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HomeMy WebLinkAbout04-3526 IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA ROBIN D. GIORDANO, NO. 02-SU-00695-03 PLAINTIFF/RESPONDENT VS. _ PAUL J. GIORDANO, SR., CIVIL ACTION -LAW DEFENDANT/PETITIONER ACTION IN CUSTODY r- ORDER AND NOW, this '; day of kS'Ilpetition 2004, upon consideration of the Defendant/Petitioner, PAUL J. GIORDANO to Transfer, it is hereby ORDERED and DECREED this case shall be transferred to Cumberland County, Pennsylvania. J. CERTIFIED from the retards of the Court of Commoo?n?PI, as 1 ofn County. I'? rum tLia day of A.D.20_Qq -VlX(y\S? cA Pamela & Lee, Prothonotary IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA ROBIN D. GIORDANO, PLAINTIFF/RESPONDENT NO. 02-SU-00695-03 Vs. PAUL J. GIORDANO, SR., DEFENDANTIPETITIONER CIVIL ACTION - LAW : ACTION IN CUSTODY :-a PETITION TO TRANSFER AND NOW, comes the Defendant/Petitioner, PAUL J. GIORDANO, SR., by and through his counsel, Susan Kay Candiello, Esquire, of the Law Firm of Susan Kay Candiello, P.C., and files this Petition for Transfer of this Custody Action of which the following is a statement: 1. The Plaintiff/Respondent is ROBIN D. GIORDANO, who currently resides at 9 Senate Drive, Pasadena, Maryland, 21122. 2. The Defendant/Petitioner is PAUL J. GIORDANO, SR., who currently resides at 11 Richland Lane, Apr. 201, Camp Hill, Pennsylvania, 17011. 3. The Plaintiff/Respondent filed a custody action in York County, which resulted in the parties entering into a custody stipulation and a signed custody order dated February 7a`, 2002. (A copy which is attached hereto and made a part hereof at Exhibit "A".) 4. Following the entry of the custody order dated February 7" 2002, attempting to reconcile their marriage, Plaintiff/Respondent and Defendsnt/PPtitioner moved from York 182090 950162 County to Cumberland County. 5. Unable to reconcile their marriage, Plaintiff/Respondent then moved to Maryland to be near her parents and presently has custody of one (1) of the parties' minor children, Brady G. Giordano. 6. Defendant/Petitioner has remained in Cumberland County and presently has custody of one (1) of the parties' minor children Adam V. Giordano. 7. The third child, Nicholas J. Giordano, is no longer a minor and resides in his own residence, independent of either parent. 8. The present custody order no longer appropriately addresses the minor children's best interests and a new custody order is needed. 9. The parties are presently engaged in a divorce action in Cumberland County. 10. Venue and jurisdiction are proper in Cumberland County. 11. Plaintiff/Respondent will not experience any disadvantage by the removal of this custody action to Cumberland County as Plaintiff/Respondent already has counsel in Cumberland County, Jane Adams Esquire. 12. Defendant/Petitioner is hopeful the parties can again enter into a second custody stipulation as they did in the past which reflects their current custody arrangement. WHEREFORE, Defendant/Petitioner, PAUL J. GIORDANO, SR., respectfully requests that this Honorable Court Order the Custody action to be transferred to Cumberland 181090950162 County. Respectfully submitted, VERIFICATION The undersigned hereby verifies that the facts averred in the foregoing document are true and correct to the best of his knowledge, information, and belief. This verification is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. o? DATED: PAUL J S PH GI RDANO, SR. 182090 950182 EXHIBIT «A99 IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA ROBIN D. GIORDANO, NO.02-SU- O J (y 0,3 Plaintiff v. CIVIL ACTION - LAW PAUL J. GIORDANO, SR., Defendant CUSTODY AND NOW, this 74 day of February, 2002, upon presentation of the attached Custody Stipulation and Agreement, said Agreement is approved and made an Order of Court. $Y THE-C-OIIRT, Richard K. Renn, Judge 0 N rn f?'1 rz? - ? i - GG 1820909501&2 "- ^' N i IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA ROBIN D. GIORDANO, Plaintiff V. PAUL J. GIORDANO, SR., Defendant n NO. 02-SU- `' c9 CIVIL ACTION - LAW CUSTODY CUSTODY STIPULATION AND AGREEMENT THIS AGREEMENT, made this day of February, 2002, by and between ROBIN D. GIORDANO, hereinafter referred to as "Mother", and PAUL J. GIORDANO, SR., hereinafter referred to as "Father", WITNESSETH: WHEREAS, the parties are the natural parents of three (3) minor children, Nicholas J. Giordano, born March 2,1984; and Adam V. Giordano, born May 3, 1988; and Brady G. Giordano, born April 8,1994; and WHEREAS, the minor children have been with both Mother and Father since birth; and WHEREAS, the parties are living separate and apart from each other; and NOW, THEREFORE, the parties hereto, intending to be legally bound hereby, agree and stipulate that the Court of Common Pleas of York County, Pennsylvania, have jurisdiction over this matter and that the Court enter a Custody Determination and Order that Mother shall have custody of the minor children. It is further agrc44 ?,96,N'.een the parties that: 1. "Legal custody" of the minor child, as that term is defined in the Pennsylvania Domestic Relations Code, 23 Pa.C.S.A. Section 5301, t't s€q., shall rest jointly with Mother and Father. Joint legal custody means the right of both parents to control and to share in making decisions of importance in the life of their children, including educational, medical, and religious decisions. Both parents shall be entitled to equal access to a child's school, medical and dental records and other important records. Domestic Relations Code, 23 Pa.C.S.A. Section 5301, et nq., shall rest jointly with Mother and Father. Joint legal custody means the right of both parents to control and to share in making decisions of importance in the life of their children, including educational, medical, and religious decisions. Both parents shall be entitled to equal access to a child's school, medical and dental records and other important records. As soon as practical after the receipt by a party, copies of the children's school schedules, special events notification, report cards, and similar items shall be provided to the other party. Each shall notify the other party of any medical, dental, optical, and other appointments of a child with health care providers, sufficiently in advance thereof so that the other party can attend. Notwithstanding that both parents share legal custody, non-major decisions involving a child's day to day living shall be made by the parent then having custody, consistent with the other provisions of this ORDER. 2. "Majority physical custody" of the minor children, as that term is defined in the aforementioned Act, shall be granted to Mother. 3. "Partial physical custody" is the right to take possession of a child away from the custodial parent for a certain period of time. The parties have agreed that Father shall have liberal rights of "partial physical custody" and shall exercise his right at any time as the parties can agree. 4. The transportation shall be provided by Father. At all times, the children shall be secured in appropriate passenger restraints. No pe;l 820 ?..g the children shall consume alcoholic beverages prior to transporting the child. No person transporting the children shall be under the influence of any alcoholic beverages while transporting the children, 5. In the event Father is more than twenty (20) minutes late for a scheduled custody exchange, in the absence of a telephone call or other communication from him, Mother may assume that Father has chosen not to exercise that period of custody, the period will be forfeited, and Mother will be free to make other plans with the children. 6. Father may, during his periods of physical custody of the child, make decisions required by an emergency or sudden illness. Father shall immediately communicate to Mother the existence of any medical, legal or educational emergency that may occur with respect to the children. Father shall also have the duty to immediately contact Mother regarding any illness. For purposes of this Agreement, the word "illness" shall mean any disability that confines a child to bed under the direction of a licensed physician for a period in excess of forty-eight (48) hours, or any serious injury to a child that would require emergency room or other immediate treatment that requires hospitalization. 7. The parties agree to approach the custody of the minor children with some flexibility and to cooperate with each other in maintaining consistent contact between Father and the children. 8. Each party shall provide the other with at least forty-eight (48) hours advance notice of school or other activities whenever possible. Both parties shall agree to honor and participate in the activities that the children wish to engage in. During the times that the parents have custody of the child, they will make certain that the children attend any extracurricular aJ&PA951Nf ?arties agree that they will be supportive of these activities and will transport the children to and from such activities and the preparations and practice for the activities that are scheduled, in such time so that the children are able to participate in those events. Neither parent, however, shall sign up a child for activities that fall on the other parent's period of custody, without the consent of the other parent, which consent shall not be unreasonably withheld. If a child is involved in an activity which occurs during both parents' periods of custody, both parents shall cooperate in providing transportation of the child to the activity. However, the custodial parent shall not be required to take a child to that activity if the custodial parent and child are out of town during that activity, for a previously scheduled vacation. In the event that the custodial parent is unable to deliver a child to the particular activity, the parent who has custody of the children at that time shall notify the noncustodial parent, who shall be entitled to pick up and deliver the child to the designated activity. The custodial parent shall make certain that the child is ready for pickup in time sufficient to enable the child to timely attend the activity. 9. Both parties shall be allowed reasonable telephone contact with the minor children. Phone calls should be kept to a maximum of twenty (20) minutes, and a maximum of three phone calls per week. 10. Each of the parties and any third party in the presence of the children shall take all measures deemed advisable to foster a feeling of affection between the children and the other party. Neither party shall do nor shall either parent permit any third person to do or say anything which may estrange a child from the other pamoAy1 Ve or relatives, or injure the children's opinion of the other party or which may hamper the free and natural development of the children's love and respect for the other parent. The parties shall not use a child to send verbal messages to the other parent about the custody situation or changes in the custody schedule. 11. In the event that a significant matter arises with respect to the medical care, education, or financial care of the children, such as a change in occupation, health insurance, educational expenses, residence of a party, those matters shall be discussed with the other parent before any change is made by either parent. 11 The welfare and convenience of the children shall be the prime consideration of the parties in any application of the provisions of this order. Both parents are directed to listen carefully and consider the wishes of the children in addressing custodial schedule, any changes to the schedule and any other parenting issues. 13. Upon the knowledge of pending relocation of either parent, either temporary or permanent, that parent must immediately inform the other of his/her new address and telephone number. 14. The parties are free to modify the terms of this order but in order to do so the Court makes it clear that both parties must be in complete agreement to any new terms. That means both parties must consent on what the new terms of the custody arrangement or visitation schedule shall be. In the event that one or the other does not consent to a change, that does not mean each follow your own idea as to what you think the arrangements should be. The reason this Court Order is set out in detail is so both parties have it to refer to and to govern your relationship with the children and with each other in J?ffr jt U j disagreement 15. Mother and Father specifically agree that the Court of Common Pleas of York , Pennsylvania shall have jurisdiction over the parties and subject matter of this case. 16. Mother and Father acknowledge that they are voluntarily entering into this with full knowledge and stipulate and agree to the entry of this Agreement as a Court IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and ROBIN D. GIORDANO PAUL J. I RDANO, SR. mate first set forth above. REASSIGNED? (YJN): TO WHOM?: DATE REASSIGNED: r ' For Current Business on Thursday, July 8, 2004, at 9:00 a.m. Note: If this is a Rule 6030, return copy of this form to Court Admin. when matter Is resolved. C 1998-2404 RiG WO K. R9 IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA ROBIN D. GIORDANO, NO.02-SU- J3 Plaintiff V. CIVIL ACTION - LAW PAUL J. GIORDANO, SR., Defendant CUSTODY AND NOW, this day of February, 2002, upon presentation of the attached Custody Stipulation and Agreement, said Agreement is approved and made an Order of Court. THE COtyRT, Richard K. Renn, Judge C.3 N rn C.D PS ift 01204) 246018 IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA ROBIN D. GIORDANO, Plaintiff V. PAUL J. GIORDANO, SR., Defendant : NO.02-SU- ?J (0 9 _?- v 3 CIVIL ACTION - LAW CUSTODY CUSTODY STIPULATION AND AGREEMENT 0 N m YJ lp : }T _ N ` N THIS AGREEMENT, made this day of February, 2002, by and between ROBIN D. GIORDANO, hereinafter referred to as "Mother", and PAUL J. GIORDANO, SR., hereinafter referred to as "Father", WITNESSETH: WHEREAS, the parties are the natural parents of three (3) minor children, Nicholas J. Giordano, born March 2,1984; and Adam V. Giordano, born May 3, 1988; and Brady G. Giordano, born April 8, 1994; and WHEREAS, the minor children have been with both Mother and Father since birth; and WHEREAS, the parties are living separate and apart from each other; and NOW, THEREFORE, the parties hereto, intending to be legally bound hereby, agree and stipulate that the Court of Common Pleas of York County, Pennsylvania, have jurisdiction over this matter and that the Court enter a Custody Determination and Order that Mother shall have custody of the minor children. It is further agreed by and between the parties that: 1. "Legal custody" of the minor child, as tha4 tirm.ic 4-f-wi in the Pennsylvania 04'091)240078 Domestic Relations Code, 23 Pa.C.S.A. Section 5301, et ssN., shall rest jointly with Mother and Father. Joint legal custody means the right of both parents to control and to share in making decisions of importance in the life of their children, including educational, medical, and religious decisions. Both parents shall be entitled to equal access to a child's school, medical and dental records and other important records. As soon as practical after the receipt by a party, copies of the children's school schedules, special events notification, report cards, and similar items shall be provided to the other parry. Each shall notify the other party of any medical, dental, optical, and other appointments of a child with health care providers, sufficiently in advance thereof so that the other party can attend. Notwithstanding that both parents share legal custody, non-major decisions involving a child's day to day living shall be made by the parent then having custody, consistent with the other provisions of this ORDER. 2. "Majority physical custody" of the minor children, as that term is defined in the aforementioned Act, shall be granted to Mother. 3. "Partial physical custody" is the right to take possession of a child away from the custodial parent for a certain period of time. The parties have agreed that Father shall have liberal rights of "partial physical custody" and shall exercise his right at any time as the parties can agree. 4. The transportation shall be provided by Father. At all times, the children shall be secured in appropriate passenger restraints. No person transporting the children shall consume alcoholic beverages prior to transporting the child. Nn pPrcnn transporting the children shall be 0420`024OC78 under the influence of any alcoholic beverages while transporting the children. 5. In the event Father is more than twenty (20) minutes late for a scheduled custody exchange, in the absence of a telephone call or other communication from him, Mother may assume that Father has chosen not to exercise that period of custody, the period will be forfeited, and Mother will be free to make other plans with the children. 6. Father may, during his periods of physical custody of the child, make decisions required by an emergency or sudden illness. Father shall immediately communicate to Mother the existence of any medical, legal or educational emergency that may occur with respect to the children. Father shall also have the duty to immediately contact Mother regarding any illness. For purposes of this Agreement, the word "illness" shall mean any disability that confines a child to bed under the direction of a licensed physician for a period in excess of forty-eight (48) hours, or any serious injury to a child that would require emergency room or other immediate treatment that requires hospitalization. 7. The parties agree to approach the custody of the minor children with some flexibility and to cooperate with each other in maintaining consistent contact between Father and the children. 8. Each party shall provide the other with at least forty-eight (48) hours advance notice of school or other activities whenever possible. Both parties shall agree to honor and participate in the activities that the children wish to engage in. During the times that the parents have custody of the child, they will make certain that the children attend any extracurricular activities. The parties agree that they will be supportive of these activities and will transport the chit w46tQaPdfrom such activities and the C42' )024V78 preparations and practice for the activities that are scheduled, in such time so that the children are able to participate in those events. Neither parent, however, shall sign up a child for activities that fall on the other parent's period of custody, without the consent of the other parent, which consent shall not be unreasonably withheld. If a child is involved in an activity which occurs during both parents' periods of custody, both parents shall cooperate in providing transportation of the child to the activity. However, the custodial parent shall not be required to take a child to that activity if the custodial parent and child are out of town during that activity, for a previously scheduled vacation. In the event that the custodial parent is unable to deliver a child to the particular activity, the parent who has custody of the children at that time shall notify the noncustodial parent, who shall be entitled to pick up and deliver the child to the designated activity. The custodial parent shall make certain that the child is ready for pickup in time sufficient to enable the child to timely attend the activity. 9. Both parties shall be allowed reasonable telephone contact with the minor children. Phone calls should be kept to a maximum of twenty (20) minutes, and a maximum of three phone calls per week. 10. Each of the parties and any third party in the presence of the children shall take all measures deemed advisable to foster a feeling of affection between the children and the other party. Neither party shall do nor shall either parent permit any third person to do or say anything which may estrange a child from the other parent, their spouse or relatives, or injure the children's opinion of the other party or which may hPn1per the free and natural development of C4 ',26 !1) NOC78 the children's love and respect for the other parent. The parties shall not use a child to send verbal messages to the other parent about the custody situation or changes in the custody schedule. 11. In the event that a significant matter arises with respect to the medical care, education, or financial care of the children, such as a change in occupation, health insurance, educational expenses, residence of a party, those matters shall be discussed with the other parent before any change is made by either parent. 12. The welfare and convenience of the children shall be the prime consideration of the parties in any application of the provisions of this order. Both parents are directed to listen carefully and consider the wishes of the children in addressing custodial schedule, any changes to the schedule and any other parenting issues. 13. Upon the knowledge of pending relocation of either parent, either temporary or permanent, that parent must immediately inform the other of his/her new address and telephone number. 14. The parties are free to modify the terms of this order but in order to do so the Court makes it clear that both parties must be in complete agreement to any new terms. That means both parties must consent on what the new terms of the custody arrangement or visitation schedule shall be. In the event that one or the other does not consent to a change, that does not mean each follow your own idea as to what you think the arrangements should be. The reason this Court Order is set out in detail is so both parties have it to refer to and to govern your relationship with the children and with each other in the event of a disagreement. 15. Mother and Father specifically agree that t?°,'?G'? '? hnmen Pleas of York County, Pennsylvania shall have jurisdiction over the parties and subject matter of this case. 16. Mother and Father acknowledge that they are voluntarily entering into this Agreement with full knowledge and stipulate and agree to the entry of this Agreement as a Court Order. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and date first set forth above. ESS• r- 7? o- -- ROBIN D. GIORDANO PAUL J. I RDANO, SR. 04'20 ' J240(78 i Rj ROBIN D. GIORDANO, PLAINTIFF/RESPONDENT VS. PAUL J. GIORDANO, SR DEFENDANT/PETITIONER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :NO. 6)q_ 3'&24 CIVIL ACTION -LAW IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY ORDER AND NOW, comes the Defendant/Petitioner, PAUL J. GIORDANO, SR, by and through his counsel, Susan Kay Candiello, Esquire, of the Law Firm of Susan Kay Candiello, P.C., and files this Petition for Modification of Custody Order upon a cause of action of which the following is a statement: 1. The Defendant/Petitioner is PAUL J. GIORDANO, SR. who presently resides at 11 Richland Lane, Apartment 201, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. The Plaintiff/Respondent is ROBIN D. GIORDANO, who presently resides at 9 Senate Drive, Pasadena, Maryland, 21122. 3. Defendant/Petitioner seeks Shared Legal Custody and Primary Physical Custody of the following child: Name Present Residence Date of Birth Adam V. Giordano 11 Richland Lane, Apt. 201 May 3, 1998 Camp Hill, PA 4. Defendant/Petitioner seeks Shared Legal Custody and Partial Physical Custody of the following child: Name Present Residence Date of Birth Brady G. Giordano 9 Senate Drive Pasadena, MD 5. The children were born in wedlock. April 8, 1994 6. The child, Adam V. Giordano is presently in the Primary Physical Custody of the Defendant/Petitioner. The child, Brady G. Giordano is presently in the Primary Physical Custody of the Plaintiff/Respondent. During the past five (5) years, the children have resided with both the Plaintiff/Respondent and the Defendant/Petitioner. 8. The mother of the children is Plaintiff/Respondent who presently resides at 9 Senate Drive, Pasadena, MD, 21122. 9. The father of the children is Defendant/Petitioner who currently resides at 11 Richland Lane, Apt. 201, Camp Hill, Cumberland County, Pennsylvania 17011. 9. Defendant/Petitioner and Plaintiff/Respondent are married, but a divorce is pending with a Master's hearing presently scheduled. 10. The relationship of the Plaintiff/Respondent to the children is that of natural mother. The Plaintiff/Respondent currently resides with her parents in their home in Maryland. 11. The relationship of the Defendant/Petitioner to the children is that of natural father. The Plaintiff/Petitioner currently resides alone. 12. Plaintiff/Petitioner has participated as a party in a prior custody agreement concerning the custody of the children. The court, term and number, and its relationship to this action are as follows: the court was York County, the docket number there was 02-SU-00695-03, the result was a custody stipulation and order dated February 7, 2002 which is attached hereto and made a part hereof as Exhibit "A". 13. Defendant/Petitioner has no information of a custody proceeding concerning the children pending in a court of this Commonwealth at this time. 14. Defendant/Petitioner does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 15. The best interest and permanent welfare of the children will be served by granting the relief requested because: A. Defendant/Petitioner has great love and concern for his children's physical, educational and psychological safety and well-being; B. The child, Adam, has encountered problems in his education and discipline, which the Plaintiff(Repondent is not able to manage; C. Defendant/Petitioner believes it is in the best interest of his son, Adam to be with him enrolled and attending school with his assistance and supervision; I Defendant/Petitioner believes his son, Brady, prefers to be with the Plaintiff/Respondent and his grandparents. 16. Each parent whose parental rights to the children has not been terminated and the persons who have physical custody of the children has been named as parties to this action. WHEREFORE, Defendant/Petitioner, PAUL J. GIORDANO, SR., requests this Honorable Court grant the Defendant/Petitioner, PAUL L GIORDANO, SR and the Plaintiff/Respondent, ROBIN D. GIORDANO, SHARED LEGAL CUSTODY of the two (2) minor children, ADAM V. GIORDANO and BRADY G. GIORDANO with PRIMARY PHYSICAL CUSTODY of the minor child, ADAM V. GIORDANO to the Defendant/Petitioner, PAUL J. GIORDANO, SR. and PARTIAL PHYSICAL CUSTODY of the minor child, ADAM V. GIORDANO to the Plaintiff/Respondent, ROBIN D. GIORDANO and PRIMARY PHYSICAL CUSTODY of the minor child, BRADY G. GIORDANO to the Plaintiff/Respondent, ROBIN D. GIORDANO and PARTIAL PHYSICAL CUSTODY of the minor child, BRADY G. GIORDANO to the Defendant/Petitioner, PAUL J. GIORDANO, Respectfully submitted, LAW FIRM OF SUSAN KAY CANDIELLO, P.C. Dated: Jul}, 2004 ??V`C7s? J Susan Kay nkiell quire Counsel fo, Defen nt/Petitioner PA I.D. # 99 5021 East Trindle Road Suite 100 Mechanicsburg PA 17050 (717) 796-1930 VERIFICATION The undersigned hereby verifies that the facts averred in the foregoing document are true and correct to the best of his knowledge, information, and belief. This verification is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. DATED:? C't ??. PAUL JOS P GIORDANO, SR. EXHIBIT "A" IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA ROBIN D. GIORDANO, NO.02-SU- 6 03 Plaintiff V. PAUL J. GIORDANO, SR., Defendant CIVIL ACTION - LAW CUSTODY ORDER AND NOW, this 74day of February, 2002, upon presentation of the attached Custody Stipulation and Agreement, said Agreement is approved and made an Order of Court. BT TH'E?OURT, Richard K. Renn, Judge 0 N ? - rvi W J b _ N N Ln IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA ROBIN D. GIORDANO, Plaintiff NO. 02-SU- T V. PAUL J. GIORDANO, SR., Defendant CIVIL ACTION - LAW CUSTODY CUSTODY STTPULATIQN AND AGREEMENT -c THIS AGREEMENT, made this day of February, 2002, by and between ROBIN D. GIORDANO, hereinafter referred to as "Mother", and PAUL J. GIORDANO, SR., hereinafter referred to as "Father", WITNESSETH: WHEREAS, the parties are the natural parents of three (3) minor children, Nicholas J. Giordano, born March 2, 1984; and Adam V. Giordano, born May 3, 1988; and Brady G. Giordano, born April 8, 1994; and WHEREAS, the minor children have been with both Mother and Father since birth; and WHEREAS, the parties are living separate and apart from each other; and NOW, THEREFORE, the parties hereto, intending to be legally bound hereby, agree and stipulate that the Court of Common Pleas of York County, Pennsylvania, have jurisdiction over this matter and that the Court enter a Custody Determination and Order that Mother shall have custody of the minor children. It is further agreed by and between the parties that: 1. "Legal custody" of the minor child, as that term is defined in the Pennsylvania Domestic Relations Code, 23 Pa.C.S.A. Section 5301, et s&q., shall rest jointly with Mother and Father. Joint legal custody means the right of both parents to control and to share in making decisions of importance in the life of their children, including educational, medical, and religious decisions. Both parents shall be entitled to equal access to a child's school, medical and dental records and other important records. As soon as practical after the receipt by a party, copies of the children's school schedules, special events notification, report cards, and similar items shall be provided to the other party. Each shall notify the other party of any medical, dental, optical, and other appointments of a child with health care providers, sufficiently in advance thereof so that the other party can attend. Notwithstanding that both parents share legal custody, non-major decisions involving a child's day to day living shall be made by the parent then having custody, consistent with the other provisions of this ORDER. 2. "Majority physical custody" of the minor children, as that term is defined in the aforementioned Act, shall be granted to Mother. 3. "Partial physical custody" is the right to take possession of a child away from the custodial parent for a certain period of time. The parties have agreed that Father shall have liberal rights of "partial physical custody" and shall exercise his right at any time as the parties can agree. 4. The transportation shall be provided by Father. At all times, the children shall be secured in appropriate passenger restraints. No person transporting the children shall consume alcoholic beverages prior to transporting the child. No person transporting the children shall be under the influence of any alcoholic beverages while transporting the children. 5. In the event Father is more than twenty (20) minutes late for a scheduled custody exchange, in the absence of a telephone call or other communication from him, Mother may assume that Father has chosen not to exercise that period of custody, the period will be forfeited, and Mother will be free to make other plans with the children. 6. Father may, during his periods of physical custody of the child, make decisions required by an emergency or sudden illness. Father shall immediately communicate to Mother the existence of any medical, legal or educational emergency that may occur with respect to the children. Father shall also have the duty to immediately contact Mother regarding any illness. For purposes of this Agreement, the word "illness" shall mean any disability that confines a child to bed under the direction of a licensed physician for a period in excess of forty-eight (48) hours, or any serious injury to a child that would require emergency room or other immediate treatment that requires hospitalization. 7. The parties agree to approach the custody of the minor children with some flexibility and to cooperate with each other in maintaining consistent contact between Father and the children. 8. Each party shall provide the other with at least forty-eight (48) hours advance notice of school or other activities whenever possible. Both parties shall agree to honor and participate in the activities that the children wish to engage in. During the times that the parents have custody of the child, they will make certain that the children attend any extracurricular activities. The parties agree that they will be supportive of these activities and will transport the children to and from such activities and the preparations and practice for the activities that are scheduled, in such time so that the children are able to participate in those events. Neither parent, however, shall sign up a child for activities that fall on the other parent's period of custody, without the consent of the other parent, which consent shall not be unreasonably withheld. If a child is involved in an activity which occurs during both parents' periods of custody, both parents shall cooperate in providing transportation of the child to the activity. However, the custodial parent shall not be required to take a child to that activity if the custodial parent and child are out of town during that activity, for a previously scheduled vacation. In the event that the custodial parent is unable to deliver a child to the particular activity, the parent who has custody of the children at that time shall notify the noncustodial parent, who shall be entitled to pick up and deliver the child to the designated activity. The custodial parent shall make certain that the child is ready for pickup in time sufficient to enable the child to timely attend the activity. 9. Both parties shall be allowed reasonable telephone contact with the minor children. Phone calls should be kept to a maximum of twenty (20) minutes, and a maximum of three phone calls per week. 10. Each of the parties and any third party in the presence of the children shall take all measures deemed advisable to foster a feeling of affection between the children and the other party. Neither party shall do nor shall either parent permit any third person to do or say anything which may estrange a child from the other parent, their spouse or relatives, or injure the children's opinion of the other party or which may hamper the free and natural development of the children's love and respect for the other parent. The parties shall not use a child to send verbal messages to the other parent about the custody situation or changes in the custody schedule. 11. In the event that a significant matter arises with respect to the medical care, education, or financial care of the children, such as a change in occupation, health insurance, educational expenses, residence of a party, those matters shall be discussed with the other parent before any change is made by either parent. 12. The welfare and convenience of the children shall be the prime consideration of the parties in any application of the provisions of this order. Both parents are directed to listen carefully and consider the wishes of the children in addressing custodial schedule, any changes to the schedule and any other parenting issues. 13. Upon the knowledge of pending relocation of either parent, either temporary or permanent, that parent must immediately inform the other of his/her new address and telephone number. 14. The parties are free to modify the terms of this order but in order to do so the Court makes it clear that both parties must be in complete agreement to any new terms. That means both parties must consent on what the new terms of the custody arrangement or visitation schedule shall be. In the event that one or the other does not consent to a change, that does not mean each follow your own idea as to what you think the arrangements should be. The reason this Court Order is set out in detail is so both parties have it to refer to and to govern your relationship with the children and with each other in the event of a disagreement. 15. Mother and Father specifically agree that the Court of Common Pleas of York , Pennsylvania shall have jurisdiction over the parties and subject matter of this case. 16. Mother and Father acknowledge that they are voluntarily entering into this with full knowledge and stipulate and agree to the entry of this Agreement as a Court IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and first set forth above. ROBIN D. GIORDANO J atL RDANO, SR. N ? ? ? o _ > -: , ? ? ? ? ' ? d ,, C ? ?- F' `J ` , ?? ROBIN D. GIORDANO IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. 04-3526 CIVIL ACTION LAW PAUL J. GIORDANO, SR. DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday July 28 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before ]Dawn S. Sunday Esq. the conciliator, at 39 West Main Street Mechanicsburg PA 17055 on Wednesday, September 01, 2004 at 12:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Da o n C C: nday,Esq. mhc 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 OUI' WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 b9NHAIMN3d 11Nno or.?np?smo ?C :£ wd 8a l(tr woo AdV1.ONOHiO} d Ni C 30(30-03 OCT 0 6 2004 , ROBIN D. GIORDANO IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 04-3526 CIVIL ACTION LAW PAUL J. GIORDANO, SR. Defendant IN CUSTODY ORDER OF COURT AND NOW, this (LC day of . 6) A = L P r , 2004, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Robin D. Giordano, and the Father, Paul J. Giordano, Sr., shall have shared legal custody of Adam V. Giordano, born May 3, 1988, and Brady G. Giordano, born April 8, 1994. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. Both parents' names shall be listed with the Children's schools as parents to be contacted in the event of an emergency and to be notified regarding school events. The Mother shall promptly provide copies of all report cards and notification of major school events to the Father promptly upon receipt. Neither party shall schedule activities or appointments for the Children which would require the Children's attendance or participation during the other party's periods of custody, unless otherwise agreed. 2. The Mother shall have primary physical custody of the Children. 3. The Father shall have partial physical custody of the Children on alternating weekends from Friday at 4:00 p.m. through Sunday at 7:00 p.m. if there is school the following day, and at 9:00 p.m. if there is no school the following Monday. During the summer school break, the Father's alternating weekend periods of custody shall be expanded to run from Thursday at 6:00 p.m. through Sunday at 9:00 P.M. 4. The parties shall share or alternate having custody of the Children on holidays as follows: A. Christmas: hi every year, the Father shall have custody of the Children from Christmas Eve at 4:00 p.m. through Christmas Day at 1:00 p.m. and the Mother shall have custody from Christmas Day at 1:00 p.m. through December 26 at 6:00 p.m. 0 n. ' .°; r} °?, ?' •.?. r --ril c. .. ;'? B. Thanksgiving: The Mother shall have custody of the Children in even numbered years for Thanksgiving and the Father shall have custody of the Children in odd numbered years for Thanksgiving with the specific times to be arranged by agreement between the parties. C. Alternating Holidays: In odd numbered years, the Mother shall have custody of the Children on New Year's Eve and Day (for purposes of this provision, the New Year's holiday shall be deemed to fall within the same year as New Year's Eve), Memorial Day and Labor Day and the Father shall have custody on Easter and Independence Day. In even numbered years, the Father shall have custody of the Children for New Year's Eve and Day, Memorial Day and Labor Day and the Mother shall have custody on Easter and Independence Day. The alternating holiday periods of custody under this provision shall run from 5:00 p.m. on the night before the holiday through 7:00 p.m. on the holiday if there is school the following day or 9:00 p.m. if there is no school. The Independence Day holiday may be extended later in the evening to enable the parties to take the Children to the fireworks. D. Mother's Day/Father's Day: The Mother shall have custody of the Children every year on Mother's Day and the Father shall have custody of the Children every year on Father's Day from 5:00 p.m. on Saturday through 7:00 p.m. on Sunday if there is school the following day or 9:00 p.m. if there is no school. E. The holiday custody schedule shall supercede and take precedence over the regular custody schedule. 5. Each party shall be entitled to have up to two consecutive weeks of vacation each year with the Children upon providing at least 30 days advance notice to the other party. Both parties shall schedule periods of custody under this provision to include that party's regular weekend period of custody to ensure that neither party has custody of the Children in excess of two consecutive weeks. 6. The Father shall not remove the Children from school without the Mother's prior consent. 7. Each party shall provide the other with at least 48 hours advance notice of school or other activities whenever possible. The custodial parent shall ensure that the Children attend all regularly scheduled activities. The parties shall cooperate in ensuring that the Children are able to fully participate in all activities in which they are enrolled. 8. The non-custodial parent shall be entitled to have reasonable telephone contact and other types of communication with the Children without interference by the custodial parent. 9. Neither party shall smoke in a confined area when the Children are present and neither party shall permit third parties to do so. Neither party shall consume alcohol to the point of intoxication or transport the Children in a vehicle following the consumption of alcohol. 10. In the event either party intends to remove either or both of the Children from his or her residence for an overnight period or longer, that party shall provide; the other party with the address and telephone number where the Child or Children can be contacted. 11. In the event either party intends to relocate his or her residence more than 30 miles from the current residence, that party shall provide the other party with at least 90 advance written notice to enable the parties to make any necessary adjustments to the custody schedule by agreement or through the legal process if necessary. 12. Neither party shall do or say anything which may estrange the Children from the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development of the Children's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Children comply with this provision. 13. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provisions of this Order by mutual consent. Any agreed upon modifications to this Order of a continuing or permanent nature shall be in writing signed by both parties. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, cc:vlt( bin D. Giordano, Mother ,/Paul J. Giordano, Sr., Father y r ?aA?? 16-13-01 ROBIN D. GIORDANO Plaintiff VS. PAUL J. GIORDANO, SR. Defendant Prior Judge: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-3526 CIVIL ACTION LAW IN CUSTODY" CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Adam V. Giordano May 3, 1988 Mother Brady G. Giordano April 8, 1994 Mother 2. A conciliation conference was held initially on September 1, 2004, with the Father, Paul J. Giordano, in attendance without counsel, and the Mother, Robin D. Giordano, participating by telephone without counsel. It was agreed at the initial conference that this matter would be held for 30 days to enable the parties to resolve school credit and enrollment issues concerning the parties' older son, Adam. At the Mother's request, a second conference was held on September 29, 2004 again with the Father in attendance and the Mother, who lives in Maryland, participating by telephone. 3. The school issues had been resolved between the parties and the parties agreed to entry of an Order in the form as attached. 4t= V ,loo C! Date Dawn -S. Sunday, Esquire Custody Conciliator ROBIN D. GIORDANO, PLAINTIFF/RESPONDENT V9. PAUL J. GIORDANO, SR. DEFENDANT/PETITIONER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2004-3526 : CIVIL ACTION -LAW : IN CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Central Pennsylvania Legal Services 213A North Front Street Harrisburg PA 17101 (800) 932-0356 ROBIN D. GIORDANO, PLAINTIFF/RESPONDENT VS. PAUL J. GIORDANO, SR. DEFENDANT/PETITIONER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2004-3526 : CIVIL ACTION -LAW : IN CUSTODY PETITION FOR CONTEMPT AND NOW, comes the Defendant/Petitioner, PAUL J. GIORDANO, SR., by and through his counsel, Susan Kay Candiello, Esquire, of the Law Firm of Susan Kay Candiello, P.C., and files this Petition for Contempt upon a cause of action of which the following is a statement: 1. The Defendant/Petitioner is PAUL J. GIORDANO, SR. (Sometimes hereinafter known as "Father".) who presently resides at 1229 Bridge Street, New Cumberland, Cumberland County, Pennsylvania, 17070. 2. The Plaintiff/Respondent is ROBIN D. GIORDANO, (Sometimes hereinafter known as "Mother".) who presently resides at 8421 Arbutus Road, Pasadena, Maryland, 21122. 3. The parties entered into a custody agreement dated October 12th, 2004, (A copy which is attached hereto and made a part hereof at Exhibit "A".) which directs the custody of Adam V. Giordano and Brady G. Giordano. 4. This petition does not concern Adam V. Giordano, since Father obtained Primary Physical Custody of Adam V. Giordano on or about November, 2004. Mother continues to have Primary Physical Custody of Brady. G. Giordano. VERIFICATION The undersigned hereby verifies that the facts averred in the foregoing document are true and correct to the best of his knowledge, information, and belief This verification is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. DATED: lb-TUeJOS QJN PAUL JO E H GI RDANO, SR. EXHIBIT "'A" Feb 17 aS 05:07p Linda A. Clotfelter, E=sq. (717) 796-1933 p.2 FEB-15-2005 TUE 10:15 Alf FAX NO. P, 02 W ROBIN D. GIORDANO PlailIds vs. OCT 0 62004 $( IN TkM COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAM 04-3526 CIVIL ACTION LAW PAUL J. GIORDANO, SR. Defendant IN CUSTODY aRnm OF COOM AND NOW 'this day of ayn' consideration of the attached Custody Conciliation Report, it is ordered and directed as follows; 1. The Mother, Robin D. Giordano, and the Father, Paul J. Giordano, Sr., shall have shared legal custody of Adam V. Chordano. born May 3, 1988, and Brady G. C3iordano, born April 8, 1994. Each parent shall have an equal rift. to be exercised jointly with the other parent, to make all rAjor decisions affecting the Children's general well-being includin& but not limited to, all shoe-ernet'$ency decisions regarding their health, education and religion. Pursuant to the terrU 9f this paragraph each parent dWI be entitled to all records and information petsininS to the Children including. but not limited to, school and medical records and information. Both parentis' names shall be listed with the Children's schools as parents to be contacted in the event of an emergency and to be notified ragstdiug school events. The Mother shall promptly provide copies of all report cards and notificadon of major school events to the Father promptly upon receipt. Neitber parry shall schedule activities or appointments for the Children which would require the Children's attendance or participation during the other party's periods of custody, unless otherwise agreed. 2. The Mother shall have primary physical custody of the Children. 3. The Fattier shall have partial physical custody of the Childress on altmmd * weekends from -Friday at 4;04 p.m. through Sunday at 7:00 P•tn. if there is school the following day: and at 9:04 p.m. if -- - there is no school the following Mooday. During the rummer school break, the Father's alternating weekend periods of custody shall be expanded to rein from Thursday at 6:00 p.m. through Sunday at 9:00 P.M. 4. The parties shall there or alternate having custody of the Children on holidays as follows: In every year, the Father shall have custody of the Children from Christmas Eve A. at 4:00 p.m. through Cluistinas Day at 1:00 p.m. and the Mother shall have custody lleom Chrismias Day at 1:00 p.m. Wou& December 26 at 6:00 p.m. nniIier9nnn Twt 17.19 - rT!/Y?T Nn SAAM 00n2 ,_Feb 17 05 05:07p Linda R. Clotfelter, Esq. (717) 796-1933 p.3 - HO P. 03 FEB-15-2005 TUE 10:15 AM FAX ' The Mother shah have custody of the Children in even numbered years for B. hire t Itlli Tqwksgiving and the Father shall have custody of the Child= iU been cities. f°T Thwksevni with the specific times to be arranged by agreetn : In odd numbered years, the Mother shall have custody of the C. Children New Year's Eve and Day (for purposes of this provision, the Now Year's on New Year's Eve), Meatarial DAY holiday stall be deaoned to fall within the same year as dance otD even p y and Labor Day and the bather shall have custody on Easter and Indeen numbered years, the F9dW shall have custody of the Children for NewYear's ? Day, Memorial Day and Labor Day and the Mother shall have custody and Indepmdeotce Day. The alternating holiday periods of custody under this provision shall run ffom 5:00 p.m. on the night before the holiday through 7:00 P•m, an the holiday if there is school the following day or 9:00 p.m. if there is no school. The Indeptandence Day holiday any be extended later in the evening to enable the parties to take the Ch khen to the fireworks. ' on D. er /F?thrr'a.17LV: The Mother shall have custody of the Children every years Day Moth y - - Mother's Day and the Fatter shall have custody of the Children every year on Father mom 5:00 pan. on Saturday through 7:00 p.m. on Sunday if there is school the following day or 9:00 p.m. if there is no school: B. The holiday custody schedule shall sapercede and take precedence over the regular custody schedule. shall be entitled to have up to two consecutive weeks of vacation each year with the ChChild anee notice to the other party. Both panics ri upon providing at least 30 days afi+ regular weelm?td shall schedule periods of custody under, this provision to include that pa?rly's period of custody to ensure that neither party has custody of the Children in excess of two consecutive weeks. 6. The Father shall not remove the Child= from school without the Mothor's prior consent, 7. Each parry shall provide the other with at least 481?ours advance notice of school or other activities whenever possible. The custodial parent shall ensure that the Children amend all regularly scheduled activities. The parties shall cooperate in ensudog that the Child= are able to fully participate in all activities in which they are enrolled. shall be entitled to have reasonable telephone contact and other $. The non-custodial parent types of comnnunication with the Children without interference by the custodial parent. a confined area when the Children are present and neither parity 9. Neither party shall smoke ' m shsll permit third parties to do so. Neither party shall consume alcohol to the point of itttoxicatlott OT transport the Children in a vehicle following the consumption of alcohol. ne?,???nn?e Tftrr ?'ti•?? rmxirY Nn RLdRI' L?I(ii?9 Feb 17 05 05:07p Linda A. C1'otfelter, Esq. (717) 796-1933 p.4 . FEB-15-2005 TUE 10:15 AN FAX NO. P. 04 10. In the cvcnt either party intends to remove either or both ofd* Children ftm his or her residence for an overnight period or longw, that party shall provide the odw party with the addt+eas and telephone number where the Child or Children can be contacted. 11. In the event either party intends to relocate his or her residence more than 30 miles 8tam the current residence, that party shalt provide the other party with at least 90 advance written notice to enable the patties to make any necessary adjustments to the custody schedule by agreement or through the legal process if necessary. 12. Neither party shall do or say anything which may estrange the Children fiom the other parent, injure the opinion of the Children as to the other parent, or hamper the ftx and natural development of the Children's love and respect for the other parent. Both parties shalt ensute that third parties having contact with the Children comply with this provision. 13. This Order is entorcd pursuant to an agreement of the parties at a custody conciliation conference. The parries may modify the provisions of this Order by mutual consent. Any agroed upon modifcatrons to this Order of a coat dw or permanent nature shall be in writing signed by bath parties u the absence of mutual consent, the temas of this Order shall control BY THE COURT, J. cc: Robin D. Giordano, Mother Paul J. Giordano, Sr., Father Twexory, - in T fila4 J WQ' * '.0t my hand seal of acid n9it779nnK TwT 17.19 rqY/RX Nn:sAxA1 2004 rJ C? i ."r. CrN ROBIN D. GIORDANO IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 2004-3526 CIVIL ACTION LAW PAUL J. GIORDANO, SR. IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, June 18, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, July 17, 2008 at 1:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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: Is/ Dawn S. Sunda Es q. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 iN A`1,kSNa AlNn, r ? r 'zs d'1? 9 S ,z Wd 91 n 8002 A J1C3?vt r r lu Hl jQ ROBIN D. GIORDANO Plaintiff VS. PAUL J. GIORDANO, SR. Defendant IN THE COURT OF ( CUMBERLAND COUN 2004-3526 CIVIL A( IN CUSTODY ORDER OF COURT AND NOW, this 21st day of August, 2008, the conciliator, having either party or counsel to proceed further or reschedule the custody conci held on July 17, 2008, hereby relinquishes jurisdiction. For the Court AUG /- 6 ?uuO MMON PLEAS OF ', PENNSYLVANIA ON LAW ved no request from i conference initially 4 Dawn S. Sunday. Custody Conciliator ti ROBIN D. GIORDANO Plaintiff vs. PAUL J. GIORDANO, SR. Defendant Prior Judge: J. Wesley Oler, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2004-3526 CIVIL ACTION LAW IN CUSTODY Y IN ACCORDANCE WITH CUMBERLAND COUP PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the 1. The pertinent information concerning the Child who is the subj follows: NAME DATE OF BIRTH CURRENTLY] Brady G. Giordano April 8, 1994 Mother RULE OF CIVIL ving report: of this litigation is as 2. A custody conciliation conference was held on July 17, 2008, with the following individuals in attendance: the Father, Paul J. Giordano, Sr., The Father's counsel, Sus K. Candiello, Esquire, was not in attendance. The Mother, Robin D. Giordano, did not attend the conference or contact the conciliator. 3. The Father filed this Petition for Contempt and was seeking to re schedule as provided in the prior Order of this Court dated October 12, 200 Father advised the conciliator that he and the Mother were going to go to resolve the issues which have developed. The conciliator agreed to hold thi of thirty (30) days during which time either the Father or his counsel could rescheduled for an additional conciliation conference or jurisdiction relinquis] estate his partial custody . At the conference, the ounseling in an effort to matter open for a period equest that the matter be 4. As of this date, no request for the rescheduling of this matter h?s been received and the conciliator submits an Order relinquishing jurisdiction. A c ,.?? 2, dcof- .? a Date Dawn S. Sunday, Esquire Custody Conciliator cc: Susan K. Candiello, Esquire - Counsel for Father Robin D. Giordano - Mother CO f