at the YWCA or by a supervisor mutually agreeable to the parties and at times mutually agreeable to the parties. 5. This Court shall maintain jurisdiction over the issue of custody of the parties minor children and shall retain such jurisdiction should ./~ tJ w~ ~ ~<}: a circumstances change and either party desires further modification of said Order. 6. This Order shall remain in effect until a Court Order is entered pursuant to a custody conciliation conference to be held in the near future. J. , \7'fi\j-'/l\lAS;~J:-'E~d ) ''''-'''- .-, ,-' ,...,~.. "'In" .......1\1:,- . "",,":n IV Z; :( :,d'G .'irw SO dO - JOSEPH PHILIP GARZA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLA~D COUNTY, PA v. NO. TIFFANY DENISE HOLLINGER, Defendant CIVIL ACTION - LAW IN CUSTODY TEMPORARY CUSTODY STIPULATION AND AGREEMENT AND NOW; this _ day of July, 2003, the parties, Joseph Philip Garza, hereinafter referred to as "Father", and Tiffany Denise Hollinger, hereinafter referred to as "Mother", stipulate to the following: 1. The parties are the natural parents of three minor children, Y uri Dylan Hollinger, born March 16, 1999; Cole Joseph Hollinger, bom July 1,2002; and Nathaniel Rain Hollinger, bomJuly 1, 2002. 2. The parties shall share legal custody of the minor children. 3. Mother shall have primary physical custody of the parties' minor children. 4. Father shall have partial physical custody of the parties' minor children by way of supervised visitation to occur at the YWCA or by a supervisor mutually agreeable to the parties and at times mutually agreeable to the parties. 5. The parties desire that this Stipulation be made an Order of Court through the Court of Cornmon Pleas of Cumberland County, and further acknowledge that the Court of Cornmon Pleas of Cumberland County has jurisdiction over the issue of custody of the parties minor child and shall retain such jurisdiction should circumstances change and either party desires further modification of said Order. 6. This Agreement and Stipulation shall remain in effect until a Court Order is entered pursuant to a custody conciliation conference to be held in the near future. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound terms thereof, set forth their hands and seals the date and year herein set forth. (~r1 t-;.{JRr"-,,,_ ~) RE ~~~SEHOLUNGER ,~~~ JOSEPH PHIU GARZA ON P. KUTULAKIS, ESQUIRE JOSEPH PffiLIP GARZA PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. 03-3522 CIVIL ACTION LAW TIFFANY DENISE HOLLINGER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, July 29, 2003 , upon consideration ofthe attached Complaint, it is hereby directed that parties and their respective counsel appear before. Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberlaud County Courthouse, Carlisle on Thursday, AU2ust 28, 2003 at 10:30 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 defme 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 hearin2. FOR THE COURT, By; Isl Hubert X. GilrOJl. Esq. Custody Conciliator l/ 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 nIE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle. Pennsylvania 17013 Telephone (717) 249-3166 ~ ~j" ~~~ &'O[:i.. ~ 7"> ~ ~~ ~ ~b0 Co.CC-L, , ~ b ?-~ ~ ~ p;>.~r(, , ,,~'1!'JV^lASNN3d A.Li\;~ ':,!~ I}r)'~(}q:.::n~no S'l :Z ~.id os lnr so Ai:J\iW,-I(" IV'.; :11'1 ;10 301;1:10-0318 ' OCT 0 3 2003 r./ JOSEPH PHILIP GARZA, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW TIFFANY DENISE HOLLINGER, Defendant NO. 2003 - 3522 CIVIL IN CUSTODY COURT ORDER AND NOW, this ",... day of 0 ~ ,2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that this court's prior order of July 24, 2003 is modified as follows: 1. Father's periods of temporary custody shall b{, as follows: A. On Saturdays from 1:00 p.m. until 5:00 p.m. Father shall have temporary custody of Yuri. On Sundays from 1:00 p.m. until 5:00 p.m. Father shall have temporary custody of Cole and Nathaniel. This arrangement shall begin Saturday, September 20,2003. 2. Father shall contact Parentworks in New Cumberland to make arrangements with respect to parent education program services to be provided to the Father. 3. Father's periods of custody with the minor children shall be exercised at Father's home and Father's mother shall be present at the home. 4. Father shall ensure that he has adequate child car seats for all three children. 5. For exchange of custody, Mother shall take the children to the Father's home and pick the children up at the Father's home. 6. Prior to September 20, 2003 Mother may make arrangements to meet with the Paternal Grandmother and to also inspect Father's home. She shall do so by contacting the Father for arranging that meeting and inspection. 7. Legal counsel for the parties shall conduct another custody conciliation conference with the conciliator via a telephone conference call on Thursday, October 23, 2003 at 8:30 a.m. BY JHE c~~;J ~._-~-\' ~/~. . Edward E. Guido J. cc: . ....... P. K."""", "'q"" [~~~ ...Joan E. Carey, Esquire ~ . l<5 IO.O'7-lG '71Vi:!i~{(\ AJ/\~/!,~,{,,-, ~ )J: ,?i:,~V:.?d . .. .-, , : 1..:.-',: I~._~., .. . -'"-;J1f:7J ~S:C (I. "0 f-J.JD[;O ,<yw,..",,,. .... ......., 1(//',,'/'::'.,-'.< "', :j'"'1../ I,::"VC~. :"-/iL :fa _\,..I_.~..u-o:n.t~( . JOSEPH PHILIP GARZA, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW TIFFANY DENISE HOLLINGER, Defendant NO. 2003 - 3522 CIVIL IN CUSTODY Prior Judge: Edward E. Guido CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE ~TH THE CUMBERLAND COUNTY CI~L RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent infonnation pertaining to the children who are the subject of this litigation is as follows: Yuri Dylan Hollinger, born March 16, 1999; Cole Joseph Hollinger, born July 1, 2002; and Nathauiel Rain Hollinger, born July 1, 2002. 2. A Conciliation Conference was held on September 12, 2003, with the following individuals in attendance: The Father, Joseph Philip Garza, with his counsel, Jason P. Kutulakis, Esquire; and the Mother, Tiffany Denise Hollinger, with her counsel, Joan E. Carey, Esquire. 3. The parties agree to the entry of an order in the form as attached. (uhf oY DATE (})/sI---KI Hubert X. Gilroy, Custody Concilia r / NOV 0 3 Z003 \1 JOSEPH PHILIP GARZA, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW TIFFANY DENISE ~OLLINGER, Defendant NO. 2003 - 3522 CIVIL IN CUSTODY COURT ORDER ! ~ AND NOW, thiS ;;rv day of cJVf. , 2003, the conciliator having scheduled a t,lephone conference call with the attorneys for the parties and having been advised that 40 further action needs to be taken on this case, the conciliator relinquishes jurisdictipn. BY THE COURT, (') 0 ~ ~ c.:> z: :~::n -err::. 0 rrw 'C: '~~~ Z~l I 6jC '0 \'.- W ')r!:... l) J" .: :;i~ ~b -0 t:; ~(: 3 -7 --rn -c. tf! C;; >c~ -7 N ~ ~:;j -, c.:> JOSEPH PHILIP GARZA, Plaintiff ~\ J Cl 2D04 IN THE COURT OF COMMON PL S OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW TIFFANY DENISE HOLLINGER, Defendant NO. 2003-3522 CIVIL IN CUSTODY COURT ORDER ; AND NOW, this d'O day of January, 2004, upon consideration of the attached Custody Conciliation report, it is ordered and directed that this courts prior orders of July 24, 2003 and October 7, 2003 shall remain in effect subject to the following modifications: 1. Father's periods of temporary custody shall be every Wednesday and Sunday from 9:00 a.m. until 6:00 p.m. Exchange of custody shall be either at a middle point between the parents homes as agreed upon by the parents or shall be such that the father shall pick up the children in the morning at 9:00 a.m. and mother shall pick the children up at the fathers in the evening at 6:00 p.m. 2. Father shall work on making all necessary arrangements relative to handling the minor children with respect to facilities within his home to care for the children. 3. Father shall complete the Parent Works program pursuant to the courts prior order. 4. Father shall cooperate in any counseling programs that involve any of the children, and father shall ensure that the children shall attend those counseling sessions in the event they are scheduled at times when father has custody. 5. The parties shall meet again with the custody conciliator for another custody conciliation conference on March 25, 2004 at 8:30 a.m. It is anticipated at the next custody conciliation conference that there will be a discussion relative to expanding fathers periods of temporary custody to include over nights, subject, however, to the living arrangements of the father and other issues that may develop prior to that conciliation conference. cc: /Jessica Diamondstone, Esquire j'Kara Haggerty, Esquire BY Judge Edward E. Guido I !,t',.l:,",' ,,"', i-';' roo ",:;;1"".,,., 1'_ - .-,I\;,)J 90 :2 [.!d ZZ mr flGOZ ~Hl :10 :(;L:':!O-(E::'~ JAN 2 0 2DD4 JOSEPH PHILIP GARZA, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v CIVIL ACTION - LAW TIFFANY DENISE HOLLINGER, Defendant NO. 2003 -3522 CIVIL IN CUSTODY Prior Judge: Edward E. Guido CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITII TIlE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent infonnation pertaining to the children who are the subject of this litigation is as follows: Yuri Dylan Hollinger, born March 16, 1999; Cole Joseph Hollinger, born July 1, 2002; and Nathaniel Rain Hollinger, born July 1, 2002. 2. A Conciliation Conference was held on January 16, 2004, with the following individuals in attendance: The father, Joseph Philip Garza, with his attorney, Kara W. Haggerty, and the mother, Tiffany Denise Hollinger, with her attorney, Jessica Diamondstone. 3. The parties agreed to the entry of an order and the fonn is attached. I If r;(() "5 DA ~Jl JOSEPH PHILIP GARZA, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION- LAW TIFF ANY DENISE HOLLINGER Defendant : NO. 2003-3522 CIVIL : IN CUSTODY PRAECIPE TO WITHDRA W APPEARANCE TO THE PROTHONOTARY: Please \\ithdraw my appearance fur the Plaintiff, Joseph Philip Garza the above captioned case. Date: M&- Kara Haggerty, Esqu' e 36 South Hanover S Carlisle, PAl 7013 (717) 249-0900 Attorney for Plaintiff PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter my appearance for the Plaintiff, Joseph Philip Garza the above captioned r."'ro...... ,",,"..:I"". Date: -.1f.1(r. 10" I I'-.) = = r;:r. a n -t o ." ~ n"l ::0 r- :R r-n -::.::) r.# '::hl " 11 '~~~l =~ Cj?n --l ....... ':0 ~ I 0"' ;g r.J 0-. JOSEPH PHILIP GARZA, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION- LAW TIFFANY DENISE HOLLINGER Defendant : NO. 2003-3522 CIVIL : IN CUSTODY PETITION TO MODIFY CUSTODY 1. Petitioner is Joseph Philip Garza who resides at 36 East Locust Avenue, Carlisle, Cumberland County, Pennsylvania 17013. 2. Respondent is Tiffany Denise Hollinger who resided/resides at 217 Green Lane Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 3. On January 22, 2004, the Honorable Judge 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. Petitioner's current scheduled days off work have changed and do not correspond with the Order. b. Petitioner wishes to see his children on holidays, birthdays and schedule vacations with the children. The current order does not address any of the above. 5. The best interest of the child will be served by the Court in modifying said Order. WHEREFORE, Petitioner prays this Court to grant modification of the Custody Order as follows: Petitioner and the Respondent have shared physical custody of children, with an appropriate exchange schedule determined by the Court. Date:~ Respectfully submitted, ROMINGER & WHARE Les. A. Tomeo, 155 South Hanov Street Carlisle, P A 17013 (717) 241-6070 Supreme Court ID # 200198 Attorney for Petitioner JOSEPH PHILIP GARZA, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION- LAW TIFF ANY DENISE HOLLINGER Defendant : NO. 2003-3522 CIVIL : IN CUSTODY VERIFICATION I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. 9 4904 relating to unsworn falsification to authorities. . . - - . . "3 Jose~:r Petition , 1_- A ..r-- JOSEPH PHILIP GARZA, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION- LAW TIFFANY DENISE HOLLINGER Defendant : NO. 2003-3522 CIVIL : IN CUSTODY CERTIFICATE OF SERVICE I, Leslie A. Tomeo, Esquire, attorney for Defendant, Joseph Philip Garza, do hereby certify that I this day served a copy of the Petition to Modify Custody upon the following by First Class Mail delivery at Carlisle, Pennsylvania, addressed as follows: Tiffany D. Hollinger 217 Green Lane Drive Camp Hill, Pa 17011 Dated: 10 {Iz../ /)'" Respectfully submitted, ROMINGER & WHARE Les e A. Tome , Esquire 155 South Hano er Street Carlisle, P A 17013 (717) 241-6070 Supreme Court ID # 200198 Attorney for Petitioner ~? _~c-- JOSEPH PHILIP GARZA, Plaintiff IN THE COURT OF COMMON p~~rt gpJ04 CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW TIFFANY DENISE HOLLINGER, Defendant NO. 2003-3522 CIVIL IN CUSTODY COURT ORDER J AND NOW, this d d day of January, 2004, upon consideration of the attached. Custody Conciliation report, it is ordered and directed that this courts prior orders of July 24, 2003 and October 7, 2003 shall remain in effect subject to the following modifications: 1. Father's periods of temporary custody shall be every Wednesday and Sunday from 9:00 a.m. until 6:00 p.m. Exchange of custody shall be either at a middle point between the parents homes as agreed upon by the parents or shall be such that the father shall pick up the children in the Inorning at 9:00 a.m. and mother shall pick the children up at the fathers in the evening at 6:00 p.m. 2. Father shall work on making all necessary arrangements relative to handling the minor children with respect to facilities within his home to care for the children. , 3. Father shall complete the Parent Works program pursuant to the courts prior order. 4. Father shall cooperate in any counseling programs that involve any of the children, and father shall ensure that the children shall attend those counseling sessions in the event they are scheduled at times when father has custody. 5. The parties shall meet again with the custody conciliator for another custody conciliation conference on March 25, 2004 at 8:30 a.m. It is anticipated at the next custody conciliation conference that there will be a discussion relative to expanding fathers periods of temporary custody to include over nights, subject, however, to the living arrangements of the father and other issues that may develop prior to that conciliation conference. t~h.{ ht f- F( if It' cc: /Jessica Diamondstone, Esquire jXara Haggerty, Esquire BY Judge Edward E. Guido tr:ilJE C()7{ FR:'~~~ RECORD In T~UfOOny wNJroof.1 nor~ unto. sat HlY hand """d t'''1..\ ~. . ...I.... '" 'A C^Hn' .""... f',\>'i;~t~ ~ :.t,) l..l~liJ;(1::' WI ~ 'VU ~l"'- i~~l r-a. ) fh..~ 1')- daf. ol~'?it: d~ . {I.,;-= () - _.~. Prothoou . ;: t~ hr 9, f1 f>., t"\ ti: fj VG'-i~lJ\ /.~1 'J l~Ul)'f JOSEPH PHILIP GARZA, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW TIFFANY DENISE HOLLINGER, Defendant NO. 2003 -3522 CIVIL IN CUSTODY Prior Judge: Edward E. Guido 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 pertinent information pertaining to the children who are the subject of this litigation is as follows: Yuri Dylan Hollinger, born March 16, 1999; Cole Joseph Hollinger, born July 1, 2002; and Nathaniel Rain Hollinger, born July 1, 2002. 2. A Conciliation Conference was held on January 16, 2004, with the following individuals in attendance: The father, Joseph Philip Garza, with his attorney, Kara W. Haggerty, and the mother, Tiffany Denise Hollinger, with her attorney, Jessica Diamondstone. 3. The parties agreed to the entry of an order and the form is attached. I ~(ff(!J ") DA E ~ ~-g, ~ p ? -! ~ < ~8jt~ -I:::. - Qi 3 f\ o -t:\ - ~ 0 ,...:..:.-.> .1 w--" .-4 -:.1: -n (lle .~:._; " t1. .-_l,) ...::::t >, ;l.) . ,~. ~:~:. ,.,,} 2~) _ ~?\ r1". r"":> ?D 0:> .""- N -c --:r"... JOSEPH PHILIP GARZA PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 03-3522 CIVIL ACTION LAW TlFF ANY DENISE HOLLINGER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, October 17,2006 , 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, Cumberlaud Couuly courthouse, Carlisle on Friday, Decemher 01,2006 at 8,30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or ifthis cannot be accomplished, to define and narrow the issues to be heard hy the court, and to enter into a temporary order. Ali 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 Ahuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearin,. FOR THE COURT. By: Isl Hubert X. Gilrov. Esq. ~ Custody Conciliator I The Court of Common Pleas of Cumberland County is required by law to comply with tbe 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. Ali arrangements must be made at least 72 bours 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 HA VE AN A TIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 fJ?< ~.~ "": ~ ~ :7a'..I/-V'/ :~ 2 ~ ~ ~,J/-<7/ ~ j}P ~ ~ ~.~ 1/?'?/'r?/ 'v7NVA1\SNN3d AlNnOCJ (it ,1If{ij3fWVno 2C :e Hd 81130 gOOl AW10NOH10Cld 3H.L :JO 301:1:10-0311:1 o ....... JOSEPH PHILIP GARZA Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 03-3522 CIVIL TERM TIFFANY DENISE HOLLINGER: IN CUSTODY Defendant PRAECIPE FOR ENTRY OF APPEARANCE To Curtis R. Long, Prothonotary: Please enter my appearance on behalf of the Defendant, Tiffany Hollinger, in the above captioned case. Respectfully submitted, Je si a Hol . Esquire idPenn Legal Services 401 E. Louther Street Carlisle, PA 17013 (717) 243-9400 Date: JO' o-()'0~ . ~ JOSEPH PHILIP GARZA Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 03-3522 CIVIL TERM TIFFANY DENISE HOLLINGER: IN CUSTODY Defendant CERTIFICATE OF SERVICE I, Jessica Holst, Esquire, of MidPenn Legal Services, attorney for the Defendant, Tiffany Hollinger, hereby certify that I have served a copy of the foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following date and in the manner indicated below: U.S. First Class Mail, Postage Pre-Paid Leslie Tomeo, Esquire 155 South Hanover Street Carlisle, PA 17013 Date: )0' dO - ~ Jessica olst, Esquire MidPenn Legal Services 401 E. Louther Street Carlisle, PA 17013 (717) 243-9400 (') c S": -0 co mrn ~~(-\ L. (./1; -~..t..;.; !<= '. ~f=_: J;>C -7 ~ -.... I'-.)- <:::) c:::> <::r> o ('"") -f N o ~ ~ m# -om -ut? 9Q ~..,.~ 1 $ ;--n (::> n" 7m (5 :-;! 1J ~ ~ -- W \D ~.. , 2001 ~~ 7 JOSEPH PHILIP GARZA, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v CIVIL ACTION - LAW TIFFANY DENISE HOLLINGER, Defendant NO. 03-3522 IN CUSTODY COURT ORDER ~ AND NOW, this L day of February, 2007, upon consideration of the attached Custody Conciliation report, it is ordered and directed that this Court's prior Orders of January 24, 2004, July 24, 2003 and October 7, 2003 shall be vacated and replaced with the following Order: 1. The mother, Tiffany Denise Hollinger, shall enjoy legal and primary physical custody of Yuri Dylan Hollinger, born March 16, 1999, Cole Joseph Hollinger, born July 1, 2002 and Nathaniel Rain Hollinger, born Julyl, 2002. 2. The father shall have periods of temporary physical custody with the minor children as follows: a. One day a week from 9:00 a.m.. until 5:00 p.m. subject to the first three visits being arranged through Parent Works which shall provide some type supervision/monitoring/direction for the visitation. The extent ofthe visitation will be subject to the availability of Parent Works in connection with arranging these visitations. Costs of Parent Works shall be paid by the father. 3. Upon father's conclusion of three visits with the minor children at Parent Works and assuming things are going well with the visitation, it is anticipated that visitation would be expanded to allow father unsupervised visitation subject to the agreement ofthe parties. In the event the parties are unable to reach an agreement, counsel for either party may contact the Custody Conciliator to schedule another Custody Conciliation Conference. In light of the father residing in North Carolina, this Conciliation Conference may be scheduled with .,," ~ a telephone conference between legal counsel and the Conciliator. Judge Edward E. Guido cc: Leslie Tomeo, Esquire Jessica Holst, Esquire ~ ~ ;2~()~-o1 ~ F:\FILESIDATAFILEIGenera1\CurrentI12321IGarza v Hollinger report and order I " .71 lid I::" .(., vV 8- fEU LDOZ . " ~. JOSEPH PHILIP GARZA, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v CIVIL ACTION - LAW TIFFANY DENISE HOLLINGER, Defendant NO. 03-3522 IN CUSTODY Prior Judge: Edward E. Guido 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 pertinent information pertaining to the children who are the subject of this litigation is as follows: Yuri Dylan Hollinger, born March16, 1999, Cole Joseph Hollinger, born July 1, 2002 and Nathaniel Rain Hollinger, born July 1, 2002. 2. A Conciliation Conference was held on February 1, 2007, with the following individuals in attendance: The father, Joseph Philip Garza, with his counsel, Leslie Tomeo, Esquire and the mother, Tiffany Denise Hollinger, with her counsel, Jessica Holst, Esquire. 3. The parties agree to the entry of an Order in the form as attached. DATE: February 5, 2007