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HomeMy WebLinkAbout05-2907 Copies Distributed CJr- - ~9D 7 Date S~ \ XC'i'S Initials ~ ()~ G'ui..~ MICHELE R. TURKOWSKY, now known as MICHELE GULA, Plaintiff, IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA v. No. 509 S 1997 CHARLES J. TURKOWSKY, Defendant. CIVIL ACTION. LAW IN CUSTODY ~'--') ORDER C~) .t- (,y) AND NOW, this E!.day of ;11,4-; ,2005, upon review of Plaintiff s Petition for Transfer of Custody Action, it is hereby ORDERED that the above captioned custody action be transferred to the Court of Common Pleas of Cumberland County. The prothonotary of the Dauphin County Court of Common Pleas is directed to transfer the record' to the prothonotary of the Cumberland County Court of Common Pleas in accordance with Pa. R.C.P. 1915.2(d). AMY 2,. h9l'e,ny certify that the fore(lOing ~ a :. "" ,,"'" "'Z .~ ...... .j6p.1w ~. ~ Protnonotary '/ :Vb./' I '---- J. MEYERS, OESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 236-2817 Distribution: The Honorable Bruce F. Bratton Laurie A. Saltzgiver, Esquire, 410 North Second Street, Harrisburg, P A 17108 Charles J. Turkowsky, Esquire, 210 Herman Avenue, Lemoyne, PA 17043 - t D 7"'- l - ~ ~ -..() -() "6Q ....... ~ - f' W if) V( OtJ ~ t- ~ (') c <;'" ~~~~ :2:::~: -7[ ~.~~F k'.--; 1:> I~~_ ~(:S Pc ~ ...., = = c.n '- c: Z I C7\ '"t:I ::J;: .r:- .- ~ ~:o ;e 00 ~:f1 9~ o ~ ~ CI Date: 5/20/2005 Time: 08:38 AM Page 1 of 1 Dauphin County ROA Report Case: 1997.CV-0509-DC Current Judge: No Judge User: LGARCIA Michele Turkowsky vs. Charles Turkowsky Date 1/29/1997 4/21/2005 4/22/2005 5/4/2005 5/17/2005 5/20/2005 - Divorce with Custody Judge No JUdge No Judge No Judge Bruce F. Bratton New Civil Case Filed This Date. See Docket Book for prior entries. Petition for Emergency and Special Relief, filed Upon consideration of the Plaintiff's Petition for Emergency and Special Relief, it is hereby ORDERED as follows: 1. The Order of this Court dated June 5, 1997, is hereby STAYED; 2. Plaintiff/Mother Michele Turkowsky, now known as Michele Gula, is hereby awarded sole legal and physical custody of the parties' minor children Kaiy Kristen Turkowsky (DOB 12/23/92) and Alyssa Kathryn Turkowsky (DOB 1/4/94), pending further Order of this Court. 3. It appearing from the Petition that there is a question as to the propriety of jurisdiction of this Court under 23 Pa.C.S.A 5364, and venue under Pa.R.C.P 1915.2, the parties are instructed to submit a brief or memoranda (together with affidavits or other documentation of factual matters in support of the position each party has taken) selling forth the days of the date fo this Order. Copies of all documents filed with the Prothonotary shall be simultaneously forwarded to the undersigned's chambers. 4. Plaintiff's counsel shall promptly undertake the service of Plaintiff's Petition and of this Order upon the Defendant in accordance with the applicable provisions of Pennsylvania Rules of Civil Procedure, and shall file proof of such service with the Court forthwith. 5. In the event Plaintiff/Mother determines that jurisdiction and/or venue is properly in Cumberland County Court of Common Pleas, she shall arrange for transfer of the instant proceedings to the Cumberland County Court Pleas within thirty (30) days of the date of this Order. This Order shall remain effective until further Order of this Court or further Order entered by the Court of Common Pleas of Cumberland County, Pennsylvania, or any other Court then having proper jurisdiction and venue, if the matter is transferred as hereinabove provided. See ORDER, filed. Copy to atty. 4.22-05 Petition to Transfer Custody Action, filed. No Judge Upon review of Plaintiff's Petition for Transfer of Custody Action, it is hereby Bruce F. Bratton ORDERED that the above captioned custody action be transferred to the Court of Common Pleas of Cumberland County. The prothonotary of the Dauphin County Court of Common Pleas is directed to transfer the record to the prothonotary of the Cumberland County Court of Common Pleas in accordance with Pa.R.C.p. 1915.2(d). See ORDER, filed. Copies dis!. 5.18-05 The above action transferred to the Court of Common Pleas of Cumberland No Judge County. ""NO MORE ENTRIES CASE TRANSFERRED"" TO THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No Judge _2._ I hereby certify that the tOfegoing 16 a true and. .....1' .. .".., filed. -!!f!1.w ~. ~. Prothonotary . . . MICHELE R. TURKOWSKY, Plaintiff ~ ~ Date Submitted: 7/7/97 J>f1~ \)(/ SLM ORDER : IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA v. NO. 509 S, 1997 CHARLES J. TURKOWSKY, Defendant CIVIL ACTION - LAW CUSTODY/VISITATION INSTRUCTIONS x .''''1 " j',)') .J Case settled - See attached Order ,,' ...., en 'I ~ L, ,.. \,;t.\'J~:.J ",,~ ~'\.,,,, Case continued Case not settled No Interim Order See attached Interim Order Assign to Judge c_ c.:: r- Reassign to Judge <:0 .r:::: a '. 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 prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim of relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the grounds for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the prothonotary, Room 101, Dauphin county Courthouse, Front and Market streets, Harrisburg, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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. Lawyer Referral Service Dauphin County Courthouse 213 North Front Street Harrisburg, PA 17101 (717) 232-7536 . COMPLAINT IN DIVORCE AND NOW, comes the Plaintiff, Michele R. Turkowsky, by her attorneys, wix, Wenger & Weidner, and files the within Complaint against the Defendant, averring as follows: Count I - Under section 3301(cl of the Divorce Code 1. Plaintiff is Michele R. Turkowsky, an adult individual who currently resides at 810 Berne Court, Hummelstown, Dauphin County, Pennsylvania 17036. Plaintiff has lived at said address since April, 1996. 2. Defendant is Charles J. Turkowsky, an adult individual who currently resides at 13 Portland street, Mechanicsburg, Cumberland County, Pennsylvania 17055. Defendant has lived at such address since May, 1996. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 16, 1992, in Miami, Dade County, Florida. 5. Plaintiff avers that there are children of the parties under the age of 18, namely: '< Kaly K. Turkowsky DOB 12/23/92 Alyssa K. Turkowsky DOB 1/4/94 6. The marriage is irretrievably broken. 7. The Plaintiff and Defendant are both citizens of the united states of America and are not members of the Armed Forces. 8. There have been no prior actions of divorce or for annulment between the parties in this or any other jurisdiction. 9. Plaintiff has been advised of the availability of counseling and understands that she may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree of Divorce pursuant to section 3301(c) of the Pennsylvania Divorce Code of 1980, as amended (the "Divorce Code"). Count II - Eauitable Distribution 10. Paragraphs 1 through 9 hereof are incorporated herein by reference. 11. During the marriage, Plaintiff and Defendant have acquired various items of marital property, both real and personal, which are subject to equitable distribution under Section 3501 of the Divorce Code. 12. Plaintiff and Defendant have been unable to agree as to an equitable division of said property to the date of the filing of this Complaint, and substantial portions of said property are in the exclusive control of Defendant. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree for Equitable Distribution pursuant to section 3501 of the Divorce Code. Count III - Child Custodv and SUDDort 13. Paragraphs 1 through 12 are incorporated herein by reference. 14. Plaintiff seeks custody of the following children: Kaly K. Turkowsky (age 4) and Alyssa K. Turkowsky (age 3). The children were not born out of wedlock. The children are presently in the custody of Plaintiff, who resides at 810 Berne Court, Hummelstown, Dauphin County, Pennsylvania. The children have lived at that address since April 1996. Prior to that time, the children lived with Plaintiff and Defendant at 67 Southmont Drive, Enola, Cumberland County, Pennsylvania. The mother of the children is Plaintiff. She is married to Defendant. The father of the children is Defendant. 15. The relationship of Plaintiff to the children is that of mother. The Plaintiff currently resides with her two children. 16. The relationship of Defendant to the children is that of father. The Defendant currently resides by himself to the best of Plaintiff's knowledge. 17. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning '. the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning these children 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 children or claims to have custody or visitation rights with respect to the children. The best interest and permanent welfare of the children will be served by granting the relief requested because the children are of young age and have resided continuously with their mother during the present separation and during a prior separation of the parents. Further, the father is currently out of the state on business. 18. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. 19. Plaintiff has been advised of the requirement to attend the Seminar for Separating Parents and of the program description set forth in Local Rule 1930. 20. Defendant will be provided along with the Complaint, a copy of the Order requiring attendance at the Seminar for Separating Parents set forth herein and program description set forth in Local Rule 1930. 21. Plaintiff also requests spousal support for herself and child support for the parties two minor children. WHEREFORE, Plaintiff requests the Court to grant joint legal custody of the children to Plaintiff and Defendant and physical custody of the children to the Plaintiff subject only to reasonable visitation by Defendant in the Commonwealth of Pennsylvania as the parties may agree. Respectfully submitted, WIX, WENGER & WEIDNER .'\\ .. J -K DATE: ;:jG.....".;;L~ /997 By: David R. Getz, Esquire 1.D. #34838 508 North Second Street P.O. Box 845 Harrisburg, PA 17108-0845 (717) 234-4182 . . VERIFICATION I, Michele R. Turkowsky, Plaintiff in the foregoing Complaint, have read the foregoing Complaint and hereby affirm and verify that it is true and correct to the best of my personal knowledge, information and belief. I verify that all of the statements made in the foregoing are true and correct and that false statements made therein may subject me to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. \ DATE:~,o..n ~ 'I; I q q7 MICHELE R. TURKOWSKY, IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA Plaintiff v. . NO. SO 9 S 1.997 . : CHARLES J. TURKOWSKY, CIVIL ACTION - LAW . . Defendant IN DIVORCE AND CUSTODY ORDER OJ' COUBT you, Charles J. Turkowsky, are ORDERED to appear in person in the custodY Mediatio~Off}ce, Fo~r~ Floor, Harrisburg, pennsylvania, on !lJ~ rJ 1~11 at Ii: 36 o'clock a.m./~' for a custody Mediati6n conference. All parties are further ORDERED to attend a seminar entitled "seminar for separating parents" and bring with you to the Mediation conference the certificate of Attendance you will receive at th~/seminar. The Plaintiff is schedule to attend on 1Il"~" ,1Iw> ",,.jn . The Defendant is schedUled tn attend nn ~ <,Ik d/..rl.~/n ~. Any requests for rescheduling must be directed to the provider and will be granted upon cause shown. (see attached instructions and provider brochure with registration form). FAILURE TO APpEAR AT THE SEMINAR OR FAILURE TO REGISTER AND COMPLETE THE PROGRAM WILL BE BROUGHT TO THE ATTENTION OF THE COURT AND MAY RESULT IN A FINDING OF CONTEMPT AND THE IMPOSITION OF SANCTIONS BY THE COURT. If you fail to appear as provided by this order, an Order for custody may be entered against you or the court may issue a warrant for your arrest. 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. Dauphin County Lawyer Referral Service 21.3 North Front street Harrisburg, PA 1.71.01. (71.7) 232-7536 FOR THE COURT: Dated: 'Y/I{ , ~ custodY conference Officer , 1.997 - PROTHON. 27A Commonwealth of Pennsylvania County of Dauphin, ss: MICHELE R. TURKOWSKY In the Court of Common Pleas of Dauphin County, Pennsylvania Plaintiff VS. CHARLES J. TURKOWSKY No. 509 S 19 97 ------------------------- ---- Defendant Decree in Divorce AND NOW~ rn 2r it is ordered and decreed that MICHELE R. TURKOWSKY 1977 Plaintiff, and CHARLES J. TURKOWSKY Defendant, are divorced from the bonds of matrimony. BY THE COURT, 9-?.}!C-~-'-~-- Judge Certified 19____ Prothonotary MICHELE R. TURKOWSKY, IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA plaintiff : v. NO. 509 S 1997 CHARLES J. TURKOWSKY, . CIVIL ACTION - LAW . Defendant IN DIVORCE AND CUSTODY AFFIDAVIT OF SERVICE I, Karen S. carter, secretary in the law firm of Wix, Wenger, & Weidner, P.C., hereby certify that on February 6, 1997, I sent a true and correct copy of the Complaint in Divorce, properly endorsed, to Defendant, Charles J. Turkowsky, by certified Mail, Restricted Delivery, No. P 487 031 413, postage prepaid, return receipt requested, to 6746 Stuart Avenue, suite A, Jacksonville, FL 32254, the Defendant's last known address; and that the Defendant received the Complaint in Divorce on February 10, 1997, pursuant to the return receipt card, which is attached hereto and marked Exhibit A. WIX, WENGER & WEIDNER Attorneys for plaintiff By: Kar n S. Lega Secretary 508 North Second Street P.O. Box 845 Harrisburg, PA 17108-0845 Sworn to and subscribed before me this 14th, day of February, 1996. , ~~?---~ Notary Public -- My commission Expires: (SEAL) NotarialSe,; UsaR. Rowe, Notary Public Hanisburg. Dauphin County My CommiSSion Expires July 12, 1997 -,-....--. Iteme 3, .... and ~.P1lnt your name and add can return thI, to you. ~.thietonntOthefrontofthi " . doeanol . -Writ.'Rotum R_pt Req...~~I"--' artlde_. 'Ii -The Return Receiplwill th~~andthedal8 i delivered. I H';~c.;;;;nJljrKD~ (P'T%~a1J~ . 0 &AL.- ~ JiasonvlI/-4',FL ./ 3IJ.!J.5/u 5. Received By: (Print Name) .. 'iI _ or , EXHIBIT "A" . 1...._10'-" ~..... (for III .xtra lee): i 1. 0 Addr....... Add.... 2.)(.RestrIcted Delivery Consult postmaster lor I... I 48. Ar1lcI. Number 4b. S.rvIce Type ~ o R.glstered )( CertIIecI I o Express Mall 0 InsuNd f o Retum RecsIpt for _se 0 COD II 7. DaI.oI DaHve,\ ~ i 8. Add.......'. Add..... (Only If 'I and lee Is paid) ! m - MICHELE R. TURKOWSKY, IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA Plaintiff v. NO. 509 S 1997 CHARLES J. TURKOWSKY, CIVIL ACTION - LAW Defendant IN DIVORCE AND CUSTODY AFFIDAVIT OF CONSENT 1. A Complaint in Divorce was filed on January 29, 1997. The Complaint was served on February 10, 1997. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or ,",xpenses if I do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. S4904, relating to unsworn falsification to authorities. l/v1! dle~kfu~(k(;\/ Michele R. T~kOWSki~~Intiff DATE: J,f I} ~- J: ~ ~ ~ U1 ?< ... '" 0 me" ex> ~ ~ ~95~rn o ~ "tl -i ;:a .., Z ~:;;j mo..,Or-. ~_ z."J:~" _ IV I Z :!! l/l Z tT1 ::! It !:( () '" !:1 ..,., ~;.. r lTl n (.II r"" ~~ ~~~~e> ~ >~oS;~ ~ ~~~~tT1 ~ ~ 0 o ... Z ~ rn Ul ~ I:' 111 LiJ "~ 7 , \ -"'I '" II:. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. section 4904 Dated: I' ; ;~, , J relating to unsworn <.,---"' ,-...,.... ~ '" !;; n o - ~ :! - ~ '" - ~ '" ~ i: ~ ' - . '" 0; i: '" ~ '" '" . ~ ~ '" >< '" ()> ~ ~ ~ .~() 9 is ~ tTl ~ '" ., z ~Oi~() z ~ Z tT1 I z - '" "' i" ~ Q ~ ~ ~ .. g ~ G:> ~ ~ 0 s; ~ >~~~~ :::; ()> fn tJ g "1 Z o t'T1 ~ i" ()> l Ie Pl , .' ." ~~ .: "-~~ ...;: ~~~ (", 'i' ~:"1 ,~' '-J 'I lnr J ~ r . - . - ~T 'T' mT ., "", . '."""V ';'./" ... AFFIDAVIT OF CONSENT 1. A Complaint in Divorce was filed on January 29, 1997. I was was served with the Complaint on February 10, 1997. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made ln this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. 54904, relating to unsworn falsification to authorities. ", CharTe~ J". -;~~k01ilsky, D~f~- .. ~ _'" r~----- . .. "../ DATE: C:\UP51\DRG\OOCUMENTS\TURKOUSKY.CON 'V"hO'''''''-'--- '0"'-' F'~. .,;r'-' -, '-""".k '-,- - '=..::r'~ ---. '-",.",'" L:......._-' .... '., .:;.......- ..... --~ J: ~ :>- '" .?< '" "' <;; 0 ~ '" III -1 c: " '" ~ 0 Z ~ rn ~ ~ 0 Z n ~ o - " 0 0 () ~ :; m J: '" - ~ Z ." Z rn '" - ." '" '" IZ n V> m '" ~ It ~ m ~ m () ~ ' ~ '" ~ ~ C3> - ~ '" ~ :>- ~ ~ W'" Z 0 ~ ~ :> ~ ~ ~ rn '" :;; '" '" '" ti ~ i3 m m Z III -1 0 rn ~ '" '" , I ", :.,:3 . \ 'I H.' WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(0) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. section 4904 relating to unsworn falsification to authorities. Dated: '. Charle'S J. TUrkawsky ~- . --_.-,.-..-~-- C:\WP51\DRG\DOCUMENTS\TURKOWSKY.WVR ~~ -< l""I'l""~~_~,."".___~.....-.--._.___.__,,____ ..-.-- '-- ~,,"_, '..c._,.... - ..~.. :t ~ > " ?< " '" 0; 0 ~ ... '" Cll m C '0 ~ 0 0 z ~ rn n '^ 0 z ... 0- '0 ~ 0 ." ::! "' 0 Cl - ~ Z :t ~ m _ ." rn ^' N Z ." I n '^ "' ?O ::i It ~ "' ~ ~ ' < "' () - . '" g ~ G:> N ;; ~ ~ It N t! ~ ~ ;; ~ '^ ~ N :::; ... N '" " - . i5 "' ti "' Cll ... Z 0 rn ~ ?O '" pl (, I! l!li PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under section ( x ) 3301 (c) 3301 (d) (1) of the Divorc,e Code. (Check the appropriate section). 2. Date and manner of service of the complaint: ,Januarv 29~ 1997 by certified mail, return receipt requested. Affidavit of Seryice filed on February 14, 1997. 3. (Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by section 3301 (c) of the Divorce Code: by plaintiff July 17, 1997; by defendant June 21, 1997. 4. Related claims pending: Attorney for (X) Plaintiff ( ) Defendant -~'-= <.--~ '--;.;;.>'"" c,.,_..", J: ~ :> '" >< '" iJ1 v; 0 ~ '" III ... c:: ." '" ~ 0 z ~ tTl r;; ~ 0 z () ~ o - ." 0 () ." :; m 0 - ~ Z ." J: ~ tTl '" - '" ~ I Z :!l '" m i" ~ Ii: ~ () m ~ " m () ~ ' ~ (l:l - .. ~ '" ~ ~ 0; Ii: ~ :': ~ 0 ~ ~ 6 :> ~ '" tTl -I ~ ::j iJ1 '" - .. i5 m 0 m 0/ -I Z 0 tTl ~ i" II iJ1 II! , I -I\'~r .-.- ...... cof 5 Tr'.Ill. I" 9/ IlJ.9./' Nt' . ...--.-------.-.- -". pnlC' _____..._. ______.-.._--,,-.--~--__.n Ie 3 HC'(."lvC'tl rl",m I"" "l'o!hOl1ot"ry II.., r"Il:;d"'" I""""'~! V~,~ ...--: . - ~.. -- - e0:~~'.-.' ... ~__'_'--"'l"_--~---"-~- . -.-..-------- . - --,- -_...-~_..-.._- ----------.-----.--------- - -.-----..-... ..-.-"- -.-....-..----. _________________n.____ - .-.....--..-.---. - ------ - - ..._.__.-..---._~.-...- ..-. --- --.------.- ." "1'01"0111 jiJ/'Lz.~wdA b (J~O ~'t (Sir,I1"!\1!''') \ \ Certificate of Compliance :::I~~~~Pll~ Action 1llDivorce o Custody o Court Order o V olunlary o Refeml Date Orde.lJld / / Date of Compliance /) / c90/ q7 Innerworks 4415 North Front Street Harrisurg, P A 17110 717-236-2616 e Signed: TvDe Party o Defendant JiPlainfiff o PetitiooerJDefendant o RespnrvfantJplaintiff o Third Party p atJ' C/'c9:(r7 MICHELE R. TURKOWSKY, Plaintiff IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA v. NO. 509 S, 1997 CHARLES J. TURKOWSKY, Defendant CUSTODY/VISITATION AMENDED ORDER OF COURT AND NOW, upon consideration of the Complaint for Custody, it is hereby directed that the parties and their respective counsel appear before Sandra L. Meilton, Custody Conference Officer, on the 30th day of Mav , 1997, at 1:30 p.m. on the 4th Floor, Dauphin County Court House, Front and Market Streets, Harrisburg, Pennsylvania, 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, at the request of either attorney or party, be present at the Conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT, Date of Order: 4/24/97 By: Custody Conference Officer 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. The Dauphin County Lawyer Referral Service 213 North Front Street Harrisburg, PA 17101 Telephone No. (717) 232-7536 Oate i./,; '-r'il,j bv "::> ~ ~, ))-. .., ~ ..',.} , , I'v k5 ::-" ::::iE -""" ~ , v. CIVIL ACTION - LAW CUSTODY . MICHELE R. TURKOWSKY, plaintiff Date submitted: 6/5/97 SLM Co(31~ +D tW-k., IN THE COURT OF COMMON PLEAS 0 I'd ~7 DAUPHIN COUNTY, PENNSYLVANIA /()/,17 NO. 509 S, 1997 L CHARLES J. TURKOWSKY, Defendant INSTRUCTIONS X Case settled - See attached Order Assign to Judge c !if -;::1 :;co :::::J ,~.> ~ ~ . ~. <J'l " . N ton W -0 ,. ::r- ~ ~ Case continued Case not settled No Interim Order See attached Interim order Reassign to Judge - "" , MICHELE R. TURKOWSKY, plaintiff IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA v. NO. 509 S, 1997 CHARLES J. TURKOWSKY, Defendant CIVIL ACTION - LAW CUSTODY TEMPORARY ORDER OF COURT AND NOW, to wit, this s1A '-----" {1&.4~ day of 1997, the plaintiff, having appeared without counsel, and the defendant having been served, but having failed to appear, for a Custody Conference on May 30, 1997, before the Conference officer, Sandra L. Meilton, Esquire. Mother indicated that she and Father had reached an amicable agreement with regard to custody of their minor children, Kaly K. Turkowsky, born December 23, 1992, and Alyssa K. Turkowsky, born January 4, 1994, and it is hereby ORDERED AND DECREED as follows: 1. The parents shall share legal custody of the children and each parent shall consult with the other concerning all major decisions affecting the children, including but not limited to, health, education and religion. 2. Primary physical custody of the children shall be with Mother, Michele R. Turkowsky. 3. Father, Charles J. Turkowsky, shall have partial physical custody of the children at times mutually agreed upon by the parties. J. e.-" .1,)0 4. Father has failed to attend the Seminar for Separating Parents. Father has ninety (90) days from the date of this Order to attend the Pennsylvania Seminar or to attend a comparable seminar in Florida. Father shall provide proof of attendance at the Seminar to the office of the Conference Officer within ninety (90) days. 5. This Order is a Temporary Order and shall be mailed to Defendant at his last known address providing him with thirty (30) days in which to notify the Custody Conference Officer, in writing, of his desire to attend a Custody Conference and providing proof of attendance at the Seminar (or comparable program). Such Conference shall be rescheduled promptly upon Defendant's request. In the event that Defendant does not contact the Custody Conference Officer within the prescribed thirty (30) days, this Order shall become a final Order. if tI.,., <::) ~ -w :"''10 ~ ;:;:J '- ".~;. c.r, "'- .. '-_u ....,-.. ti "v <n tu ~ -...:: <..C :~;'! -. ._,<: ,.."'1>.........,,'" IV ----~,.....---.-.. ...... .?...,~..... ~ - MICHELE R. TURKOWSKY, Plaintiff IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. 509 S, 1997 v. CIVIL ACTION - LAW CUSTODY CHARLES J. TURKOWSKY, Defendant TEMPORAEY ORDER OF COURT '----'" (\//./.4 e.- 'AND NOW, to wit, this sf! day of 1997, the plaintiff, having appeared without counsel, and the defendant having been served, but having failed to appear, for a custody Conference on May 30, 1997, before the Conference officer, Sandra L. Meilton, ESquire. Mother indicated that she and Father had reached an amicable agreement with regard to custody of their minor children, Kaly K. Turkowsky, born December 23, 1992, and Alyssa K. Turkowsky, born January 4, 1994, and it is hereby ORDERED AND DECREED as follows: 1. The parents shall share legal custody of the children and each parent shall consult with the other concerning all major decisions affecting the children, including but not limited to, health, education and religion. 2. primary physical custody of the children shall be with Mother, Michele R. Turkowsky. 3. Father, Charles J. Turkowsky, shall have partial physical custody of the children at times mutually agreed upon by the parties. EXHIBIT I A - -- J. - 4. Father has failed to attend the Seminar for Separating Parents. Father has ninety (90) days from the date of this Order to attend the Pennsylvania Seminar or to attend a comparable seminar in Florida. Father shall provide proof of attendance at the Seminar to the office of the Conference Officer within ninety (90) days. 5. This Order is a Temporary Order and shall be mailed to Defendant at his last known address providing him with thirty (30) days in which to notify the Custody Conference Officer, in writing, of his desire to attend a Custody Conference and providing proof of attendance at the Seminar (or comparable program). Such Conference shall be rescheduled promptly upon Defendant's request. In the event that Defendant does not contact the Custody Conference Officer within the prescribed thirty (30) days, this Order shall become a final Order. - Stephen E. Farina prothonotary OFFICE OF ,,~01'RONOTARY Front & Market Streets Harrisburg, P A 17101 County of Dauphin May 20, 2005 2 ::~ ""1Je"! mp! Z:~L t05~,: 2\,- ~(',-" Zc' IN RE: Michele R Turkowsky nka Michele Gula Vs Charles J TurkowskY~ :;! Dauphin County Dkt No 509 S 1997 f) LL..- Cumberland County DktNo. ~r- ~qt'J1 l'l~'" 1'EJZb1 Curtis R Long, Prothonotary Cumberland County Court House Hanover & High Streets Carlisle, Pa 17013 Dear Sir/ Madam: By Order of May 174, 2005 by Hon Bruce R Bratton, Judge The above matter has been transferred to the Court of Common Please of Cumberland County. 1 am, accordingly, sending originals of all the papers herewith. I Will appreciate the return of the attached receipt address to the Attention: of Ms. Lisandra Garcia. Very truly yours, (jlIt.tj/t.em 00 W;'yhla. Stephen E. Farina Prothonotary (7\ 7) 780.6520 ,.., ~ = = <J' '- ~ c:: r,,:II Z r- I -om CT'l ~:36 ~-ri -0 ---:n :3: q(') r- Om ~ c:> .CO N -< . .' . . MICHELE R. TURKOWSKY, Plaintiff ~ ~ ,'v1Date Submitted: 7/7/97 'f<- 1..---l \ PlI SLM ORDER : IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA v. NO. 509 S, 1997 CHARLES J. TURKOWSKY, Defendant CIVIL ACTION - LAW CUSTODY/VISITATION INSTRUCTIONS x Case settled - See attached Order . .&:\\JE,C J..,- j lr\t.\...~ ",~t\1 "', ;;,,j .., Case continued Case not settled No Interim Order See attached Interim Order Assign to Judge '-- c.;:: .- Reassign to Judge <:'0 o ... . Dr-i) . MICHELE R. TURKOWSKY, plaintiff IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA v. NO. 509 S, 1997 CHARLES J. TURKOWSKY, Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, to wit, this //(A day of C$if 1997, the plaintiff, having appeared without counsel, and the defendant having been served, but having failed to appear, for a Custody Conference on May 30, 1997, before the Conference Officer, Sandra L. Meilton, Esquire. Mother indicated that she andJ'ather had reached an amicable agreement with regard to custody ot~iheir minor children, Kaly K. Turkowsky, born December 23, 1992, and Alyssa K. Turkowsky, born January 4, 1994, and it is hereby ORDERED AND DECREED as follows: 1. The parents shall share legal custody of the children and each parent shall consult with the other concerning all major decisions affecting the children, including but not limited to, health, education and religion. 2. Primary physical custody of the children shall be with Mother, Michele R. Turkowsky. 3. Father, Charles J. Turkowsky, shall have partial physical custody of the children at times mutually agreed upon by the parties. 'V ~ , 4. Father has failed to attend the Seminar for Separating Parents. Father has ninety (90) days from the date of this Order to attend the Pennsylvania Seminar or to attend a comparable seminar in Florida. Father shall provide proof of attendance at the Seminar to the office of the Conference Officer within ninety (90) days. J. 1"1mf! , & 'J\ c f", .,1 '-- = r- C'_") C) ._-~\- --- - MICHELE R. TURKOWSKY, Plaintiff IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA v. NO. 509 S 1997 CHARLES J. TURKOWSKY, Defendant : IN DIVORCE : MOTION FOR ENTRY OF DIVORCE AND, NOW comes the Plaintiff, Michele R. Turkowsky, by and through her attorney, David R. Getz, Esquire of Wix, Wenger & thereof sets forth the following: Weidner, and moves this Court to enter the divorce, and a support 1997, which Complaint was served on February 10, 1997. 1. Plaintiff filed a Complaint in Divorce on January 29, Affidavits of Consent and Waivers of Notice. 2. Both Plaintiff and Defendant have signed the requisite Praecipe to Enter Divorce on or about July 17, 1997. Plaintiff filed a 3. Because the parties have minor children, this Court ordered the parties to attend the Seminar For Separating Parents. Plaintiff attended the Seminar on February 20, 1997 and the Plaintiff's original certificate of attendance was delivered to the Conciliator, Sandra L. Meilton, Esquire. 1997 (Defendant, who lives in Florida, did not attend). The 4. Custody was determined at a Custody Conference on May 30, parties reached an amicable agreement and a Temporary Order of -- - . Court was entered on June 5, 1997. A Final Order of Custody was Order. entered on July 11, 1997, as Defendant did not appeal the Temporary Defendant was ordered to attend the Pennsylvania Seminar or a In the Custody Order, entered by Judge Kleinfelter, comparable seminar in Florida within ninety (90) days from the date of the Order and to provide proof thereof to the Conference Officer. 5. Plaintiff desires to finalize the divorce as custody and financial difficulties as a result of the continuation of the support have been decided and Plaintiff continues to experience marriage. Defendant's car, which is owned in joint names, is being her credit by having the divorce finalized. repossessed and Plaintiff hopes that she can minimize the damage to WHEREFORE, Plaintiff respectfully requests that this Court enter an Order granting the divorce as requested. Respectfully submitted, WIX, WENGER & WEIDNER By: ,!JroZ-..:_ ) David R. Get , EsqUt e LD. # 34838 508 North Second Street Post Office Box 845 Harrisburg, PA 17108-0845 (717) 234-4182 DATE: July 24, 1997 drg.a:\turkowsky.motion July 24, 1997 -- - MICHELE R. TURKOWSKY, Plaintiff IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA v. NO. 509 S 1997 CHARLES J. TURKOWSKY, Defendant IN DIVORCE AND CUSTODY CERTIFICATE OF SERVICE I hereby certify that the foregoing Motion For Entry of Divorce was sent by certified/return receipt requested and first class, postage prepaid mail this day to the following: Charles J. Turkowsky 6746 Stuart Avenue, suite A Jacksonville, FL 32254 WIX, WENGER & WEIDNER By: David R. Getz, Esqu 1. D. #34838 508 North Second Street Post Office Box 845 Harrisburg, PA 17108-0845 (717) 234-4182 DATE: July 24, 1997 drg.a:\turkowsky.cert July 24, 1997 MICHELE R. TURKOWSKY, Plaintiff v. : IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNSYLVANIA CHARLES J. TURKOWSKY, Defendant : NO. 509 S 1997 INDIRECT CONTEMPT - FAILURE TO ATTEND SEMINAR FOR SEPARATING PARENTS RULE TO SHOW CAUSE AND NOW, thi~ day of July, 1997, a Rule is issued in the above- captioned matter to show cause why Defendant, Charles J. Turkowsky, should not be held in contempt of court for failure to comply with the Order to attend the Seminar for Separating Parents. Rule returnable SeDtember 19,1997 at 1:30 P.M., COURTROOM NO. 1, Fifth Floor, Dauphin County Courthouse, Front and Market Streets, Harrisburg, Pennsylvania. Upon finding a violation of any provision of a court order, the court, either pnrsuant to a petition for civil contempt or on its own accord, may hold a party in civil contempt and constrain that party in accordance with law. A sentence for civil contempt may include imprisonment of up to six (6) months and/or a fine of up to $1,000.00 dollars.. If you desire legal counsel, please contact: Dauphin County Lawyer Referral Services 213 N. Front Street Harrisburg, PA 17101 (717) 232-7536 OR Office of the Public Defender Veterans' Memorial Building 112 Market Street Harrisburg, PA 17101 (717) 255-2746 The Plaintiff, Michele R. Turkowsky, need not attend. Distribution: BY THE COURT: }o i, T""",~'-~ ( v Petitioner, Michele R. Turkowsky c/o David R. Getz, Esquire 508 North Second Street P.O. Box 845 Harrisburg, PA 17108-0845 Respondent, Charles J. Turkowsky 6746 Stuart Avenue, Suite A Jacksonville, FL 32254 Innerworks, 4415 N. Front St., Harrisburg, PA 17110 '=' ~ " )> ;:0 c::: ..... 0 0 ;x: " C=> --{ '~q fT', -0:,':: ::r: .. , a ,-r'''- -, . "", CX> .'Y'! ":iO"".Or "'0-," +:' C) ..~ ._\ '-,",." ""'" ~. -,...~ "'" ::z:: ~.,. -' ;;0 -< c..5 -< -.. '. '''''!'i~ /#1 crp ~e:; 1v~O 4{~u5V MICHELE R. TURKOWSKY, now known as MICHELE GULA, : IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNSYL VANIA Plaintiff vs. : NO. 509 S 1997 CHARLES J. TURKOWSKY, -:".... .~~? ."J f'v ::? Defendant CNIL ACTION - LAW ORDER ;s> f'v W ~ AND NOW, this.dZ.. day of April, 2005, upon consideration of the Plaintiff's Petition for Emergency and Special Relief, it is hereby ORDERED as follows: 1. The Order of this Court dated June 5, 1997, is hereby STAYED; 2. PlaintiIDMother Michele Turkowsky, now known as Michele Gu1a, is hereby awarded sole legal and physical custody of the parties' minor children Kaly Kristen Turkowsky (DOB 12/23/92) and Alyssa Kathryn Turkowsky (DOB 1/4/94), pending further Order of this Court. 3. It appearing from the Petition that there is a question as to the propriety of jUrisdiction of this Court under 23 Pa.C.S.A. *5364, and venue under Pa.R.C.p. *1915.2, the Parties are instructed to submit a brief or memoranda (together with affidavits or other documentation offactual matters in suppon of the position each party has taken) setting forth the position of each party with respect to jurisdiction and venue of this Court within twenty (20) days of the date of this Order. Copies of all documents filed with the Prothonotary shall be simultaneously forwarded to the undersigned's chambers. ,.-0_, r~ _.~!('-,-. . 4. Plaintiff's counsel shall promptly undertake the service of Plaintiff's Petition and of this Order upon the Defendant in accordance with the applicable provisions of Pennsylvania Rules of Civil Procedure, and shall file proof of such service with the Court forthwith. 5. In the event Plaintiff/Mother determines that jurisdiction and/or venue is properly in Cumberland County Court of Common Pleas, she shall arrange for transfer of the instant proceedings to the Cumberland County Court of Common Pleas within thirty (30) days of the date of this Order. This Order shall remain effective until further Order of this Court or further Order entered by the Court of Common Pleas of Cumberland County, Pennsylvania, or any other Court then having proper jurisdiction and venue, if the matter is transferred as hereinabove provided. Bruce F. Bratton, Judge 2 --- - 6 MICHELE R. TURKOWSKY, now known as, MICHELE GULA, Plaintiff : IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNSYLVANIA v. : NO. 509 S 1997 CHARLES J. TURKOWSKY, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER AND NOW, this _ day of , 2005, upon consideration of Plaintiffs Petition for Emergency and Special Relief, it is hereby ordered that Plaintiff/Mother, Michele Turkowsky, now Michele Gula, shall havc sole legal and physical custody ofthe children, Kaly Turkowsky and Alyssa Turkowsky. BY THE COURT: . J. MEYERS, DESFOR. SALTZGIVER & BOYLE 410 NORTH SECOND STREET. P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 236-2817 MICHELE R. TURKOWSKY, now known as, MICHELE GULA, PlaintifJ : IN THE COURT OF COMMON PLEAS. : DAUPHIN COUNTY, PENNSYLVANIA v. : NO. 509 S 1997 ~--) ;:;;::. ~:::~ (_'-1 ~ .I :--",. CHARLES 1. TURKOWSKY, Defendant : CIVIL ACTION. LA W : IN CUSTODY r --I:., .. J r'~ ) v r::> PETITION FOR EMERGENCY AND SPECIAL RELIEF' co AND NOW, comes the Plaintiff, Michele Gula, by and through her attorneys, Meyers, Desfor, Saltzgiver & Boyle and files the following Petition for Emergency and Special Relief and in support thereof avers as follows: I. Petitioner is Michele R. Turkowsky, now Michele R. Gula, an adult individual residing at 34 Emlyn Lane Mechanicsburg, Pennsylvania. (hereinafter referred to as "Mother") 2. Respondent is Charles J. Turkowsky, an adult individual residing at 210 Herman Avenue, Lemoyne, Pennsylvania. (hereinafter referred to as "Father") 3. The parties are the parents of two minor children namely Kaly Kristen Turkowsky, date of birth December 23, 1992 and Alyssa Kathryn Turkowsky, date of birth January 4, 1994. 4. The parties were previously married and have been separated since April of 1996 and divorced since July 28, 1997. 5. The most recent custody order is the Temporary Order of COllrt of June 5, 1997. (See Exhibit "A"). 6. Mother has always had primary physical cllstody of the children. 7. Since the parties separation and divorce in 1997, Father has resided in a number of MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 236-2817 states. He has had a number ofresidences and a number of jobs. Father's custody and contact with the children has been sporadic in light of his frequent relocations. 8. Mother has always facilitated a relationship between Father and the children when she believed it was appropriate and in the children's best interests. 9. Mother has discovered a number of things about Father's behavior and lifestyle which lead her to believe that it is harmful for the children to have any contact with Father. 10. Father has a history of drug and alcohol abuse. Mother believes that Father continues to abuse alcohol and use drugs. Mother separated frolll Father largely due to his alcoholism and drug abuse. II. Father has been living in Florida and recently returned to the Central Pennsylvania area. 12. Father was arrested on February 28,2004 Illr possession of cocaine in Broward County, Florida. This action is pending and there is a warrant out for Father's arrest. Father has recently moved to Lemoyne, Pennsylvania trom Broward County, Florida. Mother believes that Father has moved to Pennsylvania to evade prosecution for cocaine possessIOn. 13. Mother has been advised by the children that Father drinks copious amounts of beer while they are in his custody. 14. Father has had a number of DUI' s in a number of difTerent states including Florida and Maryland. 15. Mother has been advised by the children that Father has been drinking and driving with the children in the car. Additionally, the children have advised Mother that Father has o ., MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 236.2817 driven them in an automobile without a valid drivcrs license. 16. There have been occasions when therc was marijuana and cocaine in Father's home when the children were in Father's custody, and Father has used drugs while the children were in his care. 17. Mother has been advised by the children that F athcr has taken money out of their purses when they have visited him and used the money to buy cigarettes and beer. Additionally, Mother has been advised by the children that Father has sold their possessions which they believed to have becn missing. 18. Since Father has returned to Central Pennsylvania he has requested partial physical custody of the children. Mother has retllsed to permit this due to his alcoholism and drug abuse. 19. Mother is afraid that Father may take the childrcn and try to pick them up from school or from one of their activities. Mother does not believc it is safe for the children to be in Father's care as he drinks alcohol all day, cvery day. Mother greatly fears for the safety of the children. Mother requests that she bc granted sole legal and physical custody so Father cannot pick the children up tram school or any other activity. Mother fears that Father may try to kidnap the children and cause thcm harm. 20. For all of these reasons, Petitioner, Michele Gula, mother of the children herein, hereby requests that this Honorable Court issue an Order ordering that Father have no contact with the children. Mother is very conccrned for the safety and welfare ofthe children. Mother is concerned that Father may in some way attempt to take the children and keep 4 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET. P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 236-2817 I Respect/Lilly submitted, the children from her. WHEREFORE, in light of all of the above, Mother requests that an Order be issued which grants Mother sole legal and physical custody and prohibits Father from having any contact with the children. Laurie Pi. altz r, Attorney 1.0. 6138- Meyers. Des1or, Saltzgiver & Boyle 410 North Second Street P.O. Box 1062 Harrisburg, I' A 17 I 08 (717)236.9428 Attorney t(Jr Petitioner 5 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET. P.o. BOX 1062 . HARRISBURG. PA 17108 (717) 236-9428 . FAX (717) 236-2817 VERIFICATION I, M;("'Ihplp (;111.:=1 , verify that the statements made in this Pe~t~inn for F.m~rgpn~y ~nn Sp~~;~l Relief are true and correct to the bes of my knowledge, information and belief. I understand that fals statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: 4/;;>1/0<; Plaintiff Defendant II II 'I I !i II Ii ,! ij I, MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 236-2817 MICHELE R. TURKOWSKY, now known as, MICHELE GULA, Plaintiff : IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNSYL VANIA' v. : NO. 509 S 1997 CHARLES J. TURKOWSKY, Defendant : CIVIL ACTION. LA W : IN CUSTODY CERTIFICATE OF SERVICE I hereby certify on this 21st day of April, 2005, that a copy of the foregoing Petition for Emergency and Special Reliefwas mailed, first.class, postage pre'paid to: Charles J. Turkowsky 210 Herman A venue Lcmoyne, P A J 7043 Laurie . c altz vel', Esquire Attorney for Petitioner MEYERS, DESFOR, SAlTZGIVEA & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 236-2817 - (..j\,. MICHELE R. TURKOWSKY, Plaintiff IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA v. CHARLES J. TURKOWSKY, Defendant NO. 509 S, 1997 CIVIL ACTION - LAW CUSTODY TEMPORARY ORDER OF COURT 'AND NOW, to wit, this .sJ% day of "---'" ~4C!L 1997, the plaintiff, having appeared without counsel, and the defendant having been served, but having failed to appear, for a Custody Conference on May 30, 1997, before the Conference Officer, Sandra L. Meilton, Esquire. Mother indicated that she and Father had reached an amicable agreement with regard to custody of their minor children, Kaly K. Turkowsky, born December 23, 1992, and Alyssa K. Turkowsky, born January 4, 1994, and it is hereby ORDERED AND DECREED as follows: 1. The parents shall share legal Custody of the children and each parent shall consult with the other concerning all major decisions affecting the children, including but not limited to, health, education and religion. 2. Primary physical custody of the children shall be with Mother, Michele R. Turkowsky. 3. Father, Charles J. Turkowsky, shall have partial physical custody of the children at times mutually agreed upon by the parties. EXHIBIT I A - - - 4. Father has failed to attend the Seminar for Separating Parents. Father has ninety (90) days from the date of this Order to attend the Pennsylvania Seminar or to attend a comparable seminar in Florida. Father shall provide proof of attendance at the Seminar to the office of the Conference Officer within ninety (90) days. 5. This Order is a Temporary Order and shall be mailed to Defendant at his last known address providing him with thirty (30) days in which to notify the Custody Conference Officer, in writing, of his desire to attend a Custody Conference and providing proof of attendance at the Seminar (or comparable program). Such Conference shall be rescheduled promptly upon Defendant's request. In the event that Defendant does not contact the Custody Conference Officer within the prescribed thirty (30) days, this Order shall become a final Order. J. -