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HomeMy WebLinkAbout02-3362 NM BAYLEY & MANGAN Mark F. Bayley, Esquire Attorney I.D. #: 87663 17 West South Street Carlisle, PA 17013 (717) 241-2446 Jill A. Borgaonkar, Plaintiff Fil..ED-QE~~IC~ w~FOQ~T zS ~~~ Q; (# ~IJP°4E3E~LAt~D GGJ~dT~f ~E~N~'t'L~~',~.~1,'~, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Rajendra D. Borgaonkar, No. 02 - 3362 CIVIL Defendant IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY AND NOW comes Petitioner, Rajendra D. Borgaonkar, by and through his attorney, Mark F. Bayley, and in support of the within petition avers as follows: 1. Rajendra D. Borgaonkar, Petitioner, (hereinafter referred to as "Father"), is the Plaintiff in the above caption-matter, and is an adult currently residing at 515 Sandbank Rd., Mt. Holly Springs, PA 17065. 2. Jill A. Borgaonkar, k/n/a Jill A. Markel, Respondent, (hereinafter referred to as "Mother"), is the Defendant in the above-captioned matter, and is an adult individual residing at either 28 Woodview Drive, Mt. Holly Springs, PA 17065 or 267 Park Drive, Boiling Springs, PA 17007. 3. The parties are the natural parents of: Nicholas Borgaonkar (born September 24, 1995) ~~~ N`~ ~~ ~,~ ~-'~ Noah Borgaonkar (born May 16, 1998) Evan Borgaonkar (born January 12, 2000) 4. A prior order was entered on September 5, 2002, by the Honorable Wesley J. Oler (copy is attached as Exhibit "A") 5. A change of circumstances has since occurred. 6. Father is requesting that the current order be modified as agreed upon by the parties or otherwise determined by the court to be in the best interests of the child. WHEREFORE, Petitioner requests this Honorable Court to schedule a custody conciliation conference. Date: l(/ ~ `~'~/ ~ y Respectfully submitted, BAYLEY & MANGAN Mark F. Bayley, Es ire 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court ID # 87663 Jill A. Borgaonkar, 1N THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Rajendra D. Borgaonkar, No. 02 - 3362 CIVIL Defendant IN CUSTODY ATTORNEY VERIFICATION Mark F. Bayley, Esquire, states that he is the attorney in relation to the within matter; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: ~ O .~ 2 ~ '' , U Mar F. Bayley, Esquire Jill A. Borgaonkar, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Rajendra D. Borgaonkar, No. 02 - 3362 CIVIL Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, do hereby certify that I this day served a copy of the foregoing document upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Dated: ~ `' ^ " ~ / ` Hannah Herman-Snyder, Esquire 200 Hanover Street Carlisle, PA 17013 Mark F. Bayley, Esquire JILL A. BORGAONKAR IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2002-336 CIVIL ACTION LAW RAJENDRA D. BORGAONKAR DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, October 28, 2010 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. ,the conciliator, at 4th Floor , Cumberlaud County Courthouse, Carlisle on Thursday, December 02, 2010 at 2:00 PM for aPre-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/ Hebert X. Gilro Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangem ents 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 ~~~als/D ~• ~~ h(~/ Yj ~~~~~~ 32 South. Bedford Street ', e-s ~ ~ Carlisle, Pennsylvania 17013 ~_.._ ~--.~ /O d~'h ~~7~ ~ ~ `"9 -- a /fG+eLc. ~ 7~~'~,yr~_ Telephone (717) 249-3166 ~' ~' rr, a=W ~:~ w -='- -rt lQ ~rY, .~, e~.' ~ ~0' ~ y ~~ r~i~ ~ ~ ~' ., , l / ibt, ~ --~ ~':.. Cra ~ ~-~~~2~e= ~ y a ~ ~ ~~ ~ ~ ~ ~~ ~ s ~ ~-a ~~ r~ c~ ~r~ ..~= ~ ~ JILL A. BORGAONKAR IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 2002-3362 CIVIL ACTION - LAW RAJENDRA D. BORGAONKAR CUSTODY Df d e en c o =rn PRAECIPE FOR ENTRY OF APPEARANCE `<> N r ca =C) To David D. Buell, Prothonotary: c Please enter my appearance on behalf of the Plaintiff, Jill A. Borgaonkar (Markel), in the above captioned case. Respectfully submitted, Tes'Holst, Esquire Mi enn Legal Services 401 E. Louther Street Carlisle, PA 17013 (717) 243-9400 Date: ?' 2 2 • 10 C) rni= -0m :?u o o-n ;za om JILL A. BORGAONKAR Plaintiff VS. RAJENDRA D. BORGAONKAR Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002-3362 CIVIL ACTION - LAW : CUSTODY CERTIFICATE-OF SERVICE I, Jessica Holst, Esquire, of MidPenn Legal Services, attorney for the Plaintiff, Jill A. Borgaonkar (Markel), hereby certify that I have served a copy of the foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following date and in the manner indicated below: U.S. First Class Mail, Postage Pre-Paid Mark F. Bayley, Esquire 17 West South Street Carlisle, PA 17013 Date: I? - 2'1.1D Jessr dlst, Esquire ices Mid Legal Serv 401 uther Street Carlisle, PA 17013 (717) 243-9400 JILL A. MARKEL, (f/k/a JILL A. BORGAONKAR), Plaintiff VS. RAJENDRA D. BORGAONKAR, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.20023(P oZ ac:: n rn C'7 I -Q ri r- -°-4 ' Prior Judge: The Honorable J. Wesley Oler, Jr. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE 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: Nicholas Borgaonkar, born September 24,1995, Noah Borgaonkar, born May 16, 1998, and Evan Borgaonkar, born January 12, 2000. 2. A Conciliation Conference was held on December 2, 2010, with the following individuals in attendance: The mother, Jill A. Markel, with her counsel, Jessica Holst, Esquire and the father, Rajendra D. Borgaonkar, with his counsel, Mark F. Bayley, Esquire. 3. There is an existing order from September 2002 which provides for a 50150 custody situation. The parties have been living under that order for the past eight years. The father is now petitioning for a modification and is seeking primary custody of the minor children. There have been some mental health issues with the mother. However, the mother is not in agreement to change the custody situation at this point and a hearing is required. 4. The Conciliator recommends an Order in the form as attached. Date: December, 2010 Hubert X. Gil y, Esquire Custody Co ciliator n JILL A. MARKEL, (f/k/a JILL A. BORGAONKAR), Plaintiff VS. RAJENDRA D. BORGAONKAR, Defendant Prior Judge: The Honorable J. Wesley Oler, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA c G ' CIVIL ACTION - LAW ? 1 M-- NO. 2002363-• 33(o :,, r7 r- t._: C) cz C.' N :z C3 COURT ORDER G: NOW, this 1 Z. day of December, 2010, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Court Room No. 1 of the Cumberland County Courthouse on the day ojl?-, 2011 at LiDL-p-m. At this hearing, the father shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a memorandum setting forth the history of custody in this case, the issues currently before the Court, a summary of each parties position on these issues, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least five days prior to the mentioned hearing date. 2. Pending further Order of this Court, this court's prior order of September 5, 2002, shall remain in effect. cc: Jessica Holst, Esquire Mark F. Bayley, Esquire Copes tK4, led lo-11,311o ,IG BY THE COURT, BAYLEY & MANGAN Mark F. Bayley, Esquire ,,,, CD Attorney I.D. #: 87663 G C ..{, 17 West South Street -vco 2; rn` r Carlisle, PA 17013 r*t : .o r n ? ' (717) 241-2446 1 v1 1 o ZO 3 ? ? Jill A. Borgaonkar, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW Rajendra D. Borgaonkar, No. 02 - 3362 CIVIL Defendant IN CUSTODY MOTION TO CANCEL HEARING AND NOW, comes Rajendra D. Borgaonkar, by and through his attorney, Mark F. Bayley, and in support of the within motion avers as follows: 1. The Honorable J. Wesley Oler is assigned to the within matter. 2. A hearing is scheduled for April 8, 2011. 3. The parties are in agreement to cancel said hearing and to comply with the prior Order of Court dated September 5, 2002. 4. Jessica Holst, Esquire, represents the Plaintiff and concurs with the within motion. Wherefore, Defendant respectfully requests the Court to cancel the upcoming hearing and to enter the attached order. r ^? Date: Respectfully submitted, BAYLEY & MANGAN U Mark F. Bayle , squire 57 W. Pomfret St. Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D. # 87663 Attorney for Plaintiff Jill A. Borgaonkar, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW Rajendra D. Borgaonkar, No. 02 - 3362 CIVIL Defendant IN CUSTODY VERIFICATION Mark F. Bayley, Esquire, states that makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: Mark F. Bayley, Esqui r Jill A. Borgaonkar, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW Rajendra D. Borgaonkar, No. 02 - 3362 CIVIL Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, do hereby certify that I this day served a copy of the foregoing document upon the following by First Class U.S. Mail: Jessica Holst, Esquire MidPenn Legal Services 401 E. Louther St. Carlisle, PA 17013 Mark F. Bayley, Esquire I i Jill A. Borgaonkar, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA c r-a c -n v MM 3 ? . CIVIL ACTION - LAW = 70 7:0 ":) rn Rajendra D. Borgaonkar, No. 02 - 3362 CIVIL Defendant IN CUSTODY =c-" 77' :D ORDER AND NOW, this day of , 2011, upon agreement by the parties it is hereby Ordered and Directed as follows: I . The hearing scheduled for April 8, 2011 is hereby cancelled. 2. The prior Order of Court dated September 5, 2002 shall remain in full force and effect. By the Court, n J. Wesley er, ?s T t Distribution: `Jessica Holst, Esquire Mark F. Bayley, Esquire ? r/?,tled SOP' N'5?1 JILL A. BORGAONKAR (N.K.A. Markel) : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW RAJENDRA D. BORGAONKAR, : NO. 02-3362 CIVIL TERM Defendant. : IN CUSTODY PETITION TO MODIFY CUSTODY AND NOW, comes Rajendra Borganonkar by and through his attorney, Mark F. Bayley, and in support of the within motion avers as follows: 1. The Honorable J. Wesley Oler, Jr. was previously assigned to the within matter. 2. The Petitioner is Rajendra Borgaonkar, (hereafter "Father") who resides at 515 Sandbank Road, Mt. Holly Springs, Pennsylvania, 17065. 3. The Respondent is Jill A. Borgaonkar(k/n/a Jill A. Markel) (hereafter "Mother") who resides at 28 Woodview Drive, Mt. Holly Springs, PA 17065. 4. The parties are the natural parents of the children at issue: Noah Borgaonkar,born May 16, 1998 and Evan Borgaonkar,born January 12, 2000. 5. The controlling Order in this matter was executed on September 5, 2002 (attached as "Exhibit A"). 6. Since August of 2013 the children have been residing primarily with Father. 7. The entry of an order that reflects the actual custodial arrangement is now appropriate. 7_73 -n `- a4 3 01 WHEREFORE, Father requests the scheduling of a custody conciliation conference. Respectfully submitted, BAYLEY & MANGAN Date. Mark F. Bayley, Es ire 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court ID # 87663 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unsworn falsification to authorities. Date Raj Borgao r JILL S. BORGAONKAR (N.K.A. Markel) : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY,PENNSYLVANIA v. : CIVIL ACTION - LAW RAJENDRA D. BORGAONKAR, : NO. 02-3362 CIVIL TERM Defendant. : IN CUSTODY CRIMINAL RECORD/ABUSE HISTORY VERIFICATION C 3 rm►C -1- m I, RAJENDRA D. BORGAONKAR, Hereby swear or affirm, subject of pens of ffw .:741'2 including - p-T 18 Pa.C.S. §4904 relating to unsworn falsification to authorities that: - r--i 1. Unless indicated by my checking the box next to the crime below, neither I nor any other member of my household have been convicted or pled guilty or plead no contest or was adjudicated deliquent 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: Date of conviction, guilty plea, no contest Other plea,or Check all household pending that Apply Crime(or related crime) Self member charges Sentence 18 Pa.C.S.Ch. 25 (relating to LI criminal homicide) 18 Pa.C.S. §2702(relating to aggravated assault) 18 Pa.C.S. §2706 (relating to — terroristic threats) 18 Pa.C.S. §2709.1 (relating to — — stalking) 18 Pa.C.S. §2901 (relating to kidnapping) 18 Pa.C.S. §2902(relating to [I LI unlawful restraint) Date of conviction, guilty plea, no contest Other plea,or Check all household pending that Apply Crime(or related crime) Self member charges Sentence 18 Pa.C.S. §2910 (relating to luring a child into a motor vehicle or structure) 18 Pa.C.S. §3121(relating to rape) — — 18 Pa.C.S. §3122.1(relating to statutory sexual assasult) — 18 Pa.C.S. §3123(relating to involuntary deviate sexual intercourse) 18 Pa.C.S. §3124.1(relating to sexual assault) 18 Pa.C.S. §3125(relating to - aggravated indecent assault) 18 Pa.C.S. §3126(relating to indecent assault) 18 Pa.C.S. §3127(relating to indecent exposure) 18 Pa.C.S. §3129(relating to sexuaal intercourse with — animals) 18 Pa.C.S. §3130(relating to ❑ conduct relating to sex ❑ ❑ offenders) 18 Pa.C.S. §3301(relating to arson and relating offenses) 18 Pa.C.S. §4302 (relating to incest) 18 Pa.C.S. §4303 (relating to — concealing death of children) 18 Pa.C.S. §4304(relating to endangering welfare of — children) 18 Pa.C.S. §4305 (relating to — — dealing in infant children) Date of conviction, guilty plea, no contest Other plea,or Check all household pending that Apply Crime(or related crime) Self member charges Sentence 18 Pa.C.S. §5902(b)(relating — to prostitution and related — offenses) 18 Pa.C.S. §5903(c)or(d) (relating to obscene and other — sexual material and performances) 18 Pa.C.S. §6301 (relating to — corruption of minors) — 18 Pa.C.S. §6312 (relating to — sexual abuse of children) — 18 Pa.C.S. §6318 (relating to unlawful contact with minors) — 18 Pa.C.S. §6320(relating to sexual exploitation of children) 18 Pa.C.S. §6114(relating to contempt for violation of — protection order or agreement) Driving under the influence of _ April 20013 1 y, s� L. drugs or alcohol April _ck Manufacture, sale,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 householdhave a history of violent or abusive conduct including the following: A finding of abuse by Children &Youth Agency or similar — — agency in Pennsylvania or — — similar statute in another jurisdiction Date of conviction, guilty plea, no contest Other plea,or Check all household pending that Apply Crime(or related crime) Self member charges Sentence Abusive conduct as defined under the Protection from — Abuse Act in Pennsylvania or — similar statute in another jurisdiction Other: 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 other 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. Sign.. Ire Rajendra D. Borgaonkar Printed Name } • • SEP 0 4 42 JILL A.BORGAONKAR, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA v : CIVIL ACTION•-LAW RAJENDRA D.BORGAONKAR, : NO.02—3362 CIVIL Defendant : IN CUSTODY COURT ORDER AND NOW, this 54 day of S e r t (- l I cS , 2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Jill S. Borgaonkar, and the Father, Rajendra D. Borgaonkar, shall enjoy shared legal and shared physical custody of Nicholas Borgaonkar, born September 24, 1995; Noah Borgaonkar, born May 16, 1998; and Evan Borgaonkar born January 12, 2000. 2. As long as the parties continue to live together, there shall be no specific physical custody arrangement except for the parties enjoying a shared physical custody situation with the minor children. 3. In the event the parties separate, physical custody shall be shared equally on a week on/week off basis with exchange of custody to be Sunday evening at 6:00 p.m. unless agreed otherwise by the parties. 4. Upon one of the parties relocating from the marital home, counsel for either party may contact the conciliator directly to have another custody conciliation conference scheduled at which time the conciliator may recommend a modification to this order subject to the circumstances present at that time. BY THE COURT, �r 0 J. cc: Ruby D. Weeks, Esquire Jane Adams, Esquire JILL A. BORGAONKAR(N.K.A. Markel) : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW RAJENDRA D. BORGAONKAR, : NO. 02-3362 CIVIL TERM Defendant. : IN CUSTODY CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, do hereby certify that I this day served a copy of the within document upon the following by depositing same in the United States mail,postage prepaid, at Carlisle, Pennsylvania, addressed as follows: MidPenn Legal Services 401 E. Louther St. Carlisle, PA 17013 Jill A. Markel 28 Woodview Drive Mt. Holly Springs, PA 17065 L Mark F. Bayley, Esquire JILL A. BORGAONKAR N/K/A MARKEL IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA r� C) o v. 2002-3362 CIVIL ACTION LAW -cia - co RAJENDRA D. BORGAONKAR co IN CUSTODY �� rn DEFENDANT • co r - -..1 CC3 CD- =O U r' ORDER OF COURT 5 >r-n AND NOW, Tuesday,February 18,2014 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor,Cumberland County Courthouse,Carlisle on Wednesday, March 19,2014 8:30 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/ Hubert X. Gilroy,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. (� Cumberland County Bar Association `" I es' l 32 South Bedford Street R-1-.k( . y, L- Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 /r2ag)eut, Legal_ 902.utcr,3' J . makEL_ 1944y atiAly aftaM JILL A. BORGAONKAR N/K/A : IN THE COURT OF COMMON PLEAS OF MARKEL, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . C N --, . G ---iv t 2002-3362 CIVIL ACTION - LAVA = f-,„`J_: RAJENDRA D. BORGAONKAR, : p _ Defendant : IN CUSTODY <p -0 Y C”) '2'.---- D-4 N f; COURT ORDER _ AND NOW, this 1.4 day of 0 2 i , 2014, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. This Court's prior Order of September 5, 2002, shall remain in place with the parties proceeding under a 50/50 physical custody arrangement. 2. Legal counsel for the parties shall have a second custody conciliation conference with the Conciliator which shall be in the nature of a telephone call on Thursday, June 5, 2014, at 9:00 a.m. At that time, it shall be determined whether this case should be referred to the Court for a hearing or whether the parties can reach a more permanent resolution themselves. No party shall be permitted to relocate the residence of the child where said relocation will significantly impair the ability to exercise custody unless every individual who has custodial rights to the child consents to the proposed relocation or the court approves the proposed relocation. Any party proposing to relocate MUST comply with 23 Pa. C.S. § 5337. BY THE COURT, W,/ 1...JJesley Oler, ., Judge cc: ,.‘e, cus A. McKnight, III, Esquire, 60 W. Pomfret Street, Carlisle, PA 17013 /Mark F. Bayley, Esquire, 17 W. South Street, Carlisle, PA 17013 t iccc SPY 4i JILL A. BORGAONKAR, N/K/A : IN THE COURT OF COMMON PLEAS OF MARKEL, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff • v : 2002-3362 CIVIL ACTION - LAW • RAJENDRA D. BORGAONKAR, Defendant : IN CUSTODY Prior Judge: The Honorable J. Wesley Oler, Jr. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE 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: Noah Borgaonkar, born May 16, 1998 Evan Borgaonkar, born January 12, 2000 cu L.- 2. A Conciliation Conference was held on April 25,2014,with the following indNiduals in attendance: cI.-) $._.; The mother, Jill A. Markel, with her counsel, Marcus A. McKnight, III, Esquire, and the father, Rajendra D. Borgaonkar, with his counse1,1 Mark F. Bayley, Esquire F--, 3. The parties agreed to the entry of an Order in the form as attached. Date: April 0() , 2014 4j4; I Hubert X. Gilroy, .quire Custody Concili.-or JILL BORGAONKAR, n/k/a IN THE COURT OF COMMON PLEAS OF MARKEL, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. CIVIL ACTION - LAW NO. 02-3362 CIVIL RAJENDRA D. BORGAONKAR, Defendant ORDER AND NOW, this I'D day of May, 2014, the above-captioned case is assigned to the Honorable J. Wesley Oler, Jr., Senior Judge. BY THE COURT, A14Kevin . Hess, P. J. he Honorable J. Wesley Oler, Jr. .-.' (ort Administrator :rlm �,s Y�2�►� � � T� M � r C>� I"C-) 's �.J JILL A. BORGAONKAR N/K/A MARKEL, Plaintiff vs. RAJENDRA D. BORGAONKAR, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW PRIOR JUDGE: The Honorable J. Wesley Oler NO. 2002-3362 IN CUSTODY COURT ORDER h.� Cj Cri ; 711 AND NOW, this f2 ett day of June, 2014, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. A pre-trial conference is scheduled in the above case on the ''day of , 2014, at / D.'b0 -A . m. in .. of the Cumb'rlanCounty Courthouse. The parties are directed to proceed with filing a pre- trial statement with the Court and the other party consistent with Pennsylvania Rule Of Civil Procedure 1915.4-4. Flobr 2. A hearing is scheduled in Courtroom No. of the Cumberland County Courthouse on the Ic —day of , 2014, at q:0 A . m. At this hearing, the Father shall be the oving party and shall proceed initially with testimony. 3. Pending further Order of this Court, the existing Custody Order shall remain in place. BY THE COURT: J. ]G/esley Oler, /., Judge cc: "Marcus A. McKnight, III, Esquire, 60 W. Pomfret Street, Carlisle, PA 17013 Mark F. Bayley, Esquire, 17 W. South Street, Carlisle, PA 17013 CoP� ES M.U. JILL A. BORGAONKAR N/K/A MARKEL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW RAJENDRA D. BORGAONKAR, : NO. 2002-3362 Defendant : IN CUSTODY PRIOR JUDGE: The Honorable J. Wesley Oler CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The Conciliator conducted a telephone conference with legal counsel in this matter on June 5, 2014, which followed a prior conciliation conference that took place in April. Father has petitioned to modify the existing custody Order and the matters could not be resolved even after a second conciliation conference via telephone. The Father desires a hearing, and the Conciliator recommends an Order in the form as attached. Date: June , 2014 Hubert X. Gilroy, quire Custody Concir . or Q.) JILL BORGAONKAR, n/k/a IN THE COURT OF COMMON PLEAS OF MARKEL, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff/Respondent: V. RAJENDRA D. BORGAONKAR, CIVIL ACTION - LAW Defendant/Petitioner: NO. 02-3362 CIVIL TERM IN RE: MODIFICATION OF CUSTODY ORDER OF COURT AND NOW, this 12th day of August, 2014, upon consideration of the Father's Petition for Modification of Custody and following a hearing, the record is declared closed and the matter is taken under advisement. By the Court, Marcus A. McKnight, III, Esquire For the Plaintiff/Respondent ✓ Mark F. Bayley, Esquire For the Defendant/Petitioner :lfh -31:E0C gliattati y1 ,_, r -13 cia rnrri_ CD t (!) ro • ZC� W G JILL BORGAONKAR, n/k/a : IN THE COURT OF COMMON PLEAS MARKEL, : OF CUMBERLAND COUNTY, Plaintiff/Respondent : PENNSYLVANIA v. RAJENDRA D. BORGAONKAR, : CIVIL ACTION (CUSTODY) Defendant/Petitioner NO. 02-3362 CIVIL TERM IN RE: DEFENDANT'S PETITION TO MODIFY CUSTODY ORDER OF COURT AND NOW, this t 3 day of August, 2014, upon consideration of Petitioner Rajendra D. Borgaonkar's Petition To Modify Custody, with respect to the parties' children Noah R. Borgaonkar (d.o.b. May 16, 1998) and Evan R. Borgaonkar (d.o.b. January 12, 2000), and following a hearing held on August 12, 2014, it is ordered and directed as follows: (1) The petition to modify custody is denied; and (2) The parties are directed to provide continuing psychiatric treatment for their child Noah R. Borgaonkar until he is discharged from treatment by the psychiatrist. By the court, Aark F. Bayley, Esq. 17 West South Street Carlisle, PA 17013 Attorney for Defendant/Petitioner Marcus A. McKnight, III, Esq. 60 West Pomfret Street Carlisle, PA 17013 Attorney for Plaintiff/Respondent 1