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HomeMy WebLinkAbout09-0554too:,; "4? BRETT A. GREEGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law :No. REBECCA L. GREEGER, Defendant IN DIVORCE and CUSTODY NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may also lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Streets, Carlisle. IF YOU SO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland Comity is required by law to comply with the Americans with Disabilities Act of 1990. For information about able 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. BRETT A. GREEGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law REBECCA L. GREEGER, Defendant IN DIVORCE and CUSTODY CO WLAINT UNDER SEMON.S' 33OUe) or 3311(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Brett A. Greeger, by and through his counsel, Michael J. Whare, Esquire and avers as follows: 1. Plaintiff is Brett A. Greeger, an adult individual, who currently resides at 120 Greenview Drive, Carlisle, Cumberland County, Pennsylvania 17015. 2. Defendant is Rebecca L. Greeger, an adult individual, who currently resides at 17 South Baltimore Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on February 17, 2007, in Enola, Cumberland County, Pennsylvania and separated on or about July 13, 2008. 5. There have been no prior actions of divorce or annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available, and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. COUNT 2 - CUSTODY 9. The previous paragraphs 1-8 are incorporated by reference. 10. Plaintiff seeks shared physical custody of the following children: Name Present residence DOB Bailey R. Greeger 17 S. Baltimore Ave. 07/14/2001 Mt. Holly Springs, PA 17065 Evan M. Greeger 17 S. Baltimore Ave. 07/17/2007 Mt. Holly Springs, PA 17065 11. One child was not born out of wedlock and one child was born out of wedlock. 12. The children are presently in the custody of Mother, who resides at 17 S. Baltimore Ave., Mt. Holly Springs, Pennsylvania 17065. 13. During the past five years, the children have resided with the following persons and at the following addresses: List all Persons List All Addresses Dates Brett Greeger, Rebecca Greeger, Garrett Greeger, Ashley Hudson Rebecca Greeger and Ashley Hudson 17 S. Baltimore Ave. Nov. 2004- July 13 2008 Mt. Holly Springs, PA 17065 17 S. Baltimore Ave. July 13, 2008- Present Mt. Holly Springs, PA 17065 14. The Mother of the children is Rebecca L. Greeger, who resides at 17 S. Baltimore Ave., Mt. Holly Springs, Cumberland County, Pennsylvania 17065. She is married to the Plaintiff. 15. The Father of the children is Brett A. Greeger, who resides at 120 Greenview Drive, Carlisle, Cumberland County, Pennsylvania 17015. He is married to the Defendant. 16. The relationship of plaintiff to children is that of Father. The Father currently resides with the following persons: Name Relationship Garrett Greeger Son Ray and Martha Greeger Parents Brad Greeger Brother 17. The relationship of defendant to children is that of Mother. The Mother currently resides with the following persons: Name Relationship Ashley Hudson Daughter Bailey R. Greeger Daughter Evan M. Greeger Son 18. 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 another court. 19. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 20. 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. 21. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children 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 children will be given notice of the pendency of this action and the right to intervene: Nam s Address Basis of Claim None 22. Reasons for granting relief A) A Court Order of custody and structured visitation is desired so that Plaintiff and children may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion. B) A Court ordered determination of custody is required to avoid continuing conflict between the parties regarding parental responsibility for custody and support. WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant his petition for shared physical custody of the children. ;7ri mi tted, Date: J - 3-Dq 1-./A Michael J. Whare, squire 3 7 East Pomfret Street Carlisle, PA 17013 Supreme Ct. Id No. 89028 Attorney for Plaintiff BRETT A. GREEGER : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law REBECCA L. GREEGER, Defendant : No. : IN DIVORCE and 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.C.S. & 4904 relating to unworn falsification to authorities. Date:o? ?3 Brett A. 6-uger, Plaintiff C co d ? C? o ^ e a n G C t BRETT A. GREEGER PLAINTIFF V. REBECCA L. GREEGER DEFENDANT IN THE COURT OF COMM(N PLEAS OF CUMBERLAND COUNTY, ENNSYLVANIA 2009-554 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Monday, February 09, 2009 upon consideratio of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacquelin M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, Mar h 10, 2009 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made t resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the co rt, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a tempo ary or permanent order. The court hereby directs the parties to furnish any and all existing Prote tion from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to se eduled hearing. FOR THE COURT, By: /s/ rueline M. Verne Custody Conciliator The Court of Common Pleas of Cumberland County is required by 1 with Disabilites Act of 1990. For informatiop about accessible facilities and rf available to disabled individuals having kisiness before the court, please cont? must be made at least 72 hours prior to any hearing or business before the coui conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPI 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 comply with the Americans onable accommodations our office. All arrangements You must attend the scheduled -E. IF YOU DO NOT E THE OFFICE SET • ?a? Gi/??jr?s?y?J ',Y/jM ?? 46P y £ S :I Wd 6- 833 6001 X Sd1U kl; f `: :j'Hi JO 11 MAR 1 6 2000 C) BRETT A. GREEGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 09-554 CIVIL ACTION LAW REBECCA L. GREEGER, IN CUSTODY Defendant ORDER OF COURT AND NOW this - day of March 2009, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. Legal Custody: The Father, Brett A. Greeger, and the Mother, Rebecca L. Greeger, shall have shared legal custody of Bailey R. Greeger, born 07/14/2001 and Evan M. Greeger, born 07/17/2007. The parties shall have an equal right to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their 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 Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children 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. Physical Custody: Mother and Father shall share physical custody of the Children on a repeating week on/ week off schedule as follows: a. Commencing 03/15/09, Mother shall have physical custody of the Children from Sunday 6:00 pm until Sunday 03/22/09 at 6:00 pm. Father shall then have physical custody of the Children from 03/22/09 at 6:00 pm until the following Sunday at 6:00 pm. The non-custodial parent shall pick up the Children from the custodial parent's residence. b. In the event Father determines that his health issues prevent him from adequately caring for the Children, Father shall immediately notify Mother to request assistance. C. The parents may alter the custodial schedule by mutual agreement as necessary or proper. 3. The custodial parent shall ensure that the Children attend any and all, within reason, of their extra-curricular/social activities when the Children are in his/her care. 4. The non-custodial parent shall have liberal telephone contact with the Children on a reasonable basis. 5. Holidays: The parents shall arrange the holiday schedule as attached unless otherwise mutually agreed upon. For Easter Sunday, whichever parent has the Children shall relinquish custody at 2:00 pm on Easter Sunday to the other parent. V .r 6. Each parent shall have two non-consecutive weeks of vacation with the Children per year. 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. 7. In the event the custodial parent should take the Children out of state, the custodial parent shall notify the non-custodial parent within twenty-four hours of departure of the intended destination and a telephone number at which they can be reached. 8. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 9. A status conference is hereby scheduled for April 30, 2009 at 9:00 am with the assigned conciliator at the Court of Common Pleas in Carlisle, PA 17013. 10. 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. By the Court, I dILL ? 7 istribution: 'chael Whare, Esq. Langan, 3reeger, 17 South Baltimore Ave., Mt. Holly Springs, PA 17065 ohn J. Esquire co ID I E r ry%a4 l L.? 3 12 /0 h I •C d L i SVW 60OZ rtbbiOri' i ? iC",?Ii d :J'Hi JO HOLIDAYS AND SEEC.IAL DAYS IDMS EVEN YEARS ODD YEARS Easter Da 1 Half From 9 am until 3 m Father Mother Easter Da 2° Half From 3 m until 9 m Mother Father Memorial Da From 9 am until 9 m Mother Father Independence Da From 9 am until 9 m Father Mother Labor Da From 9 am until 9 m Mother Father Halloween From one hour before trick or treating to one hour after trick or treating Father Mother Thanksgiving 1 Half From 8 am Thanksgiving Day to 2 m on Thanksgiving Da Father Mother Thanksgiving 2° half From 2 pm on Thanksgiving Day to noon the day after Thanksgiving Day I Mother Father Christmas 1 Half From noon on 12/24 to noon on 12/25 Father Mother Christmas 2 Half From noon on 12/25 to noon on 12/26 Mother Father New Year's From 6 pm 12/31 until noon January I" (with the 12/31 year to control the even/odd determination Mother Father Mother's Da From 9 am until 9 m Mother Mother Father's Da From 9 am until 9 m Father Father BRETT A. GREEGER, Plaintiff V. REBECCA L. GREEGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 09-554 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUbEK"Y REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CPAL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the Children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Bailey R. Greeger 07/14/2001 Shared Evan M. Greeger 07/17/2007 Shared 2. A Conciliation Conference was held with regard to this matter on March 10, 2009 with the following individuals in attendance: The Mother, Rebecca Greeger, pro se The Father, Brett Greeger, with his counsel, Michael Whare, Esq. 3. The parties agreed to the entry of an Order in the form as attached. Date John J an, Esquire Custo y C nciliator i APR 3 0 2009 G BRETT A. GREEGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 09-554 CIVIL ACTION LAW REBECCA L. GREEGER, IN CUSTODY Defendant Prior Judge: J. Wesley Oler, Jr., J. ORDER OF COURT AND NOW this .5 day of May 2009, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: I. All prior Orders entered in this matter are hereby VACATED and replaced with this Order. 2. Legal Custody: The Father, Brett A. Greeger, and the Mother, Rebecca L. Greeger, shall have shared legal custody of Bailey R. Greeger, born 07/14/2001 and Evan M. Greeger, born 07/17/2007. The parties shall have an equal right to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their 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 Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children 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. 3. Physical Custody: Mother and Father shall arrange physical custody of the Children as follows: a. Commencing 05/06/09, Father shall have physical custody of the Children from Wednesday 6:00 pm until Sunday 6:00 pm every other week b. Once the Child/ren are off for summer vacation, Father shall have physical custody of the Children from Wednesday 6:00 pm until Saturday 12:00 pm every week. C. The non-custodial parent shall pick up the Children from the custodial parent's residence. d. In the event Father determines that his health issues prevent him from adequately caring for the Children, Father shall immediately notify Mother to request assistance. e. The parents may alter the custodial schedule by mutual agreement as necessary or proper. 4. The custodial parent shall ensure that the Children attend any and all, within reason, of their extra-curricular/social activities when the Children are in his/her care. 5. The non-custodial parent shall have liberal telephone contact with the Children on a reasonable basis. 6. Holidays: The parents shall arrange the holiday schedule mutually agreed. In the absence of agreement, the parents shall follow the holiday schedule as attached. 7. Each parent shall have two non-consecutive weeks of vacation with the Children per year. 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. In the event the custodial parent should take the Children out of state, the custodial parent shall notify the non-custodial parent within twenty-four hours of departure of the intended destination and a telephone number at which they can be reached. 9. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 10. 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. tribution: 'chael Whare, Esq. becca Greeger, 17 South Baltimore Ave., Mt. Holly Springs, PA 17065 hn J. Mangan, Esquire ozrlies M W t3C V s???oq Rv the C mirt VINVA lN3d WI M Wd 9- AVW 6001 AWiOWHiOdd 3K -40 HOLIDAYS AND SPECIAL DAYS IDWS EVEN YEARS ODD YEARS Easter Da 16' Half From 9 am until 3 m Father Mother Easter Da 2° Half From 3 m until 9 m Mother Father Memorial Da From 9 am until 9 m Mother Father Independence Da From 9 am until 9 m Father Mother Labor Da From 9 am until 9 m Mother Father Halloween From one hour before trick or treating to one hour after trick or treatin Father Mother Thanksgiving 1 s Half From 8 am Thanksgiving Day to 2 m on Thanksgiving Da Father Mother Thanksgiving 2° half From 2 pm on Thanksgiving Day to noon the day after Thanksgiving Da Mother Father Christmas 1 s Half From noon on 12/24 to noon on 12/25 Father Mother Christmas 2° Half From noon on 12/25 to noon on 12/26 Mother Father New Year's From 6 pm 12/31 until noon January Pt (with the 12/31 year to control the even/odd determination Mother Father Mother's Da From 9 am until 9 m Mother oer Father's Da From 9 am until 9 m Father + Fa--th!r- BRETT A. GREEGER, Plaintiff V. REBECCA L. GREEGER, Defendant Prior Judge: J. Wesley Oler, Jr., J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 09-554 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVII., PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the Children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Bailey R. Greeger 07/14/2001 Shared Evan M. Greeger 07/17/2007 Shared 2. A Conciliation Conference was held with regard to this matter on March 10, 2009, an Order issued March 16, 2009 and a conciliation conference held April 30, 2009 with the following individuals in attendance: The Mother, Rebecca Greeger, pro se The Father, Brett Greeger, with his counsel, Michael Whare, Esq. 3. The parties agreed to the entry of an Order in the form as attached. Date John J gan, Esquire Cust d Conciliator BRETT A. GREEGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :Civil Action- Law No. 09-554 Civil Term ~ „o^'_ -. REBECCA L. GREEGER, D f d -~~ ITt rx< °- ° en e ant ~ -' IN DNORCE ~.~ ~ ~ ~ ~ ~;~ c C,~ ~ . AFFIDAVIT OF CONSENT y z o 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 3, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit 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. `~ ~} ~,~ 1 Date: ~ dti ~~a `r Brett A. Greeger, Plaintiff BRETT A. GREEGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA o ~` v. :Civil Action- Law ~' ~~ "~ . ~ ; r*~ cz+ ~-: ' No. 09-554 Civil Term ~ ~=' cia REBECCA L. GREEGER, ~ ~' ~,,, Defendant mac: ~ ~ cA;~ _ IN DIVORCE ~ °• w c.n WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit 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: ~ ~ ~y ~~~(;V~~~ Brett A. Greeger, BRETT A. GREEGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. Civil Action- Law ~ ° ~ : ~ cx~ ` "'*~ w ""~ No. 09-554 Civil Term ~ {~ ~ REBECCA L. GREEGER, e i_ ~ ,~ Defendant ~ ~„ ` IN DIVORCE ~ « ~ ~ ca to AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 3, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit 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: ~ ~' ~ ' ebecca L. Greeger, Defen ant BRETT A. GREEGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA d v. :Civil Action- Law .t,~~ ~ • ~ ~r- ap No. 09-554 Civil Term ~~: ~ -v REBECCA L. GREEGER, ~ i•: ~ Defendant , ~ ~ 3 _ IN DIVORCE ~''~~ c can WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit 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: Rebecca L. Greeger, De endant ~ IN THE COURT OF COMMON PLEAS OF BRETT A. GREEGER :CUMBERLAND COUNTY, PENNSYLVANIA V. REBECCA L. GREEGER 09-554 CIVIL TERM NO. DIVORCE DECREE AND NOW, ~ ~ ` ~ 2 o t o , it is ordered and decreed that BRETT A. GREEGER plaintiff, and REBECCA L. GREEGER ,defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente life if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as .follows: (If no claims remain indicate °None.") NONE. R.. +tio r.,~ ~~+ 7-~~~ ~o 7~ a~ • ~~ Ce..c~-. Gc rnC.~ tQc~ I~ofic.¢- ~`~a ~ o ~ A~h~. GJha~e. ~ ems. ry y E PR 0 jj 1-1 !11 DEC 20 PM 2. 33 %MBERLAI-4U CGU, ; Y PENNSYLVANIA BRETT A. GREEGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law No. 09-554 Civil Term REBECCA L. GREEGER, Defendant IN CUSTODY PETITION FOR CONTEMPT AND MODIFICATION OF CUSTODY AND NOW, comes the Petitioner, Brett Greeger, by and through his counsel, Michael J. Whare, Esquire and avers as follows: 1. Petitioner, hereinafter referred to as Father, resides at 20 Gobin Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. Respondent, hereinafter referred to as Mother, resides at 927 North West Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. Mother and Father are the parents of Bailey R. Greeger, born July 14, 2001 and Evan M. Greeger, born July 17, 2007, hereinafter referred to as Children. 4. A prior custody order was entered on May 5, 2009 by the Honorable Judge J. Wesley Oler, Jr. (attached as Exhibit "A") 5. Mother has willfully disobeyed the current Order and is not acting in the children's best interests, including but not limited to: $,1o.oo PD ATM Or a to p.-4 &08831 a. Mother has continually not allowed father to have his regular periods of custody with the children, except for this past summer, since November 2010. b. Mother promised father that the children could attend father's wedding on October 29, 2011 but at last the minute refused to allow the children to attend the wedding. 6. Father also desires to modify the current custody order, which is in the children's best interests, as follows: a. Father proposes a custody schedule that provides him with primary physical custody and partial physical custody in mother. WHEREFORE, Petitioner respectfully requests this Honorable Court find the Respondent in contempt for willfully disobeying the Custody Order, grant his Petition to Modify Custody to provide the father with primary physical custody and any other relief that is just and proper. Respectfully submitted, Date: 1 Michael J. Whare, squire 37 East Pomfret Street Carlisle, PA 17013 Supreme Ct. Id No. 89028 Attorney for Plaintiff BRETT A. GREEGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law : No. 09-554 Civil Term REBECCA L. GREEGER, Defendant : IN CUSTODY VERIFICATION 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.C.S. § 4904 relating to unworn falsification to authorities. Date: Greeger, Petitioner APR 1 0 2009 BRETT A. GREEGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 09-554 CIVIL ACTION LAW REBECCA L. GREEGER, IN CUSTODY Defendant Prior Judge: J. Wesley Oler, Jr., J. ORDER OF COURT AND NOW this -l. day of May 2009, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. All prior Orders entered in this matter are hereby VACATED and replaced with this Order. 2. Legal Custody: The Father, Brett A. Greeger, and the Mother, Rebecca L. Greeger, shall have shared legal custody of Bailey R. Greeger, born 07/14/2001 and Evan M. Greeger, born 07/17/2007. The parties shall have an equal right to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their 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 Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children 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. 3. Physical Custody: Mother and Father shall arrange physical custody of the Children as follows: a. Commencing 05/06/09, Father shall have physical custody of the Children from Wednesday 6:00 pm until Sunday 6:00 pm every other week b. Once the Child/ren are off for summer vacation, Father shall have physical custody of the Children from Wednesday 6:00 pm until Saturday 12:00 pm every week. C. The non-custodial parent shall pick up the Children from the custodial parent's residence. d. In the event Father determines that his health issues prevent him from adequately caring for the Children, Father shall immediately notify Mother to request assistance. e. The parents may alter the custodial schedule by mutual agreement as necessary or proper. 4. The custodial parent shall ensure that the Children attend any and all, within reason, of their extra-curricular/social activities when the Children are in his/her care. 5. The non-custodial parent shall have liberal telephone contact with the Children on a reasonable basis. ????- A 6. Holidays: The parents shall arrange the holiday schedule mutually agreed. In the absence of agreement, the parents shall follow the holiday schedule as attached. 7. Each parent shall have two non-consecutive weeks of vacation with the Children per year. 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. In the event the custodial parent should take the Children out of state, the custodial parent shall notify the non-custodial parent within twenty-four hours of departure of the intended destination and a telephone number at which they can be reached. 9. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 10. 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. By the Court, J. Distribution: Michael Whare, Esq. Rebecca Greeger, 17 South Baltimore Ave., Mt. Holly Springs, PA 17065 John J. Mangan, Esquire CIOPi' 1 Y ail -; ?" `'rye fiv'?7E '? 4 ?q 7 HOLIDAYS AND SPECIAL DAYS TIMES EVEN YEARS ODD YEARS Easter Da 1 Half From 9 am until 3 m Father Mother Easter Da 2° Half From 3 m until 9 m Mother Father Memorial Da From 9 am until 9 m Mother Father Independence Da From 9 am until 9 m Father Mother Labor Da From 9 am until 9 m Mother Father Halloween From one hour before trick or treating to one hour after trick or treating Father Mother Thanksgiving 1 s Half From 8 am Thanksgiving Day to 2 m on Thanksgiving Da Father Mother Thanksgiving 2° half From 2 pm on Thanksgiving Day to noon the day after Thanksgiving Da Mother Father Christmas 1 s Half From noon on 12/24 to noon on 12/25 Father Mother Christmas 2° Half From noon on 12/25 to noon on 12/26 Mother Father New Year's From 6 pm 12/31 until noon January 1st (with the 12/31 year to control the even/odd determination Mother Father Mother's Da From 9 am until 9 m Mother Mother Father's Da From 9 am until 9 m Father Father BRETT A. GREEGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 09-554 CIVIL ACTION LAW REBECCA L. GREEGER, IN CUSTODY Defendant Prior Judge: J. Wesley Oler, Jr., J. 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 Children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Bailey R. Greeger 07/14/2001 Shared Evan M. Greeger 07/17/2007 Shared 2. A Conciliation Conference was held with regard to this matter on March 10, 2009, an Order issued March 16, 2009 and a conciliation conference held April 30, 2009 with the following individuals in attendance: The Mother, Rebecca Greeger, pro se The Father, Brett Greeger, with his counsel, Michael Whare, Esq. 3. The parties agreed to the entry of an Order in the form as attached. r S ' Date John gan, Esquire Cust 'd Conciliator BRETT A. GREEGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law No. 09-554 Civil Term REBECCA L. GREEGER, Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Michael J. Whare, Esquire, attorney for Petitioner, do hereby certify that I this day mailed a copy of the within Petition for Contempt and Modification of Custody upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Rebecca Greeger 927 North West Street Carlisle, PA 17013 Dated: Id -d 0 -Zl Michael J. Wh , Esquire Attorney for Petitioner BRE.TT A. GREEGER PLAINTIFF V. REBECCA L. GREEGER DEFENDANT AND NOW, Thursd; it is hereby directed that parties and at 4th Floor, Cumberland Coun for a Pre-Hearing Custody Conferei if this cannot be accomplished, to d order. Failure to appear at the confs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAN IA C ? 2009-554 CIVIL ACTION LAW ?M z? c.? ?«n -,r»- cn? -t N X,? e'er IN CUSTODY ay ? C) --? rv b ORDER OF COURT 22, 2011 , upon consideration of the attached Complaint, r respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, ourthouse, Carlisle on Tuesday, January. 24, 2012 at 8:30 AM At such conference, an effort will be made to resolve the issues in dispute; or and narrow the issues to be heard by the court, and to enter into a temporary may provide grounds for entry of a temporary or permanent order. The court hereby directs the arties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody rders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ jacquelrne M. Verney, 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. Fo information about accessible facilities and reasonable accommodations available to disabled individuals aving business before the court, please contact our office. All arrangements must be made at least 72 hours p for to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAK 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 Coe/ 1.vd,e?;d d "Oof? -/.,, Py BRETT A. GREEGER, Plaintiff V. REBECCA L. GREEGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-554 CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 2 y ? day of , 2012, upon consideration of the attached Custody Conciliation R ort, it is ordered and directed as follows: 1. Father's Petition for Contempt shall be held in abeyance. The prior Order of Court dated May 5, 2009 shall remain in full force and effect with the following modifications. 2. During the school year, Father shall have physical custody of the children on alternating weeks from Wednesday at 4:30 p.m. to Monday at 4:30 p.m. 3. During the summer, the parties shall share physical custody of the children on a week on/week off basis with Sunday at 6:00 p.m. being the exchange day and time. Father's week shall begin the first Sunday after school recesses, unless it is his alternating weekend, in which case Father's week will commence the following Sunday. The parties' summer vacations shall coincide with their custodial weeks in the summer. 4. Transportation shall be shared such that the receiving party shall transport. The parties shall not exit their vehicle except to assist the children in getting into the car. 5. Neither party shall do nor permit a third party to do, or say anything that would estrange the Children from the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development of the Children's love and respect for the other parent. 6. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual. consent. In the absence of mutual consent, the terms of this Order shall control. Another conciliation conference is scheduled for June 5, 2012 at 9:30 p.m. cc: Michael I / Rebecca L BY THE COURT, Whare, Esquire, Counsel for Father Greeger, pro se 927 North West Street Carlisle, PA 17013 , -* fiS C? ?M 00 c_- k.ry -nw f N CV i Y BRETT A. GREEGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-554 CIVIL ACTION - LAW REBECCA L. GREEGER, Defendant : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Bailey R. Greeger July 14, 2001 Mother Evan M. Greeger July 17, 2007 Mother 2. A Conciliation Conference was held in this matter on January 24, 2012, with the following in attendance: The Father, Brett A. Greeger, with his counsel, Michael J. Whare, Esquire, and the Mother, Rebecca L. Greeger, pro se. 3. The Honorable J. Wesley Oler, Jr. previously entered an Order of Court dated May 5, 2009 providing for shared legal custody, Mother having primary physical custody with Father having four overnights on alternating weeks during the school year and three overnights per week in the summer. 4. Father filed a Petition for Contempt and Modification. 5. The parties agreed to an Order in the form as attached. i Date: 1 -L-- '? )acqidine M. Verney, Esquire Custody Conciliator BRETT A. GREEGER, Plaintiff V. REBECCA L. GREEGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-554 CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this &_ day of 2012, upon consideration of the attached Custody Conciliat on Report, it is ordered and directed as follows: The prior Orders of Court dated May 5, 2009 and January 24, 2012 are hereby vacated. 2. Father's Petition for Contempt is hereby withdrawn. 3. The Father, Brett A. Greeger and the Mother, Rebecca L. Greeger, shall have shared legal custody of Bailey R. Greeger, born July 14, 2001 and Evan M. Greeger, born July 17, 2007. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their 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 children and 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. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor children. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 4. During the school year, Mother shall have primary physical custody of the children and Father shall have partial physical custody of the children on alternating weeks from Wednesday at 4:30 p.m. to Monday at 4:30 p.m. 5. During the summer, the parties shall share physical custody of the children on a week on/week off basis with Sunday at 6:00 p.m. being the exchange day and time. Father's week shall begin the first Sunday after school recesses, unless it is his alternating weekend, in which case Father's week will commence the following Sunday. The parties' summer vacations shall coincide with their custodial weeks in the summer. 6. Transportation shall be shared such that the receiving party shall transport. The parties shall not exit their vehicle except to assist the children in getting into the car. 7. Neither party shall do nor permit a third party to do, or say anything that would estrange the Children from the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development of the Children's love and respect for the other parent. 8. The custodial parent shall ensure that the Children attend any and all, within reason, of their extra-curricular/social activities when the children are in his/her care. 9. Holidays: The parents shall arrange the holiday schedule as mutually agreed. In the absence of agreement, the parents shall follow the holiday schedule as attached. 10. In the event the custodial parent shall take the Children out of state, the custodial parent shall notify the non-custodial parent within twenty-four hours of departure of the intended destination and a telephone number at which they can be reached. 11. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 12. RELOCATION. No party shall be permitted to relocate the residence of the children which significantly impairs the ability to exercise custody unless every individual who has custodial rights to the children consents to the proposed relocation or the court approves the proposed relocation. A person proposing to relocate MUST comply with 23 Pa.C.S. 5337. 13. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control BY THE COURT, Kevin cc Michael J. Whare, Esquire, Counsel for Father Rebecca L. Greeger, pro se 927 North West Street Carlisle, PA 17013 eV P. e.5 Ma, le &/7/la- I/- t P.J. HOLIDAYS AND SPECIAL DAYS TBRS EVEN YEARS ODD YEARS Easter Da 1 Half From 9 am until 3 m Father Mother Easter Da 2° Half From 3 m until 9 m Mother Father Memorial Da From 9 am,until 9 m Mother Father Independence Da From 9 am until 9 m Father Mother Labor Da From 9 am until 9 m Mother Father Halloween From one hour before trick or treating to one hour after trick or treating Father Mother Thanksgiving 1 s Half From 8 am Thanksgiving Day to 2 m on Thanksgiving Da Father Mother Thanksgiving 2° half From 2 pm on Thanksgiving Day to noon the day after Thanksgiving Da Mother Father Christmas 1 s Half From noon on 12/24 to noon on 12/25 Father Mother Christmas 2° Half From noon on 12/25 to noon on 12/26 Mother _ Father New Year's From 6 pm 12/31 until noon January 1't (with the 12/31 year to control the even/odd determination Mother Father Mother's Da From 9 am until 9 m Mother Mother Father's Da From 9 am until 9 m Father Father BRETT A. GREEGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-554 CIVIL ACTION - LAW REBECCA L. GREEGER, Defendant : IN CUSTODY PRIOR JUDGE: Kevin A. Hess, P.J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Bailey R. Greeger July 14, 2001 Evan M. Greeger July 17, 2007 Mother Mother 2. A Conciliation Conference was held in this matter on June 5, 2012, with the following in attendance: The Father, Brett A. Greeger, with his counsel, Michael J. Whare, Esquire, and the Mother, Rebecca L. Greeger, pro se. 3. The Honorable J. Wesley Oler, Jr. previously entered an Order of Court dated May 5, 2009 providing for shared legal custody, Mother having primary physical custody with Father having four overnights on alternating weeks during the school year and three overnights per week in the summer. The Honorable Kevin A. Hess entered an Order of Court dated January 24, 2012 providing for Mother to have primary physical custody with Father having five overnights on alternating weeks during the school year and the parties alternating weeks in the summer. 4. Father previously filed a Petition for Contempt that was held in abeyance. Father is willing to withdraw his Contempt Petition. 5. The parties agreed to an Order in the form as attached. / Date: Iv`1f ? cq ine M. Verney, Esquire Custody Conciliator