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HomeMy WebLinkAbout07-2123Elizabeth A. Hoffman, Esquire 106 Walnut Street Harrisburg, PA 17101 (717) 236-2956 RYAN A. LOPEZ, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-d-(Xa aad tcrti ALICIA LOPEZ, ACTION IN CUSTODY Defendant : COMPLAINT IN CUSTODY 1. Plaintiff is Ryan A. Lopez ("Father"), an adult individual whose current mailing address is 2 Fetrow Drive, Mechanicsburg (Cumberland County), Pennsylvania 17050. 2. Defendant is Alicia Lopez ("Mother"), an adult individual whose current mailing address is 308 Tichy Drive, Mt. Holly Springs (Cumberland County), Pennsylvania 17065. 3. Mother and Father are the natural parents of the following minor child: Chloe Lee Lopez DOB 6/11/2003 4. The minor child has lived in the following locations with the following persons since her birth: Residence 308 Tichy Drive Mt. Holly Springs, PA Carlisle, PA Persons in residence Dates Mother, maternal grandparents 7/05 - present Father and Mother 6/04 -7/05 Gardner, PA Father and Mother Birth - 6/04 5. There is no custody order in this case. 6. Father does not know of a person not a party to the proceedings concerning the child who has custody of the child or who claims to have custody or visitation rights to the child. 7. Father seeks primary custody of the minor child because, for the following reasons, it is in her best interests and welfare: (1) Until recently, Father and Mother have followed a schedule wherein Father has custody of the child on alternating weekends from Friday to Sunday evening and one overnight during the week. However, Mother has lately threatened to withhold the visitations unless Father complies with her unreasonable demands. Therefore, Father believes that Mother will not continue to promote a relationship between him and the child whereas he would ensure that the child has consistent visitation with Mother. (2) Mother has stopped sending the child to day care but has not provided a reason for doing so. Father believes that the child benefits from socializing with other children her age. (3) Mother's current unreasonable behavior is not in the child's best interests. WHEREFORE, it is respectfully requested that this Honorable Court enter an order which grants Father primary physical custody and Mother partial custody, and gives the parties shared legal custody. Respectfully submitted, Eliza th A. Hoffman, squire Attorney for Plaintiff 106 Walnut Street Harrisburg, PA 17101 (717) 236-2956 1 D #71000 VERIFICATION I verify that the information provided in the attached document is true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Date: 3?15?07 I?L 1?1. Rya . Lopez CERTIFICATE OF SERVICE I, Elizabeth A. Hoffman, Esquire, do hereby certify that a true and correct copy of the attached complaint will be sent by U.S. mail to the following person pursuant to the procedures in the Cumberland County Prothonotary's Office: Alicia Lopez 308 Tichy Drive Mt. Holly Springs, PA 17065 Date: 4EIiz //? 07 Zath A. Hoffma Esquire Attorney for Plaintiff 106 Walnut Street Harrisburg, PA 17101 (717) 236-2956 1 D #71000 -_ tom, c4? - 'tom f7'??T ILA - • J `17 `-? ` R ?L RYAN A. LOPEZ IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ALICIA LOPEZ DEFENDANT 07-2123 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, April 20, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, May 18, 2007 at 3:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. 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/ John j Mangan, jr., Esg V Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 r VA --),wXwW -?v _.2p 7, ?'v"' ' La lrP•h 80 :ZI Wd ?Z Hdn [OOZ 'OH -1 A-?MH SEP 2 8 2007 ,off RYAN A. LOPEZ, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 07-2123 CIVIL ACTION LAW ALICIA LOPEZ, IN CUSTODY Defendant ORDER OF COURT AND NOW this S" day of 0 CA V(-, 2007, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: The Father, Ryan Lopez, and the Mother, Alicia Lopez, shall have shared legal custody of Chloe Lopez, date of birth 6/11/03. The parties shall have an equal right to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. The Mother shall enjoy primary physical custody of Chloe Lopez, date of birth 6/11/03. 3. The Father shall have periods of partial physical custody with Chloe Lopez every Wednesday from 5:45 pm until Thursday 8:00 am, and every other weekend from Friday 5:45 pm until Sunday 6:00 pm and such other times as the parties may mutually agree. The exchange location shall be at the Carlisle Early Education Center, however, when the Child is not in day care, the exchange location shall be at the Boiling Springs Post Office. 4. Holidays: Major holidays with the Child shall be alternated between the parents as attached. Father's custodial time with the Child shall begin July 4 h, 2007 with the holidays to be alternated thereafter. It is understood that Mother always has Mother's Day and Father always has Father's Day. 5. Each parent is entitled to at least one week of vacation when the Child is not in school for summer. The parent desiring said vacation time is directed to furnish the other parent with a least one week notice of the planned custodial time. 6. Telephone contact between the Child and the non-custodial parent shall be liberal as agreed upon between the parties. It is directed that both parents shall communicate with one another regarding the custody matter and to not involve the Child in said communications. 7. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other party, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties disparage the other v parent in the presence of the Child. 8. In the event of a medical emergency, the custodial party shall notify the other parties as soon as practicable after the emergency is handled. 9. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. J. Distribution: ,,,Xlizabeth Hoffman, Esquir V8'amuel Andes, Esquire ,John J. Mangan, Esquire S Z .V H,d I -1 "10 LGOZ -]'A 2 HOLIDAYS AND TIlVli';S EVEN ODD SPECIAL DAYS YEARS YEARS Easter Day From 6 pm the evening before the Mother Father holiday to 6 pm the day of the holiday Memorial Day From 6 pm the evening before the Father Mother holiday to 6 pm the day of the holiday Independence Day From 6 pm the evening before the Mother Father holiday to6 m the day of the holiday Labor Day From 6 pm the evening before the Father Mother holiday to 6 pm the day of the holiday Thanksgiving 0 From 6 pm the evening before Mother Mother Half Thanksgiving Day to 3 pm on Thanks ivin Da Thanksgiving 2" From 3 pm on Thanksgiving Day to Mother Father half 6 m the day after Thanksgiving Da Christmas 1 S Half From noon on 12/24 to noon on Father Father 12/25 Christmas 2° Half From noon on 12/25 to noon on Mother Mother 12/26 Mother's Day From 6 pm the evening before the Mother Mother holiday to 6 pm the day of the holiday Father's Day From 6 pm the evening before the Father Father holiday to 6 pm the day of the holiday RYAN A. LOPEZ, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 07-2123 CIVIL ACTION LAW ALICIA LOPEZ, IN CUSTODY Defendant CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL, PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Child who is the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Chloe L. Lopez 6/11/03 Mother 2. A Conciliation Conference was held with regard to this matter on 6/18/07 with the following individuals in attendance: The Father, Ryan Lopez, with his counsel, Elizabeth Hoffinan, Esquire The Mother, Alicia Lopez, with her counsel, Samuel Andes, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. (Z? - Date Jo J. angan, Esqu' Custody Conciliator Elizabeth A. Hoffman, Esquire 106 Walnut Street Harrisburg, PA 17101 (717) 236-2956 RYAN A. LOPEZ, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-2123- CIVIL ACTION ALICIA LOPEZ, ACTION IN CUSTODY Defendant PETITION FOR MODIFICATION OF CUSTODY ORDER Plaintiff/Petitioner is Ryan A. Lopez ("Father"), an adult individual whose current mailing address is 2 Fetrow Drive, Mechanicsburg (Cumberland County), Pennsylvania 17050. 2. Defendant/Respondent is Alicia Lopez ("Mother"), an adult individual whose current mailing address is 308 Tichy Drive, Mt. Holly Springs (Cumberland County), Pennsylvania 17065. 3. Mother and Father are the natural parents of the following minor child: Chloe Lee Lopez DOB 6/11/2003 4. On October 1, 2007, a custody order was entered by this Honorable Court which granted primary physical custody to Mother and partial physical custody to Father. (Order attached). 5. Father does not know of a person not a party to the proceedings concerning the child who has custody of the child or who claims to have custody or visitation rights to the child. 6. Father seeks a modification of the current order wherein he shall receive primary physical custody for the following reasons: (1) Mother has not been providing a stable home for the minor child. (2) Several weeks ago Mother did not show up to pick up the minor child and did not call to say where she was for almost a full day. (3) Recently, Father and Mother had agreed that the minor child would be better off going to school in the district where Father resides, and now Mother has changed her mind. (4) Mother's current unreasonable behavior is not in the child's best interests. WHEREFORE, it is respectfully requested that this Honorable Court enter an order which modifies the current order by granting Father primary physical custody and Mother partial custody of the minor child. Respectfully submitted, 4. 44,? Eliza th A. Hoffman Jltsqu Attorney for Plaintiff/Petitioner 106 Walnut Street Harrisburg, PA 17101 (717) 236-2956 1 D #71000 RYAN A. LOPEZ, Plaintiff V. ALICIA LOPEZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 07-2123 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW this 1 S" day of Cdr , 2007, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. The Father, Ryan Lopez, and the Mother, Alicia Lopez, shall have shared legal custody of Chloe Lopez, date of birth 6/11/03. The parties shall have an equal right to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. The Mother shall enjoy primary physical custody of Chloe Lopez, date of birth 6/11/03. 3. The Father shall have periods of partial physical custody with Chloe Lopez every Wednesday from 5:45 pm until Thursday 8:00 am, and every other weekend from Friday 5:45 pm until Sunday 6:00 pm and such other times as the parties may mutually agree. The exchange location shall be at the Carlisle Early Education Center, however, when the Child is not in day care, the exchange location shall be at the Boiling Springs Post Office. 4. Holidays: Major holidays with the Child shall_ be alternated between the parents as attached. Father's custodial time with the Child shall begin July 4th, 2007 with the holidays to be alternated thereafter. It is understood that Mother always has Mother's Day and Father always has Father's Day. 5. Each parent is entitled to at least one week of vacation when the Child is not in school for summer. The parent desiring said vacation time is directed to furnish the other parent with a least one week notice of the planned custodial time. 6. Telephone contact between the Child and the non-custodial parent shall be liberal as agreed upon between the parties. It is directed that both parents shall communicate with one another regarding the custody matter and to not involve the Child in said communications. 7. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other parry, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties disparage the other 0 parent in the presence of the Child. 8. In the event of a medical emergency, the custodial party shall notify the other parties as soon as practicable after the emergency is handled. 9. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. J. Distribution: Elizabeth Hoffman, Esquire Samuel Andes, Esquire John J. Mangan, Esquire ,T j vuf ?d a seal of a3•d Th . • i 0 ?*A ' ECORD and y-.o Lu;?o set nY d 8t, r 3E 2 li. HOLIDAYS AND TIMES EVEN ODD SPECIAL DAYS YEARS YEARS Easter Day From 6 pm the evening before the Mother Father holiday to 6 pm the day of the holiday Memorial Day From 6 pm the evening before the Father Mother holiday to 6 pm the day of the holiday Independence Day From 6 pm the evening before the Mother Father holiday to6 pm the day of the holiday Labor Day From 6 pm the evening before the Father Mother holiday to 6 pm the day of the holiday Thanksgiving 1St From 6 pm the evening before Mother Mother Half Thanksgiving Day to 3 pm on Thanksgiving Day Thanksgiving 2n From 3 pm on Thanksgiving Day to Mother Father half 6 m the day after Thanksgiving Day Christmas 1St Half From noon on 12/24 to noon on Father Father 12/25 Christmas 2n Half From noon on 12/25 to noon on Mother Mother 12/26 Mother's Day From 6 pm the evening before the Mother Mother holiday to 6 pm the day of the holiday Father's Day From 6 pm the evening before the Father Father holiday to 6 pm the day of the holiday RYAN A. LOPEZ, : Plaintiff V. ; ALICIA LOPEZ, : Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 07-2123 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Child who is the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Chloe L. Lopez 6/11/03 Mother 2. A Conciliation Conference was held with regard to this matter on 6/18/07 with the following individuals in attendance: The Father, Ryan Lopez, with his counsel, Elizabeth Hoffman, Esquire The Mother, Alicia Lopez, with her counsel, Samuel Andes, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. Date Jo 61?41a&ngan,?Esqu' Custody Conciliator VERIFICATION I verify that the information provided in the attached document is true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Date: vs- Ryan Lo CERTIFICATE OF SERVICE I, Elizabeth A. Hoffman, Esquire, do hereby certify that a true and correct copy of the attached Petition will be sent by U.S. mail to the following person pursuant to the procedures in the Cumberland County Prothonotary's Office: Samuel Andes, Esquire 525 N. 12th Street P.O. Box 168 Lemoyne, PA 17043 Alicia Lopez 308 Tichy Drive Mt. Holly Springs, PA 17065 Date: ?3 Q ?v d. Eliz ?th A. Hoffmajis qu ire JAttorney for Plaintiff 106 Walnut Street Harrisburg, PA 17101 (717) 236-2956 1 D #71000 RYAN A. LOPEZ IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ALICIA LOPEZ DEFENDANT 2007-2123 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, May 22, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, June 25, 2008 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 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/ ohn .Man an r. Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 to ^-Iwb RYAN A. LOPEZ, Plaintiff V. ALICIA LOPEZ, Defendant Prior Judge: Edward E. Guido, J. UN ao2oo? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 07-2123 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW this34y of July 2008, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: v This Order is entered pursuant to a Custody Conciliation Conference. ustody Hearing is hereby scheduled on the /31 day of/2008 at/0 ?.3 ivfpw in Courtroom number .14A_ in the Cumberland County Court of Common Pleas, Carlisle, PA 17013 at which time testimony will be taken. For purposes of this hearing, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least five days prior to the hearing date. 2. The Order of Court dated October 1, 2007 shall remain in full force and effect absent mutual agreement or further Order of Court. 3. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. The parties may mutually cancel the scheduled court hearing and request this matter to be rescheduled before the assigned conciliator if the circumstances deem an update conciliation necessary or proper. Distribution: 60 Aizabeth Hoffinan, Esquire uel Andes, Esquire J. Mangan, Esquire J 3 ?Ml ,tM RYAN A. LOPEZ, Plaintiff V. ALICIA LOPEZ, Defendant Prior Judge: Edward E. Guido, J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 07-2123 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the Child who is the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Chloe L. Lopez 6/11/03 Primary Mother 2. A prior Order of Court was issued October 1, 2007 and a Conciliation Conference was held with regard to this matter on 6/25/08 with the following individuals in attendance: The Father, Ryan Lopez, with his counsel, Elizabeth Hoffman, Esquire The Mother, Alicia Lopez, with her counsel, Samuel Andes, Esquire. 3. Mother's position is that she requests that the status quo remain in place with Mother having primary custody. Mother currently lives in Mount Holly Springs and is in the Carlisle School District. There is a possibility that Mother may be moving into another school district. Mother alleges that Chloe is doing very well now. Mother is employed and mainly works nights. Mother resides with her parents Mother cares for Chloe during the day. Mother acknowledges that she has had some anxiety issues that necessitated medical attention. Mother acknowledges that she has discussed the possibility of Chloe going into Father's school district but currently feels that Chloe should primarily live with her and that Mother is able to provide a stable environment. 4. Father's position is that he desires primary custody of Chloe and wants her to attend school in the Cumberland Valley School District. Father alleges that Mother is not stable in her residence and takes Chloe overnight without informing him of Chloe's whereabouts. Father requests that Chloe reside with him Monday through Friday and Mother would have every weekend. Father resides with the Child's grandfather in Mechanicsburg and that the Child's aunt lives next door with her children approximately the same age as Chloe. Father alleges that he is in a better position to offer Chloe a stable environment. 0 5. The Conciliator recommends an Order in the form as attached scheduling a Hearing before the Court. It is the Conciliator's belief that this would be in the Child's best interest. It is expected that the Hearing will require half a day. 6. The proposed recommended Order may contain a requirement that the parties file a pre- trial memorandum with the Judge to whom the matter has been assigned. ?2, s<6?-16 Date John J. an, Esquire Custo C ciliator RYAN A. LOPEZ, VS. ALICIA LOPEZ, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-2123 CIVIL TERM CIVIL ACTION - LAW MOTION FOR CONTINUANCE AND NOW comes the above-named Defendant, by her attorney, Samuel L. Andes, and moves the court to continue and reschedule the hearing now set for 13 August 2008, based upon the following: 1. This action was the subject of a conciliation conference on 28 June 2008 on the Plaintiff s petition to modify the custody order entered in 2007. 2. The parties were not able to resolve the matter at the conciliation conference and so the matter was forwarded to the chambers of the Honorable Edward E. Guido, to schedule a hearing. 3. Judge Guido's chambers contacted counsel for Defendant to obtain a date clear on his calendar when the hearing could be held. During the conversations regarding scheduling, Defendant's counsel mistakenly advised Judge Guido's secretary that his schedule was clear after 10 a.m. on Wednesday, 13 August 2008. 4. As it turns out, Defendant's counsel is scheduled to appear in another custody action, before the Honorable Skip Ebert, at 9:30 a.m. on Wednesday, 13 August 2008. That matter, which Judge Ebert has scheduled for a full day, has been scheduled for several months. 5. As a result of the mistake of Defendant's counsel, he is not available for a hearing in this matter on 13 August 2008 and respectfully requests that the matter be continued and scheduled for another time. 6. Defendant's counsel has provided Plaintiff's counsel with a copy of this motion and has requested that she express her concurrence or opposition to this request but, as of this time, has not heard from Plaintiff's counsel in response. WHEREFORE, Defendant moves this Court to reschedule the hearing now set for 13 August 2008. Samuel L. Andes Attorney for Defendant Supreme Court ID 17225 P.O. Box 168 Lemoyne, PA 17043 (717) 761-5361 I verify that the statements made in this document are true and correct. I understand that any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). t DATE: t Samue L. Andes CERTIFICATE OF SERVICE I hereby certify that on l U cJ? 2008, I served a copy of the foregoing document upon counsel for Plaintiff by U.S. Mail, pos ge prepaid, addressed as follows: Elizabeth A. Hoffinan, Esquire 106 Walnut Street Harrisburg, PA 17101 Samuel L. Andes Attorney for Defendant Supreme Court ID 17225 P.O. Box 168 Lemoyne, PA 17043 (717) 761-5361 rv jrn JUL 10 2008 RYAN A. LOPEZ, ) Plaintiff ) VS. ) ALICIA LOPEZ, ) Defendant ) ORDER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-2123 CIVIL TERM CIVIL ACTION - LAW AND NOW this /Y -64 day of d a /! 2008, upon consideration of the attached motion, the hearing previously scheduled for August 13, 2008 is hereby continued. It will now be held, before the undersigned, on the //?( day of , 2008, commencing at .o'clock / Om., in Court Room No. 3 of the Cumberland County Court House. The other provisions of our order of July 3, 2008, shall remain in full force and effect. ' DIY THE CO T, DISTRIBUTION: lizabeth A. Hoffman, Attorney for Plaintiff, 106 Walnut Street, Harrisburg, PA 17101 Samuel L. Andes, Attorney for Defendant, P.O. Box 168, Lemoyne, PA 17043 C? J. ?Z =8 WV ZZ Inr BOOZ IrtlbluNU i Odd 3Hi --lo KN-l,c.-C.ITY RYAN A. LOPEZ, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-2123 CIVIL TERM ALICIA LOPEZ, Defendant IN CUSTODY ORDER OF COURT AND NOW, this 11th day of August, 2008, after hearing, the petition to modify our prior order is DENIED. Our Order of October 1, 2007, shall remain in full force and effect. Edward E. Guido, J. 4.9flizabeth A. Hoffman, Esquire ` For the Plaintiff ?Samuel L. Andes, Esquire For the Defendant V o srs N 0 AE N _ n z t? U Ryan A. Lopez PlaintifF/Petitioner V. Alicia Lopez Defendant/Respondent IN THE COURT OF COMMON PLEAS Dauphin COUNTY, PENNSYLVANIA NO. 07-2123 Civil Term o c' 4 CIVIL ACTION - LAW ' a IN CUSTODY r-?C y PETITION TO MODIFY CUSTODY NOW COMES Petitioner, Ryan A. Lopez, and respectfully petitiojt yo r Honorable Court for special relief and award Petitioner primary physical custody, and for reasons therefore states: 1. Petitioner is Ryan A. Lopez (hereinafter "Father"). 2. Respondent is Alicia Lopez (hereinafter "Mother"). 3. The parties are the parents of the minor child, Chloe Lee Lopez, DOB 6/11/2003. 4. On October 1, 2007, an Order of Court for Custody in the above entitled action was entered (See attached Exhibit A - October 1, 2007, Order of Court). 5. After numerous unexcused absences from school, Carlisle School District filed for Truancy with the local District Justice. The mother did not attend the first hearing without notification to the District Justice Office. The mother showed up at the rescheduled hearing. 6. On or about January 15, 2010, Children and Youth Services made an unscheduled visit to the Respondent's home. Petitioner was contacted by Shilo Haggarty of Children and Youth Services for assistance because Respondent was not answering the door. Ms. Haggary had visual and audible confirmation"t?ta4t rhfrroi was inside the home but also would not answer the i rno door. 'g E?'?1 L ! 83.?QIOZ t? -n r? t 70,00 f/• 4 M.o J-275 0,?- i? 6s 13 7. Children and Youth Services set up a safety plan for the Respondent and minor child. The safety plan included 24 hour supervision by a third party, originally to be the child's grandmother. 8. Respondent and her mother were unable to guarantee that respondent would not be alone with the child without interfering with the current living situation and grandmother's work schedule. Temporary custody for the Petitioner was offered as an alternative. 9. On or about January 19, 2009, Shilo Haggarty contacted the Petitioner and he was asked to assume temporary physical custody of the minor child for a period of not less than 2 weeks, to be extended as needed, until the respondent's situation could be re-evaluated. 10. The minor child has since been enrolled in Cumberland Valley School District and has been attending school regularly while in the Petitioner's care. 11. Your Honorable Court has the authority to grant the relief requested herein. WHEREFORE, pursuant to Pa. R.C.P. 1915.13, Father respectfully requests your Honorable Court to: 1) Modify the court order to reflect a change in weekend custodial periods. Respectfully submitted, Q. y: yan 4 Lopez VERIFICATION I verify that the statements made in the attached Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DATE: g-Jol /I ( / ?,, , a, 'e Z Ryan 4?A Lopez Exl?,bk 1 S? 2007 go/ RYAN A. LOPEZ, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 07-2123 CIVIL ACTION LAW ALICIA LOPEZ, IN CUSTODY Defendant ORDER OF COURT AND NOW this s" day of d C!(j , 2007, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. The Father, Ryan Lopez, and the Mother, Alicia Lopez, shall have shared legal custody of Chloe Lopez, date,of birth 6/11/03. The parties shall have an equal right to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. The Mother shall enjoy primary physical custody of Chloe Lopez, date of birth 6/11/03. 3. The Father shall have periods of partial physical custody with Chloe Lopez every Wednesday from 5:45 pm until Thursday 8:00 am, and every other weekend from Friday 5:45 pm until Sunday 6:00 pm and such other times as the parties may mutually agree. The exchange location shall be at the Carlisle Early Education Center, however, when the Child is not in day care, the exchange location shall be at the Boiling Springs Post Office. 4. Holidays: Major holidays with the Child shall be alternated between the parents as attached. Father's custodial time with the Child shall begin July 0, 2007 with the holidays to be alternated thereafter. It is understood that Mother always has Mother's Day and Father always has Father's Day. 5. Each parent is entitled to at least one week of vacation when the Child is not in school for summer. The parent desiring said vacation time is directed to finish the other parent with a least one week notice of the planned custodial time. 6. Telephone contact between the Child and the non-custodial parent shall be liberal as agreed upon between the parties. It is directed that both parents shall communicate with one another regarding the custody matter and to not involve the Child in said communications. 7. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other party, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties disparage the other parent in the presence of the Child. In the event of a medical emergency, the custodial party shall notify the other parties as soon as practicable after the emergency is handled. 9. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. J. Distribution: Elizabeth Hoffinan, Esquire Samuel Andes, Esquire John J. Mangan, Esquire CORD TRUE COPv FR ' set my and imori;r ?v4?er?cf, ! tiere unto set my in I 'st Ta• r and a seal of said. C '?rt 4 HOLIDAYS AND TIlVIES EVEN ODD SPECIAL DAYS YEARS YEARS Easter Day From 6 pm the evening before the Mother Father holiday to 6 pm the day of the holiday Memorial Day From 6 pm the evening before the Father Mother holiday to 6 pm the day of the holiday Independence Day From 6 pm the evening before the Mother Father .holiday to6 m the day of the holiday Labor Day From 6 pm the evening before the Father Mother holiday to 6 pm the day of the holiday Thanksgiving 1 From 6 pm the evening before Mother Mother Half Thanksgiving Day to 3 pm on Thanksgiving Da Thanksgiving 2n From 3 pm on Thanksgiving Day to Mother Father half 6 m the day after Thanksgiving Da Christmas 1 Half From noon on 12/24 to noon on Father Father 12/25 Christmas 2" Half From noon on 12/25 to noon on Mother Mother 12/26 Mother's Day From 6 pm the evening before the Mother Mother holiday to 6 pm the day of the holiday Father's Day From 6 pm the evening before the Father Father holiday to 6 pm the day of the holiday CERTIFICATE OF SERVICE I, Ryan A. Lopez, do hereby certify that a true and correct copy of the attached complaint will be sent by U.S. mail to the following person(s) pursuant to the procedures in the Cumberland County Prothonotary's Office: Samuel Andes, Esquire 525 N. 12th Street P.O. Box 168 Lemoyne, PA 17043 Alicia Lopez 105 E. High Street Carlisle, PA 17013 Date: 911 `7/10 yan A. Lopez e RYAN A. LOPEZ IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2007-2123 CIVIL ACTION LAW ALICIA LOPEZ IN CUSTODY DI I:.NDANT ORDER OF COURT AND NOW, Friday, February 19, 2010 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland Coup Courthouse, Carlisle on Monday, March 29, 2010 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 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/ ohn .Man an r. Es Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 (T TH7 2e10FES 26 r`'.'? i : 38 APR 2 0 Z??u 3 C2 RYAN A. LOPEZ, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 07-2123 CIVIL ACTION LAW IN CUSTODY o' ALICIA LOPEZ, Defendant=' ter, ?_ .: -v Prior Judge: Edward E. Guido, J.' N_ TEMPORARY ORDER OF COURT AND NOW this ,17 day of April 2010, upon consideration of the attached Cindy Z Conciliation Report, it is Ordered and Directed as follows: All prior Orders of Court entered in this matter are hereby VACATED and replaced with the instant Order. 2. This Order is entered pursuant o a Custody Conciliatiojl ,Conference. A Custody Hearing is hereby scheduled on the aL day c*WOO at TA amAft in Courtroom number 3 in the Cumberland County Court of Common Pleas, Carlisle, PA 17013 at which time testimony will be taken. For purposes of this hearing, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least five days prior to the hearing date. 3. Legal Custodv: The Father, Ryan Lopez, and the Mother, Alicia Lopez, shall have shared legal custody of Chloe Lopez, date of birth 6/11/03. The parties shall have an equal right to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 4. Physical Custody: The parents shall share physical custody on a 2/2/3 schedule as follows: In week one, Father shall have physical custody Monday and Tuesday overnight, Mother has Wednesday and Thursday overnight and Father has Friday through Monday morning. In week two, Mother shall have physical custody Monday and Tuesday overnight, Father has Wednesday and Thursday overnight and Mother has Friday through Monday morning. Each parent shall be responsible for transporting Chloe to school during their custodial periods. The custodial arrangement pursuant to this paragraph shall not prejudice either parent if a custody hearing is conducted. 5. Holidays: Major holidays with the Child shall be alternated between the parents as attached in the absence of agreement otherwise. 6. The non-custodial parent shall have liberal telephone contact with the Child on a reasonable basis. 7. Each parent shall have one week of vacation with the Child during her summer vacation. The requesting parent shall give the other parent 30 days advance notice of the requested time and this vacation week shall supersede the regular physical custody schedule. In the event the parties schedule conflicting vacations, the party first providing written notice shall have the choice of vacation. Prior to departure, the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. 8. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other party, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Child. 9. In the event of a medical emergency, the custodial party shall notify the other pary as soon as possible after the emergency is handled. 10. A status conference with the assigned conciliator is hereby scheduled for June 22, 2010 at 10.30 am at the Court of Common Pleas, Carlisle, PA. 11. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. B e Court, J. D' tribution: an Lopez, 2 Fetrow Dr., Mechanicsburg, PA 17050 ::?Ztacy Wolf, Esquire ,,4'ohn J. Mangan, Esquire `mi'l, HOLIDAYS AND TIMES EVEN ODD SPECIAL DAYS YEARS YEARS Easter Day From 6 pm the evening before the Mother Father holiday to 6 pm the day of the holiday Memorial Day From 6 pm the evening before the Father Mother holiday to 6 pm the day of the holiday Independence Day From 6 pm the evening before the Mother Father holiday to 6 pm the day of the holiday Labor Day From 6 pm the evening before the Father Mother holiday to 6 pm the day of the holiday Thanksgiving 1" From 6 pm the evening before Mother Father Half Thanksgiving Day to 3 pm on Thanksgiving Da Thanksgiving 2n From 3 pm on Thanksgiving Day to Father Mother half 6 m the day after Thanksgiving Da Christmas 1St Half From noon on 12/24 to noon on Father Father 12/25 Christmas 2° Half From noon on 12/25 to noon on Mother Mother 12/26 Mother's Day From 6 pm the evening before the Mother Mother holiday to 6 pm the day of the holiday Father's Day From 6 pm the evening before the Father Father holiday to 6 pm the day of the holiday RYAN A. LOPEZ, Plaintiff V. ALICIA LOPEZ, Defendant Prior Judge: Edward E. Guido, J. IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the Child who is the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Chloe L. Lopez 6/11/03 Primary Father 2. A prior Order of Court was issued October 1, 2007, a Conciliation Conference was held with regard to'this matter on 6/25/08, an Order issued 07/03/08, a hearing was held 08/11/2008 and an Order issued denying Father's petition to modify and a conciliation conference was held April 06, 2010 with the following individuals in attendance: The Father, Ryan Lopez, appeared by himself The Mother, Alicia Lopez, with her counsel, Stacy Wolf, Esquire. 3. Mother's position is that she requests that the previous Order of Court dated October 01, 2007 remain in place, whereby Mother has primary physical custody. Mother currently resides in Carlisle by herself. Mother acknowledges that when she had primary custody of Chloe, there had been school attendance issues. Mother further acknowledges that Mother had some mental health issues and some problems with her medication up until January 2010. Mother asserts that she had medication check ups since January whereby her medication has been altered. As such, Mother indicates that she is functioning much better now and desires expanded time with Chloe. Mother indicates that her custodial periods with Chloe are now unsupervised as of the end of March 2010. Mother notes that the Child attends River Rock Academy. When Mother had primary custody, Carlisle School District was funding the Academy and a van/bus would pick Chloe up from her residence. Now since Father has had primary physical custody, Cumberland Valley is funding the Academy and a bus/van will not pick the Child up from her residence. Mother indicates that Father lives in close proximity to River Rock and it would be more convenient for Father to drop the Child off at school when he has custody and to transfer the Child back into Carlisle School District so that the van/bus would pick Chloe up from her residence. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 07-2123 CIVIL ACTION LAW 4. Father's position is that he desires continued primary custody of Chloe and wants her to legally attend the Cumberland Valley School District. However, Father was willing to discuss with Mother the possibility/logistics of transferring the Child back to Carlisle School District. Father is not pleased that Chloe had significant attendance issues when the Child was in Mother's primary care. Additionally, Father indicates that the Child also had behavioral issues in and out of school when the Child was primarily with Mother. Father indicates that the Mother still is not emotionally/mentally stable. Father indicates that there was some Cumberland County Children and Youth involvement in regard to Mother's care of Chloe at the end of January 2010. As part of an agreed upon safety plan, Father gained primary custody of Chloe and Mother had periods of supervised contact with the Child. Father indicates that since he has had primary custody of Chloe, the Child has been attending school on a consistent basis and that Chloe's behavior has overall improved. Father indicates that he had made arrangements for the Child to engage in therapy through Beech Street Counseling, but that Chloe is not currently in therapy. Father alleges that he is in a better position to offer Chloe a stable environment. Father indicates that he desires a custody hearing before this Honorable Court but that he would be willing to agree to a temporary Order until trial whereby the parents will attempt to share physical custody on a 2/2/3 basis. Father would like it noted that this agreed upon shared arrangement is not the status quo prior to the conciliation conference and should not prejudice his custodial position if a hearing is necessary. Both parties agreed to a status conference in June 2010 prior to the scheduled hearing in order to ascertain whether the hearing is necessary. 5. The Conciliator recommends an Order in the form as attached scheduling a Hearing before the Court. It is the Conciliator's belief that this would be in the Child's best interest. It is expected that the Hearing will require half a day. 6. The proposed recommended Order may contain a requirement that the parties file a pre- trial memorandum with the Judge to whom the matter has been assigned. Date John . M gan, Esquire Cust y Conciliator f 1i-'? J.?{?F -{VC OF THE P, ,.) f-I-110TAPY STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 2010 MAY 17 AM 10: 11 (717) 241 4436 ATTORNEY FOR DEFENDANT C fsj W.t? r `d 6"JUNTY O A1hkO I i1AN0A RYAN A. LOPEZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW ALICIA LOPEZ, : NO. 07-2123 CIVIL TERM Defendant : IN CUSTODY PETITION FOR LEAVE TO WITHDRAW AS COUNSEL FOR DEFENDANT ALICIA LOPEZ NOW COMES counsel of record for the defendant, Alicia Lopez, Stacy B. Wolf, Esquire, and respectfully submits this Petition for Leave of Court to Withdraw as Counsel for the defendant, Alicia Lopez, pursuant to Pa.R.C.P. 1012, and in support thereof, avers as follows: 1. Defendant, Alicia Lopez, is an adult individual who resides at 105 East High St., Carlisle, Pennsylvania 17013. 2. The undersigned was retained by the defendant on or about March 31, 2010. 3. On April 6, 2010, the undersigned attended a custody conciliation conference with Defendant. 4. A status conference is scheduled for June 22, 2010 at 10:30 a.m. as well as a hearing before the Honorable Edward E. Guido on July 28, 2010 at 9:30 a.m. 5. On or about April 8, 2010 a check for representation at the April 6, 2010 conciliation was returned from the defendant's bank for insufficient funds. 6. Petitioner has tried to contact Defendant numerous times by telephone and also by mail. 7. Defendant has not returned phone calls or responded to mail, has not appeared in Petitioner's office and has not made good on the bad check or paid any additional fees for representation in connection with the upcoming status conference or the custody hearing. 8. Because Defendant has failed to compensate Petitioner for the bad check and the associated bank fee, has failed to provide counsel with any compensation for the next stage of representation, and has failed to communicate with counsel and provide information necessary to carry out the representation of Defendant in this matter, representation of Defendant would constitute an undue hardship on Petitioner. 9. Petitioner respectfully requests permission to withdraw as counsel for Defendant. 10. To Petitioner's knowledge, Plaintiff is not represented by counsel. WHEREFORE, the petitioner, Stacy B. Wolf, Esquire, respectfully prays that this Court grant leave for the undersigned to withdraw her representation of Defendant, Alicia Lopez, and to grant any further relief that the Court deems appropriate. Dated: May-17,2010 Respectfully submitted, WOLF & WOLF, Attorneys at Law By: A.SStaB If, Esquire 10 West igh Street Carlisle, PA 17013 Supreme Court I.D. No. 88732 (717) 241-4436 VERIFICATION I verify that the statements made in the foregoing Petition of Plaintiff's Counsel for Leave to Withdraw Appearance are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein may subject to me to the penalties of Pa.C.S. § 4904 relating to unsworn falsification to authorities. 7, Dated: May -IT, 2010 Stacy B. Wo "Isquirre STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR DEFENDANT RYAN A. LOPEZ, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. ALICIA LOPEZ, CIVIL ACTION -LAW Defendant : NO. 07-2123 CIVIL TERM : IN CUSTODY CERTIFICATE OF SERVICE I, Stacy B. Wolf, Esquire, hereby certify that I mailed a true and correct copy of the foregoing Petition for Leave to Withdraw as Counsel to the below-listed persons: Alicia A. Lopez 105 East High St. Carlisle, PA 17013 Dated: May 1-7, 2010 Ryan A. Lopez 2 Fetrow Drive Mechanicsburg, PA 17050 -7 -&/JZ Stacy B. off, Esquire(/ 0 MAY i d 2010 STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR DEFENDANT rr- Ct RYAN A. LOPEZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW ALICIA LOPEZ, : NO. 07-2123 CIVIL TERM Defendant : IN CUSTODY ORDER OF COURT AND NOW this day of /A V , 2010, upon consideration of the foregoing Petition for Leave to Withdraw as Counsel for Defendant, Alicia Lopez, the requested relief therein his hereby GRANTED and counsel is hereby authorized to file a praecipe to withdraw as counsel with the Prothonotary and to serve notice of this Order and such praecipe upon Defendant, Alicia Lopez and Plaintiff, Ryan A. Lopez, who is not represented by counsel. This Order shall in no way effect the scheduling of the status conference for June 22, 2010 at 10:30 a.m. or the custody hearing scheduled for July 28, 2010 at 9:30 a.m. before the undersigned in Courtroom 3 of the Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013. B 4ECOUR Edward E. Guido, J. D' tribut'on: Stacy B. Wolf, Esquire ./cyan A. Lopez, pro se ., ricia Lopez, pro se Court Ad iE& ministration S'??,v? IU RYAN A. LOPEZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA ~• :CIVIL ACTION -LAW ALICIA LOPEZ, : N0.07-2123 CIVIL TERM Defendaat : IN CUSTODY Praecine ~ _.._ ~, To the Prothonotary: a ~:-' r E;r~ {I (~? "L7 t"Y"T - ;-_ Q Kindly enter James A Miller, Esquire and the law firm of Miller Lipsitt LLC ~s`coun~l for Plaintiff, Ryan A Lopez ~. - ~ ~ (~- =: tt James A Mil ,Esquire PA ID 6 ~plar Church Road Camp Hill, PA 17011 (717) 73 7-6400 I hereby certify that on Tuesday, July 20, 2010, I forwarded a copy of this Praecipe to Defendant, Alicia Lopez, by United States First Class Mail to her last known address, Alicia A. Lopez 105 East High St. Carlisle, PA 17013 James filler, Esquire PA I 1352 7 oplar Church Road amp Hill, PA 17011 (717) 737-6400 RYAN A. LOPEZ, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 07-2123 CIVIL TERM ALICIA LOPEZ, Defendant IN CUSTODY ORDER OF COURT AND NOW, this 28th day of July, 2010, Paragraph 4 of our Order of June 23, 2010, is modified as follows: Physical Custody: The Father shall have primary physical custody of the Child subject to Mother's periods of partial custody as the parties may agree. Mother's periods of partial custody shall be supervised by her mother or some other person agreed to by the parties or Cumberland County Children and Youth Services. Said supervised visitation shall remain in effect until such time as Children and Youth Services would indicate otherwise or further Order of this Court. In the event that Mother is not satisfied with this provision, she may contact the assigned conciliator to schedule a conference. In all other respects, our Order of June 23, 2010, shall remain in full force and effect. B~ 'James A. Miller, Esquire For the Plaintiff Alicia A. Lopez 105 East High Street Carlisle, PA 17013 ~_ srs ~ ~'£,,~ t~~t ~ 2s~rv ~~ Edward E. Guido, J. ~~ J ,~.- ,._. na t/. ~C., ~ ~,_: -- :-: ,~~ ~ t,~