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HomeMy WebLinkAbout10-17236 1 6 ,*estrnoreland Count,PROTHONOTARY CHRISTINA O'BIEN Charles L. Wolf Deputy Prothonotary Curt Long Prothonotary One Courthouse Square Carlisle PA 17013-3387 Dear Mr. Long 724-830-3502 January 29, 2010 The enclosed papers, case 1136 of 2002-D are being sent to you as per order of court dated January 29.2010. Sincerely , ask. Ak??? Debora K. Phillips IN THE COURT OF COMMON PLEAS OF WESTMORELAND COURT CIVIL ACTION iO - l7a 3 Ccu-? Brian David Cavada Cari Lee Cavada Filings 1136 of 2002-D File Date 1. Divorce complaint 06-19-2002 2. Order custody conciliation 06-19-2002 3. Mot/Pet -Plaintiff 06-19-2002 4. Affidavit of service 06-27-2002 5. Order custody 7-24-2002 07-24-2002 6. Order custody 10-17-2002 10-18-2002 7. Order amending 10-17-2002 10-21-2002 8. Order hearing rescheduled 02-12-2003 9. Order hearing rescheduled 05-20-2003 10. Mot/Pet continuance/order 08-08-2003 11. Order dated 11-10-2003 11-17-2003 12. Marital settlement agreement 01-26-2004 13. Affidavit of consent & waiver 01-26-2004 14. Affidavit of consent & waiver 02-17-2004 15. Praecipe transmit record 02-18-2004 16. Affidavit non military service 02-18-2004 17. Divorce granted 2-27-2004 02-27-2004 18. Order custody dated 5-18-2004 05-18-2004 19. Mot/Pet modify custody/order 11-15-2004 20. Order custody consent 01-05-2005 21. Mot/Pet continuance/order 03-03-2005 22. Mot/Pet cancel hearing 05-02-2005 23. Certified copy order change venue to New Cumberland County 01-29-2010 Address: One Courthouse Square C= Carlisle PA 17013-3387 C Phone# 717-240-6100 ? .? 9 • ©? A ? k Curt Long- Prothonotary t. - P au - ,. c o ?„ 1W ' -3 w DKP ' Westmoreland County PO Bo&0. Greensburg, 15601 PA. Phone: (724)832 EXT CASE HISTORY FOR CASE 02DO01136 BRIAN DAVID CAVADA VS. CARI LEE CAVADA FILED DATE: 6/19/2002 CASE TYPE: DO/DIVORCE STATUS: MGT CL JUDGE: ANTHONY G. MARSILI CASE PARTIES: PLAINTIFF Cavada, Brian David DEFENDANT Cavada, Cari Lee PLAINTIFF ATTY Bitar, Raymond CASE HISTORY FOR CASE 02DO01136 Cavada, Brian David Current Age: Unknown DOB: Unknown DL#: SSN: 000-00-0000 Total Paid: $ 145.00 Balance Due: $ 0.00 COST AMOUNT PAY PRIORITY Total: DATE TIME DESCRIPTION 01/29/2010 10:43 am Filing recorded: ORDER CHANGE VENUE TO NEW CUMBERLAND COUNTY Cavada, Brian David _ 05/02/2005 12:00 am Filing recorded: MOT/PET FILED ON BEHALF OF DEFT TO CANCEL THE HEARING ON APR Cavada, Brian David 05/02/2005 12:00 am CNV recorded the following Case Action Note: 2005 AND ORDER DATED APRIL 28 2005 GRANTING MOTION Cavada, Brian David 03/03/2005 12:00 am Filing recorded: DEFT'S MOT/PET CONTINUANCE AND ORDER DATED MARCH 2 2005 SCHE Cavada, Brian David 03/03/2005 12:00 am CNV recorded the following Case Action Note: A CCC FOR APRIL 18 2005 AT 1:00 PM Cavada, Brian David 01/05/2005 12:00 am Filing recorded: ORDER CUSTODY BY CONSENT DATED JANUARY 3 2005 AND RESCHEDULI Cavada, Brian David 01/05/2005 12:00 am CNV recorded the following Case Action Note: FOR FEBRUARY 23 2005 AT 10:00 AM Cavada, Brian David 11/15/2004 12:00 am Filing recorded: DEFT'S MOT/PET MODIFY CUSTODY ORDER AND ORDER DATED NOVEMBER Cavada, Brian David 11/15/2004 12:00 am CNV recorded the following Case Action Note: SCHEDULING HEARING FOR JANUARY 3 2005 AT 10:00 AM Cavada, Brian David 05/18/2004 12:00 am Filing recorded: ORDER CUSTODY DATED MAY 18 2004 AS SET FORTH Cavada, Brian David 02/27/2004 12:00 am Filing recorded: DIVORCE GRANTED FEBRUARY 27 2004 BY THE COURT ANTHONY G MA Cavada, Brian David 02/18/2004 12:00 am Filing recorded: AFFIDAVIT NON MILITARY SERVICE Cavada, Brian David 02/18/2004 12:00 am Filing recorded: PRAECIPE TRANSMIT RECORD Cavada, Brian David 02/17/2004 12:00 am Filing recorded: AFFIDAVIT OF CONSENT & WAIVER OF NOTICE TO REQUEST ENTRY OF Cavada, Brian David 02/17/2004 12:00 am CNV recorded the following Case Action Note: PLFF Cavada, Brian David Print Date: 01/29/2010 Print Time: 1:56:27PM Requested By: DPHILLIP File: \\QWEST400\ROOT\JEMS\JEMS Server 5\Reports\CaseHistoryCivil.RPT Page 1 of 2 CASE HISTORY FOR CASE 02DO011 01/26/2004 12:00 am Filing recorded: AFFIDAVIT OF CONSENT & WAIVER OF NOTICE TO REQUEST ENTRY OF Cavada, Brian David 01/26/2004 12:00 am CNV recorded the following Case Action Note: DEFT Cavada, Brian David 01/26/2004 12:00 am Filing recorded: AGREEMENT SETTLEMENT MARITAL DATED JANUARY 23 2004 Cavada, Brian David 11/17/2003 12:00 am Filing recorded: ORDER DATED NOVEMBER 10 2003 CANCELLING REVIEW CONFERENCE AN Cavada, Brian David 11/17/2003 12:00 am CNV recorded the following Case Action Note: TERMS AND CONDITIONS OF OCT 17 2002 ORDER REMAIN IN FULL FORCE AND EFFECT Cavada, Brian David 08/08/2003 12:00 am Filing recorded: PLAINTIFF'S MOT/PET CONTINUANCE AND ORDER AUGUST 6 2003 SETT Cavada, Brian David 08/08/2003 12:00 am CNV recorded the following Case Action Note: A REVIEW CONFERENCE FOR NOV 10 2003 AT 10:15 AM Cavada, Brian David 05/20/2003 12:00 am Filing recorded: ORDER HEARING RESCHEDULED TO MONDAY AUGUST 25 2003 AT 2:30 P Cavada, Brian David 05/20/2003 12:00 am CNV recorded the following Case Action Note: DATED MAY 20 2003 Cavada, Brian David 02/12/2003 12:00 am Filing recorded: ORDER HEARING RESCHEDULED TO AUG 12 2003 AT 9:00 AM BEFORE J Cavada, Brian David 02/12/2003 12:00 am CNV recorded the following Case Action Note: MARSILI ORDER DATED FEB 11 2003 Cavada, Brian David 10/21/2002 12:00 am Filing recorded: ORDER AMENDING PARAGRAPH 10 OF THE ORDER DATED OCT 17 2002 A Cavada, Brian David 10/21/2002 12:00 am CNV recorded the following Case Action Note: FORTH ORDER DATED OCT 21 2002 Cavada. Brian David 10/18/2002 12:00 am Filing recorded: ORDER CUSTODY DATED OCT 17 2002 AS SET FORTH AND A REVIEW CO Cavada, Brian David 10/18/2002 12:00 am CNV recorded the following Case Action Note: IS SCHEDULED FOR AUGUST OF 2003 Cavada, Brian David 07/24/2002 12:00 am Filing recorded: ORDER CUSTODY DATED JULY 24 2002 AS SET FORTH AND SCHEDULING Cavada, Brian David 07/24/2002 12:00 am CNV recorded the following Case Action Note: CONFERENCE FOR THURSDAY OCTOBER 17 2002 AT 1:15 PM Cavada. Brian David 06/27/2002 12:00 am Filing recorded: AFFIDAVIT OF SERVICE OF COMPLAINT IN DIVORCE UPON DEFT BY CE Cavada, Brian David 06/27/2002 12:00 am CNV recorded the following Case Action Note: JUNE 24 2002 RECEIPT ATTACHED Cavada, Brian David _ 06/19/2002 12:00 am Filing recorded: COMPLAINT DIVORCE Cavada, Brian David 06/19/2002 12:00 am Filing recorded: COUNT CUSTODY Cavada, Brian David 06/19/2002 12:00 am Filing recorded: ORDER CUSTODY CONCILIATION CONFERENCE SCHEDULED FOR JULY 12 Cavada, Brian David 06/19/2002 12:00 am CNV recorded the following Case Action Note: 2:30 PM Cavada, Brian David 06/19/2002 12:00 am Filing recorded: MOT/PET FILED ON BEHALF OF: PLAINTIFF TO STOP DEFT FROM TAKI Cavada, Brian David 06/19/2002 12:00 am CNV recorded the following Case Action Note: MINOR CHILD OUT OF STATE WITHOUT FURTHER ORDER OF COURT AND ORDER DATED JUNE 19 2002 THAT SAID CHILD WILL NOT BE REMOVED FROM COMMONWEALTH OF PA AND HEARING IS SET FOR JULY 1 2002 Cavada, Brian David Print Date: 01/29/2010 Print Time: 1:56:27PM Requested By: DPHILLIP File: \\QWEST400\ROOT\JEMS\JEMS Server 5\Reports\CaseHistoryCivil.RPT Page 2 of 2 0 0 IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA - FAMILY DIVISION - LAW BRIAN DAVID CAVADA, SS#: 192-68-4335 Plaintiff VS. CARI LEE CAVADA, SS#: 601-32-0362 Defendant No.: 1136 OF 2002-D DECREE AND NOW, a27 , 2004, it is ordered and decreed that BRIAN DAVID CAVADA, ntiff, and CARI LEE CAVADA, defendant, are divorced from the bonds of matrimony. The Court hereby incorporates by reference the terms of the parties Marital Settlement Agreement filed of record at the above number and term. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. ATTEST ?' lsa# PROTHONOTARY BY THE COURT V- 4 J )NJ 15 ?ZId LZ 93.E 40' A IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA - FAMILY DIVISION BRIAN DAVID CAVADA, Plaintiff vs. CARI LEE CAVADA, Defendant J ?d l :6 -:r FAMILY DIVISION No.: 1136 OF 2002-D TYPE OF PLEADING: MARRIAGE SETTLEMENT AGREEMENT FILED ON BEHALF OF: BRIAN DAVID CAVADA, Plaintiff Counsel for Record for this Party: RAYMOND W. BITAR Attorney at Law PA I. D. # 19676 Suite 10 Feldarelli Square 2300 Freeport Road New Kensington, PA 15068 (724) 339-1023 MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT made this ,9 day of , 20 by and between, BRIAN DAVID CAVADA, hereinafter referre to as "H band" A N D CARI LEE CAVADA, hereinafter referred to as "Wife" WITNESSESTH WHEREAS, the parties hereto were married on September 18, 1998, and since that date of said marriage, have been, and are now, Husband and Wife. WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties, it is the intention of the Wife and Husband to live separate and apart, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation by specification: the settling of all matters between them relating to the ownership and equitable distribution of their real and personal property; and settling all matters between them relating to equitable distribution, alimony, claim for alimony pendente lite, counsel fees, costs and expenses, and the settling of any and all claims and possible claims by one against the other of their respective estates. • • NOW, THEREFORE, in consideration of the promises and the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties, hereto, Wife and Husband, each intending to be legally bond hereby, covenant and agree as follows: 1. AGREEMENT TO EXECUTE CONSENT DECREES - The parties hereto intend to secure a mutual consent, no-fault divorce pursuant to the terms of section 3301 (c) of the Pennsylvania Divorce Code of 1980. The parties agree to execute affidavits of consent simultaneous with the execution of this agreement. 2. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE - The parties hereto agree that if a divorce is agreed to between the parties then this Agreement shall be incorporated into any divorce decree, which may be entered with respect to them. 3. DATE OF EXECUTION - The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which it is executed by the parties it they have executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement, shall be defined at the date of execution by the party last executing this Agreement. 4. DISTRIBUTION DATE - The transfer of property, funds and/or documents provided for herein shall take place on the date that each document has been or will be signed. ADVICE OF COUNSEL - Husband and Wife recite that counsel representing him/her was selected by him/her without any interference or suggestion by the other, that he/she has complete confidence in his/her counsel, that he/she has consulted with his/her respective counsel and that he/she has discussed and been advised by his/her counsel as to the nature of his/her rights and obligations herein, that he/she has the ability to and does understand the terms hereof and that he/she consents hereto of his/her own volition and on advice of counsel, intending and designing to be permanently bound hereby. 6. FINANCIAL DISCLOSURE - The parties confirm that each has relied on the substantial accuracy of the financial disclosure made to each other. They agree that they are satisfied with the nature and extent of such disclosure, respectively, and each has considered the same as inducement to the execution of this Agreement. 7. PERSONAL RIGHTS - Wife and Husband may and shall, at all times hereafter, live separate and apart. They shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respect as fully as if they were unmarried. They may reside at such place or places as they may select. Each may, for his or her separate use or benefit, conduct, carry on or engage in any business, occupation, profession or employment which to him or her may seem advisable. Wife and Husband shall not molest, harass, disturb or malign each other or the respective families of each other, nor compel or attempt to compel the 0 0 other to cohabit or dwell by any means or in any manner whatsoever with him or her. 8. MUTUAL RELEASES - Husband and Wife each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interest, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or curtesy, or claims in the nature of dower or curtesy, of widow's or widower's rights, family exemption or similar allowance, or under the interstate law, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any state, Commonwealth or territory of the United States, or (c) any other Country or any rights which either party may have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendent lite, counsel fees, equitable distribution, costs or expenses, whether arising as a result of the marital relation or otherwise, except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. 0 0 9. PERSONAL PROPERTY -The parties agree that all personal property has been divided and each shall retain possession of all such said property currently in his/her possession. 10. AFTER - ACQUIRED PERSONAL PROPERTY - Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of personal property, tangible or intangible, hereafter acquired by Husband and Wife, with full power in Husband and Wife to dispose of the same fully and effectively, in all respects and for all purposes, as though Husband or Wife were unmarried. 11. WARRANTY AS TO EXISTING OBLIGATIONS - Each party represents that they have not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the other party may be responsible or liable except as may be provided for in this Agreement. Each party agrees to indemnify or hold the other party harmless from and against any and all such debtors, liabilities or obligations of every kind which may have heretofore been incurred by them, including those for necessities, except for the obligations arising out of this Agreement. 1.2. WARRANTY AS TO FUTURE OBLIGATIONS - Wife and Husband each covenant, warrant, represent and agree that each will now and at all times hereafter save harmless and keep the other indemnified from all debts, charges and liabilities incurred by the other after the execution date of this Agreement, except as may be otherwise specifically provided for 0 0 by the terms of this Agreement and that neither of them shall hereafter incur any liability whatsoever for which the estate of the other may be liable. 13. LIFE INSURANCE - Both Husband and Wife shall hereby acknowledge and agree that each one will retain their own insurance policies and each be able to name their own beneficiaries. 14. PENSION - Both Husband and Wife hereby agree and acknowledge that each one will retain their own pensions, 401 K plans and profit sharing; therefore, waiving any and all right, title or interest to each others respective plan. 15. ATTORNEY FEES - Both Husband and Wife shall hereby acknowledge and agree that each one will be solely liable for his or her own legal fees owed to respective counsel for representation in this matter. 16. ALIMONY - Both Husband and Wife expressly relinquish their respective rights to receive and/or modify alimony for the remainder of their lives. 17. CHILD SUPPORT - Both Husband and Wife shall hereby acknowledge and agree that the current Order of Court shall stay in effect until such time that either party file a modification. 18. WAIVER OF MODIFICATION TO BE IN WRITING - No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default 0 0 hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 19. DEFAULT - If either party defaults in the due performance of any of the terms of this Agreement on his or her part to be performed, the non- defaulting party shall have the right to sue for specific performance or damages for the breach of this Agreement, and the defaulting party shall pay the reasonable legal fees and costs for any services rendered by the non-defaulting party's attorney as well as any other attendant expenses in any action or proceeding to compel the defaulting party's due performance hereunder. 20. LAW OF PENNSYLVANIA APPLICABLE - This Agreement shall be construed in accordance with laws of the Commonwealth of Pennsylvania. 21. AGREEMENT BINDING ON HEIRS - This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 22. INTEGRATION - This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. 23. OTHER DOCUMENTATION - Wife and Husband covenant and agree that the will forthwith (and within at least five (5) days after demand therefore) execute any and all written documents, instruments, assignments, releases, satisfactions, deeds, notes or such other writings as • may be necessary or desirable for the proper effectuation of this Agreement, and as their respective counsel shall mutually agree should be so executed in order to carry out fully effectively the terms of this Agreement. 24. NO WAIVER OF DEFAULT - This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any breach of any provisions hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. 25. SEVERABILITY - If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law, or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet his or her obligations under any one or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way void or alter the remaining obligations of the parties. 0 0 26. HEADINGS NOT PART OF AGREEMENT - Any headings preceding the text of several paragraphs and subparagraphs hereof are inserted solely for convenience or reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. WI zlz an D d avada ari Lee Cavada IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA - FAMILY DIVISION BRIAN DAVID CAVADA, SS# 192-68-4335 Plaintiff vs. CARI LEE CAVADA, SS# 601-32-0362 Defendant -s co >- C%: - LLJ v < c , C'`J FAMILY DIVISION No.. //L3 TYPE OF PLEADING: COMPLAINT IN DIVORCE FILED ON BEHALF OF: BRIAN DAVID CAVADA, Plaintiff Counsel for Record for this Party: RAYMOND W. BITAR Attorney at Law PA I. D. # 19676 Suite 10 Feldarelli Square 2300 Freeport Road New Kensington, PA 15068 (724) 339-1023 op(od 0 ?? IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA - FAMILY DIVISION - LAW BRIAN DAVID CAVADA, Plaintiff vs. No.: C.? CARI LEE CAVADA, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS 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 OR CLAIM RELIEF REQUESTED IN THESE PAPERS BY THE PLAINTEFF. YOU MAY LOSE MONEY OR PROPERTY OF OTHER RIGHTS IMPORTANT TO YOU, INCLUDING CUSTODY OR VISITATION OF YOUR CHILDREN. WHEN GROUNDS FOR THE DIVORCE IS INDIGNITIES OR IRRETRIEVABLE BREAKDOWN OF THE MARRIAGE, YOU MAY REQUEST COUNSELING. A LIST OF MARRIAGE COUNSELORS IS AVAILABLE IN THE OFFICE OF THE PROTHONOTARY AT THE WESTMORELAND COUNTY COURTHOUSE, ROOM 501, COURTHOUSE SQUARE, GREENSBURG, PENNSYLVANIA, 15601. IF YOU DO 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 WHERE YOU CAN RECEIVE LEGAL HELP: WESTMORELAND BAR ASSOCIATION 129 NORTH PENNSYLVANIA AVENUE GREENSBURG, PA 15601 (724) 834-6730 • IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA - FAMILY DIVISION - LAW BRIAN DAVID CAVADA, Plaintiff VS. No.: 113(o G- CARI LEE CAVADA, Defendant COMPLAINT IN DIVORCE AND NOW, comes the Plaintiff, BRIAN DAVID CAVADA, by and through his attorney, RAYMOND W. BITAR, ESQUIRE, and files this Complaint in Divorce, and in support thereof avers the following: COUNT I - DIVORCE 1. The Plaintiff is BRIAN DAVID CAVADA, who currently resides at 891 Wildlife Lodge Road, Lower Burrell, Pennsylvania 15068 in Westmoreland County. His social security number is 192-68-4335. 2. The Defendant is CARI LEE CAVADA, who currently resides at 2127 Keystone Avenue, Apartment C, Greensburg, Pennsylvania 15601 in Westmoreland County. Her social security number is 601-32-0362. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately prior to the filing of this complaint. 4. Plaintiff and Defendant were married on September 18, 1998. 5. Plaintiff avers that the marriage is irretrievably broken. 6. No prior action in divorce or for annulment of marriage between the parties has been filed in this or any other jurisdiction. 7. Plaintiff has been advised of the availability of counseling and may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree of Divorce. COUNT II - CUSTODY 8. The averments of Paragraphs 1 through 7 are hereby incorporated by reference as though the same were more fully set forth at length herein. 9. The parties herein are the parents of one (1) minor child, namely; Meghan Lee born November 3, 1998 10. The relationship of Plaintiff to the child is the father. 11. The relationship of the Defendant to the child is the mother. 12. No proceeding has heretofore been begun, nor any Order entered in any Court affecting the right of the parties to the custody and or visitation of said child. 13. Plaintiff avers that the best interests and welfare of the child will be served by granting the relief requested. WHEREFORE, Plaintiff requests that custody of the aforesaid child be granted to him. Respectfully submitted, Raymond W. Bitar, Esquire Attorney for Plaintiff 0 0 VERIFICATION I, BRIAN DAVID CAVADA, have read the foregoing Complaint in Divorce. The statements therein are true and correct to the best of my personal knowledge or information and belief. This statement and verification is made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn fabrication to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. BRIAN DAVID CAVADA Dated: 0/-/9-02- • • IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA - FAMILY DIVISION BRIAN DAVID CAVADA, Plaintiff vs. CARI LEE CAVADA, Defendant 00 L'77- r CZ) i-i.`1 -3 :- Ca ?- T ill ?... _- r ? iz?-- «C Q/ } > r FAMILY DIVISION No.: I l i. Z vcZ- (? TYPE OF PLEADING: PETITION TO STOP DEFENDANT, CARI LEE CAVADA, FROM TAKING MINOR CHILD OUT OF STATE WITHOUT FURTHER ORDER OF COURT FILED ON BEHALF OF: BRIAN DAVID CAVADA, Plaintiff Counsel for Record for this Party: RAYMOND W. BITAR Attorney at Law PA I. D. # 19676 Suite 10 Feldarelli Square 2300 Freeport Road New Kensington, PA 15068 (724) 339-1023 IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA - FAMILY DIVISION - LAW BRIAN DAVID CAVADA, Plaintiff vs. No.: 3!o CARI LEE CAVADA, Defendant PETITION TO STOP DEFENDANT, CARI LEE CAVADA. FROM TAKING MINOR CHILD OUT OF STATE WITHOUT FURTHER ORDER OF COURT AND NOW, comes the Plaintiff, BRIAN DAVID CAVADA, by and through his attorney, RAYMOND W. BITAR, ESQUIRE, and states the following: 1. BRIAN DAVID CAVADA, the Plaintiff herein, is the natural father of the minor child Meghan Lee Cavada, born November 3, 1998. 2. CARI LEE CAVADA, the Defendant herein, is the natural mother of the minor child Meghan Lee Cavada, born November 3, 1998. 3. The Plaintiff named above has filed the divorce at the above caption and number and has filed a count for custody of the minor child. 4. CARI LEE CAVADA, the Defendant named above, has told the Plaintiff that she is going to take the minor child and move to Arizona. WHEREFORE, your Petitioner prays that your Honorable Court enter an Order of Court stopping the Defendant, CARI LEE CAVADA, from leaving the state of Pennsylvania with the minor child, Meghan Lee Cavada, until such time that a Court Order allows her to do so. Respectfully submitted, Raymond . Bitar Attorney for Petitioner • VERIFICATION I, BRIAN DAVID CAVADA, have read the foregoing PETITION TO STOP DEFENDANT, CA RI LEE CAVADA, FROM TAKING MINOR CHILD OUT OF STATE WITHOUT FURTHER ORDER OF COURT. The statements therein are true and correct to the best of my personal knowledge or information and belief. This statement and verification is made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn fabrication to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. zlj- ?7 z BRIAN DAVID C-AVA-DA Dated: v -/ 9 - D Z IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA - FAMILY DIVISION BRIAN DAVID CAVADA, FAMILY DIVISION Plaintiff No.. I I 3 ?. 2C/ G L V vs. TYPE OF PLEADING: CARI LEE CAVADA, Defendant ORDER OF COURT FILED ON BEHALF OF: BRIAN DAVID CAVADA, Plaintiff Counsel for Record for this Party: RAYMOND W. BITAR Attorney at Law PA I. D. # 19676 Suite 10 Feldarelli Square 2300 Freeport Road New Kensington, PA 15068 (724) 339-1023 • 0 IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA - FAMILY DIVISION - LAW BRIAN DAVID CAVADA, Plaintiff vs. CARI LEE CAVADA, Defendant ORDER OF COURT AND NOW to wit this 1 ? day of 2002, upon Q460 consideration of the attached Petition, it is h y ORDERED that CARI LEE CAVADA, the natural mother of MEGHAN LEE CAVADA will not remove said child from the Commonwealth of Pennsylvania without further Order of Court, and further, that a custodial conference BY THE COURT: a??PM R7TEST. Rot4 DIEM. PROTHONOTARY J 010= IN THE COURT OF CONRYION PLEAS OF WESTMORELAND COUNTY, PENNSYLVAtiTLA, CIVIL ACTION -LAW (CUSTODY) 6r1'l"J CQVara& V. (.&r/ ea V&&& Plaintiff No. 11,36 of 20 0.2-b Defendant CUSTODY SCHEDULING ORDER You, 69 / (defendant) (respondent), have been sued in court to (o-t§Lin) (modify) custody, partial custody or visitation of the children: -a Name Date of Birth ? c ? 0 -Z _ / " e 1rt ez l1 h2 Q ? /? ?// r? !? !` -,J33 9 Z r -< Ei O CA in (1) The Plaintiff is ORDERED to attend the mandatory Children Hurt In Loss through Divorce/Separation (CHILD) Program on t c, . 2002at (-f P.M. at the Memorial Conference Center at Westmoreland Regional Hospital located at 532 West Pittsburgh Street, Greensburg, Pa. 15601, phone number (724)832-4581. The Plaintiff is also ORDERED to prepay the $40.00 program registration fee using the CHILD Program Registration Form. (No money will be accepted at the session.) The Plaintiff is further ORDERED to serve a copy of the CHILD Program Registration Form on the Defendant. (2) The Defendant is ORDERED to attend the mandatory Children Hurt In Loss through Divorce/Separation (CHILD) Program on ?ccQ /9 200a.ato1,'o0 )?.M. at the Memorial Conference Center at Westmoreland Regional Hospital located at 532 West Pittsburgh Street, Greensburg, Pa. 15601, phone number (724)832-4581. The Defendant is also ORDERED to prepay the $40.00 program registration fee using the CHILD Program Registration Form. (No money will be accepted at the session.) (3) Non resident parents must attend a program similar to the CHILD program which has been certified or approved by the local Court. A Certification of Successful Completion must be presented at the time of the Conciliation Conference. (4) Should the moving party fail to pay fees or fail to appear for the CHILD Program the Custody action shall be dismissed without prejudice, and any fees paid by such party shall be forfeited. (5) Should the responding parry fail to pay fees or fail to appear for the CHILD program; an immediate Rule to Show Cause why such parry should not be held in contempt shall be issued by .• the Court. (6) Each Parry is hereby Ordered to submit to the Family Court Administrator (Custody Office), pursuant to Westmoreland County Rule of Civil Procedure W1915.4-3, a completed Parent Information Form and a copy of your most recent Federal Income Tax Return within 30 days of the date of fling of this Custody Action. An Election to Proceed Through Mediation or a Consent Agreement may also be filed with the Family Court Administrator at that time. The Plaintiff is hereby Ordered to serve a copy of the Parent Information Form on the Defendant. (7) You are hereby ordered to appear in person on20 Od at 61'36 P.M. for a Custody Conciliation Conference in the Family Court Custody Office on the fourth floor of the Westmoreland County Courthouse Annex, 2 North Main Street, Greensburg, Pa. 15601. CHILDREN MUST ATTEND UNLESS OTHERWISE ORDERED If you fail to appear for the Custody Conciliation Conference as provided by this Order, an order for custody, partial custody or visitation maybe entered against you or the Court may issue a warrant for your arrest. YOU SHOULD TAKE THIS ORDER 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. If You Cannot Afford a Lawyer Laurel Legal Services 306 S. Pennsvlvania Ave. Greensburg, Pa. 15601 (724)836-2211 If You Do Not Have a Lawyer Westmoreland Lawyer Referral 129 N. Pennsylvania Avenue Greensburg, Pa. 15601 (724)834-8490 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Westmoreland County complies with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact (724)830-3665. All arrangements must be made at least 3 working days prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. Date: Rev. 2/28/00 ATTE PON DIE".. PROTHON0??;3y A • • IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA - FAMILY DIVISION BRIAN DAVID CAVADA, Plaintiff VS. CARI LEE CAVADA, Defendant N aQ t7 FAMILY DIVISION No.: 1136 of 2002-D TYPE OF PLEADING: AFFIDAVIT OF SERVICE BY MAIL FILED ON BEHALF OF: BRIAN DAVID CAVADA, Plaintiff Counsel for Record for this Party: RAYMOND W. BITAR Attorney at Law PA I. D. # 19676 Suite 10 Feldarelli Square 2300 Freeport Road New Kensington, PA 15068 (724) 339-1023 9 • IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA - FAMILY DIVISION - LAW BRIAN DAVID CAVADA, Plaintiff vs. No.: 1136 of 2002-D CARI LEE CAVADA, Defendant AFFIDAVIT OF SERVICE BY MAIL COMMONWEALTH OF PENNSYLVANIA COUNTY OF WESTMORELAND Raymond W. Bitar, Esquire, being duly sworn according to law, deposes and says that he is the attorney for the Plaintiff, and that he did mail a true and correct copy of the Complaint in Divorce filed in the above matter, by first-class mail, to the Defendant, on the 24th day of June, 2002, at his last known address which is 2127 Keystone Avenue, Apartment C, Greensburg, Pennsylvania 15601 in Westmoreland County. The green card is attached hereto. SWORN to and subscbed fore me is _,ec"day of '2002. ?_ ?z_m? Notary Public My Commission Expires: Notarial Seal Frimoas E Albert, NOoMYy P{tbMQ NNIM K?rNkpllon, WestngN?gdp,p? t14-:9-- Raymond W. Bitar, Esquire Attorney for Plaintiff (:S?' My/ 0011N1MMion ExpirM JUL 18? !F ania Assocledlon of NM IBe a 0 0 ¦ Complete items 1, 2, and 3. Also complete A. c d bpa e A y) B. Date of Delivery item 4 if Restricted Delivery is desired. -d?4 ¦ Print your name and address on the reverse C. S re so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, X Agent or on the front if space permits. Addream D. Is ivery address different from item 1 ? ? Yes Article Addressed to: If YES, lei rw address below: ? No CARI LEE CAVADA .'.? 2127 KEYSTONE AVENUE APARTMENT C 'tom GREENSBURG, PA 15601 3. lei, 4-" rtq?Z MdIIf jIO Express Mail ? Reg-Dow- - 41 Retum Receipt for Merchandho R' ? Insured Mail ? C.O.D. „ 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Number (Copy from service label) 7099 3220 0007 9897 3896 PS Form 3811, July 1999 Domestic Return Receipt 102595-00-M-0952 • • IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW CUSTODY BRIAN DAVID CAVADA ) Plaintiff ) VS. ) CART LEE CAVADA ) Defendant ) No: 1136 OF 2002-D ORDER OF COURT AND NOW, this day of July, 2002, IT IS HEREBY ORDERED AND DECREED that shared legal custody of the minor child, Meghan Lee Cavada, born November 3, 1998, is granted to the Mother, Cari Lee Cavada, Defendant herein, and to the Father, Brian David Cavada, Plaintiff herein. Primary physical custody of the minor child is granted to the Mother. The Father shall have such partial physical custody as follows: 1. Every weekend from Saturday at 9:30 a.m. until Sunday at 9:00 p.m. 2. Father shall provide roundtrip transportation for all of his periods of partial custody. 3. The parties shall share holidays and other special occasions as they can mutually agree. The child, Meghan Lee Cavada, shall not be removed from the' Commonwealth of Pennsylvania without further Order of Court. I ? rrri r, cn C-? <rr', 46. The Mother, the Father and the minor child are to submit to custody evaluations at Westmoreland Comprehensive Counseling Center at Westmoreland Regional Hospital, 532 West Pittsburgh Street, Greensburg, Pennsylvania 15601 (724) 832-4450. The cost of said evaluation is set at $1,150.00, in accordance with Westmoreland County Local Rule W-1915.8, and shall be paid as follows: Mother is to pay $426.00, and Father to pay 724.00, who will make direct payment to the Comprehensive Counseling Center in five equal installments with the first payment due within ten days of the date of this order. The parties are to contact the Comprehensive Counseling Center within ten (10) days of this Order to schedule the evaluations. A Pre-Trial Conference is scheduled for the Thursday, October 17, 2002, at 1:15 o'clock p.m. before the Honorable Judge Anthony G. Marsili, in Courtroom No. 8, in the Westmoreland County Courthouse, 2 North Main Street, Greensburg, PA 15601. Counsel or the parties, if unrepresented, shall file a Pre-Trial Narrative at least 10 days prior to the Pre-trial Conference. The parties and any children over whom custody or visitation is sought are required to attend the Pre-Trial Conference pursuant to Westmoreland Rule W 1915.10. • This order shall remain in full force and effect pending further Order of Court. R MMENDED BY: B e C. Tobin, Custod aring ffi ATTEST: Ron Die I, Prothonotary BY TONCOURT: 7 • Judge CC: Raymond W. Bitar, Attorney for Plaintiff Maureen Kroll, Attorney for Defendant Comprehensive Counseling Center • • IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PA CIVIL ACTION - LAW (CUSTODY) BRIAN DAVID CAVADA, Plaintiff, vs. CARI LEE CAVADA, Defendant. No. 1136 of 2002-D ORDER OF COURT r ; C, _ co v I C-n -9- ` T AND NOW, to wit, this 17th day of October, 2002, after conducting a pretrial conference and receiving information from the attorneys of record and the representative from Comprehensive Counseling Center, and with certain understandings reached by the parties, it is hereby ORDERED, ADJUDGED and DECREED as follows: 1. That shared legal custody of the minor child, Meghan Lee Cavada, bom November 3, 1998, is granted to the Mother, Cari Lee Cavada, Defendant herein, and to the Father, Brian David Cavada, Plaintiff herein. 2. Primary physical custody of the minor child is granted to the Mother. 3. Father shall have such periods of partial physical custody of the minor child as follows: (a) Every weekend from Saturday at 9:30 a.m. until Sunday at 9:00 p.m. until November 9, 2002. 1 (b) Every weekend from Sunday at 9:30 a.m. until Tuesday at 7:00 p.m. beginning November 9, 2002. 4. The parties shall share holidays and other special occasions as they agree. 5. Father shall have any other visitation to be agreed upon by the parties. 6. The parties agree that transportation for all periods of partial custody shall be provided by the Father or the Father's parents. The custody shall take place at the Father's parents' home located at 891 Wildlife Lodge Road, Lower Burrell, PA 15068. 7. The parties hereby acknowledge that Mother shall be permitted a two- week period wherein she shall be permitted to visit maternal grandmother who presently resides in the State of Arizona, with the following conditions: (a) Mother shall provide to Father, in writing, at least ten (10) days in advance, a specific address and telephone number where Mother and child will be residing and may be contacted. (b) Mother shall also, at the time of the ten-day notice to Father, contact Comprehensive Counseling Center at Telephone No. (724) 832-4450 in order to make arrangements so that within forty-eight (48) hours of her return to Westmoreland County, Comprehensive Counseling Center may meet with the minor child for monitoring purposes. 2 • • (c) Father shall be permitted to contact and speak with the minor child by telephone at least one (1) time per day, with a time to be agreed to in advance by the parties. (d) At the conclusion of said two-week period, Mother is directed to insure that the minor child is returned to Westmoreland County, Commonwealth of Pennsylvania. 8. Neither party shall be permitted, other than the above stated terms of Paragraph 7, to remove the minor child from the Commonwealth of Pennsylvania without written consent of the parties or further Order of Court. 9. This court hereby retains jurisdiction of this case regarding custody matters until further Order of Court. 10.A review conference is hereby scheduled for August of 2003. In the event that the parties reach a consent agreement, they are permitted to notify the court in reference to canceling the review conference. ATTEST' BY THE COURT: SON DIE.HL PROTHONOTARY *'Anthony Vv. rsili, Judge( Cc: File Raymond W. Bitar, Esq. - Attorney for Father Maureen Kroll, Esq. - Attorney for Mother Came Gallatin - CCC Connie Hetrick - Family Court Administrator 3 0 0 IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA CIVIL DIVISION - CUSTODY BRIAN DAVID CAVADA, ) Plaintiff ) No. 1136 of 2002-D VS. ) CARI LEE CAVADA, ) Defendant ) AMENDED ORDER OF COURT AND NOW, to wit, this 21st day of October, 2002, it is hereby ORDERED, ADJUDGED and DECREED that Paragraph 10 of the Order of Court dated October 17, 2002, is amended to state that the Review Conference is scheduled for Thursday, the 10 day of August, 2003 at 9:00 a.m., before the undersigned in Courtroom No. 8. In the event that the parties reach a consent agreement prior to the scheduled date, the Review Conference will be canceled at that time. All other terms and conditions of the October 17, 2002 Order of Court are to remain in full force and effect. BY T COURT: Anthony, . rsili, J. A T: + a4re PROTHONOTARY cc: Raymond W. Bitar, Esquire, Attorney for Plaintiff Maureen Kroll, Esquire, Attorney for Defendant File Carrie Gallatin, CCC Connie Hetrick, Family Court Administrator T yl-i I C.J I r (`? -n cr IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA CIVIL DIVISION - CUSTODY BRIAN DAVID CAVADA, ) Plaintiff ) No. 1136 of 2002-D vs. ) CARI LEE CAVADA, ) Defendant ) r ORDER OF COURT I AND NOW, to wit, this 11th day of February 2003 , due to the recent change in the Family Court calendar, it is hereby ORDERED, ADJUDGED and DECREED that the Review Conference previously scheduled for Thursday, August 14, 2003 at 9:00 o'clock a.m., is hereby rescheduled for Tuesday, the 12t' day of August, 2003 at 9:00 o'clock a.m., before the undersigned in Courtroom No. 8. At that time, the parties, the attorneys of record and the representative from Comprehensive Counseling Center are directed to appear. All other terms and conditions of previous Orders of Court, not in conflict with this Order of Court, shall remain in full force and effect. BY THE COURT: AAnthon 4GM iii, J. cc: Raymond W. Bitar, Esquire, Attorney for Plaintiff AT Maureen Kroll, Esquire, Attorney for Defendant RON UI`k Came Gallatin, Comprehensive Counseling Center PROThCONOT, 4yr File 0 IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA CIVIL DIVISION - CUSTODY BRIAN DAVID CAVADA, ) Plaintiff ) No. 1136 of 2002-D vs. ) CARI LEE CAVADA, ) Defendant ) ORDER OF COURT AND NOW, to wit, this 20"' day of May 2003, due to an additional conflict in the Court's schedule, it is hereby ORDERED, ADJUDGED and DECREED that the Review Conference previously scheduled for Tuesday, August 12, 2003 at 9:00 o'clock a.m., is hereby rescheduled for Monday, the 25°i day of August, 2003 at 2:30 p.m., before the undersigned in Courtroom No. 8. At that time, the parties, the attomeys of record and the representative from Comprehensive Counseling Center are directed to appear. All other terms and conditions of previous Orders of Court, not in conflict with this Order of Court, shall remain in full force and effect. BY THE COURT: ArMST: cc: RON ME HL PROTHONGTARY nthony . M i, J. Raymond W. Bitar, Esquire, Attomey for laintiff Maureen Kroll, Esquire, Attomey for Odfend t Came Gallatin, Comprehensive Counseling Center File 6 t • • IN THE COURT OF COMMON PLEAS IN WESTMORELAND COUNTY, PENNSYLVANIA - FAMILY DIVISION BRIAN DAVID CAVADA, Plaintiff vs. CARI LEE CAVADA, Defendant co c~ C" ° t ?r tr - l.ii Ca ? CU No.: 1136 of 2002-D TYPE OF PLEADING: MOTION TO CONTINUE FILED ON BEHALF OF: Brian David Cavada, Plaintiff COUNSEL OF RECORD FOR THIS PARTY: RAYMOND W. BITAR, ESQUIRE Suite 10 Feldarelli Square 2300 Freeport Road New Kensington, PA 15068 (724) 339-1023 PA I.D. #19676 • • IN THE COURT OF COMMON PLEAS IN WESTMORELAND COUNTY, PENNSYLVANIA - FAMILY DIVISION BRIAN DAVID CAVADA, ) Plaintiff ) VS. ) CARI LEE CAVADA, ) Defendant ) No.: 1136 of 2002-D MOTION TO CONTINUE AND NOW comes the Plaintiff, Brian David Cavada, by and through his attorney, Raymond W. Bitar, Esquire and states the following: 1. A Review Conference is scheduled before the Honorable Judge Anthony G. Marsili on the 25th day of August, 2003 at 2:30 PM in Courtroom 8. 2. Raymond W. Bitar, Esquire is unable to attend said Review Conference on that day. 3. Raymond W. Bitar, Esquire respectfully request a continuance of the Review Conference scheduled for August 25, 2003 at 2:30 PM. WHEREFORE, we pray that this Honorable Court will grant a continuance of the above noted matter. Re 1 submitted Raymond W. itar, Esquire Attorney for Plaintiff E • IN THE COURT OF COMMON PLEAS IN WESTMORELAND COUNTY, PENNSYLVANIA - FAMILY DIVISION BRIAN DAVID CAVADA, ) Plaintiff ) vs. ) CARI LEE CAVADA, ) Defendant ) No.: 1136 of 2002-D ORDER OF COURT AND now to wit this 10 7kday of '? 0 , 2003, it is hereby ORDERED, ADJUDGED AND DECREED an upon the consent of the parties that the Review Conference scheduled for the 25`" day of August 2003 at 2:30 PM is continued until the [day of NQN , 2003 at LU k5 N?- o'clock at the Westmoreland County Courthouse in Greensburg, Pennsylvania before Judge Anthony G. Marsili in Courthoom 8. ATTEST: RON Dl`=! RROTHON? W4, Y Consenting: Maureen Kroll, Esquire - consented via telephone BY THE COURT: IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA CIVIL DIVISION - CUSTODY BRIAN DAVID CAVADA ) C= , Plaintiff ) No. 1136 of 2002-D vs. orn z,. a rz CART LEE CAVADA, ) ?? Defendant ) ? cn r ORDER OF COURT AND NOW, to wit, this 10' day of November 2003, with a Review Conference having been scheduled for this date, and after receiving information from the attorney of record on behalf of Mother that both attorneys received information from their respective clients as to neither party wishing to be present for the Review Conference and that neither party has any strong objections to the current status of the matter, therefore, it is hereby ORDERED, ADJUDGED and DECREED as follows: 1. That the terms and conditions of the October 17, 2002 Order of Court shall remain in full force and effect. 2. That the Review Conference is hereby cancelled, the matter concluded, and that Comprehensive Counseling Center may conclude its involvement and close interest in this case. 3. That as of this date, regarding costs for services rendered by Comprehensive Counseling Center, Father has paid in full his pro rata amount of $726.00; Mother, whose pro rata share was $426.00, has a remaining outstanding •r i balance of $255.00. Accordingly, Mother is directed to make monthly payments of $50.00 per month until the balance has been paid in full. BY THE COURT: 4Antho G arsili, J. ATTEST: ;1 ' a?" PROTHONOTARY cc: Raymond W. Bitar, Esquire, Attorney for Plaintiff Maureen Kroll, Esquire, Attomey for Defendant Came Gallatin, Comprehensive Counseling Center File 2 0 0 IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA - FAMILY DIVISION - LAW BRIAN DAVID CAVADA, Plaintiff VS. No.: 1136 OF 2002-D CARI LEE CAVADA, Defendant AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENT 1. A complaint in divorce under section 3301(c) of the Divorce Code, was filed on June 19, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint. 3. I consent to the entry of a final decree of divorce without notice. 4. 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. 5. 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 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. Section 4904 relating to uns rn falsification to authorities. + ? ??if )140 Date: - L!_)8d --- =" tv XV ari Lee Cavada E 1 :6 NV 92 NVf h001 31,q ?, ` C? IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA - FAMILY DIVISION - LAW BRIAN DAVID CAVADA, Plaintiff VS. No.: 1136 OF 2002-D CARI LEE CAVADA, Defendant AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENT 1. A complaint in divorce under section 3301(c) of the Divorce Code, was filed on June 19, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint. 3. I consent to the entry of a final decree of divorce without notice. 4. 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. 5. 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 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. Section 4904 relating to unsworn falsification to authorities. Date: 2?t?o y 71 T 1-- r'+.. 0 V-- L CL Brian David Cavada • IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA - FAMILY DIVISION - LAW BRIAN DAVID CAVADA, Plaintiff VS. No.: 1136 OF 2002-D CARI LEE CAVADA, Defendant AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA) SS COUNTY OF WESTMORELAND ) Brian David Cavada, Plaintiff, being duly sworn according to law, deposes and says that he is the Plaintiff in the above matter; that he personally knows the Defendant, is over the age of eighteen (18) years; and that the Defendant is not in the military or naval service of the United States or its allies or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of 1940 and its amendments. Zf",-/l 61-1 Brian David Cavada SWORN TO and subscribed before me this r day 20(. ?•?/1.?7ba(y S? Notary Public My Commission Expires: %.-- Frances New Kensing, 2005 My Commissunt Member, Pennsyvania ssoiation of Notaries .2 C ?- r C 7) M - - Co C) < Z J 0 0 IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA - FAMILY DIVISION - LAW BRIAN DAVID CAVADA, Plaintiff vs. No.: 1136 OF 2002-D CARI LEE CAVADA, Defendant PRAECIPE TO TRANSIMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: --Irretrievable Breakdown 2. Date and manner of service of the Complaint: --Accepted by certified mail, restricted delivery on June 24, 2002. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce code: 6 --by Plaintiff, by Defendant, U 4. Related claims pending: --none zcs= Raymond W. Bitar, Esquire Attorney for Plaintiff -n w co .. (. O . -1 z IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA - FAMILY DIVISION BRIAN DAVID CAVADA, Plaintiff VS. CARI LEE CAVADA, Defendant FAMILY DIVISION No.: 1136 of 2002-D TYPE OF PLEADING: 'AMENDED ORDER OF COURT REGARDING CUSTODY FILED ON BEHALF OF: BRIAN DAVID CAVADA, Plaintiff Counsel for Record for this Party: RAYMOND W. BITAR, ESQ. PA I. D. # 19676 BITAR & BITAR, L.L.P. Suite 10 Feldarelli Square 2300 Freeport Road New Kensington, PA 15068 (724) 339-1023 (724) 330-3349 fax IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA BRIAN DAVID CAVADA, Plaintiff, CIVIL DIVISION - LAW (CUSTODY) NO.: 1136- OF 2002 - D Vs. CARI LEE CAVADA, NAME OF PLEADING: Defendant. s N _ ?T rQ - -_ ,may [. i..10 ct C) . a Petition to Modify Custody FILED ON BEHALF OF: Cari Lee Cavada, Defendant COUNSEL OF RECORD: Maureen Kroll, Esquire Pa. I.D. No. 61359 8981 Norwin Avenue Norwin Hills Office Park Suite 203 N. Huntingdon, PA 15642 (724) 863-6770 IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY,PENNSYLVANIA CIVIL ACTION - LAW (CUSTODY) BRIAN DAVID CAVADA, ) Plaintiff, ) Vs. ) CARI LEE CAVADA, ) Defendant. ) No. 1136 OF 2002 - D PETITION TO MODIFY CUSTODY ORDER AND NOW, COMES the Petitioner/Defendant, CARI LEE CAVADA, by and through her attorney, MAUREEN KROLL, ESQUIRE, and avers the following in support of her Petition to Modify Custody Order: 1. The Petitioner is Cari Lee Cavada. 2. The Respondent is Brian David Cavada. 3. The parties are the parents of Meghan Lee Cavada, born November 3, 1998. 4. A Custody Order was entered into on October 17, 2002, wherein Petitioner was awarded primary physical and the parties were awarded shared legal custody of the minor child. A copy is attached hereto and marked as Exhibit "A". 5. The Petitioner/Defendant has moved to Long Island, New York. 6. The Petitioner/Defendant is desirous of having the minor child visit her every other weekend and the exchange to be in Allentown, Pennsylvania. 7. The Petitioner/Defendant is also requesting to have her minor child for two (2) consecutive weeks of time in the summer. WHEREFORE, Petitioner/Defendant requests this Honorable Court to enter an Order granting the Petitioner/Defendant a hearing to determine the matter within. Respectfully submitted, Matreen Krol Attorney for Esquire titioner VERIFICATION I, Cari Lee Cavada, verify that the statements made in this Petition to Modify Custody Order are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. falsification to authorities. § 4904, relating to unsworn ?/Vdv. ?? 2,0 Y Date Ca- Cxzg " ( ri Lee Cavada _ C, -. 9 M IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY,PENNSYLVANIA CIVIL ACTION - LAW (CUSTODY) BRIAN DAVID CAVADA, ) Plaintiff, ) Vs. ) No. 1136 OF 2002 - D CARI LEE CAVADA, ) Defendant. ) ORDER OF COURT t7'Jt/ AND NOW, to wit this /J day of Alov"aA... , 2004, it is hereby ADJUDGED, ORDERED and DECREED that a hearing is scheduled for L?? ic_l ?sprlu?ry 3 , 200! at 11 /0.'06 19.M. to determine the within matter. , aos;?4v axC4 BY THE COURT: l r J. Z4 A,iEc"nf' RQ?j [itrHL pR0Tti0jq6TAR1 0 0 IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW CUSTODY BRIAN DAVID CAVADA ) No: 1136 OF 2002-D VS. IE )- ? CART LEE CAVADA ) C Defendant ) r CONSENT ORDER OF COURT o AND NOW, this 3rd day of January, 2005, IT IS HEREBY ORDERED AND DECREE that shared legal custody of the minor child, Meghan Lee Cavada, born November 3, 1998, is granted to the Mother, Cari Lee Cavada, Defendant herein, and to the Father, Brian David Cavada, Plaintiff herein. Primary physical custody of the minor child is granted to the Father. Mother shall secure the services of a private detective agency to perform a complete background check on Christian Marsh, including but not limited to current employment, employment history, criminal background check and residence history. The report shall be provided to counsel of record, who shall have authority to speak directly to the investigator. If counsel do not agree as to the findings of the report, then the Custody Conciliation Conference shall be rescheduled for Wednesday, February 23, 2005 at 10:00 a.m. before the undersigned Custody Hearing Officer. If counsel agree as to the findings of the report, then Mother shall have partial physical custody of the minor child as follows: 1. Alternate weekends from Friday at 7:30 p.m. until Sunday at 5:00 p.m. 2. The custody exchange shall take place in Allentown, Pennsylvania at a public location mutually agreeable to the parties. -< r1' 3. One week of vacation during the month of July and one week of vacation during the month of August. Mother shall give Father at least thirty days written notice of her vacation selection. Mother will plan her vacation from work during this time period. 4. In 2005, and in every odd year thereafter, from Christmas Eve at 9:00 a.m. until December 26 at 7:30 p.m. 5. The holidays of Easter and Thanksgiving will be shared by the parties from year to year as the parties may mutually agree. 6. Any additional periods of physical custody as the parties may mutually agree. This Order of Court shall remain in full force and effect until further Order of Court. BY;,?KCOIJRT: CON ING: B ' vid Cavada, Plaintiff Raymond W. Bitar, CWnsel for Plaintiff Kroll, Co4n)el for Defendant C. ATTES . 'j* V K Ron M6 1, Prothonotary IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA BRIAN DAVID CAVADA, CIVIL DIVISION - LAW (CUSTODY) Plaintiff, NO.: 1136- OF 2002 - D Vs. CARI LEE CAVADA, Defendant. us>- T- G cr : -- Cn ? t 8'ON !tCd 3 '? _4ir1.h Xb 6Z :01 WV Ow V-111111 1,[Nnoo Gi .?: ; rr NAME OF PLEADING: Petition to Modify Custody FILED ON BEHALF OF: Cari Lee Cavada, Defendant COUNSEL OF RECORD: Maureen Kroll, Esquire Pa. I.D. No. 61359 8981 Norwin Avenue Norwin Hills Office Park Suite 203 N. Huntingdon, PA 15642 (724) 863-6770 IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY,PENNSYLVANIA CIVIL ACTION - LAW (CUSTODY) BRIAN DAVID CAVADA, ) Plaintiff, ) Vs. } No. 1136 OF 2002 - D CARI LEE CAVADA, ) Defendant. ) MOTION TO CONTINUE AND NOW COMES the Defendant, CARI LEE CAVADA, by and through her attorney, Maureen Kroll, Esquire, and respect fully avers as follows: 1. The Plaintiff is Brian David Cavada and is represented by Attorney Raymond W. Bitar. 2. The Defendant is Cari Lee Cavada and is represented by Attorney Maureen Kroll. 3. Defendant received notice of a Custody Conciliation Hearing scheduled for February 23, 2005 at 10:00 A.M. 4. Defendant's attorney is unable to attend the hearing on February 23, 2005 hearing due to a scheduling conflict. 8. Plaintiff's attorney has agreed to the continuance. WHEREFORE, Defendant, CARI LEE CAVADA, prays this Honorable Court to continue this hearing until the next available hearing date. Respectfully Submitted, Maureen Kroll, uire Attorney for Defendant 0 0 IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY,PENNSYLVANIA CIVIL ACTION - LAW (CUSTODY) BRIAN DAVID CAVADA, ) Plaintiff, ) Vs. ) CARI LEE CAVADA, ) Defendant. ) No. 1136 OF 2002 - D ORDER OF COURT AND NOW, to wit this day of 2005, it is hereby ADJUDGED, ORDERED and DECREED that a Custody Conciliartion Conference is scheduled for /.? 2005 at M. to determine the within matter. BY THE COURT: ROPROTtjGINC?TARY . CONSENTED TO: Ray?morid W itar, 'Esquire Attorney for Plaintiff f r Maureen Kroll, quire Attorney for De endant IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA BRIAN DAVID CAVADA, Plaintiff, Vs. CARI LEE CAVADA, Defendant. c? a J Y cnO Q uc0 N >- d CL .C Ow g CIVIL DIVISION - LAW (CUSTODY) NO.: 1136- OF 2002 - D NAME OF PLEADING: Motion to Cancel FILED ON BEHALF OF: Cari Lee Cavada, Defendant COUNSEL OF RECORD: Maureen Kroll, Esquire Pa. I.D. No. 61359 8981 Norwin Avenue Norwin Hills Office Park Suite 203 N. Huntingdon, PA 15642 (724) 863-6770 IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY,PENNSYLVANIA CIVIL ACTION - LAW (CUSTODY) BRIAN DAVID CAVADA, ) Plaintiff, ) Vs. ) No. 1136 OF 2002 - D CARI LEE CAVADA, ) Defendant. ) MOTION TO CANCEL AND NOW COMES the Defendant, CARI LEE CAVADA, by and through her attorney, Maureen Kroll, Esquire, and respect fully avers as follows: 1. The Plaintiff is Brian David Cavada and is represented by Attorney Raymond W. Bitar. 2. The Defendant is Cari Lee Cavada and is represented by Attorney Maureen Kroll. 3. Defendant received notice of a Custody Conciliation Hearing scheduled for February 23, 2005 at 10:00 A.M., which was continued to April 18, 2005 at 1:00 P.M. 4. The parties have been following the Consent Order of Court dated January 3, 2005. 5. The parties have worked out all visitation issues and are in agreement that another hearing is unnecessary at this time. 6. Plaintiffs attorney has agreed to the cancellation. WHEREFORE, Defendant, CARI LEE CAVADA, prays this Honorable Court to cancel the hearing scheduled for April 18, 2005 at 1:00 P.M. Respectfully Submitted, a2?? J Maureen Kroll Esquire Attorney for Defendant IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY,PENNSYLVANIA CIVIL ACTION - LAW (CUSTODY) BRIAN DAVID CAVADA, ) Plaintiff, ) Vs. ) CARI LEE CAVADA, ) Defendant. ) No. 1136 OF 2002 - D ORDER OF COURT AND NOW, to wit this ? ay of , 2005, it is hereby ADJUDGED, ORDERED and DEC EED that a Custody Conciliartion Conference is scheduled for April 18, 2005 at 1:00 P.M. to determine the within matter is cancelled. RON PROTHONOTARY CONSENTED TO: BY THE COURT: 67. ?Ra nd W. Bitar, Esquire Attorney for Plaintiff A?& 4reM`enK!rr-oo111(,) Esquire Attorney for Defendant 11 6 0 IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA BRIAN DAVID CAVADA, Plaintiff vs. CARI LEE CAVADA, Defendant No.: 1136 of 2002-D ORDER OF COURT AND NOW to wit, this 2 R day of J" 2010, upon consideration of the following: Brian David Cavada, the Plaintiff named above, currently resides in 215 Reno Avenue, New Cumberland, Pennsylvania 17070. 2. Cari Lee Cavada, the Defendant named above currently lives outside of Pennsylvania. 3. Mr. Cavada has requested that the venue be transferred to New Cumberland County. 4. It is hereby ORDERED, ADJUDGED, and DECREED that the above case will be transferred to New Cumberland County, Pennsylvania. BY THE COURT: %AV -x z J. ATTEST CHRISTINA O'BRIEN PROTHONOTARY a 0 Date: ) X" - Certified to be a C True Copy Prothonotary Carrucoli & Associates, P.C. 875 Market Street Suite 200 Lemoyne, PA 17043 Attorney for Defendant BRIAN DAVID CAVADA, Plaintiff V. CARI LEE CAVADA, Defendant. FILED-OFFICE DP THE PROTHONOTARY 2010 DEC -2 PM 1: 14 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 2010-1723 CIVIL ACTION - LAW CUSTODY PETITION FOR CONTEMPT AND PETITION FOR MODIFICATION OF CUSTODY AND NOW, comes Defendant, Cari Lee Cavada, by and through her counsel, Cindy L. Villanella, Esq., of Carrucoli & Associates, P.C., and avers the following in support of her Petition: Cari Lee Cavada, hereinafter "Mother," resides at 2029 Cunningham Drive, Apt. 201, Hampton, Virginia 23666. 2. Brian David Cavada, hereinafter "Father," resides at 215 Reno Avenue, New Cumberland, Pennsylvania 17070. 3. The parties are the parents of Meghan Lee Cavada, born November 3, 1998. 4. A stipulated Order of Court was entered on January 3, 2005 by the Court of Common Pleas of Westmoreland County. This order granted the parties shared legal custody of the minor child with Father having primary physical custody and Mother having partial physical STD a Carrucoli & Associates, P.C. 875 Market Street Suite 200 Lemoyne, PA 17043 Attorney for Defendant custody of the minor child on alternating weekends. The current Custody Order is attached hereto and incorporated herein as Exhibit "A." On January 29, 2010, Father requested that the case be transferred to Cumberland County, where Father and the minor child are currently residing. The Order transferring jurisdiction is attached hereto and incorporated herein as Exhibit "B." 6. Father has prevented Mother from having her periods of partial physical custody of the minor child since 2006, when Mother spent Thanksgiving with the child. 7. Mother visited Father's home in New Cumberland, PA in 2008 and Father would not allow her to see the minor child. 8. Mother has sent various gifts and cards to the minor child and has no knowledge of whether or not the minor child ever received such items. 9. During the times Father would allow Mother to have phone contact with the minor child, the Father would not allow the minor child to speak to the Mother in private. 10. Mother wishes to resume her partial physical custody of the minor child and also wishes to have shared custody of the minor child during summer and school vacations. 11. Mother has incurred reasonable attorney's fees in the preparation and presentation of this Petition for Contempt. WHEREFORE, Mother requests this Honorable Court: a. find Father in contempt of court and order Father to follow the current custody order; b. order Father to pay Mother's reasonable attorney's fees; and Carrucoli & Associates, P.C. 875 Market Street Suite 200 Lemoyne, PA 17043 Attorney for Defendant c. grant Mother the additional time requested as stated above. Date: -iVQ / //a Respectfully submitted, ?ella, Esq. .D. Num. . Carirucoli & Associates, P.C. PA Supreme Court ID 202325 875 Market Street Lemoyne, PA 17043 Carrucoli & Associates, P.C. 875 Market Street Suite 200 Lemoyne, PA 17043 Attorney for Defendant VERIFICATION I, Cari Lee Cavada, verify that the statements made in this Petition to Modify Custody 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: -10 t r6mI) ari Lee Cavada Carrucoli & Associates, P.C. 875 Market Street Suite 200 Lemoyne, PA 17043 Attorney for Defendant BRIAN DAVID CAVADA, Plaintiff V. CARI LEE CAVADA, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 2010-1723 CIVIL ACTION - LAW CUSTODY CERTIFICATE OF SERVICE I, Cindy L. Villanella, Esq., hereby certify that a true and correct copy of the Petition for Contempt and Petition to Modify Custody was served this date on the below named, by placing same in the United States mail, certified, postage prepaid thereon, addressed as follows: Brian David Cavada 215 Reno Ave. New Cumberland, PA 17070 a Date: ///,g BRIAN DAVID CAVADA IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA c V ma) CD M = . 2010-1723 CIVIL ACTION LAW M ? F -0m z ? QO CARI LEE CAVADA -<> r x J . 0 IN CUSTODY n° DEFENDANT =C:> w ? n C3 . s,c :Z M -< N D ORDER OF COURT AND NOW, Tuesday, December 07, 2010 , upon consideration of the attached Complai nt, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Monday, December 27, 2010 at 9:00 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/ Dawn S. Sunda Es q. 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 ,. PV I C BRIAN D. DA, Plaintiff/Respondent VS. CARI L. CAVADA, Defendant/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010 -1723 CIVIL ACTION -- LAW IN CHILD CUSTODY PLAINTIFF'S RESPONSE TO DEFENDANT'S PETITION FOR CONTEMPT AND MODIFICATION OF CUSTODY AND NOW, comes Plaintiff/Respondent, Brian D. Cavada, (hereinafter "Father"), by and through his attorney, Linda A. Clotfelter, Esquire, and files this response to Defendant's Petition for Contempt and Modification of Custody, respectfully stating as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. rj CD r"I r- r.11) c? rrt C-) N .^ W V w r-D M CD C7 l V rn r 6. Denied. It is specifically denied that Father has prevented Mother from having partial custody periods since 2006. In further answer hereof, in 2006 without prior notice to Father and without first petitioning to relocate, Mother made the current Order of alternating weekends impossible upon her move to Virginia Beach, Virginia. Mother has made no attempts to contact the child by telephone, text or otherwise for the past 14 months. Her last attempt to contact the child was a voicemail left on the home answering machine on November 3, 2009, during the day while the child was in school when Mother stated, "I just called to wish Meg a happy birthday. I will call back later." Mother did not call again. Mother's last custody period was November 2006 at the maternal grandparent's home in the Washington D.C. area. The child has never gone to Virginia Beach with Mother. Earlier that November Mother was a no show for the child's birthday party and shortly after the November visit Mother cancelled her New Year's holiday time. Mother's efforts to maintain a relationship with the child since then have been almost non-existent. Mother has stated that she will call or write the child and often failed to follow through with the acts. Two years after the last visit, Mother appeared unannounced to see the child on November 1, 2008 and the child, who has been traumatized by Mother's conduct, asked to talk to a police officer rather than seeing her mother. In the two years since that time Mother's contact with the child has been limited to seven (7) text messages; Mother left one voicemail and there was one voicemail from the maternal grandparents. There has been no effort on Mother's part whatsoever for fourteen (14) months as stated above, until the instant proceeding for contempt was initiated. Given these facts and the concern that the child's reaction to Mother's attempt to contact her may cause irreparable emotional harm, Father wishes to have any reunification proceed only upon the involvement of a family therapeutic counsellor or similar professional especially given the fact that Father has no information from Mother regarding her household, its residents and whether the child being there at some future time would be in the child's best interests. 7. Admitted in part and denied in part. It is admitted that Mother appeared at Father's home, but her appearance was unannounced and the child, who was traumatized by the unexpected appearance refused to see her mother and instead asked to talk to the police officer who, after reviewing the Order and talking to the child directed Mother to leave the property. Mother has made no attempts to see the child to any extent since then until the Petition for Contempt and for Modification of Custody. Also see Father's answer to paragraph 6, above. 8. Denied. The allegations of this paragraph are denied as Father lacks sufficient knowledge or information to determine the truth of the allegation. Therefore strict proof thereof is demanded. 9. Denied. The child, who has been traumatized by her Mother's repeated broken promises and failure to show any love or concern, has been adamant in her preference that she not have contact with her mother by telephone or otherwise and when it occurs she has sought the support of her family during those stressful times and it is anticipated that she will continue to do so. Moreover, the child expressly wrote Mother and asked that their contact begin with simple regular emails. Despite Mother's agreement to that process for contact, Mother failed to follow through with the regular emails and as stated, has made no effort to contact the child in 14 months. 10. Denied. States a conclusion to which no response is required. In further answer, any implication that any physical custody to Mother at this point in time is in the best interests of the child is specifically denied. The child feels strongly about her Mother's conduct in ignoring her existence and given her emotional response to these matters it is anticipated that any reunification must be very gradual and only upon the recommendation of a professional. 11. Denied. States a conclusion of law to which no responsive pleading is required. Therefore, strict proof is demanded. WHEREFORE, Father respectfully requests that this Honorable Court deny Mother's Petition for Contempt and for counsel fees and enter an Order stating that any reunification proceed as per the recommendation of a professional and granting such other relief as this Court deems just and proper. Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER Dated: / J 5021 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 (717) 796-1930 telephone (717) 796-1933 facsimile BRIAN D. CAVADA, : IN THE COURT OF COMMON PLEAS OF PtiiWUVRespondent : CUMBERLAND COUNTY, PENNSYLVANIA Vs. : NO. 2010 - 1723 CARI L. CAVADA, : CIVIL ACTION - LAW Defezdant/Petitioner : IN CHILD CUSTODY VERIFICATION I, BRIAN D. CAVADA, verify that the statements in the foregoing document are true and correct to the best of my knowledge, information and belief I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904, relating to unswom falsification to authorities. Date: / Z'.2?-20/° BRIAN D. CAVADA BRIAN D. CAVADA, Plaintiff/Respondent VS. CARI L. CAVADA, Defendant/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2010 -1723 : CIVIL ACTION - LAW : IN CHILD CUSTODY CERTIFICATE OF SERVICE AND NOW, this q day of December, 2010, the undersigned hereby certifies that a true and correct copy of the foregoing Plaintiffs Response to Defendant Petition for Contempt and Modification of Custody was served upon the interested parties by facsimile and first class mail, postage prepaid, addressed as follows: Dawn S. Sunday, Esquire 39 West Main Street Mechanicsburg, PA 17055 Cindy Villanella, Esquire 875 Market Street Suite 100 Lemoyne, PA 17043 Dated: 1 A h f I a Lida A. Clotfelter, Esquire Attorney ID No. 72963 5021 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 (717) 796-1930 telephone (717) 796-1933 facsimile Attorney for Plaintiff 110 2011 2 BRIAN DAVID CAVADA IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2010-1723 CIVIL ACTION LAW CARI LEE CAVADA Defendant : IN CUSTODY ORDER OF COURT AND NOW, this Iday of 1 kh J ary 2011, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The parties shall make arrangements for the Mother and the Child to participate in reunification counseling with a professional to be selected by agreement. The purpose of the counseling shall be to assist in the reestablishment of the parent child relationship between the Mother and the Child and also to provide guidance to the family in support of fostering that relationship and promoting the emotional well-being of the Child. The parties shall follow the recommendations of the counselor with regard to initiating contact between the Mother and the Child. Any costs of the counseling which are not covered by insurance shall be shared equally between the parents. The parties shall sign any authorizations deemed necessary by the counselor in order to provide information to the parties' counsel or to obtain additional information pertaining to the parties or the Child. 2. Within three months of the date of this Order, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference, if necessary, to establish custodial arrangements following counseling. BY THE COURT, J. cc: ?Cindy L. Villanella, Esquire Counsel for Mother = Linda A. Clotfelter, Esquire Counsel for Father ?I ies o ?l OP DID IX r_ -r < _ _ ? iTa BRIAN DAVID CAVADA Plaintiff VS. CARI LEE CAVADA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2010-1723 CIVIL ACTION LAW Defendant . IN CUSTODY 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 Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Meghan Lee Cavada November 3, 1998 Father 2. A custody conciliation conference was held on December 30, 2010, with the following individuals in attendance: the Father, Brian D. Cavada, with his counsel, Linda A. Clotfelter, Esquire, and the Mother, Cari Lee Cavada, with her counsel, Cindy L. Villanella, Esquire. 3. The parties agreed to entry of an Order in the form as attached. 1 1-.,r, 0th 12011 Date Dawn S. Sunday, Esqui Custody Conciliator COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Briecuu--- Plaintiff ) ) ) v. ) No. 10-1723 bk( 1—‘)) Defen ant ) °t– 0A-vt Lao fr)(k- Petition for Contempt and Modification co 1. Petitioner isbF(; CARI L. GRIGSBY, who currently resides at 2825 Ironbound Rd, Williamsburg, James City County County, VA 23185. 2. Respondent is QC, >, BRIAN D. CAVADA, who currently resides at 511 Jacob Lane, Mechanicsburg, Cumberland County, PA 17050. 3. Petitioner and Respondent are the natural parents of the following child: Name MEGHAN L. CAVADA Age 15 years 4. A custody order was entered on 01/03/2005, in the Cumberland County Court of Common Pleas. A copy of the custody order is attached. 5. Respondent has willfully violated the custody order, as follows: The order has been violated by the father of the child. Father has not allowed any communication whatsoever between mother and daughter since 11/2006. 6. Petitioner seeks to modify the custody order because: It is in the best interest for the current order to be changed to guarantee, and give set guidelines in regards to communication and visitation between mother and daughter. If a new order is in place the child may not be afraid to have a relationship with the mother as the relationship has been denied by the father since 2006. 7. Petitioner believes the custody order should be changed as follows: Custody remain the same as shared legal custody of the child. With mother having visitation on a regular 1/4* 23 . 00 poi C'aS3//02 6 L, Petition for Contempt and Modification Page 3 of 5 basis as well as holidays, and summer vacation (more than 2 weeks at a time). Phone calls every night as well as when child would like to speak to mother including emails, or any other forms of communication. WHEREFORE, Petitioner respectfully requests that this Court find Respondent in contempt of Court and modify the Order as requested. D,,e q ke.N Verification I, CARI L. GRIGSBY, Plaintiff; verify that the facts stated in the foregoing Petition are true and correct to the best of my knowledge, information and belief. Petitioner understands that false statements therein are subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Date: q A.F;\ (.1-1 CARI L. GRIG 'C Y, PI intiff Petition for Contempt and Modification Page 4 of 5 • IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW CUSTODY BRIAN DAVID CAVADA VS. CARI LEE CAVADA Defendant ) ) ) No: 1136 OF 2002-0 ) ) ) ) ) ) CONSENT ORDER OF COURT AND NOW, this 3rd day of January, 2005, IT IS HEREBY ORDERED AND DECREE that shared legal custody of the minor child, Meghan Lee Cavada, born November 3, 1998, is granted to the Mother, Cari Lee Cavada, Defendant herein, and to the Father, Brian David Cavada, Plaintiff herein. Primary physical custody of the minor child is granted to the Father. Mother shall secure the services of a private detective agency to perform a complete background check on Christian Marsh, including but not limited to current employment, employment history, criminal background check and residence history. The report shall be provided to counsel of record, who shall have authority to speak directly to the investigator. If counsel do not agree as to the findings of the report, then the Custody Conciliation Conference shall be rescheduled for Wednesday, February 23, 2005 at 10:00 a.m. before the undersigned Custody Hearing Officer. If counsel agree as to the findings of the report, then Mother shall have partial physical custody of the minor child as follows: 1. Alternate weekends from Friday at 7:30 p.m. until Sunday at 5:00 p.m. 2. The custody exchange shall take place in Allentown, Pennsylvania at a public location mutually agreeable to the parties. 3. One week of vacation during the month of July and one week of vacation during the month of August. Mother shall give Father at least thirty days wriffen notice of her vacation selection. Mother will plan her vacation from work during this time period. 4. In 2005, and in every odd year thereafter, from Christmas Eve at 9:00 a.m. until December 26 at 7:30 p.m. 5. The holidays of Easter and Thanksgiving will be shared by the parties from • year to year as the parties may mutually agree. 6. Any additional periods of physical custody as the parties may mutually agree. This Order of Court shall remain in full force and effect until further Order of Court. , Plaintiff nsel for P intiff el tor Defendant Bruce C. ATTES Ron IiehL Prothonotary • IN THE COURT OF COMMON PLEAS OF WESTMORELAND COUNTY,• PENNSYLVANIA BRIAN DAVID CAVADA, Plaintiff vs. CARI LEE CAVADA, Defendant No.: 1136 of 2002-D ORDER OF COURT AND NOW to wit, this 2/ day of considerationof the fpllowipg: Jebobtuitbb>.., , 2010, upon I. Brian David Cavada, the Plaintinamed above, currently resides in 215 Reno Avenue, New Cumberland, Pennsylvania 17070. 2. Cari Lee Cavada, the Defendant named above currently lives outside of Pennsylvania. 3. Mr. Cavada has requested that the venue be transferred to New Cumberland County. 4. It is hereby ORDERED, ADJUDGED, and DECREED that the above case will be transferred to New Cumberland County, Pennsylvania. BY THE COURT: ill is.j).- ATTEST CHRISTINA O'BRIEN 3C ..er cicD PROTHONOTARY cr% -) C:1 X < c2 , Certified to be a - True CoPY 01‘/', LC� �1 t IlYIN THE COURT OF COMMON PLEAS de Pe- CUMBERLAND COUNTY, PA &tic.. VsNo. )t) t 1'2 CIVIL TERM �4vV CIVIL ACTION - LAW Pi fe� ' &la- ' r7/�'i . IN CUSTODY(}-��% 090/ ii). CRIMINAL RECORD / ABUSE HISTORY VERIFICATION Cialikb"/.4ACI Cti , hereby swear or affirm, subject to penalties of . law including 18 Pa. C.S. § 4904 - lating torfi sworn falsification to authorities that: 1. Unless indicated by my checking the box next to a crime below, neither I nor any other member of my household have been convicted or pled guilty or pled no contest or was adjudicated delinquent where the record is publicly available pursuant to the Juvenile Act 42 Pa.C.S. § 6307 to any of the following crimes in Pennsylvania or a substantially equivalent crime in any other jurisdiction, including pending charges: Check all that apply Crime 18 Pa.C.S. Ch. 25 (relating to criminal homicide 18 Pa.C.S. §2702 (relating to aggravated assault) Self Other Date of Sentence household conviction, member guilty plea, no contest plea or pending charges �I 18 Pa.C.S. §2706 fl (relating to terroristic threats) 18 Pa.C.S. §2709.1 r (relating to stalking) 18 Pa.C.S. §2901 (relating to kidnapping) E ti 18 Pa.C.S. §2902 IT fl (relating to unlawful restraint) 18 Pa.C.S. §2903 r (relating to false imprisonment) 18 Pa.C.S. §2910 E E (relating to luring a child into a motor vehicle or structure) 18 Pa.C.S. §3121 IT f (relating to rape) 18 Pa.C.S. §3122.1 relating to statutory -sexual assault) 18 Pa.C.S. §3123 (relating to involuntary deviate sexual intercourse) 18 Pa.C.S. §3124.1 ri (relating to sexual assault) i 18 Pa.C.S. §3125 I1 (relating to aggravated indecent assault) 18 Pa.C.S. §3126 (relating to indecent assault) 18 Pa.C.S. §3127 (relating to indecent exposure) E El IT 18 Pa.C.S. §3129 [7] (relating to sexual intercourse with animals) 18 Pa.C.S. §3130 17 FT (relating to conduct relating to sex offenders), FT 18 Pa.C.S. §3301 r IT (relating to arson and related offenses) fl 18 Pa.C.S. §4302 (relating to incest) fl 18 Pa.C.S. §4303 (relating to concealing death of child) E 18 Pa.C.S. §4304 fl (relating to endangering welfare of children) ETJ 18 Pa.C.S. §4305 (relating to dealing in infant children) 18 Pa.C.S. §5902(b) fl (relating to prostitution and related offenses) fl 18 Pa.C.S. §5903 (c) or (d) (relating to obscene and other sexual materials and performances) n 17 18 Pa.C.S. §6301 FT (relating to corruption of minors) fl 18 Pa.C.S. §6312 (relating to sexual abuse of children) fl 18 Pa.C.S. §6318 (relating to unlawful contact with minor), 18 Pa.C.S. §6320 (relating to sexual exploitation of children) IT 23 Pa.C.S. §6114 EFT (relating to contempt for violation of Protection order or agreement) EJ Driving under the EJ F7 influence of drugs - or alcohol 1 Manufacture, sale, FT delivery, holding, offering for sale or possession of any controlled substance or other drug or device 2. Unless indicated by my checking the box next to an item below, neither I nor any other member of my household have a history of violent or abusive conduct including the following: Check all that apply IT A finding of abuse by a Children & Youth Agency or similar agency in Pennsylvania or similar statute in another jurisdiction Abusive conduct as defined under the Protection from Abuse Act in Pennsylvania or similar statute in Self Other household member 7,E Date another jurisdiction r Other: E fl 3. Please list any evaluation, counseling or other treatment received following conviction or finding of abuse: 4. If any conviction above applies to a household member, not a party, state that person's name, date of birth and relationship to the child : 5. If you are aware that the other party or members of the party's household has or have a criminal / abuse history, please explain: I verify that the information above is true and correct to the best of my knowledge information or belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. 7 k Signature L. aiv3S Printed Name COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLL, II4 CIVIL DIVISION' +i rl r� a Y ajk VG:) Plaintiff ) v. ) No. 10-1723 r- ) ear L-0(macko- ) Defendant ) (\\CI\ �Y t �-= a‘i erf)ficate Of Service I, CARI L. GRIGSBY,Cin the above matter, hereby certify that on k,5k,14 , I mailed a true and correct copy of the Petition for Contempt and Modification, by certified mail, return receipt requested, restricted delivery, and another copy of the same document by first class mail, postage prepaid, to: BRIAN D. CAVADA 511 Jacob Lane Mechanicsburg, PA 17050 I certify that (check ALL of the following which are true): Certified mail: [X] The green and white sender's receipt is attached. (ATTACH receipt.) [ ] The green recipient's receipt is attached; BRIAN D. CAVADA signed the certified mail receipt on (ATTACH receipt.) [ ] The certified mail was returned to me unsigned, with the notation that the certified mail was: [ ] refused [ ] unclaimed [ ] other notation: Neither the certified mail envelope nor the certified mail receipt was returned to me. [] Regular mail: [] [] The regular mail has not been returned to me. The regular mail was returned to me, with the notation: Certificate of Service Page 1 of 3 I verify that the information in the Certificate of Service is true and correct. 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\A4C61L-t. (Signature) CARL L. G j SB STAPLE OR TAPE THE CERTIFIED MAIL RECEIPTS BELOW: • r- U.S. Postal ServiceTM CERTIFIED MAILTM RECEIPT (Domestic Mail Only; No insurance Coverage Provided) For delivery information visit our website at www.usps.coma a Postage Certified Fee • Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees 33.30 30.01) GREEN RECEIPT WITH BRIAN D. CAVADA'S SIGNATURE Certificate of Service Page 2 of 3 BRIAN D. CAVADA PLAINTIFF V. CARI L. CAVADA N/K/A CART L. GRIGSBY DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL 2010-1723 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT N.) AND NOW, Friday, September 19, 2014 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, October 23, 2014 11:30 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. You must file with the Court a verification regarding any criminal record or abuse history regarding you and anyone living in your household on or before the initial in-person contact with the court (including, but not limited to, a conference with a Judge or custody conciliator) but not later than 30 days after service of the complaint or petition. No party may make a change in the residence of any child which significantly impairs the ability of the other party to exercise custodial rights without first complying with all of the applicable provisions of 23 Pa.C.S. §5337 and Pa.R.C.P. No. 1915.17 regarding relocation. FOR THE COURT. By: /s/ Dawn S. Sunday, Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR 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. Copies ,'a'd' o PI CP olefi 0 Scind WPX >1 Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 BRIAN D. CAVADA IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CARI L. CAVADA n/k/a CARI L. GRIGSBY 2010-1723 Defendant IN CUSTODY ORDER OF COURT CIVIL ACTION LAVA rn co 2: rri3 r - --� rr71 N) C) zp N AND NOW, this AD day of 0 L16 , 2014, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The parties shall make arrangements to reinitiate reunification counseling for the Mother and the Child with Sally Rooney or other professional selected by agreement. The purpose of the counseling shall be to assist in the reestablishment of the Parent/Child relationship between the Mother and the Child and also to provide guidance to the family in support of fostering that relationship and promoting the emotional wellbeing of the Child. The Mother shall initially contact the counselor to schedule separate appointments to prepare for, and obtain guidance about, the reunification process. The Father and his wife may also schedule separate appointments prior to the reunification sessions in order for them to also obtain guidance in supporting the Child through the process. Any costs of the separate sessions shall be paid by the parent participating in the sessions. Any costs of the counseling sessions involving the Child, either individually or with the Mother, shall be shared equally between the parties. All reimbursements for payment of shared counseling fees pursuant to this provision shall be paid to the parent who made the initial payment within 30 days of notification that the fee was paid. The parties shall sign any authorizations deemed necessary by the counselor in order to obtain additional information pertaining to the parties or the Child. 2. Within six months of the date of this Order, after reunification counseling has been completed, counsel for either party or an unrepresented party may contact the conciliator to schedule an additional custody conciliation conference, if necessary, to establish custodial arrangements following the counseling. cc: BY THE COURT, M. L. Ebert Jr. i L. Grigsby — Mother Linda A. Clotfelter Esquire P2;t LecL io/a.Q/iy BRIAN D. CAVADA IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CARI L. CAVADA n/k/a CARI L. GRIGSBY Defendant Prior Judge: M. L. Ebert Jr. 2010-1723 CIVIL ACTION LAW IN CUSTODY 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 Child who is the subject of this litigation is as follows: NAME Meghan Lee Cavada BIRTH YEAR CURRENTLY IN CUSTODY OF 1998 Father 2. A custody conciliation conference was held on October 23, 2014, with the following individuals in attendance: the Mother, Cari L. Grigsby, formerly Cavada, who is not represented by counsel in this matter, and the Father, Brian D. Cavada, with his counsel, Linda A. Clotfelter Esquire. 4 3. The parties agreed to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator