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HomeMy WebLinkAbout01-2824 VICTORIA E. GREEGER Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : CUSTODY/VISlTATION : NO. () 1- ;J.. r J. 'I CIVIL TERM (\) BRETI A. GREEGER, Defendant COMPLAINT FOR CUSTODY I. "" ,,""<iff i. V","", E. G_'. """i"" ~ 20 .... s_ No. 10. MI. Hol1, spri.... Cumberland County. Pennsylvania \7065. 2. "" "",,",WI" B"U A. G_. """" ,"""" ""''''' i. boli"'''' " 632 Nouh W.... Street, Carlisle. cumberland County. Pennsylvania 170 I 3. 3. Plaintiff seeks custody of the following child: NAME RESIDENCE DOB ~ AGE ~ Garrett Quinn Greeger 20 East Street. No, IO February 18, 1999 Mt. Holly Springs, P A 17065 2 years The child was not bom out of wedlock. The child is presently in the custody of Victoria E. Greeger. During his life. the child has resided with the following persons and at the following addresses: DATES ADDRESS Victoria E. Greeger and Step-sister. Akira S. Opilo 20 East Street, No. IO Mt. Holly Springs, PAl 7065 Dec. 20. 2000 to present NAME Victoria E. Greeger. Step-sister. Akira S. Opilo, Father, Lewis Opilo. Jr. Mother. Phyllis Opilo Brother. Alexander Opilo And niece Jessie Opilo 7 I 5 Sherwood Drive Carlisle. P A 17013 October 2000 to December 2000 Victoria E. Greeger and Step-sister, Akira S. Opilo 10 Hanlilton Street. Apt. C Norristown. P A August 2000 to October 2000 Victoria E. Greeger and Step-sister, Akira S. Opilo 109 Third Street, Apt. 2 Boiling Springs. PA 17007 March 2000 to August 2000 Brett A. & Victoria E. Greeger Step-sister, Akira S. Opilo 109 Third Street. Apt. 2 Boiling Springs. PAl 7007 Birth until March 2000 The mother of the child is Victoria E. Greeger. currently residing at 20 East Street. Apt 10. Mt, Holly Springs. PA 17065. She is married. Tho """" of "" ,hild i. ."" A. "",g<<. """,ii, i. 1<1"'''' '" I< ",\ding" 632 North West Street. Carlisle, PA 17013. He is married. 4. The relationship ofthe Plaintiff to the child is that of Mother. The Plaintiff currently resides with the following persons: daughter. Akira S. Opilo and son. Garrett Quinn Greeger 5. The relationship of the Defendant to the child is that of Father. The Defendant currently resides with the following persons: Rebecca O'Donnell and her child 6. Plaintiff has not participated as a party or witness. or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. plaintiff does not know of a person not a party to the proceedings who haS physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested for the following reasons: A. Plaintiff haS untaken and performed the primary parental responsibilities for the child; and B. Plaintiff is best able to provide the care and nurture which the child needs for healthy development; and C. Over the last several months the Defendant haS rarely had partial custody of the child and has seen the child or otherwise had contact with the child on few occasions. The Defendant has. however, threaten to remove the child from the primary custody of the mother. Therefore a Court Order determination of custody is required to avoid continuing conflict between the parties regarding parental responsibility for custody and support. D. In addition and referenced to the above a Court Order of custody ora strUctured visitation and/or partial custody is desired so that the Plaintiff and the child may plan their schedules accordingly and so that misunderstandings and unmeet expectations regarding custody and visitation can be avoided. E. plaintiff desires to maintain the family household, which has been established, and the continued stability of the household is in the best interest of the child. 8. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child haS been named as parties to this action. WHEREFORE, Plaintiff requests the Court to grant custody of the child to Plaintiff pending the hearing. Respectfully submitted, ANDREWS & JOHNSON By: Ronald E. Jo Attorney for 78 West Po t Street Carlisle, PA 17013 Telephone: (717) 243-0123 Supreme Court ID No. 16453 COMMONWEALTH OF PENNSYLVANIA ) : SS. coUNTY OF CUMBERLAND ) I verify tllat the statements made in the foregoing Complaint are true and correct. I """""""..... _ .-.~"!<rein "" ""'" ",bi'" "'... ,"",,'''' nf" he.s. 14904. relating to unsWom falsification to authorities. DATE: sa-OJ ~~~~Plf ~ R ~ C') c) ( , c- .011 :;.... ::r. , cJ ." l, ,,' '-'."; -. mil .< ..-- -. ..,....:. ..:.] -. i:::: zi: c,J u.. (f~ ", . ~") ..... -, . ~ r::\..:.. ~~ "I: Lv ~~\.:~ ; ". ~'. ~ ~I --- -. '"_.,,11 "\T' ....f. :;-"J ~. "f ~ )::~:'; => ~. "'- ~ 0, -, ell =< -< ' "" ~ c::: VICTORIA E. GREEGER PLAINTIFF V. BRETT A. GREEGER DEFENDANT IN THE COURT OF coMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-2824 CIVIL ACTION LAW IN CUSTODY 91101\:R OF C.01JR'[ , upon consideration of the attached Complaint. ,,;, _ ,_ ....,.rti~.... ".._~ _~\'PI"" ......_M. v"'"'..... . '" _;\.'M. " ..._.C_C- ~C._ ~ W".....,..-"'.." ",,,, ..... ... ,.,..._", """,,, COO_. A1_h _-=.. .ff"".m "'...... ~ -,~ "" ,- ,. ....." M if""'''- '" .-~,..... ~ d<\1n' .... ..... '" _ ~ '" ""'" by ,'" ""'" "" ~ ~'" ,.~ · ""'''''''' _. A11 ,hil_'" fi~ M ,ld<<~'''~ '" ""'"'" '" """~'" f.J1nre ~ --"" --..., provide grounds for entry of a temporary or pennanent order. The court hereby directs the parties to furnish any and al\ existing protection from Abnse orders, _ .....onI....... c_ ,.......... ~.- AS ...,n p'.... --"".- FOR THE COURT. AND NOW, Friday, May 18,2001 By: Is! Tacqueline M. VPnI'OI- Esq./:/J 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 infonmation about accessible facilities and reasonable ............_ "",,,,,,, ~ '"""'" '00"""'" "'''''' ""'"'" ""~ "" _. ,1_ ........ = - All ._" _ '" _" ''''' n _ """ ~~, ",,"', M ...,_...... '" - yoo ...., attend the scheduled conference or hearing. YOU SHOULD TAKE THlS pAPER TO YOUR ATfORNEY AT ONCE. IF YOU 00 NOT HA VB AN ATfORNEY 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~o; .; '>'77 ~ --:- -".' ~ /f?,8/oF ~ '? ~ ~ /C?:/'/..Y c..-~ P ?- 'i7~ 4,.; n /V' .~/ j_' 'j 1 (":'.~"J~d ".fl \-"N.,I/\'''\''':~.:~:: . :r.il !.... .-: :.. (": ~~.. .' iJ.i'\i" ' .., ."' "~";1 .".. .., fJ, \ ,',: ~ . JUN 0 ? 200ft! VICTORIA E. GREEGER, Plaintiff V. : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYL VANIA NO. 2001-2824 CIVIL TERM : CIVIL ACTION - LA W BRETT A. GREEGER, Defendant : IN CUSTODY ORDER OF COURT . AND NOW, this v~ day of j,~- ,2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I. The Mother, Victoria E. Greeger, and the Father, Brett A. Greeger, shall have shared legal custody of Garrett Quinn Greeger, born February 2, 1999. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. Mother shall have primary physical custody of the child. 3. follows: Father shall have periods of Partial physical custody of the child as a. Beginning June 14, 200 I, alternating weeks from Thursday at 7:00 p.m. to Sunday at 5:00 p.m. b. Such other times as the Parties agree. 4. birthday. Each party shall be entitled to a block of time with the child on their 5. Transportation shall be shared such that Mother will transport the child to Father's residence and Father shall return the child to Mother's residence, unless otherwise agreed by the Parties. 6. Both parents shall have liberal and reasonable telephone contact with the child when the child is in the custody of the other parent. 7. The parties shall keep each other advised immediately relative to any medical care or medical emergencies concerning the child and shall further take any necessary steps to ensure that the health and well being of the child is protected. During such illness or medical emergency, both parents shall have the right to visit the child as often as he/she desires consistent with the proper medical care of the child. 8, Neither parent shall do anything nor permit anyone else to do anything which may estrange the child from the other party, or injure the opinion of the child as to the other party, or which may hamper the free and natural development of the child's love or affection for the other party. 9. This Order is an interim Order entered pursuant to an agreement of the parties at a Custody Conciliation conference. Either party may contact the Conciliator within sixty days from the date of this Order to schedule another conciliation conference. 10. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. ,. .-? BY THE COURT, .' \.. ,,- .i J, cc: Ronald E. Johnson, Esquire - Counsel for Mother , () ~_ I I I / I Jason P. Kutulakis, Esquire, Counsel for Father ,)~,~. 1l"l;;u.U4L ,./~& /01 ~ ~ "A",,- ..{L.'~.,",:~,:. i.~.! ~{Sti~I,V":1d ". ';. '>~~~;Vn., .... 'I,' "'] ~ " , ;','., 'I' . ..... ".1, I/) ',. " .f!..;.;:.... V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLV ANIA : 2001-2824 CIVIL TERM : CIVIL ACTION - LAW VICTORIA E. GREEGER, Plaintiff BRETT A. GREEGER, Defendant : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1, The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Garrett Quinn Greeger February 18, 1999 Mother 2. A Conciliation Conference was held in this matter on June 6. 2001. Mother, Victoria E. Greeger, was present with counsel, Ronald E. Johnson, Esquire, and Father, Brett A. Greeger, was present with counsel, Jason P. Kutulakis, Esquire. 3. The parties agreed to an interim Order in the form attached. fo-1-v( Date '~tn, ~/~~ acq line M. Verney, Esquire Custody Conciliator VICTORIA E. GREEGER, Plaintiff V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLV ANIA 4lJG 1. 'I ZOOId} BRETT A. GREEGER, Defendant : CIVIL ACTION _ LA W : NO.200I-2824 CIVIL TERM : IN CUSTODY ORDER OF COURT - 2. "",.."" funh" Onl".f e""" " _ 'f"" _" "" ."'" """" of Court dated June 20, 200 I shall remain in full force and effect. AND NOW, <HI, dKP_ doy.f _ C (<.(''-'!~ _' 200', 'po, "'-"'"".f"" -hod e....,y e''''''''"09 Repo" i, "._ "'" ........" fOlloWs: I. A H_ i, """''''"U. Court Roo" N.. _ ~ of "" <;'''''''''''''' C.""" C.", H."" .. "" _.... doy.f I'l.:..... _. _ _' 200;." , . 'IS: · '''''''- A. M.. " ""'ob .", '-..y will '" ""'" P" ......" of <HI, H_ "" """''' """, '" - " '" "" -log ""'" "'" """i _ '''''''iy wi<H '''.''''Y. e._,... "'. ""'" """i fi~ wi <H "" Co", "'" '_''''' "O,"", , ............ """" fOrth "" """", -... .n ''''fndy. . Ii" .f wi"""" Who will '" -,'" 0> ""tify " "" H_. "'" . _ .f"" "'<ie'''''''' ""'''..y .f "'. wi_. ""'" ".....""", ""'" '" filed " ~." ... do" Fri" 0> <H, H..,,,,, ""'. \ 1. Ronald E. Johnson, Esquire, Counsel for Mother Jason P. Kutulakis, Esquire, Counsel for Father ~ I ? O~,')J -1', ......;. ~.... .... :.~" < '.~'. -1". \';.' I. iA.,;;:, ,:-,'',,- , .'),........ . ~?2,,, '/(,.!', "- I"~ .~."'~->.> '.:.";~"" -, ", ..... <~. V .~ .<., , :t;) L') :~ VICTORIA E. GREEGER, Plaintiff AUG 1 72001 fj? . V. BRETT A. GREEGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTy,PENNSYLV ANIA : CIVIL ACTION _ LA W : NO. 2001-2824 CIVIL TERM : IN CUSTODY PRIOR JUDGE: Edgar B. Bayley, J. IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 19153.8. tho "d",,_ c.,,,,,,y C"'il_ "'bmi. tho fo'o..., report: CUSTODY CONCILlA TlON SUMMARY REPORT - 1. The pertinent infonnation concerning the Child who is the subject of this litigation is as follows: NAME Garrett Quinn Greeger DATE OF BIRTH CURRENTLY IN CUSTODY OF 2. A C""",.,,,,, C""f_, "" boldA_, 16. 200, ..'" tho follow;"" '"Il,;d"" '0 -<boo", "'-. V""," E. G",,,,,. ..'" '" ""_. '''''''d E. John.,o. ""'oire, F."". B"" A. "'-'. w,'" hi, "'_. J_ P. K,Io""" ""'oire February 18,1999 Mother 3. Follo..og · """","""" eo""""",, .. ""'" of""", dM<<" "'" 2~ 200 '.., '"- by Tho Ho""""",, 'dgo, a Bay." ,""",0 "'_ "'" F."" """'" ''''' ''''''''y "'" """" ",",0.'"", pno",,> pb",,,,, '""""y w,'" F Mb", ""log ""'''''' of"",", ph",,,, '""""y " "'......g _.. m.m "'''''''y " S"",,"y 4. "'0""', _ri"" "''''''log '""""y ,," fu'o,,", S,,", _ """'" '''''' ..d """'''Y ph",,,,, '""""y of tho ,hi !d. S,,", "'."".." "'" F_ "" OO,__y 'bo"" .. ",-, '" tho <hi'd. b" """"y --10 "",0"", tho <hi!d from "'0""', Custody which prompted Mother to tile this custody Complaint. Mother asserts that F ","", dJd "'" ""', "y,""", of tho ,,,""'., time ....."" "him ,,"" tho ""'" of Court dated June 20, 2001. 5. Father's position regarding custody is as fOlloWs: He seeks shared legal and shared physical custody on a week on/week off basis. He maintains that he took ""- Of,,, d""....."", '" "', ""'" 0nI", of Co..... ."'_ ""' """,. ""-'og at least one visit for a birthday celebration. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing. The prior Order of Court shall remain in full force and effect until the hearing, It is expected that a hearing will require one half day. f-I(,-ol Date 'th. L-t que eM. Verney, Esquire J ustody Conciliator VICTORIA E. GREEGER Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO: 2001-2824 BRETT A. GREEGER Defendant/Petitioner : CIVIL ACTION - LAW : IN CUSTODY PETITION TO MODIFY CUSTODY 1. Petitioner is Brett A. Greeger, who resides at 120 Greenview Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. Respondent is Victoria E. Greeger, who resides at 175 E. North Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. On June 21, 2001, the Honorable Edgar B. Bayley entered a Custody Order attached as Exhibit "A". 4. Since the entry of said Order, there has been a significant change in circumstances in that: a) Petitioner believes and avers that the child is not receiving the basic needs such as food and clothing. b) Petitioner is best suited to provide a stable environment for the child. c) Petitioner is best able to provide the care and nurture which the child needs for healthy development. 5. The best interest of the child will be served by the Court modifying said Order. . WHEREFORE, Petitioner prays this Court to grant the modification of the Custody Order as follows: Primary physical custody in Father with partial custody in Mother. Respectfully submitted, ROMINGER, SA YLEY & WHARE Date: / 1- /'~ - 0 -;;- rVl~ .1 L-/( Michael J. Whare, Eiquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID 1/ 89028 Attorney for Defendant/Petitioner VERIFICATION I verify that I am the petitioner and that the statements made in the foregoing Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. s. 9 4904, relating to unsworn falsification to authorities. Date: \ \! \7 /o~ g~QJB.1 oa9!!-/ Brett Greegerl Defen ant ~ }1J!\f t~ '> ~r: tI ,I U' !: /,\!"i'"i . - ~Uft j VICTORIA E. GREEGER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYL VANIA V. NO. 2001-2824 CIVIL TERM CIVIL ACTION - LAW BRETT A. GREEGER, Defendant IN CUSTODY ORDER OF COURT \, AND NOW, this -V::-j day of ')v.,:;:2.-- ,2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Victoria E. Greeger, and the Father, Brett A. Greeger, shall have shared legal custody of Garrett Quinn Greeger, born February 2,1999. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding his health, education and religion, 2. Mother shall have primary physical custody of the child, 3. follows: Father shall have periods of partial physical custody of the child as a. Beginning June 14,2001, alternating weeks from Thursday at 7:00 p.m. to Sunday at 5:00 p.m. b. Such other times as the parties agree. 4. birthday. Each party shall be entitled to a block oftime with the child on their 5. Transportation shall be shared such that Mother will transport the child to Father's residence and Father shall return the child to Mother's residence, unless otherwise agreed by the parties. 6. Both parents shall have liberal and reasonable telephone contact with the child when the child is in the custody of the other parent. 7. The parties shall keep each other advised immediately relative to any medical care or medical emergencies concerning the child and shall further take any , necessary steps to ensure that the health and well being of the child is protected. During such illness or medical emergency, both parents shall have the right to visit the child as often as he/she desires consistent with the proper medical care of the child. 8. Neither parent shall do anything nor permit anyone else to do anything which may estrange the child from the other party, or injure the opinion of the child as to the other party, or which may hamper the free and natural development of the child's love or affection for the other party. 9, This Order is an interim Order entered pursuant to an agreement of the parties at a Custody Conciliation conference. Either party may contact the Conciliator within sixty days from the date of this Order to schedule another conciliation conference. 10. 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, f.. ~!' .~,./' .#' , W&/iJ ! J. i ?' '-'~'''''''', ..,,/'</-, / /' cc: Ronald E. Johnson, Esquire - Counsel for Mother 5 n I I / I / Jason P. Kutulakis, Esquire, Counsel for Father \.:.Cf'~' :n~~~ "",J.t 01 ~ 'l\ c) r-'~' (:) ~ I"J f-.' ,'c\ -,j (,'.-," " ~ .-j ~ :r: ~-.- '%:: i-;-; -- ~ ~ en --J "'-.. - ~ ~ , , ~ \.AI ------ _/ , ... VICTORIA E. GREEGER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, 01-2824 CIVIL ACTION LA W BRETT A. GREEGER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, November 29, 2005 , upon consideration of the attached Complaint, it is hereby directed that paIiies and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator, at 4th Floor, Cumberlaud County Courthouse, Carlisle on __"...!-"esd~y.!.~_anu_a!Y 10, 20Q~_~,_ at 9:30 _AM for a Pre-Hearing Custody Conference. At sueh conference, an effort will be made to resolve the issucs 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 agc 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 herehy 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 hearin\!,. FOR THE COURT. By: /s/ Tacqueline M. Vemev, Esq. Custody Conciliator fY' The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For infonnation 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 HA VE 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 . r/ ~fp - ~.M? ,OPCI #1; ~ ~L/7 .>05("1 -r>>y('" /iF " /fI'P"";4A,,; .;"9 -,17;; t'f o t.'.;: - y/ .I"'~! 1 1J lOUb q VICTORIA E. GREEGER, IN THE COURT OF COMMON PLEAS OF PlaintifflRespondent: CUMBERLAND COUNTY,PENNSYL VANIA V. NO. 2001-2824 CIVIL TERM CIVIL ACTION - LAW BRETT A. GREEGER, DefendantlPetitioner: IN CUSTODY ORDER OF COURT rd -.,.I AND NOW, this 1.:) day of ..\ 0.....,,) IV' "I ,2006, upon consideration ofthe attached Custody Conciliation Report, It IS ordered and dIrected as follows: 1. The prior Order of Court dated June 20, 200 I shall remain in full force and effect with the following modification. 2. Father shall have periods of partial physical custody every weekend from Thursday to Monday until after school, except for the third weekend of every month, when Mother shall have physical custody of the child. 3. This Order is entered pursuant to an agreement ofthe parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference is scheduled for March 14, 2006 at 10:30 a.m. BY THE COURT, cc:4chael J. Whare, Esquire - Counsel for Father vNathan Wolf, Esquire, Counsel for Mother a 't, ".!' t,',::" . <""', '" , '\< , '0 t.c. , :'.1 .-:(1 ~,'-' VICTORIA E. GREEGER, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent: CUMBERLAND COUNTY,PENNSYL VANIA V. 2001-2824 CIVIL TERM CIVIL ACTION - LAW BRETT A. GREEGER, DefendantlPetitioner: IN CUSTODY PRIOR JUDGE: Edgar B. Bayley, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Garrett Quinn Greeger February 18, 1999 Mother 2. A Conciliation Conference was held in this matter on January 10, 2006. Father, Brett A. Greeger, was present with counsel, Michael J. Whare, Esquire, and Mother, Victoria E. Greeger, was present with counsel, Nathan Wolf, Esquire. 3. A prior Order of Court was entered by the Honorable Edgar B. Bayley dated June 20,2001 providing for shared legal custody, Mother having primary physical custody and Father having alternating weekends, Thursday to Sunday. 4. The parties agreed to an Order in the form attached. i~ ((;-C '-' Date i ;, Il') \{ ~-1,.~<"--~-< fl~,V1..c'~l,v dacqu ine M. Verney, Esquire /j Custody Conciliator ~'---~~.:::~"-::;---::---'":"_-:-;--:':--::::-~ ~, ... ,-___,' ...... I,' ... VICTORIA E. GREEGER, Plaintiff/Respondent 6,PR 1 'i ZO(6 B( ., i. J' : IN THE COURT OF COMMON PLEA;S"i)1F-==~-== : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2001-2824 CIVIL ACTION - LAW BRETT A. GREEGER, Defendant/Petitioner : IN CUSTODY ORDER OF COURT AND NOW, this oI-Y day of ~ ,2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A Hearing is sche~d in Court Room No. 5 , of the Cumberland County Court House, on the d8' day of ~ ,2006, at q.'-3 () o'clock, lL. M., at which time testimony will e taken. For purposes ofthis Heanng, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the prior Orders of Court dated June 20, 2001 and January 23, 2006 shall remain in full force and effect. 3. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, cc~hael J. Whare, Esquire, counsel for Father ~than C. Wolf, Esquire, counsel for Mother 4 J. c,.'.\ .' \\" ;\ VICTORIA E. GREEGER, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : NO. 2001-2824 CIVIL ACTION LAW BRETT A. GREEGER, DefendantlPetitioner : IN CUSTODY PRIOR JUDGE: M. L. Ebert, Jr., J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: I. The pertinent information concerning the Child who is the subject of this litigation is as follows: CURRENTLY IN CUSTODY OF NAME DATE OF BIRTH Garrett Quinn Greeger February 18, 1999 Mother 2. A Conciliation Conference was held April 13, 2006 with the following individuals in attendance: The Father, Brett A. Greeger, with his counsel, Michael 1. Whare, Esquire, and the Mother, Victoria E. Greeger, with her counsel, Nathan C. Wolf, Esquire. 3. The Court previously entered Orders dated June 20, 2001 and January 23, 2006 providing for shared legal custody, Mother having primary physical custody and Father having 3 weekends per month from Thursday to Monday. 4. Father's position on custody is as follows: Father seeks shared legal and primary physical custody with Mother having alternating weekends. Father maintains that Mother does not properly care for or supervise the child. Another child in the home was recently rushed to the emergency room when Mother suspected the child ingested an adult's prescription medication. In the rush to the hospital, the child who is the subject of this matter was left at home alone. Father asserts that he is better fit and capable to care for the child. He also suggests that Mother's paramour has criminal charges pending. 5. Mother's position on custody is as follows: Mother seeks shared legal and primary physical custody with the current Orders remaining in effect. Mother asserts that Father works the overnight shift and is not available to care for the child. The child complains that Father spends little time with him, Father does not properly supervise homework. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and maintaining the status quo. It is expected that the Hearing will require one day. q-I'-I-ol" Date !~6/ '. . .t~. v'Jacq eline M. Verney, Esquire (} Custody Conciliator NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 WOLF & WOLF 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF VICTORIA E. GREEGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2001-2824 BRETT A. GREEGER, Defendant : IN CUSTODY MOTION FOR CONTINUANCE NOW comes the Plaintiff, Victoria E. Greeger, by her attorney, Nathan C. Wolf, Esquire, and presents the following motion for continuance of June 28, 2006, custody hearing, representing as follows: 1. Plaintiff is Victoria E. Greeger (hereinafter "Mother"), the plaintiff in the above captioned matter who resides at 175 East North Street Carlisle, Gnnberland County, Pennsylvania 17013. 2. Defendant is Brett A Greeger (hereinafter, "Father"), the defendant in the above captioned matter who resides at 17 South Baltimore Avenue, Mt. Holly Springs, Gnnberland County, Pennsylvania 17065. 3. The parties are the parents of one minor child, namely: Garrett Quinn Greeger, born February 2, 1999, age 7 years 4. The parties are subject to a custody order issued by this Court dated June 20, 2001, wherein Mother has primary physical custody and Father has periods of alternating weeks of partial physical custody of the child. 5. As a result of a petition to modify custody filed by Father on November 18, 2005, a custody hearing was scheduled for Wednesday, June 28, 2006. 6. Counsel for Mother was unable to contact Mother in preparation of the custody hearing presently scheduled until the date of the instant motion. 7. Upon contacting Mother, counsel has learned that Mother gave birth to a daughter on June 21, 2006, the morning of the instant request and is still in the hospital recuperating. 8. No previous continuances have been requested in this matter. 9. Father's counsel's concurrence was sought in this request for continuance, and such concurrence was not given. 10. The undersigned has, nevertheless, verified the availability of the Court and Father's counsel for July 11, 2006 at 1:30 p.rn. WHEREFORE, Plaintiff, Victoria E. Greeger, respectfully requests that the Court issue an Order rescheduling the custody hearing, currently scheduled for June 28, 2006, at 9:30 a.rn. to July 11, 2006, at 1:30 p.rn. and any additional relief that the Court may deem appropriate and just. Dated: Jun~ 2006 'tted, Nathan C. W , quire 10 West Street Carlisle 17013 Supreme Court I.D. No. 87380 (717) 241-4436 Attorney for Plaintiff VERIFICATION I, the undersigned, do hereby verify I am counsel for Movant, and the facts set forth in this motion are true and correct to the best of my knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.CS. Section 4904, relating to unsworn falsification to authorities. June ---2[, 2006 NATHAN C. WOLF, ESQUIRE ATTORNEY ill NO. 87380 WOLF & WOLF 10 WEST HIGH STREET CARUSLE PA 17013 (717) 241-1436 ATTORNEY FOR PLAINTiFF VICTORIA E. GREEGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2001-2824 BRETT A. GREEGER, Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Nathan G Wolf, Esquire, hereby certify that I have served a true and correct copy of Plaintiff's Motion for Continuance upon the following person and in the matter indicated: SERVICE BY U.S. MAIL: MichaelJ. Whare, Esquire Rominger & Whare 155 South Hanover Street Carlisle, P A 17013 Respectfully submitted, Dated: Jun~, 2006 WOLF & W "4 .-< ,.....) e:::::. c:::> 0' '- ~:-~ C) I") :T!.,., ni~ -::1r.~~ ,~,.- ", ~:) i ~~" ~ ( ,;;> C.J -... C.)' n ~~--j ::/j -< NATHAN C. WOLF, ESQUIRE ATTORNEY ill NO. 87380 WOLF & WOLF 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF JUN2IY : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VICTORIA E. GREEGER, Plaintiff v. : No. 2001-2824 BRETT A. GREEGER, Defendant : IN CUSTODY ORDER OF COURT ~i AND NOW this "), \ day of !,,~~ ,2006, upon consideration of the attached Motion, it is hereby ordered that the custody hearing scheduled for June 28, 2006, at 9:30 o'clock a.m, be rescheduled to Tuesday, July 11,2006, at 1:30 o'clock p.m BY THE COURT: \k~\ J. Ipstribution: vMichaelJ. Whare, Esquire 0athan C Wolf, Esquire ~ ~ \,0 .} O\J SS:I 1,Id I Z lmr 900l A8\IG,iJ;{U,~,:dd 3Hl dO :K)I:'~:{:.(Ern:f NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 WOLF & WOLF 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 VICTORIA E. GREEGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2001-2824 BRETT A. GREEGER, Defendant : IN CUSTODY MOTION FOR LEAVE TO WITHDRAW AS COUNSEL FOR PLAINTIFF NOW COMES counsel of record for Plaintiff Victoria E. Greeger, Nathan C Wolf, Esquire, and respectfully submits this Motion for Leave of Court to Withdraw as Counsel for Plaintiff, Victoria E. Greeger, pursuant to Pa.RCP. 1012, and in support thereof, avers as follows: 1. Plaintiff, Victoria E. Greeger, is an adult individual who is a resident of the State of Pennsylvania, and whose last known address was 175 East North Street Carlisle, Pennsylvania 17013. 2. The undersigned counsel was retained by the plaintiff on or about December 19, 2005. 3. The undersigned counsel contacted Plaintiff, Victoria E. Greeger, and Plaintiff orally communicated with the undersigned counsel, and the undersigned counsel sought oral confinnation, that Plaintiff no longer wished the undersigned to represent her. 4. Moreover, the undersigned counsel has performed legal services for the plaintiff in the nature of custody and divorce and has not been compensated for some such services. 5. The undersigned counsel believes and therefore avers that no prejudice would be Sllfff>rPd by his client if the inst,:mt motion is ~ntf>d, :md th:lt this Court should grant the relief requested in accordance with his client's wishes. 6. The undersigned counsel contacted Michael]. Whare, Esquire, counsel for Defendant, for concurrence in the filing of this motion and such concurrence was given. WHEREFORE, the petitioner, Nathan C Wolf, Esquire, respectfully prays that this Court grant leave for the undersigned to withdraw his representation of Plaintiff, Victoria E. Greeger, and to grant any further relief that the Court deems appropriate. Respectfully submitted, WOLF&WO F Dated: June n, 2006 By: olf,..Esquire igh Street Ca e, PA 17013 Supreme Court LD. No. 87380 (717) 241-4436 Attorney for Plaintiff VERIFICATION I, the undersigned, do hereby verify that the facts set forth in this Motion are true and correct to the best of my knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.CS. Section 4904, relating to unswo alsification to authorities. Dat-ed: June -.It 2006 NATHAN C. WOLF, ESQUIRE ATIORNEY ID NO. 87380 WOLF & WOLF 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 VICTORIA E. GREEGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2001-2824 BRETT A. GREEGER, Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Nathan C Wolf, Esquire, hereby cenifythat I mailed a true and correct copy of the foregoing Motion for Leave to WIthdraw as O>unsel to the below-listed persons: Victoria E. Greeger 175 East North Street Carlisle, PA 17013 Michael J. Whare, Esquire Rominger & Whare 155 South Hanover Street Carlisle, P A 17013 Counsel for Defendant Dated: June z,,~ 2006 "...:l c:::..::;, C-::J CY", o -i) ::;:! fil:G [3 ( - r.,) Le:J -, a r- .~_; VICTORIA E. GREEGER, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-2824 CIVIL V. BRETT A. GREEGER, DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 5th day of July, 2006, upon consideration of the Motion for Leave to Withdraw as Counsel filed by Nathan C. Wolf, Esquire, and the Court noting that a custody hearing which was continued at the Plaintiff's request is scheduled for Tuesday, July 11, 2006 at 1 :30 p.m., IT IS HEREBY ORDERED AND DIRECTED that the Motion of Nathan C. Wolf, Esquire is DENIED at this time. The Motion will be reconsidered upon conclusion of the custody hearing scheduled for July 11, 2006. By the Court, .Alctoria E. Greeger Plaintiff Athan C. Wolf, Esquire Attorney for Plaintiff ~ichael J. Whare, Esquire Attorney for Defendant \ bas tV> 0.~ D 90:S ltd I' t:- ." ~'\n;] SUul :J.Jl .:~) .. :7 RECElVEU JUll v.. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VICTORIA E. GREEGER, Plaintiff v. : No. 2001-2824 BRETT A. GREEGER, Defendant : IN CUSTODY ORDER AND NOW this \ ~"'" day of July, 2006, upon consideration of the foregoing Motion for Reconsideration of the Motion for Leave to WIthdraw as Counsel for Plaintiff, Victoria E. Greeger, filed by Nathan C Wolf, Esquire, reconsideration of the denial of said motion is hereby GRANTED. Furthermore, the Court's Order of July 5,2006 is hereby V ACAlED and counsel is hereby authorized to file a praecipe to withdraw as counsel with the Prothonotary immediately and to serve notice of this Order and such praecipe upon Plaintiff, Victoria E. Greeger, and counsel for all other parties to this matter. The parties should be advised that the hearing scheduled in this matter for July 11, 2006, at 1:30 p.rn. in Courtroom 5 of the Gunberland County Courthouse will proceed as scheduled before the undersigned. BY THE COURT: Distribution ~ath~ C. Wolf, Esquire - C!oJ~Y p'2A.SD&JZ.lly 9,tJt;AJ Vlctona E. Greeger -, C!o u- 1- , ,/ I Michael]. Whare, Esquire' f' /J\.:ll~ ~//C)IO' 4 .._~.!' ~::;l c =- 1'-"'.'" - NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 WOLF & WOLF 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 VICTORIA E. GREEGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2001-2824 BRETT A. GREEGER, Defendant : IN CUSTODY PRAECIPE FOR WITHDRAWAL OF APPEARANCE OF COUNSEL OF RECORD TO THE PROTHONOTARY: Kindfy WITIIDRA W the appearance of NA TI-IAN C WOLF, ESQUIRE, as attorney for the plaintiff, Victoria E. Greeger, in this matter. July-I!L-,2006 F, ESQUIRE eet 7013 :'"'-.":' ;.~:; \ '1 . ... "" COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NO:2001-2824 Victoria E. Greeger Plaintiff vs. Brett A. Greeger Defendant AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYL VANIA ) COUNTY OF CUMBERLAND ) AND NOW, this 10th day of July, 2006, I, Jennifer McKeehan, Legal Assistant for Rominger & Whare Law Offfice, hereby swear that I have served a true copy of the attached Subpoena, executed by the Plaintiff in the above-captioned matter, upon Officer Matthews at the Carlisle Police Department, Carlisle, Pennsylvania for Officer Latshaw of the Police Department by personal service, Date: July 10, 2006 .'. ',.. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NO:200 1-2824 Victoria E. Greeger Plaintiff vs. Brett A. Greeger Defendant SUBPOENA DUCES TECUM To: Officer Latshaw Carlisle Police Department 240 Lincoln Street Carlisle, P A 17013 1. You are ordered by the court to come to the Courtroom #5, Cumberland County Courthouse at Carlisle, Cumberland County, Pennsylvania, on July 11,2006 at 1: 15p,m, o'clock, p,m., to testify on behalf of Brett Greeger, in the above case, and to remab until excused. 2. And bring with you the following: Any documents relating to any incidences regarding the Plaintiff, Victoria Greeger and the Carlisle Police Department. If you fail to attend or to produce the documents or things required by this subpoena, you may be subject to the sanctions authorized by Rule 234.5 of the Pennsylvania Rules of Court Procedure, including but not limited to costs, attorney fees and imprisonment. Requested by a party/attorney in compliance with Pa. R.C.P. no. 234.2(a): Michael J. Whare, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 89028 BY THE COURT, Date: Q.JP'lh Ie ,2t>(J(,. Seal of e Court By: Prothonotary Qv,. L- 0, )11 L ~OLJ Deputy ... .. ::;:J ; .. c' -"""1 C',) - ~ ~~ . C~ ~ \' .. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NO:2001-2824 Victoria E. Greeger p Plaintiff . I VS. Brett A. Greeger Defendant AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYL VANIA ) COUNTY OF CUMBERLAND ) AND NOW, this 10th day of July, 2006, I, Jennifer McKeehan, Legal Assistant for Rominger & Whare Law Offfice, hereby swear that I have served a true copy of the attached Subpoena, executed by the Plaintiff in the above-captioned matter, upon Phyllis Opilo at 715 Sherwood Drive, Carlisle, Pennsylvania by personal service. Date: July 10,2006 ",",.' c.::~ .~-=:) (.:;-..... n -fJ ---4 :-ell :n= , t~ a f'-', ~ r . '.......) c..:l o '1 A COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NO:200 1-2824 Victoria E. Greeger Plaintiff vs. Brett A. Greeger Defendant SUBPOENA DUCES TECUM To: Phyllis Opilo 715 Sherwood Drive Carlisle, PAl 7013 1. You are ordered by the court to come to the Courtroom #5, Cumberland County Courthouse at Carlisle, Cumberland County, Pennsylvania, on July 11,2006 at 1 :15 o'clock, p.m., to testify on behalf of Brett Greeger, in the above case, and to remain until excused. If you fail to attend or to produce the documents or things required by this subpoena, you may be subject to the sanctions authorized by Rule 234.5 of the Pennsylvania Rules of Court Procedure, including but not limited to costs, attorney fees and imprisonment. Requested by a party/attorney in compliance with Pa. R.C.P. no. 234.2(a): Michael J. Whare, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 89028 BY THE COURT, Date: S~iL~h~O cO:~O L By: Is / Cc.~~ vr ..2oz'--( Prothonotary ;-:. . ) ~ Q. nul~ Deputy .- "" VICTORIA E. GREEGER, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-2824 CIVIL V. BRETT A. GREEGER, DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 11 th day of July, 2006, the parties having agreed to the attached stipulation with regard to custody of the minor child Garret Quinn Greeger, born February 2, 1999, IT IS HEREBY ORDERED AND DIRECTED that the stipulation as to custody is entered as an Order of Court. By the Court, Michael Whare, Esquire Attorney for Defendant Victoria E. Greeger Plaintiff ~ ~ 7_n~lJ(, 0-, .... ~'i' C :z ~ r 9UDZ . -. VICTORIA E. GREEGER, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-2824 CIVIL V. BRETT A. GREEGER, DEFENDANT IN CUSTODY STIPULATION AND NOW, this 11 th day of July, 2006, upon agreement of the parties, IT IS ORDERED AND DIRECTED as follows: 1. The Father, Brett A. Greeger, and the Mother, Victoria E. Greeger, shall have shared legal custody of Garrett Quinn Greeger, born February 2, 1999. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well being including, but not limited to, all decisions regarding his health, education and religion. 2. Father shall have primary physical custody of the child. 3. Mother shall have periods of partial physical of the child as follows: a. Beginning July 21, 2006, on alternating weekends from Friday at 6:00 p.m. until Monday at 6:00 p.m. during the Summer. b. During the school year, on alternating weekends from Friday at 6:00 p.m. until Sunday 6:00 p.m. c. Such other times as the parties agree. 4. Both parents shall have liberal and reasonable telephone contact with the child when the child is in the custody of the other parent. 5. The parties shall keep each other advised immediately relative to any medical care or medical emergencies concerning the child and shall further take any necessary steps to ensure that the health and well being of the child is protected. During such illness or medical emergency, both parents shall have the right to visit the child as often as he/she desires consistent with the proper medical care of the child. 6. Neither parent shall do anything nor permit anyone else to do anything which may estrange the child from the other party, or injure the opinion of the child as to the other party, or which may hamper the free and natural development of the child's love or affection for the other party. .- - . 7. 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. ~~.G~'~ --i ~V/~ ~j~ JV1~ f t-./L ,.