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10-3195
F(LEU F THE OM & IUTULAKIS 201g I?ry 14 PM I ?+ 8 Kara W. Haggerty, Esquire Y ? Attorney LD. #: 86914 CLUt ?1'JV'?1 1 2 West High Street PEINN Carlisle, PA 17013 (717) 249-0900 BRIAN COPE, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. CIVIL TERM AIMIE RENEE COPE, Defendant CIVIL ACTION - LAW IN DIVORCE 1. Plaintiff is the Father, Brian Cope, who currently resides at 14 North Orange Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is the Mother, Ain-lie Renee Cope, who has a last known address of 62 Cecil Hunter Road, Moreland, Georgia 30259; however, was scheduled to move to Carlisle, Pennsylvania on or about June 3, 2010. 3. The Plaintiff seeks custody of the following children: Name Address DOB Dylan Andrew Cope 14 North Orange Street, July 22, 2004 Carlisle, Pennsylvania 17013 Katelyn Jean Cope 14 North Orange Street, August 21, 2006 Carlisle, Pennsylvania 17013 4. The child, Dylan Cope, was born out of wedlock, and the child, Katelyn Cope was born in wedlock. 5. The children are in the primary custody of the Defendant as of the filing of this Complaint; however, Plaintiff is simultaneously filing a Petition for Special Relief requesting primary custody of the children. P-1 bW .? ? y A QoA' Cl- Z 3 y o :? 2 .. 6. During the children's lifetime, they have resided with the following persons and at the following addresses: Name Brian and Aimie Cope Brian and Aimie Cope Brian and Aimie Cope Brian and Ain-lie Cope Address 62 Cecil Hunter Road, Moreland, Georgia 1408 Amber Chase Drive, McDonough, Georgia Sandusky, Ohio 814 East Walton Avenue, Altoona, Pennsylvania Date January 2009 - May 14, 2010 January 2008 -January 2009 January 2007 -January 2008 Birth -January 2007 7. The father of the children is Brian Cope, who currently resides at 14 North Orange Street, Carlisle, Cumberland County, Pennsylvania 17013 8. The mother of the children is Aimie Renee Cope, who has a last known address of 62 Cecil Hunter Road, Moreland, Georgia; however, was scheduled to move to Carlisle, Pennsylvania on or about June 3, 2010. 9. The mother and father of the children are currently married. 10. The relationship of Plaintiff to the children is that of Father. 11. The relationship of Defendant to the children is that of Mother. 12. The Plaintiff currently resides alone, but is seeking primary physical custody of the children. 13. It is presently unknown where and with whom the Defendant will be residing. 14. The Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or any other court. 15. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 16. The Plaintiff does not know of a person nor a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 17. The best interest and permanent welfare of the children will be served by granting the relief requested for reasons including the following: a. The Father and Mother have shared in the caregiving responsibilities of the minor children since their birth. They have: i. Planned and prepared meals; ii. Bathed, groomed and dressed the children; iii. Purchased, cleaned and cared for the children's clothing; iv. Arranged medical care, including trips to physicians; v. Arranged alternative daycare; vi. Put the children to bed nightly, attended the children in the middle of the night, and awakened the children in the morning. b. The Father will be able to ensure for the children's safety and care. c. The Father can provide a stable home for the children. d. The children have a psychological bond with the Father. e. The Father can provide for the children both financially and emotionally. 18. Each parent whose parental rights to the children have not been terminated has been named as parties to this action. WHEREFORE, the Plaintiff requests that This Honorable Court grant primary legal and physical custody of the minor children to the Plaintiff/Father. DATE V5 ? H 110- Respectfully submitted, ABom & KUTULA"S, L.L.P. Kara W. Haggerty Supreme Court ID 869 v? 2 West High Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Plaintiff I, BRIAN COPE, verify that the statements made in this Custody Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. c? Date 5 `` BRIAN COPE CERTIFICATE OF SERVICE AND NOW, this 14`' day of May, 2010, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Custody Complaint, upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, Certified mail and First-class mail, postage prepaid addressed to the following: Aimie Renee Cope 62 Cecil Hunter Road Moreland, Georgia 30259 Last Known Address And Aimie Renee Cope c/o Robert Cowan 270316 h Street Altoona, PA 16601 By Personal Senke at herparent's residence Respectfully submitted, ABom & KUTULA"S, L.L.P. Kara W. Haggerty, Esni / ID No. 86914 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff Tit 1LL'.???~E??y? A[y _ AROM & UTULAKIs Kara W. Haggerty, Esquire Attorney I.D. #: 86914 2 West High Street Carlisle, PA 17013 (717) 249-0900 BRIAN COPE, Plaintiff V. AIMIE RENEE COPE, Defendant 2010 MAY 14 PH 1: 49 CUM `:. ;, ,vU W IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. le- 3V ?S CIVIL TERM CIVIL ACTION - LAW IN CUSTODY AND NOW, this 14`h day of May, 2010, comes the Petitioner, Brian Cope, by and through his attorney, Kara W. Haggerty, Esquire, of ABOM & KUTUL AKIS, L.L.P., and respectfully petitions this Honorable Court to grant Petitioner special relief, and in support thereof avers the following: 1. A Complaint for Custody is being filed simultaneously with this Petition by Father seeking Primary Legal Custody and Primary Physical Custody of the parties' minor children: Dylan Andrew Cope, born July 22, 2004, and Katelyn Jean Cope, born August 21, 2006. 2. The parties separated on or about May 14, 2010 when the Petitioner learned that Respondent is en route to Altoona, Pennsylvania with the two children and her paramour. 3. Petitioner had moved to Carlisle, Cumberland County, Pennsylvania on or about May 1, 2010 due to being relocated by his employer, Norfolk Southern Railroad. f,"/ 7v ao A? tl"JA 2 ? a3a? 101 o2ya4 73 4. The Respondent was scheduled to move to Carlisle, Pennsylvania with her husband and two children on or about June 3, 2010 after their oldest child had finished school. a. The moving company is scheduled to pack the parties' belongings on June 1, 2010. b. The moving company is scheduled to load the truck and begin to travel to Pennsylvania from Georgia on June 2, 2010. c. The parties and their two children are scheduled to drive from Georgia to Pennsylvania for their permanent relocation on June 3, 2010. d. The parties' lease for their home in Georgia is scheduled to terminate effective June 15, 2010. 5. The Petitioner attempted to call his wife and children on May 13, 2010 at 6:00 p.m. and thereafter for the remainder of the evening with no answer. 6. The Petitioner contacted the Sheriff's Department who checked the home and advised that no one was at home, but the parties two vehicles were there and the family dog was outside unattended in the yard. 7. The Petitioner attempted to contact Respondent this morning with no response. 8. The Petitioner once again requested the Sheriff's Department to check his home, and they reported that no one was home and the family dog was still outside. 9. The Petitioner contacted his son's school and learned that his son had not reported to school on this date. 10. The Petitioner then contacted the cell phone of Respondent's paramour and left a message stating that he believed that Respondent was with him. 3 11. The Petitioner then contacted Respondent's parents to attempt to learn of his wife and children's whereabouts, and Respondent's father was able to make initial contact with Respondent confirming that she was with her paramour and traveling to Pennsylvania. 12. The Petitioner was then able to make contact with Respondent who confirmed that she is presently traveling from Georgia to Pennsylvania with the children and her paramour. 13. Petitioner was unaware of his wife's intentions to separate from him and is unaware of what her intentions are from this point forward. 14. It is believed and therefore averred that it is in the best interest of the children for Petitioner to be granted legal and physical custody as the children need a stable home environment. 15. Petitioner is prepared to make all necessary arrangements to ensure his son will advance to the first grade as he was removed from school without notice to the school. 16. It is believed and averred that if the Respondent would maintain custody of the minor children she would flee the Commonwealth for an unknown location and not return. 17. Petitioner believes that contact with the Respondent at this time would not be in the best interest of the children, as her emotional state is unstable and unpredictable. 18. It is believed and therefore averred that it is in the best interest of the children for the Petitioner to exercise Primary Physical Custody of the children as it is unknown where the Respondent will be residing. 19. It is believed and therefore averred that the Respondent does not have a place to live at this time; therefore, a schedule will need to be determined in the future once she secures a stable and safe residence. 4 20. Petitioner would agree to a regular, supervised visitation schedule in Cumberland County that would accommodate both the parties' schedules. WHEREFORE, Petitioner prays that this Honorable Court grant his Petition for Special Relief and grant Petitioner Primary Physical Custody at this time and specifically state that Cumberland County will retain jurisdiction in this custody matter and the minor children will not be permitted to reside outside the county now or in the future without express consent of this Honorable Court. Respectfully submitted, ABOM & KUTULA"S, L.L.P. DATE l? IqlIc (v u Kara W. Haggerty, Esq ? ?[j Attorney ID No. 8691 2 West High Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Petitioner 5 I, BRIAN COPE, verify that the statements made 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 unsworn falsification to authorities. Date l ee"=- BRIAN COPE AND NOW, this 14"' day of May, 2010, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P., hereby certify that I did serve a true and correct copy of the foregoing Emergency Petition for Special Relief, upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, Certified mail and First-class mail, postage prepaid addressed to the following: Aimie Renee Cope 62 Cecil Hunter Road Moreland, Georgia 30259 Last Known Address And Aimie Renee Cope c/o Robert Cowan 270316 th Street Altoona, PA 16601 By Personal Service at herparent's residence Respectfully submitted, Abom & Sutulakis, L.L.P. C Kara W. Haggerty, Es / Attorney ID No. 869 (\ 2 West High Street Carlisle, Pennsylvania 17013 (717) 249-0900 6 0 ~` BRIAN COPE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 2010-3195 CIVIL ACTION LAW AIM[E RENEE COPE DEFENDANT IN CUSTODY ORDER OF COt1RT ~1ND NOW _Monday, Mai 17, 2010 __ _, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. ,the conciliator, at 4th Floor, Cumberland Coun Courthouse, Carlisle on Wednesday, June 09, 2010 at 1:00 PM for aPre-HcaringCustody 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, I3y: /s/ ~n~Ma~an,Jr•,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 Hr'~VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTI-f BELOW TO FIND OUT WI-IERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association c7 N `~ !7• ~D ~~ ~A`~ ~~ 3? South Bedt~~rd Street ~ ° " ~~~_~ ~ ~ ri-; ,;. Carlisle, Pennsylvania 17013 ~ r _,,;, ,= z Telephone (717) 249-3166 `~~'-- `- -~ ,~• / 7 • ! 6 . /~'/~'l`)o~, Ccs Mme; lec~ ~-Ip ^l~~- ,:~ .: -., ~~ ~ ,--~ y n /Q ~• ~(~A ,/1 r~ x 'T T C~ Lam( °^"~ ~ ~ ~ ~ ~ ~ ~ 1 L e 7 ~• l7 • ! O Cc~y, ~ lQ ~e.~ ~ n ~ n /~tan~an 's ~i ~. . ~, f7 , ~, BRIAN COPE IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. AIMIE RENEE COPE, DEFENDANT NO. 10-3195 CIVIL IN RE: EMERGENCY PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 17th day of May, 2010, upon consideration of Brian Cope's Emergency Petition for Special Relief and the Court having serious reservations regarding the jurisdiction of this Court and the ex parte nature of the request, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule to show cause shall issue upon Aimie Renee Cope to show cause why the relief requested by the Plaintiff should not be granted. 2. Defendant shall file an Answer to the Plaintiff's Emergency Petition on or before June 1, 2010. 3. Depending on the actual physical residence of the parties, and the location of By the Court, ca ~ ~ =- c ~, m - j M. L. Ebert, Jr., J. ~c~ -~-. t~ L j ~ `.:'~. r 1 .'' LL7 ~ =c ~' c.~ the children, a custody conciliation conference shall be held before Custody Conciliator, John Mangan, on June 9, 2010, at 1:00 p.m. Kara W. Ha ert Es uire g9 Y, q Attorney for Plaintiff ~ie Renee Cope Defendant ~n Mangan, Conciliator bas ~~, ~~ LFc~ SAO ~ JUN 0 9 2010 ~ BRIAN COPE, Plaintiff v. AIMIE RENEE COPE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA N0.2010-3195 CIVIL TERM CIVIL ACTION -LAW IN CUSTODY AND NOW, this 11~~ day of ~~,nc, 2010, the attached Custody Stipulation and Agreement is hereby made an Order of Court. By the Court ~~ Distribution: ~ ~ -~~, "~ r, ~T , Esquire Haggerty / Kara W E % ~ ' , . , Abom & Kutulakis, L.L.P. ~A _~ ~~ 2 West High Street r :.` _ ~.~-' Carlisle, PA 17013 ~~= ~ :" ~ ° ~~; '..? Attorney for Plaintiff ~ i_~ ,:, c . c-, _ t-r ~e Cope ~' '-~ 1 Sacramento Drive Apt. 71 Hampton, VA 23605 ~ ~E,S ~Yt~,l ~~ ~ a,~~w ~~ 1J r ~}. ~~, ~~ PM ~= ~~ KOPE & ASSOCIATES, LLC JULIE A. WEHNERT, ESQUIRE ATTORNEY I.D. 307900 395 St. Johns Church Road Camp Hill, PA 17011 (717) 761-7573 iwehnertCa~kopelaw.com BRIAN COPE, Plaintiff, vs. AIMIE RENEE COPE, Defendant. C~~~Y r._ ,.. Attorney for Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010-3195 CIVIL ACTION -LAW IN CUSTODY PETITION TO MODIFY CUSTODY ORDER AND NOW comes the above-named Defendant, AIMIE RENEE COPE, by and through her attorney, JULIE A. WEHNERT, ESQ., and makes the following Petition to Modify the Custody Order: 1. The Petitioner is Aimie Renee Cope, residing at 1 Sacramento Drive, Apt 71, Hampton, VA 23666 (hereinafter "Petitioner" or "Mother") 2. The Respondent is Brian Cope, residing at 14 North Orange Street, Carlisle, Cumberland County, Pennsylvania 17013 (hereinafter "Respondent" or "Father") 3. A Custody Complaint and Emergency Petition for Special Relief were filed in the above captioned matter on May 14, 2010. See Complaint and Petition attached as Exhibit "A". Upon the filing of the Emergency Petition for Special Relief, The Honorable M.L. Ebert, Jr. issued an Order of Court stating that there were serious reservations regarding the jurisdiction of the Court and gave Mother until G~~~9'~~ ,~~~ylo June 1, 2010 to file an Answer to the Emergency Petition for Special Relief. See Order of Court attached as Exhibit "B". A Custody Conciliation was scheduled for June 9, 2010. 4. Prior to the filing of this Complaint and Emergency Petition the parties and children lived in Georgia. Since the birth of the children, Mother has been the primary caretaker of the children. 5. Father did not obtain custody of the children until May 14' 2010, the day the Custody Complaint and Emergency Petition were filed. Father tricked Mother into giving him the children for the weekend of May 14, 2010 by to{ling her that she could have the children back on May 16, 2010 to go with them to Virginia. When Mother gave the children to Father and they were in the car, Father handed her the Custody Complaint and Emergency Petition and told her he was not going to give them back. Upon obtaining custody of the children Father did not allow Mother to see the children or talk to them on the phone. Mother believes Father is doing this as punishment for her decision to leave the marriage and not that it is in the best interests of the children. Father has a{so been disparaging her in front of the children and telling them that Mother is going to jail for leaving. Feeling she had no other choice to see her children Mother signed a Custody Stipulation and Agreement. See Stipulation attached as Exhibit "C". 6. This Agreement gave shared legal custody to both parties and gave primary physical custody to the Father. Mother was given partial physical custody of the children at such times and as such locations as Father agrees. Since the signing of this Agreement, Father has only allowed Mother to see the children a total of four times. Father is withholding his agreement to custody again as punishment to Mother. When Father does initially agree to a11ow Mother to have custody of the children he changes his mind. Mother had plans to have the children for vacation from Friday, July 23, 2010 for one week. Father initially agreed to this vacation but then retracted his agreement without reasonable cause. 7. Father does not have ability to care for the children on a regular basis. The children's 86 year old grandfather has been given the responsibility to drive the children to and from daycare and to drive them around as needed. Father did not enroll Dylan in school upon moving to Carlisle. Therefore, the child has had no schooling since May 14, 2010 even though school was still in session. 8. Mother is very concerned about the safety of the children while in Father's care. Katelyn has a severe peanut allergy and was given peanut butter in Father's home. 9. Mother is respectfully requesting that this Honorable Court issue an Order granting Mother and Father shared legal custody and Mother primary custody of the children. 10. Mother is also requesting that a conciliation be scheduled as soon as possible, as the Father is severely limiting her time with the children which is causing them mental and emotional suffering. 11. The best interest and permanent welfare of the children will be served by granting the relief requested because: (a) Father's current actions, in abruptly removing the children from their Mother's care after she has been the primary caretaker of the children demonstrate a disregard for the best interest of the children, and the of the relationship between Mother and children; (c) Mother is more than able to provide a stable home and stable emotional environment for the children; and (d) Mother has the facilities to provide for the care, comfort and control of the children, as well as the intention and desire to do so. WHEREFORE, Petitioner requests that this Honorable Court grant Mother shared legal and primary physical custody of the children. Respectfully Submitted, KOPE 8~ ASSOCIATES, LLC By: Juli A. Wehnert, Esq. Dated: (~~-( (D VERIF(CA I, Aimie Renee Cope, verify that the custody Order are true and correct. I understand subject to the penalties of 78 Pa.C.S. ~ 4904 rata authorities. Dated: ~ ~ ~~ made in this Petition to M4odify false statements herein are made to unsworn falsification to ;Renee Cope ~ ZZ59b9LL9t 9t~5ti 0t0Z/b0/80 50 3Jdd ~3SW~~ S~Z ~D ~:~~~~~ ~ ~~s _ ~B~M ~' LITLILAKIS Kara W. Haggerty. Esquire Attorney I.D. #: 86914 2 West Nigh Street Carlisle, PA 17013 (717)149-0900 BRIAN COPE, PLlintiff v. AIMIE RENEE COPE, Defendant FlLE~~rr~~c ,, e^;.,,u ,~~~. 2Qi0 i~SAY i 4 PM i ~ 48 CUM::~ e'iL.`'- s:: V~~1ViV l 1 i'EN?vS ~'LV~'~?k IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. ~G • ~~~ CNII. TERM CIVIL ACTION -LAW IN DIVORCE 1. Plaintiff is the Father, Brian Cope, who currently resides at 14 North Orange Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is the Mother, Aimie Renee Cope, who has a last known address of 62 Cecil Hunter Road, Moreland, Georgia 30259; however, was scheduled to move to Carlisle, Pennsylvania on or about June 3, 2010. 3. The Plaintiff seeks custody of the following children: Name ~ Address DQB Dylan Andrew Cope 14 North Orange Street, July 22, 2004 Carlisle, Pennsylvania 17013 Katelyn Jean Cope 14 North Orange Street, August 21, 2006 Carlisle, Pennsylvania 17013 4. The child, Dylan Cope, was bom out of wedlock, and the child, Katelyn Cope was born in wedlock. 5. The children are in the primary custody of the Defendant as of the filing of this Complaint; however, Plaintiff is simultaneously filing a Petition for Special Relief requesting primary custody of the children. ~' C 6. During the children's lifetime, they have resided with the following persons and at the following addresses: Name Brian and Aimie Cope Brian and Aimie Cope Brian and Aimie Cope Brian and Aimie Cope Address 62 Cecil Hunter Road, Moreland, Georgia 1408 Amber Chase Drive, McDonough, Georgia Sandusky, Ohio 814 East Walton Avenue, Altoona, Pennsylvania at January 2009 -May 14, 2010 January 2008 -January 2009 January zoo? -January 2008 Birth -January 2007 7. The father of the children is Brian Cope, who currently resides at 14 North Orange Street, Carlisle, Cumberland County, Pennsylvania 17013. 8. The mother of the children is Aimie Renee Cope, who has a last known address of 62 Cecil Hunter Road, Moreland, Georgia; however, was scheduled to move to Carlisle, Pennsylvania on or about June 3, 2010. 9. The mother and father of the children are currently married. 10. The relationship of Plaintiff to the children is that of Father. 11. The relationship of Defendant to the children is that of Mother. 12. The Plaintiff currently resides alone, but is seeking primary physical custody of the children. 13. It is presently unknown where and with whom the Defendant will be residing. 14. The Plaintiff has not participated as a party or witness, or is another capacity, is other litigation concerning the custody of the children in this or any other court 15. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 16. The Plaintiff does not know of a person nor a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 17. The best interest and pe**nanent welfaze of the children will be served by granting the relief requested for reasons including the following: a. The Father and Mother have shared in the caregiving responsibilities of the minor children since their birth. They have: i. Planned and prepared meals; ii. Bathed, groomed and dressed the children; iii. Purchased, cleaned and cared for the children's clothing; iv. Arranged medical caze, including trips to physicians; v. Arranged alternative daycaze; vi. Put the children to bed nightly, attended the children in the middle of the night, and awakened the children in the morning. b. The Father will be able to ensure for the children's safety and care. c. The Father can provide a stable home for the children. d. The children have a psychological bond with the Father. e. The Father can provide for the children both financially and emotionally. 18. Each parent whose pazental rights to the children have not been terminated has been named as parties to this action. tI~FIEREFORE, the Plaintiff requests that This Honorable Court grant primary legal and physical custody of the minor children to the Plaintiff/Father. D~~ 5 i v Respectfully submitted, Aaolrr & Srnvra8rs, L.L.P. .~ W. Haggerty ,• Supreme Court ID 869 . 2 West High Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Plainti~" I, BRIAN COPE, verify that the statements made in this Custody Complaint aze true and correct to the best of my knowledge, information, and belief. I understand that false statements herein aze made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. 5 !~ o . Date BRIAN COPE CERTIFICATE OF SERVICE AND NOW, this 14~' day of May, 2010, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Custody Complaint, upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, Certified mail and First-class mail, postage prepaid addressed to the following: Annie Reaee Cope 62 Cecil Hunter Road Moreland, Georgia 30259 Last Known Address And Aisnie Reaee Cope c/o Robert Cowan 2703 16`~ Street Altoona, PA 16601 By Personal Sen~icti at herparrnt's nridence Respectfully submitted, AsolrrBcSv~vr.~s, L.L.P. Kara W. Haggerty, ID No. 86914 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plainti~' BRIAN COPE PLAINTIFF V. AIMIE RENEE COPE, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-3195 CIVIL IN RE: EMERGENCY PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 17~' day of May, 2010, upon consideration of Brian Cope's Emergency Petition for Special Relief and the Court having serious reservations regarding the jurisdiction of this Court and the ex pane nature of the request, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule to show cause shall issue upon Aimie Renee Cope to show cause why the relief requested by the Plaintiff should not be granted. 2. Defendant shall file an Answer to the Plaintiff's Emergency Petition on or before June 1, 2010. 3. Depending on the actual physical residence of the parties, and the location of the children, a custody conciliation conference shaft be held before Custody Conciliator, John Mangan, on June 9, 2010, at 1:00 p.m. Kara W. Ha ert , Es uire 99 Y q Attorney for Plaintiff ~ie Renee Cope Defendant ~n Mangan, Conciliator bas `~ ~~~ ~~ S 7lld By the Court, c N -? ~ ~~ ~ t . ~~: ~; ~ ~ -~ ° , M. L. Ebert Jr J ~~:i J •r -; , ., . ; m ~p ~ ~ ~' cri ~ , .: , --.7.1 ~ ~~ Y OM CSC' ZQIQ J~J?t -9 P ..'~~ - . LILAKIS ti ,~ ,~1 Kara W. Haggem, Esquire: C+UIV`:;..:. Attorney I.D. #: 869]4 -; - ~ ~~ ~ f ~'- ~.ji~ ' T 1 ~ 1 ~ 2 Wit I~Iigh Street ~ `.~ ; ~~'' ''-~: 'M1'~i~a Carlisle, PA 17013 (717) 249-0900 BRIAN COPE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA v. N0.2010-3195 CIVIL TERM AIMIE RENEE COPE, CIVIL ACTION -LAW Defendant IN CUSTODY THIS STIPULATION AND AGREEMENT entered into the day and year hereinafter set forth, by and between BRIAN COPE, (hereinafter referred to as "Father' and AIMIE RENEE COPE, (hereinafter referred to as `2vlother'~. WHEREAS, the parties are the natural parents of two children, namely DYLAN A1vDREII~ COPE, born July 22, 2004, and SATELYIV JEAN COPE, bom August 21, 2006 (hereinafter referred to as "Children"); and WHEREAS, the parties live separate and apart, and wish to enter into a comprehensive stipulation and agreement relative to physical and legal custody of their Children. NOW THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth, the patties stipulate and agree as follows: 1. The Mother and Father shall enjoy shared legal custody of the Children. The parties equally shall have the right to make all major non-emergenry decisions affecting the Children's general well being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of Pa.C.S. §5309, the parties shall be entitled to all records and information pPrta;,,;,,g to the Children including, but not limited to medical, dental, religious or school records, the residence address of the Children and the other parent To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent The parties shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor Children. The parties shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cazds. 2. Father shall enjoy primary physical custody of the Children. 3. Mother shall enjoy partial physical custody of the Children at such times and at such locations as Father agrees. 4. The parties specificaIly agree that during Mother's periods of custody, the Children will not have any contact with Mother's paramour, Joel Astore, or any members of his family. 5. Transportation shall be shared by agreement of the parties. 6. Neither parent shall do anything which may estrange the Children from the other party, injure the opinion of the Children as to the other party, or which may hamper 2 the free and natural development of the Children's love and affection for the other Pay 7. Any modification or waiver of any of the provisions of this Agreement on a pemnanent basis shall be effective only if made in writing, and only if executed with the same formality as this Stipulation and Agreement S. The parties desire that this Stipulation and Agreement be made an Order of Court of the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County does, in fact, have jurisdiction over the issue of custody of the patties' minor Children, cvho have resided for at Ieast the past six (6) months in Cumberland County, Pennsylvania.. 9. The parties stipulate that in making this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of the other party. 10. The parties acknowledge that they have read and understand the provisions of this Agreement Each party acknowledges that the Agreement is fair and equitable and that it is not the result of anp duress or undue influence. 3 IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms hereof, set forth their hands and seals the day and year hereinafter mentioned. WITNESSETH: :! .~2cr lam' . ~-~~ ~ ~ ~% ~, ~o - DATE BRIAN COP ~ ~~~ ~r - ~ ~ !n DATE E RENEE COPE COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND , On this ~ day of , 2010, before me, the undersigned officer, personally appeared BRIAN C E, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that he executed the same for the purposes therein contained. ' V N TARY PUBLIC COMMONWEALTH OF PENNSYLVANIA Notarial Seal Shannon L. Freeman, Notary P~b1it Carlisle Bao, Cumberland County I My Commission Expires Apfil 7, qp~3 ~R COMMONWEALTH OF PENNSYLVANIA Member, ?ennsylvania Association of Nvt?ties SS. COUNTY OF CUMBERLAND , On this =J -- day of , 2010, before me, the undersigned officer, personally appeared AIMEE RE EE COPE, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that she executed the same for the purposes therein contained. TARY PUB IC c~TH of ~NSnvMtw No1NW s.r - 4 carw.~ c~e.aNo°~~'~6ge Cair~on 7~+m13 Mentbet, PanrtsyNarda a! ' •. , a ~ ' JUN 0 9 2010 BRIAN COPE, IN THE COURT OF COMMON PLEAS Plaiatiff CUMBERLAND COUNTY, PA v. N0.2010-3195 CIVIL TERM AIMIE RENEE COPE, CIVIL ACTION -LAW Defeadaat IN CUSTODY AND NOW, this 17~~ day of 3'~~c. 2010, the attached Custody Stipulation and Agreement is hereby made an Order of Court. By the Court ~.~. ~. Distribution: ~~ ~ ~ a o _ ~~ ~ ,/Kara w. Ha. ~~ ~lu~ ~ LY i r f ~- C , Abom &. Kutulakis L.L.P - . ~ ~ ~ ~ ' _.+ °- R1 -n . m , . 2 west Him street _ ~^ ;'~ :. N Y., ~' ~ = < <== Cazlisle, PA 17013 . ~ - ~ ~„ ~ ~- ~-, Attorney for Plaintiff =~'' : ~ ~~ ---':~~ r ~ Ai i ~. y z ~ , ~ r m e Cope ~ 1 Sacramento Drive Apt. 71 Hampton, VA 23605 G a.1 ~ !(~ --1..~( CERTIFICATE OF SERVICE I, Julie A. Wehnert, Esquire, do hereby certify that on this 6th day of August, 2010, I served a true and correct copy of the foregoing Petition to Modify Custody via regular U.S. First Class mail, postage prepaid, addressed as follows: Kara W. Haggerty, Esq. Abom & Kutalakis 2 West High Street Carlisle, PA 17013 lie A. Wehnert, Esq.' upreme Court I.D. 307900 395 St. Johns Church Road Camp Hill, PA 17011 Tel: (717) 761-7573 Fax: (717) 761-7572 Attorney for Defendant oM & KUTUIAKIS Kara IV Iluggerty, }:fguim Attorney L0. Na.: 86914 2 V,.d High Sheet Carlisle, PA 17013 (717) 249-0900 BRIAN COPE Plaintiff V. AIMEE RENEE COPE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 2010-3195 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY RESPONDENTS ANSWER TO PETITION TO MODIFY CUSTODY ORDER AND NOW this 20th day of August, 2010, comes the Respondent, Brian Cope, by and through his undersigned counsel, Kara W. Haggerty, of Abom & Kutulakis, L.L.P., and who respectfully sets forth the following Answer to Petition to Modifi, Custody Order and avers the following: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted in part, Denied in part. It is admitted that the parties previously resided in Georgia. It is specifically denied that Petitioner has been the primary caretaker of the children since birth. By way of further answer, Respondent and Petitioner have shared the duties of caretaker since the birth of the children. 5. Admitted in part, Denied in part. It is admitted that Respondent received custody of the children on May 14, 2010. It is specifically denied that Respondent tricked Petitioner into giving him the children and that he said he was not going to give them back. It is specifically denied that Respondent did not allow Petitioner to see the children or talk to them on the phone. By way of further response, Petitioner did not initiate contact with the children, restricted her telephone number and did not disclose to Respondent where she was living. It is specifically denied that Respondent has made disparaging remarks about Petitioner in the presence of the children and that he has said she is going to jail. By way of further response, Respondent speaks positively of Petitioner to the children for their benefit. Respondent is unable to admit or deny the averment that Petitioner feels Respondent is trying to punish her, and the averment that expresses Petitioner's thoughts regarding signing the custody stipulation. 6. Admitted in part, Denied in part. It is specifically denied that Respondent has only allowed Petitioner to see the children four times, that Respondent is withholding his agreement to custody and that Respondent changes his mind on allowing Mother to see the children. By way of further answer, Petitioner has made limited contact with Respondent regarding seeing the children, which has limited the amount of possible visits. Further, Respondent has not been able to contact Petitioner easily. Respondent had to contact Petitioner's father to contact Petitioner. It is admitted that Petitioner had plans to take the children on vacation for a week starting on July 23, 2010. It is specifically denied that Respondent agreed to allow the vacation, but then later retracted his agreement. By way of further response, Petitioner informed Respondent of dates and times for vacation, but then failed to communicate with Respondent for a week. Respondent was then unsure of what Petitioner's intentions were until a few days prior to the vacation. Petitioner then stated she was picking up the children, which would have burdened Respondent to rearrange his schedule with little notice. Furthermore, Petitioner did, in fact, take the children on vacation, spent one day with them and then left them with her parents for the remainder of the week. 7. Admitted in part, Denied in part. It is specifically denied that Respondent does not have the ability to care for the children and that Respondent's grandfather is responsible to drive the children around. By way of further response, Respondent has been primarily caring for the children and providing for their transportation needs since May 14, 2010. It is admitted that Dylan was not enrolled in school upon moving to Carlisle. By way of further response, there were only two weeks of school left before summer vacation and Petitioner was aware of this and accompanied Respondent when he dropped off the agreement at the school regarding Dylan's attendance. 8. Denied. Respondent is unable to admit or deny whether Petitioner has concerns, but specifically denies that Katelyn has a severe peanut allergy. By way of further response, Katelyn was tested for a peanut allergy when the family resided in Georgia and the allergy specialist concluded that she was not allergic. Furthermore, Respondent continues to restrict Katelyn from consuming any peanut products as a precautionary measure. 9. Respondent is unable to admit or deny this averment. 10. Denied. Respondent is unable to admit or deny as to Petitioner's reason for requesting conciliation, but specifically denies that he is limiting Petitioner's time with the children and that it is causing them mental and emotional suffering. By way of further response, the children are doing very well with Respondent and show no signs of mental and emotional suffering. 11. The averment in paragraph 11 is a legal conclusion to which no response is required. WHEREFORE, it is respectfully requested that This Honorable Court order that Petitioner's Petition to Modify Custody is denied. Respectfully submitted, ABOM & KUTULAKIS, L.L.P. Date Kara W. Haggerty, S, e Attorney I.D. No.: 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for the Respondent YE -GAILRYN I, BRIAN COPE, verify that the statements made in this Respondent's Answer to Petition to Modify Custody Order are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date t 1 127NO BRIAN COPE AND NOW, this 20" day of August, 2010, I, Kara W. Haggerty, Esquire of ABOM & KUTULAKIS, L.L.P., hereby certify that I did serve or cause to be served a true and correct copy of the foregoing Respondent's Answer to Petition to Modify Custody Order to the Plaintiff by First Class U.S. Mail at the following address: Julie A. Wehnert, Esquire Kope & Associates, LLC 395 St. Johns Church Road Suite 101 Camp Hill, PA 17011 Attorney for the Petitioner i-qt 7 l tl (? C Kara W. Haggerty, Esquire b BRIAN COPE PLAINTIFF v. AIMIE RENEE COPE DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2010-3195 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, -__ Friday, August 20, 2010upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Monday, September 27, 2010 at 8:30 AM for a Pre-Hearing Custody ConCerence. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot he 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 hearinL. FOR THE. COURT, By; /s/ ohm Mangan, Jr., E,, 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. p Cumberland County Bar Association C6 - I C-) v2'S ??2.t"-?-• CS?j t-i 32 Sotuth Bedford Street ???• Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 F5. a3 • l a IG i n NOV 19 2010 BRIAN COPE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 10-3195 CIVIL ACTION LAA o AIMIE RENEE COPE, IN CUSTODY rn-n Defendant ?r ern 0 Prior Judge: M. L. Ebert, Jr., J. r' o a ;C F3 ORDER OF COURT y; r 1J r" AND NOW this day of November 2010, upon consideration of the Ached Custody Conciliation Report, it is Ordered and Directed as follows: 1. All prior Orders entered in this matter are hereby superseded by the instant Order. 2. Legal Custody: The Father, Brian Cope, and the Mother, Aimie Renee Cope, shall have shared legal custody of Dylan Andrew Cope, born 07/22/2004 and Katelyn Jean Cope, born 08/21/2006. The parties shall have an equal right to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 3. Physical Custody: Father shall have primary physical custody of the Children subject to Mother's physical custody as follows: a. Mother shall have custody of the Children here in Pennsylvania two weekends (Friday until Sunday) before Thanksgiving 2010 at an agreed upon location. Father has agreed to pay for accommodations and Mother's paramour, Joel Astore, shall not be present for the custodial periods. Mother shall give Father adequate notice of her requested weekends. b. Mother shall also have custody of the Children here in Pennsylvania for the weekend after Thanksgiving from Friday until Monday at an agreed upon location and Mother's paramour, Joel Astore, shall not be present for the custodial period. C. Absent agreement otherwise, the parties shall exchange custody in Breezewood, PA on the designated dates. d. Mother shall have physical custody of the Children at such other times as the parties may mutually agree. 2 4. The non-custodial parent shall have liberal telephone/email contact with the Children on a reasonable basis. Absent agreement otherwise, the non-custodial parent shall communicate with the Children at 7:00 pm each day and any missed phone calls shall be returned promptly. 5. Mother has agreed to provide information in regard to Mother's living arrangements and has tentatively agreed to cooperate with a home study. 6. Holidays: The parents shall arrange the holiday schedule mutually agreed upon. In the absence of agreement, a schedule shall be established at the status conference. 7. Neither party may say or do anything nor permit a third parry to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Children. 8. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 9. A telephone conference is hereby scheduled for Tuesday November 30, 2010 at 9:00 am. The assigned conciliator shall initiate said call. 10. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. By the Court, Dis bution: li Wehnert, Esquire aggerty, Esquire ??ei Mangan, Esquire Co P I;Er It 14? //0 rt? ? BRIAN COPE, Plaintiff V. AIMIE RENEE COPE, Defendant Prior Judge: M. L. Ebert, Jr., J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 10-3195 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Dylan Andrew Cope 07/22/2004 Primary Father Katelyn Jean Cope 08/21/2006 Primary Father 2. An Order of Court was issued May 17, 2010 pursuant to an emergency petition for special relief, a custody stipulation was signed June 03, 2010, an Order issued June 17, 2010 and a Conciliation Conference was held with regard to this matter on October 05, 2010 with the following individuals in attendance: The Mother, Aimie Renee Cope, with her counsel, Julie Wehnert, Esq. The Father, Brian Cope, with his counsel, Kara Haggerty, Esq. 3. The parties agreed to the entry of an Order in the form as attached. ? ? la Date John J. VfingV, Esquire Custod Co iliator BRIAN COPE i` LE'- 1 p IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA V 2013 JUL 29 PM 2. 04 2010-3195 CIVIL ACTION LAW AIMIE RENEE COTJMBERL AND COUNTY PENNSYLVANIA IN CUSTODY N r✓ C -<3> -�C� Petition for Transfer of Venue P, c CD{�:1 I, Aimie Renee Astore,previous named Aimie Renee Cope and defendant in the case assjiat w a with docket number 2010-3195, moves the court for an order changing venue in this matter to Virginia Beach, Virginia. This Petition is based on the facts set forth: 1. The children have resided in the city of Virginia Beach, Virginia for a consecutive two years which is supported in the attachments. Enrollment into Linkhorn Park Elementary is supported with the 2011-2012 third marking period report cards which show their attendance from the beginning of the school year. Attendance with only one absence per child for the 2012-2013 is supported with the final 2012-2013 report card. Also attached is the current Student Profile which provides the address the school has on file for both students. 2. The Plaintiff for the case at hand, Brian Cope, also no longer resides in Cumberland County. His residence was moved greater than twelve months ago. 3. Due to no parties involved in this case being residences of Cumberland County, I ask you to Transfer case number 2010-3195 to Virginia Beach,VA where the children have been residing for two years. 4. Paperwork to support the name change from Aimie Renee Cope to Aimie Renee Astore is attached and found on the Marriage License from the city of Virginia Beach,VA. Also attached is a copy of driver's license providing name and address confirmation. Therefore, I respectively urge for the court to transfer docket number 2010-3195 to the Virginia Beach Court. Re tively, Date: l Aimie Renee Astore LINKHORN PARK ELEMENTARY SCHOOL Report Card 977 FIRST COLONIAL ROAD VIRGINIA BEACH,VA 23454 2011-2012 School Year 757-648-2920 3rd Marking Period Student: COPE,KATELYN SEAN ID: 352786 Teacher: Ackerman,Julia Grade: KA Grading Key-Reading,Writing,Mathematics,Science,Social Studies Grading Key-Citizenship,Work Habits,Physical Education,Art,Music, Strings,Health 4 Exceeds grade level expectations 0 Outstanding 3 Meets grade level expectations S Satisfactory 2 Experiences difficulty meeting grade level expeditions N Needs Improvement I Does not meet grade level expectations U Unsatisfactory NE Not evaluated NE Not evaluated X Area of concern/needs additional attention X Area of concemineeds additional attention * Not on grade level * Not on grade level 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr F 1st Qtr 2nd Qtr 3rd Qtr 4th Qh- READING GR-K 3 3 3 MATH GR-K cont... 3 3 3 readw Ackerman,Julla Understand the systems and processes of Uses a variety of reading comprehension measurement;use appropriate strategies to gain meaning from print techniques,tools,units,and formulas in Uses a variety of resources to gain making measurements Information and support comprehension Use and understand measurement of text reference frames In time,temperature, Applies knowledge of word study and coordinate systems (phonics,spelling,word structure,word Understand the meanings,uses,and meaning and grammar)to read and representations of numbers understand text Understand equivalent names for Responds to text in oral and written form numbers Uses listening skills to develop and Understand common numerical relations support comprehension Compute flexibly,fluently,and accurately Comments: Understand meaning of operations WRITING GR-K 3 3 3 Understand patterns and functions Tciacher Ackerman,Julia Use algebraic notation to represent and Writes for a variety of reasons to various analyze situations and structures audiences using different formats Make reasonable estimates Applies knowledge of word study Comments: (phonics,spelling,word structure,word meaning and grammar)to communicate SOC STUDIES GR-K 3 3 3 effectively through writing Teacher: Ackerman,Julia Communicates ideas in writing using Demonstrates understanding of key legible handwriting,punctuation and concepts related to history,geography, capitalization economics and civics Demonstrates effective oral Understands and applies key vocabulary communication related to history,geography,economics Comments: --- and civics T Gathers,classifies and interprets MATH GR-K 3 3 3 information related to history, TpBCAer: Ackerman,Julia •�_,� geography,economics and civics Select and create the appropriate Sequences events in chronological order graphical representations of collected or - Compares,contrasts and makes given data Analyze and interpret data connections between past and present Determines cause and effect relationships Understand and apply basic concepts of Draws conclusions and makes'— probability generalizations _ _ Investigate characteristics and properties uses and Interprets maps and globes in a of two-and three-dimensional geometric varlety of ways shapes Appy transformations(movements)and- Participates In group related activities in symmetry in geometric figures preparation for living in a democratic . Comments: Dr.3ames G.Merrip Superintendent Virginia Deach City Public Schools Mission Statement The Virginia Beach City Public Schools,in rortnershlp with the entire community,will empower every student to become a lire-long learner who Is a responsible,productive and engaged citizen within the global community. paOe I of 2 Student: COPE,KATELYN SEAN ID: 352786 Grade: KA 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr 1st Qtr 2nd Qtr 3rd Qtr 41h Qtr SCIENCE GR-K 3 3 3 CITIZENSHIP GR-K Cont.. S 0 S TeadM-n, Ackerman,Julia Teacher: Ackerman,Julia Uses science process skills to engage in Respects authority scientific Inquiry Accepts responsibility Develops questions about objects, Demonstrates self-control organisms and events in the environment Respects property and rights of others from observations Plans and conducts a simple experiment Obeys class/school rules Employs simple equipment and tools to Comments: gather data and extend the senses WORK HABITS GR-K S S S Uses data to construct a reasonable _ Teacher. Ackerman,Juna explanation follows directions Communicates investigations and Ustens attentively explanations Works well independently Demonstrates knowledge of key vocabulary Completes class assignments In timely manner Demonstrates understanding of key Completes homework on time science concepts Comments: Works for neatness and accuracy Works well with others HEALTH G' A S S S Puts forth best effort Teadrer Ackerman,]ulia Demonstrates understanding of concepts Comments: and skills Participates in discussions and/or activities ATTENDANCE REPORT Completes projects Regular attendance and punctuality are Important factors Comments: affecting your third's educational growth. ART GR-K O S S 1st Pedod 2nd Period 3rd period 41h Period Ta33dier.• Mattson,Megan Days Present 45 45 48 Behavior O S S Days Absent 0 1 0 Strives for original artwork using Times Tardy 0 0 0 curriculum objectives Demonstrates understanding of key COMMENTS concepts related to aesthetics,art Katelyn continues to make good progress in school. It Is exciting to see her De history,art criticism and art production — become such a good reader and writer. She has a good sight milord of 1p prlat knowledge and application vocabulary and is making great progress with her word study activities. I of appropriate skills and techniques _ look forward to seeing continued progress in school, Keep up the good Comments: world MUSIC GR-K S S O Teadier: Lupton,Julia Behavior S S 0 � 1 Demonstrates knowledge and application of appropriate musical concepts and skills Performs at an appropriate musical level Displays proper platform/tone production techniques Comments: l/ PHYSICAL ED GR-K S S S reacher: Ackerman,Julia Behavior 5 5 S Demonstrates manipulative and non-manipulaWe skills in modified game activities Explains the relationship between fitness and health Demonstrates sportsmanship and social skills in group situations Participates in fitness activities Comments: CITIZENSHIP GR-K _ S O S Page 2 aft LINKHORN PARK ELEMENTARY SCHOOL Report Card 977 FIRST COLONIAL ROAD VIRGINIA BEACH,VA 23454 2011-2012 Year 757-648-2920 3rd Marrking king Period Student: COPE,DYLAN ANDREW ID: 352765 Teacher: Reed,Erika Grade: 02 Grading Key-Reading,Writing,Mathemati6,Science,Social Studies Grading Key-Citizenship,Work Habits,Physical Education,Art,Music, Strings,Health 4 Exceeds grade level expectations 0 Outstanding 3 Meets grade level expectations S Satisfactory 2 Experiences difficulty meeting grade level expectations N Needs Improvement 1 Does not meet grade level expectations U Unsatisfactory NE Not evaluated NE Not evaluated X Area of concern/needs additional attention X Area of concern/needs additional attention m Not on grade level ' Not on grade level 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Ist Qtr 2nd Qtr 3rd Q& AW h READING GR-02 4- 4- 4 MATH GR-02 cont.. 3 3 3 Teacher.- Rendon,Rita Understand the systems and processes of Uses a variety of reading comprehension measurement;use appropriate strategies to gain meaning from print techniques,tools,units,and formulas in Uses a variety of resources to gain making measurements Information and support comprehension Use and understand measurement of text reference frames In time,temperature, Applies knowledge of word study and coordinate systems (phonics,spelling,word structure,word Understand the meanings,uses,and meaning and grammar)to read and representations of numbers understand text Understand equivalent names for Responds to text in oral and written form numbers Uses listening skills to develop and Understand common numerical relations support comprehension Compote flexibly,fluently,and accurately Comments: _ Understand meaning of operations WRITING GR-02 3 4 3 Understand patterns and functions Teaee,:• Rendon,Rita Use algebraic notation to represent and Writes for a variety of reasons to various analyze situations and structures audiences using different formats Make reasonable estimates _ Applies knowledge of word study Comments: (phonics,spelling,word structure,word meaning and grammar)to communicate SOC STUDIES GR-02 3 _ 4 3 effectively through w_rItI g - Teacher Reed,Frika -� Communicates ideas in writing using Demonstrates understanding of key I legible handwriting,punctuation and concepts related to history,geography, capitalization economics and civics Demonstrates effective oral Understands and applies key vocabulary communication related to history,geography,economics --"--" �-'"`'—'" and civics Comments:-- - _ y- - - _ ! Gathers,classifies and interprets MATH GR-02 3 3 3 information related to history, Teacher: Reed,Erika geography,economics and civics Select and create the appropriate Sequences events in chronological order graphical representations of collected or -`" -� given data Y- - Compares,contrasts and makes - -- connections between post and present_ Analyze and interpret data Determines cause and effect relationships Understand and apply basic concepts of r Draws conclusions and makes probability _w _ _ generalizations Investigate characteristics and properties Uses and interprets maps and globes in a_ l of two-and three-dimensional geometric variety of ways shapes ..-_ participates in group related activities ill Apply transformations(movements)and preparation for living In a democratic symmetry in geornetric fioure5 society Comments: Dr.lames G.Murrill Superintendent Virginia Deach City Pubtic Schools Mission Stalemenl The Virginia Reach City Public schools,in partnership with the emir,community,will empower every student to become:8 rite-ronl;learner who Is a respon"C,productive and engaged dozen cdthin the global commrmtty. Pdge 1 of 2 Student: COPE, DYLAN ANDREW ID: 352765 Grade: 02 1st Q& 2nd Qtr 3rd Qtr 401 Qtr 1st Qtr 2nd Qtr Std Qtr 4th Qtr SCIENCE GR-02 4- 4 3 CITIZENSHIP GR-02 cont.„ 0 0 0 Teadmr: Reed,Erika Teacher. Reed,Erika Uses science process skills to engage in Respects authority scientific inquiry Accepts responsibility Develops questions about objects, Demonstrates self-control organisms and events in the environment from observations Respects property and rights of others Plans and conducts a simple experiment Obeys class/school rules Employs simple equipment and tools to Comments: gather data and extend the senses WORK HABITS GR-02 O O O Uses data to construct a reasonable Teacher. Reed,Erika explanation Follows directions Communicates investigations and Ustens attentively explanations Works well independently Demonstrates knowledge of key Completes class assignments in timely vocabulary Demonstrates understanding of key manner 1 Completes homework on time science concepts Comments: Works for neatness and accuracy Works well with others HEALTH GR-02 o O O p�forth best effort _._. Teacher._Rendon,Rita Demonstrates understanding of concepts Comments: and skills Participates in discussions and/or ATTENDANCE REPORT activities Completes projects Regular attendance and punctuality are important factors Comments: affecting your chilMr educational growth. ART GR-02 S O S 1st Period 2nd Period 3rd Period 4th Period Teacher: Mattson,Megan Days Present 45 46 48 Behavior S O 5 Days Absent 0 0 0 Strives for original artwork using Times Tardy 0 0 0 curriculum objectives Demonstrates understanding of key COMMENTS concepts related to aesthetics,art Dylan has worked very hard this quarteri He has made great strides in all history,art criticism and art production subject areas. Demonstrates knowledge and application j Dylan has always been great In Math,but I am so happy of appropriate skills and techniques that I see him going above what is asked of him daily. Dylan is also a great help to both his teachers and friends. We are so proud of himl Comments: Double"0"Club,Perfect Attendance,and Character Honor Rolil MUSIC GR-02 0 S O Great Job Dylanl Teadrer.• Herring,Susan Erika Reed and Rita Rendon Behavior 5 0 O _ Demonstrates knowledge and application i of appropriate musical concepts and skills Performs at an appropriate musical level h /� Displays proper platform/tone production �- f y. e \J techniques r }r Comments: PHYSICAL ED GR-02 S 0 0 reader.• Slmmelink,A -, Behavior _ O 5 O Demonstrates manipulative and !^ non-manipulative skills in modified game activities _ Explains the relationship between fitness and health__ Demonstrates sportsmanship and social skills In group situations _ Participates in fitness activities Comments: CITIZENSHIP GR_02� _ O O O Page 2 oft 2012-2013 School Year LINKHORN PARK ELEMENTARY SCHOOL First Grade Report Card Krista Barton-Arnold,Principal 977 FIRST COLONIAL RD Marking Period RP4 FNL VIRGINIA BEACH,VA 23454 (757)648-2920 Student: KATELYN COPE ID: 352786 Teacher: Megan Perry Grading Key- aral Language,Responding to Literature,Written Communication, ATTENDANCE Mathemntles,Science,and Social Studies Regular attendance and punctuality are important factors affecting your child's 4 Exceeds grade level expectations educational growth. 3 Meets grade level expectations 2 Experiences difficulty meeting grade level expectations Marking Period st 2nd 3rd 4th 1 Does not meet grade level expectations Days Present 44 46 43 49 NE Not Evaluated --_ ._.__M,_.....�....e...�._._..-.._....,.. Based on modified standards Days Absent 1 0 0 X Area of Concern/Needs Attention Times Tardy 0 0 0 0 Grading Key- Citizenship,Work Habits,Art.Music,and Physical Education 0 Outstanding NE Not Evaluated ^- S Satisfactory Based on modified standards Marking Period 1st 2nd 3rd 4th N Needs Improvement X Area of Concern/Needs Attention MATHEMATICS 3 3 3 3 U Unsatisfactory Teacher. Perry,M. _ I _ _ I Understands numbers,the ways of representing whole numbers and rational numbers and the j X Marking Period 1st 2nd 3rd 4th relationships that exist among these number ---- --- and number systems ORAL LANGUAGE 3 1 3 3 I 3 —_.._......... . f Teaches Perry,M. Understands the meanings of addition arid X - -- °-- -- subtraction and computes using whole numbers • i Demonstrates(growth in or effective)oral communication skills across a variety of Understands measurable attributes of objects situations and events,units of measure,and systems of S X RESPONDING TO LITERATURE 3 3 2 3 measurement Teacher: Perry,M. �_� Applies appropriate techniques and tools to _._-..� -- determine measurements C Reads and demonstrates comprehension of fictional texts X Analyzes characteristics and properties of plane I ! and solid geometric shapes Reads and demonstrates comprehension of _ ` nonfiction texts Formulates questions and constructs answers Expands vocabulary through reading by collecting,organizing and displaying data experiences Understands patterns(repeating and growing) and relations Represents and analyzes mathematical situations and structures using algebraic symbols WRITTEN COMMUNICATION 2 3 3 3 Teacher: Perry,M. Writes to effectively communicate ideas for a X variety of purposes Edits final copies for correct capitalization ending punctuation,and spelling Virginia Beach City Public Schools Mission Slatement The Virginia Beach City Public Schools,in partnership with the entire community,vvill empower every siudenl to beLoma a life-long leamerwho is a responsible,productive and engaged citizen within tfie global community. Dr.James G.Merrill.Superintendent rrage t of 2 2012-2013 School Year LINKHORN PARK ELEMENTARY SCHOOL Third Grade Report Card Krista Barton-Arnold, Principal 977 FIRST COLONIAL RD Marking Period RP4 FNL VIRGINIA BEACH,VA 23454 (757)648-2920 Student: DYLAN COPE ID: 352765 Teacher: Ann Kampfmueller Overall Grading Key-Oral Language,Reading and Responding to Literature,Written ATTENDANCE Communication,Mathematics,Science,and Social Studies A ii-100 _ C- 70-72 Regular attendance and punctuality are important factors affecting your A- 90-92 I D+ 67-69 child's educational growth. E+ 87-89 0 64-66 Marking Period 1st 2nd 3rd 4th B 83-86 E Below 64 B- 80-82 NE Not Evaluated Days Present 44 46 43 49 C+ 77-79 X Area of ConcemlNeads Attention -- -- - C 73-76 Based on modified standards Days Absent 0 1 i 0 0 .. ..._-.................. ... _ Grading Key- Citizenship,Work Habits,Art,Music,and Physical Education Times Tardy 0 0 0 j 0 0 Outstanding NE Not Evaluated S Satisfactory Based on modified standards N Needs Improvement X Area of Concern/Needs Attention Marking Period' 1st 2nd I 3rd 1 4th JFinal U Unsatisfactory MATHEMATICS _ A B+ I A. A- A- Teacher. Kampfmueller,A Marking Period 1st 2nd 3rd 4th Final Understands the ways of representing whole i numbers and rational numbers and the ORAL LANGUAGE A B+ A- A relationships that exist among these numbers Teacher. Kampfmueller,A. and number systems Uses effective communication skills in group ! Understands the meanings ; activities s of addition,_ g - subtraction,multiplication,and division and Presents brief oral reports using visual media computes using whole numbers and rational READING and RESPONDING TO numbers LITERATURE A- A- A- B+ A- Teacher: Kampfmueller,A. I I Understands measurable attributes of objects -- °--°- - and events,units of measure,and systems of Applies knowledge of word study(phonics, measurement spelling,word structure,and word meaning)to Applies appropriate techniques and tools to expand vocabulary.read and understand text, and communicate effectively in written and oral determine measurements I forms. Analyzes characteristics and properties of Reads and demonstrates comprehension of — -- . -- ---..• -- plane and solid geometric shapes fictional texts and poetry Formulates questions and constructs answers by collecting,organizing,and displaying data Reads and demonstrates comprehension of -- - - ---- --°{ nonfiction texts Understands and'applies basic concepts of probability WRITTEN COMMUNICATION B+ B+ A- B+ A- Unde-r_"_.".. . . .-_.. _.. Understands patterns(repealing and growing) j Teacher. Kampfmueller,A. t t ._._ .. _ .. . _ ._..__ ... and relations t Writes for a variety of purposes,Including to inform,to explain,to describe,to defend an Understands,represents and analyzes opinion,and to tell about a personal experience mathematical situations and structures using I algebraic symbols i Edits writing for correct grammar,capitalization, punctuation,and spelling Uses an inquiry process to write a short report Virginia Beach City Public Schools Mission Statement The Virginia Beach City Public Schools,in partnership with the entice community,will empower every student to become a life-long learner who is a responsible,productive and enoaged citizen within the global community Dr.James G.A vIAl Superintendent Page 1 of 2 LINKHORN PARK ELEMENTARY SCHOOL Year: 2013-2014 14�I SCH=5 Student Profile Report: STU201 COPE, KATELYN J. -- Homeroom: 16 General information Student Name Perm ID Gender Grade COPE, KATELYN J. 352786 F 02 State ID Last Name Goes By Nick Name 1017345701 Birth Date Birth Place Leave Date Enter Date 08/2112006 07/01/2013 Home Phone Home Language Resolved Race/Ethnicity 757-235-6141 ENGLISH CAUCASIAN Home Address Mailing Address 1409 CHEVAL CIR 1409 CHEVAL CIR VIRGINIA BEACH, VA 23451 VIRGINIA BEACH, VA 23451 Bus Routes: AM Bus: AM K bus to home: PM Bus: PM K bus to school: Day Care: Custodial Information MOTHER Employer Q Lives With Q✓ Contact Allowed []Mailings Allowed COPE,AIMIE HOMEMAKER Has Custody Q✓ Ed.Rights Address: E-Mail: 1409 CHEVAL CIR ASTOREAIMIE2 @GMAIL.COM VIRGINIA BEACH,VA 23451 Phone Type: Phone: Extension: Q Primary n Not Listed []Contact Phone Cell 757-235-6141 I,the undersigned parent/guardian,give my consent for the above named child to be released to me or my spouse or to the friend/relative I have so designated and/or to be taken by ambulance to the nearest hospital in case of emergency. I understand that Virginia Beach City Public Schools does not provide accident medical/dental coverage for students for injurieshllnesses occurring at school. I understand that I may voluntarily purchase a student accident insurance plan. I further acknowledge that I am financially responsible for medical,dental,ambulance,or other health care expenses or transportation of my child home,which might occur as a result of such illness or injury. Signature Parent/Guardian Date Printed by Winnie Backman at 07/08/2013 12:00 PM Virginia Beach City Public Schools Page 1 of 1 LINKHORN PARK ELEMENTARY SCHOOL Year: 2013-2014 Vgy�J�J/1�ACNGIYY_PUk4�43nJOQ�i Student Profile Report: STU201 COPE, DYLAN A. -- Homeroom: 28 General Information - Student Name Perm ID Gender Grade COPE, DYLAN A. 352765 M 04 State ID Last Name Goes By Nick Name 1017345927 Birth Date Birth Place Leave Date Enter Date 07/22/2004 07101/2013 Home Phone Home Language Resolved Race/Ethnicfty 757-222-0177 ENGLISH CAUCASIAN Home Address Mailing Address 1409 CHEVAL CIR 1409 CHEVAL CIR VIRGINIA BEACH, VA 23451 VIRGINIA BEACH, VA 23451 Bus Routes: AM Bus: AM K bus to home: PM Bus: PM K bus to school: Day Care: Custodial Information_ MOTHER Employer Q✓ Lives With QContact Allowed Mailings Allowed COPE,AIMIE HOMEMAKER Has Custody Ed.Rights Address: E-Mail: 1409 CHEVAL CIR ASTOREAIMIE2 @GMAIL.COM VIRGINIA BEACH,VA 23451 Phone Type: Phone: Extension: Q primary []Not Listed O Contact Phone Cell 757-235-6141 STEP- Employer 0 Lives With n Contact Allowed [:]Mailings Allowed ASTORE, JOEL Has Custody 2 Ed.Rights Address: E-Mail: Phone Type: Phone: Extension: [-]primary []Not Listed [:]Contact Phone Cell 757-235-6151 I,the undersigned parent/guardian,give my consent for the above named child to be released to me or my spouse or to the friend/relative I have so designated and/or to be taken by ambulance to the nearest hospital in case of emergency. i understand that Virginia Beach City Public Schools does not provide accident medical/dental coverage for students for injuries/illnesses occurring at school.I understand that I may voluntarily purchase a student accident insurance plan. I further acknowledge that I am financially responsible for medical,dental,ambulance,or other health care expenses or transportation of my child home,which might occur as a result of such illness or injury. Signature Parent/Guardian Date Printed by Winnie Backman at 07/08/2013 11:57 AM Virginia Beach City Public Schools Page 1 of 1 COMMONWEALTH OF VIRGINIA RIA IAGE REGISTER GACM COURT OR COLK Y OF CLERICS FOR aEOFF COURT VIRGINIA BEACH N20130117000074270 1.RAl NAIL I?hfl to BOOK BEOURITY b OF GROOM JOEL ELY ASTORE LEAVE BLANK 2 AGE 3.DATE OF BIRTH(Uw^DO%YAW 4.PLACE OF BIRTH(sialm or f vW c wxft) 29 Y� 01/25/1983 PA 9 RACE 0.NUMBER� am��4�) 7.MARITAL STATUS�piw9ocry MARRLAGE ATE SECOND WIDOWEDG 4ORCED0 GROOM S EDUCATION Elm m(ary or Sroordary cdkw (Ia USUAL RESIDENCE:STREET ADDRESS OR RT.NUMBER ��"a (0.12) (1*4 0r 50 1409 CHEVAL CIRCLE n -C:i7 Z m"r3 VA CRY OR TOWN OF RESIDENCE 16e OOIINI v(I&XAWWzbw� trace brar+kl 1 f10.STATE(OR FOREIGN COUNTRY) 3 VMCYnQA BEACH ' VA 23451 o C) f 0.NAME OF FATHER 4 t.FULL MAIDEN NAME OF MOTHER © Z� WILLIAM FRANK ASTORE SR SUSAN MARIE JAMES ,Z�j 12 PRESENT NAME (Iyap ( ) (�+J I MAIDEN SURNAME R1 12.SOCIAL SECIJiifTYF OF BRIDE AIMIE RENEE COPE 'COWAN LEAVE BLANK P "G..( I&AGE 14.DATE OF WITH"nA Day,Yml 15.PLACE OF BIRTH(mar-brow aovmyl X :C 28 Year. 06/08/1984_ PA 3�n �` lI&RACE i7.NULBEA OF (lht asoal4 NR) tb MARITAL STATUS(!f PnKauy qQ is WHITE B�nentary THIBMARRUIGE SECOND WIDO1AfFDCLnIV -_ �� E(UDE' 1G: 7412 I (I4 o USUAL RESIDENCE.,STREET ADDRESS OR RT.NUJIBEA c') •oar 1 2 1409 CHEVAL CIRCLE X S 201x CITY OR TOWN OF RESIDENCE 120e.OOUNTY jV kAVwdwX c%Una bbt* 1 Md.STATE(OR FOREIGN COIRMrO D VIRGINIA BEACH ' 'VA 23451 III.NAME OF FATHER 22.FULL MAIDEN NAME OF MOTHER ROBERT L COWAN WENDY LEE BEAM 28.TO ANY PERSON TO MARRIAGES: QE UCEUM You we Im"by ++ �In JANUARY 17,2013 tai 1 R �O A%wd In ru C.011aaOeNGW.of DIY bWad Cab ttowa S6dy Days AW AQOvr Dated or Court fie Ofndw ad Ct 01-y^ TO OFFICIAN$ UMMIAOE CERTIFIG TE =mid = 24.DATE OF (#Amf/A AW.Yew) 25. GF .low d aYyl 2fA TYPE OF coo- tie AURR1AQfO�_ a o VIRQINU CEREMONY GM Rlcl IGIQUS� FMWm boM aPin 27.1 CERTIFY THAT 1 JONUI THE ABOVEAAMED PERSONS W ON THE DATE AND AT THE PLACE SPECIFIED. vdm Sm days le cowk at cow T > _� Marr�Qa�C,ornr�issr�stu�, C4)lb o 32 f 267. AvOprlaad to rNrlone by nr Clydif Coot Mr • •T VlQ r ..ice-K�-^`��+ .ylgh*In Di' Seer n veyrr. OAMdOF / of adnb r�r o arix.mn CAY NAME 008 of p&Q ADDRESS and v • Va• 6ck VA _ 3 T((ww a or ram (stm) cY+�s�W.+-aiaut a ua•'.M cs...rrrx u..,••-•..•.avt•:aao=w'w�a+nsar�c.a�n+w • -acx� ............ ..._ ... .... ... customer idtntifitr .. . .. -.. .. .. ..... .. . .. .... A60383577 Name ASTORE AIMIE,RENEE Address r 1409 CHEVAL CIR s. VIRGINIA BEACH,VA 23451-6003 =� Sex Class Date of birth +v F NONE 0610811954 0 Byes Endorsements Iss REI HAZ NONE 02/05/2013 He(fht Restrictions Ex ` 01)059551930 5FT 61N X aIQs1��1 `� ^r r r i ir.wr�wwr�� � � n � w� i�rrr.�r•irrrw.rr�wa� - BRIAN COPE, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. : AIMIE RENEE COPE, DEFENDANT NO. 10-3195 CIVIL ORDER OF COURT AND NOW, this 31St day of July, 2013, upon consideration of Aimie Renee Cope Astore's Pro Se-Petition for Transfer of Venue, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon Brian Cope to show cause why the relief requested should not be granted; 2. Brian Cope shall file an Answer on or before August 23, 2013; 3. Argument on the matter will be held on Friday, September 27, 2013, at 2:00 p.m. in Courtroom No. 2 of the Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, M. L. Ebert, Jr., J. to Bria Co e p Aimie Renee Cope Astore bas ZC Fri �� • _ i BRIAN COPE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA. V. 2010-3195 CIVIL ACTION LAW AIMIE RENEE COPE IN CUSTODY Petition to make Absolute I, Aimie Renee Astore,previous named Aimie Renee Cope and defendant in the case associated with docket number 2010-3195,moves the court for an order changing venue in this matter to Virginia Beach, Virginia to be made absolute. This Petition is based on the facts set forth: 1. The Plaintiff for the case at hand,Brian Cope,was given until August 23rd to respond as to the reasons against the transfer of venue. 2. The Plaintiff for the case at hand,Brian Cope,withheld response and support as to why the case should not be moved to Virginia Beach, Virginia. 3. Due to no parties involved in this case being residences of Cumberland County, I ask you to rule that the Transfer of case number 2010-3195 to Virginia Beach,VA be made Absolute. Therefore, I respectively urge for the court to make the transfer of docket number 2010-3195 to the Virginia Beach Court. i ly, (7z Date: �" C )&—� Aimie Renee Astore c co M rn = .. M BRIAN COPE, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. AIMIE RENEE COPE, DEFENDANT NO. 10-3195 CIVIL ORDER OF COURT AND NOW, this 18"day of September, 2013, upon consideration of Aimie Renee Cope Astore's Pro Se Petition for Transfer of Venue and her Petition to Make the Rule Absolute; IT IS HEREBY ORDERED AND DIRECTED that: 1. The hearing currently scheduled on this matter for Friday, September 27, 2013, at 2:00 p.m. is continued until Monday, December 16, 2013, at 2:00 p.m. in Courtroom No. 2 of the Cumberland County Courthouse. 2. A copy of this Order will be served upon Brian Cope by regular mail and certified mail, return receipt requested by Aimie Renee Cope Astore. Proof of service shall be provided to the Court on or before October 31, 2013. 3. At the hearing on Monday, December 16, 2013, the parties will be required to attend and present testimony prior to the issuance of a final Order in this case. By the Court, '131 CO M. L. Ebert, Jr., J. x-C) �Brian Cope �Aimie Renee Cope Astore bas BRIAN COPE, : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. • • AIMIE RENEE COPE, • DEFENDANT : NO. 10-3195 CIVIL IN RE: PETITION FOR TRANSFER OF VENUE ORDER OF COURT AND NOW, this 16th day of December, 2013, upon consideration of Aimie Renee Cope's Petition for Transfer of Venue and the Court noting that Brian Cope has failed to answer the Petition or appear for hearing in the matter and the Petition noting that both parties no longer reside in Cumberland County; IT IS HEREBY ORDERED AND DIRECTED that the Petition for Transfer of Venue is GRANTED. The Cumberland County Prothonotary is directed to transfer all records and files pertaining to this matter to the Circuit Court of Virginia Beach, Virginia. By the Court, ■ 'I M. L. Ebert, Jr., I J. /Aimie Renee Cope Astore 1409 Cheval Circle Virginia Beach, VA 23451 ? FJ bas c: rn r,.: DO z I�1� < .:..: