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HomeMy WebLinkAbout02-1992 NMFILED-OFFICE OF THE PROTHONOTARY 2011 APR 13 AM II: 43 CUMBERLAND COUNTY PENNSYLVANIA P. Richard Wagner, Esquire PA Supreme Court I.D. #23103 Mancke, Wagner, & Spreha 2233 North Front Street Harrisburg, PA 17110 Telephone (717) 234-7051 Fax (717) 234-7080 Attorney For Plaintiff KEVIN G. DESIDERATI, Plaintiff/Petitioner V. ADESSA R. SEITZ, Defendant/Respondent : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO: 2002-1992 CIVIL ACTION - LAW IN CUSTODY PETITION TO MODIFY AND NOW, comes the Petitioner, Kevin G. Desiderati, by and through his attorneys, Mancke, Wagner & Spreha, and files the following Petition to Modify: 1. Your Petitioner, Kevin G. Desiderati, is the Plaintiff in the above-captioned matter. 2. The Respondent, Adessa R. Seitz, is the Defendant in the above-captioned matter. 3. On the 23`d day of August, 2010, the parties entered into an agreement that was subsequently adopted as a Court Order, a copy of which is attached hereto, incorporated herein by reference, made a part hereof, and marked as Exhibit A. 4. The provisions of the Order of August 23, 2010 did not include a summer schedule which Petitioner believes should be shared by the parties. ev- 7S7? 5. Petitioner believes and therefore avers that shared physical custody in the summer and additional time throughout the school year is in the best interests of the child. 6. Petitioner requests the Court to modify the Order of August 23, 2010 by adding the following: A. Including a summer schedule that includes shared physical custody; and B. Increasing the periods of partial custody of the child with the Petitioner during the school year. 7. The Honorable J. Wesley Oler has previously had involvement in this matter. WHEREFORE, Petitioner prays this Court to grant the relief as requested. Respectfully Submitted, Mancke, Wajzner & Snreha Attorneys For Petitioner Date: C/ -2- 2233 North Front Street Harrisburg, PA 17110 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unworn falsification to authorities. Date: O? "10// r KEVIN G. DESIDERATI, Plaintiff V. ADESSA R. SEITZ, Defendant AUG 2 3 2010 G' : IN THE COURT OF C MA : CUMBERLAND COUN , NO. 2002-1992 CIVIL A IN CUSTODY ORDER OF COURT As OF )?VANIA O'N - LAW AND NOW, this ?'?day of_ , 2010, upon consideration of the attached Custody ConcilidKon it is ordered and directed as follows: 1. The prior Order of Court dated September 29, 2003 shall remain in full force and effect except as modified hereinafter. 2. Father shall have periods of partial physical custody as follows: A. Alternating weekends from Friday after school, when Father will pick up the child, to Monday morning when Father will transport the child to school. This schedule shall begin on Labor Day weekend and Father shall have physical custody until Tuesday morning when he shall transport the child to school. In the event of a Monday school holiday, Father shall have physical custody until 5:00 p.m. on Monday. B. On the off week, Father shall have physical custody on Wednesday from after school, when Father shall pick up the child, until Thursday morning when Father shall transport the child to school. C. Such other time as the parties agree. 3. All other provisions of the Order of Court dated September 29, 2003 shall remain in full force and effect except as modified herein. 4. 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. In the absence of mutual consent, the terms of this Order shall control. A telephone conference with the Conciliator and counsel is scheduled for November 1, 2010 at 8:30 a.m. BY THE COURT, J. cc: P. Richard Wagner, Esquire, Counsel for Father J. Paul Helvy, Esquire, Counsel for Mother TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of said Court at CadWe, Pa. This QN- day of 122-1 20 & Prothonotary ''IrW 192;( KEVIN G. DESIDERATI, Plaintiff V. ADESSA R. SEITZ, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002-1992 CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, 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: The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Madison C. Seitz March 5, 2002 Mother 2. A Conciliation Conference was held in this matter on August 23, 2010, with the following in attendance: The Father, Kevin G. Desiderati, with his counsel, P. Richard Wagner, Esquire, and the Mother, Adessa R. Seitz, with her counsel, J. Paul Helvy, Esquire. 3. The Honorable J. Wesley Oler, Jr. entered an Order of Court dated September 29, 2003 providing for shared legal custody, Mother having primary physical custody with Father having alternating weekends, Friday to Sunday. 4. The parties agreed to an Order in the form as attached. Date acq ine M. Verney, Esquire Custody Conciliator KEVIN G. DESIDERATI IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA c, V 2002-1992 CIVIL ACTION LAW ADESSA R. SEITZ IN CUSTODY DEFENDANT ? ?•?"-' ORDER OF COURT AND NOW, Thursday, Apri114, 2011 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, May 27, 2011 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Lacqueline M. Verney, Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. ?? Cap l Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 C1 Telephone (717) 249-3166 C&" '"4 -L,., -- , -'-? /-??