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HomeMy WebLinkAbout06-1168 MATTHEW N. GUIDO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 06- A I& k CIVIL TERM DONNA S. GUIDO, : CIVIL Defendant : IN DIN YOU HAVE BEEN SUED IN COURT. If y4 forth in the following pages, you must take action. Yot case may proceed without you and a decree of divorce the Court. A judgment may also be entered against you these papers by the Plaintiff. You may lose money or f including custody or visitation of your children. IN - LAW AND CUSTODY u wish to defend against the claims set are warned that, if you fail to do so, the 2)r annulment be entered against you by For any other claim or relief requested in roperty or other rights important to you, When the ground for divorce is indignities or i etrievable breakdown of the marriage, you may request marriage counseling. A list of marriag counselors is available in the Office of the Prothonotary, Cumberland County Courthouse One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR i LAWYER'S FEES OR EXPENSES BEFORE GRANTED, YOU MAY LOSE THE RIGHT TO YOU SHOULD TAKE THIS PAPER TO DO NOT HAVE A LAWYER OR CANNOT AF THE OFFICE SET FORTH BELOW TO FIND HELP. BONY, DIVISION OF PROPERTY, DIVORCE OR ANNULMENT IS IM ANY OF THEM. R LAWYER AT ONCE. IF YOU ) ONE, GO TO OR TELEPHONE WHERE YOU CAN GET LEGAL LAWYER REFERRAL ERVICE of the Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone (800)-990..9108 MATTHEW N. GUIDO, : IN THE Plaintiff : CUMBI VS. : NO. 06- DONNA S. GUIDO, : CIVIL Defendant : IN DI` USTED HA SIDO DEMANDADO EN LA C expuestas en ]as paginas seguientes, debe tomar accic defiende, el caso pude proceder sin usted y decreto de en su contra por las Corte. una decision puede tambi otra queja o compensacion eclamados por el dem, propiedades u otros derechos importantes para usted. OF COMMON PLEAS OF COUNTY, PENNSYLVANIA CIVIL TERM ,N - LAW AND CUSTODY RTE. Si desea defenderse de las quejas con prontitud. se le avisa que si no se vorcio o anulamiento puede ser emitido i ser emitida en su contra por caulquier iante. Usted puede perder dinero, o Cuando la base para el divorcio es indi dades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Court of Common Pleas, One Courthouse Square, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALI NTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GAST S ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA MTIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE LLOS. USTED DEBE LEVAR ESTE PAPEL A ABOGADO DE INMEDIATO. SO NO TIENE O NO PUEDE PAGAR UN ABOGAD , VAYA O LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DOND PUEDE OBTENER ASISTENCIA LEGAL. Lawyer Referral Servi a of the Cumberland County Bar, ssociat 32 South Bedford S reet Carlisle, PA 170 3 Telefono (800) 9"-1 1108 MATTHEW N. GUIDO, : IN THE Plaintiff : CUMBE VS. : NO. 06- DONNA S. GUIDO, : CIVIL Defendant : IN DIVI COMPLAINT UNDER C OF COMMON PLEAS OF ) COUNTY, PENNSYLVANIA CIVIL TERM iN - LAW AND CUSTODY 3301(C) AND NOW, comes Plaintiff, Matthew N. Guid , by and through his counsel, Linda A. Clotfelter, Esquire, and files this Complaint in Divorce, espectfully stating in support thereof the following: 1. Plaintiff is Matthew N. Guido, an adult individual who resides at 72 West Main Street, Mechanicsburg, Cumberland County, Pennsyly is 17055. 2. Defendant is Donna S. Guido, an adult individual who resides at 207 S. Stone Avenue, Shiremanstown, Cumberland County, Pennsyl is 17011. 3. Both parties have been bona fide residen 7sof the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the fi 4. Plaintiff and Defendant were married c County, Pennsylvania. 5. The parties have been separate and apart Domestic Relations Code since November 27, 2005. 6. There have been no prior actions of divor 7. Plaintiff avers that the marriage is irretrie g of this Divorce Complaint. November 27, 2005, in Cumberland within the meaning of the Pennsylvania or for annulment between the parties. broken. 8. Plaintiff has been advised of the have the right to request that the court require the does not desire counseling. WHEREFORE, Plaintiff respectfully requests and grant such other relief as this court deems just and LAW Dated: 07/00 Li da A. C A omey II 21 East ? Mechanics] (717) 796-] (717) 796-] Attorney fc of counseling and that Plaintiff may to participate in counseling. Plaintiff this Court enter a Decree of Divorce submitted, OF LINDA A. CLOTFELTER otfelter, Esquire No. 72963 'rindle Road, Suite 100 lurg, PA 17050 930 Telephone 933 Facsimile r Plaintiff I MATTHEW N. GUIDO, : IN THE Plaintiff : CUMBE VS. : NO. 06-, DONNA S. GUIDO, : CIVIL Defendant IN DIVI I, MATTHEW N. GUIDO, verify that the COMPLAINT are true and correct to the best of m} understand that false statements herein are made subje relating to unworn falsification to authorities. Date: 4 2 7 'Z? OF COMMON PLEAS OF COUNTY, PENNSYLVANIA CIVIL TERM ON - LAW AND CUSTODY atements in the foregoing DIVORCE knowledge, information and belief. I to the penalties of 18 Pa. C.S. § 4904, W N. GUIDO i l 4 Al r o MATTHEW N. GUIDO, : IN THE Plaintiff : CUMBE VS. : NO. 06-. S. GUIDO, : CIVIL Defendant : IN DIV, YOU HAVE BEEN SUED IN COURT. If y forth in the following pages, you must take action. Yoi case may proceed without you and a decree of divorce the Court. A judgment may also be entered against you these papers by the Plaintiff. You may lose money or 1 including custody or visitation of your children. OF COMMON PLEAS OF COUNTY, PENNSYLVANIA (eg CIVIL TERM )N - LAW AND CUSTODY u wish to defend against the claims set are warned that, if you fail to do so, the )r annulment be entered against you by 'or any other claim or relief requested in ?operty or other rights important to you, When the ground for divorce is indignities or i retrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthous , One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TOYOUR 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 O T WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL ERVICE of the Cumberland County B r Association 32 South Bedford treet Carlisle, PA 17(13 Telephone (800)-99 -9108 MATTHEW N. GUIDO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 06- CIVIL TERM DONNA S. GUIDO, Defendant PARA : CIVIL :IN DIV, USTED HA SIDO DEMANDADO EN LA C expuestas en las paginas seguientes, debe tomar accic defiende, el caso pude proceder sin usted y decreto de en su contra por las Corte. una decision puede tomb otra queja o compensacion eclamados por el dem: propiedades u otros derechos importantes para usted. N-LAW AND CUSTODY RTE. Si desea defenderse de las quejas con prontitud. se le avisa que si no se vorcio o anulamiento puede ser emitido ser emitida en su contra por caulquier lante. Usted puede perder dinero, o Cuando la base para el divorcio es indigo dades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County, One Courthouse Square, Carlisle, PA 17013. SI USTED NO RECLAMA PENSION ALI ENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GAST S ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA MTIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LEVAR ESTE PAPEL A U ABOGADO DE INMEDIATO. SO NO TIENE O NO PUEDE PAGAR UN ABOGAD , VAYA O LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DOND PUEDE OBTENER ASISTENCIA LEGAL. LAWYER REFERRAL: of the Cumberland County R 32 South Bedford S Carlisle, PA 170 Telefono (800)-990- ',RVICE Association 08 MATTHEW N. GUIDO, : IN THE Plaintiff : CUMBF VS. : NO. 06-, DONNA S. GUIDO, : CIVIL) Defendant IN DIVt AND NOW, comes Plaintiff, Matthew N. by and through his counsel, Linda A. Clotfelter, who OF COMMON PLEAS OF COUNTY, PENNSYLVANIA CIVIL TERM ,N-LAW AND CUSTODY (hereinafter referred to as "Plaintiff'), this Complaint for Child Custody, and in support thereof states the following: 1. Plaintiff is Matthew N. Guido, resides at 72 West Main Street, Mechanicsburg, 2. Defendant is Donna S. Guido, resides at 207 S. Stone Avenue, Shiremanstown, 3. The parties are the parents of one (1) "Plaintiff") an adult individual who County, Pennsylvania, 17050. "Defendanf'), an adult individual who County, Pennsylvania 17011. child, namely Samaya Lee Guido, (hereinafter the "Child"), born July 14, 2005, age seven ?7) months. The Child was not born out of wedlock. 4. During the child's life she has resided as WITH WHOM Plaintiff, Defendant, and Maternal Grandparents 207 S. Stone Avenue Shiremanstown, P 17011 FROM / TO Birth to 1 112 7/200 5 Defendant and Maternal 207 S. Stone Avenue 11127)2005 to Current Grandparents Shiremanstown, P 17011 5. The mother of the Child is Deft Avenue, Shiremanstown, Cumberland County, separated. 6. The father of the Child is Plaintiff, who Mechanicsburg, Cumberland County, Pennsylvania, 17 7. Plaintiff is the father of the Child and PL 8. Defendant is the mother of the Child Child's maternal grandparents. 9. Plaintiff has not participated in any othe any other state. 10. There are no other proceedings pending who currently resides at 207 S. Stone oylvania 17011. She is married, but ntly resides at 72 West Main Street, He is married but separated. f currently resides alone. Plaintiff currently resides with the litigation concerning the child in this or custody of the child in this or any other state. 11. Plaintiff knows of no person not a party custody of the child or who claims to have custody, respect to the child. 12. The best interests of the Child will be ser% and physical custody of the Child because the parties, m caring for the Child have been unable to agree upon a sc have time with each parent to establish a strong relations] to these proceedings who has physical artial custody or visitation rights with d if the parties are granted shared legal o are equally available and capable of edule and it is important that the Child p and parent/child bond. WHEREFORE, Plaintiff, Matthew N. Guido, an order, awarding the parties shared legal and Guido; and an Order granting such other relief as this LAW FIRM OF LINDA A. CLOTFELTER submitted, Dated: h h 7 0 to requests that this Court enter custody of the child, Samaya Lee deems just and proper. in a A. Clotfelter, Esquire tt rney ID No. 72963 I 5 2 East Trindte Road, Suite 100 e hanicsburg, PA 17050 (71 ) 796-1930 telephone (71 ) 796-1933 facsimile Att rnev for Plaintiff MATTHEW N. GUIDO, : IN THE Plaintiff : CUMBI VS. : NO. 06-. S. GUIDO, : CIVIL i Defendant : IN DIV( I, MATTHEW N. GUIDO, verify that the FOR CHILD CUSTODY are true and correct to the belief. I understand that false statements herein are 4904, relating to unsworn falsification to authorities. Date: OF COMMON PLEAS OF COUNTY, PENNSYLVANIA CIVIL TERM iN - LAW AND CUSTODY in the foregoing COMPLAINT of my knowledge, information and subject to the penalties of 18 Pa. C.S. § V N. GUIDO, Plaintiff " r + ? ?. !`1 ,_? ..,_ .? C:. MATTHEW N. GUIDO IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 06-1168 CIVIL ACTION LAW DONNA S. GUIDO DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, March 08, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Mom Street, Mechanicsburg, PA 17055 on Tuesday, April 04, 2006 at 10:00 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. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any, and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By:_ /s/ Dawn S. Sunday.s? Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ' i' w 7L?•? .F MATTHEW N. GUIDO, Plaintiff VS. DONNA S. GUIDO, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-1168 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action. You are warned that, if you fail to do so, the case may proceed without you and a decree of divorce or annulment be entered against you by the Court. A judgment may also be entered against you for any other claim or 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 ground for 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A 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 of the Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone (800)-990-9108 MATTHEW N. GUIDO, Plaintiff VS. DONNA S. GUIDO, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-1168 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY AVISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas seguientes, debe tomar action con promitud. se le avisa que si no se defiende, el caso pude proceder sin usted y decreto de divorcio o anulamiento puede set emitido en su contra por las Corte. una decision puede tambien set emitida en so contra por caulquier otra queja o compensation eclamados por el demandante. Usted puede perder dinero, o propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Court of Common Pleas, One Courthouse Square, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMTIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SO NO TIENE O NO PUEDE PAGAR UN ABOGADO, VAYA O LI.AME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Lawyer Referral Service of the Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telefono (800) 990-9108 MATTHEW N. GUIDO, Plaintiff VS. DONNA S. GUIDO, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-1168 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AND CUSTODY AMENDED COMPLAINT UNDER SECTION 3301(C) OR 3301(D) OF THE DOMESTIC RELATIONS CODE AND NOW, comes Plaintiff, Matthew N. Guido, by and through his counsel, Linda A. Clotfelter, Esquire, and files this Amended Complaint in Divorce, respectfully stating in support thereof the following: 1. Plaintiff is Matthew N. Guido, an adult individual who resides at 72 West Main Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Donna S. Guido, an adult individual who resides at 207 S. Stone Avenue, Shiremanstown, Cumberland County, Pennsylvania 17011. 3. Both parties have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Divorce Complaint. 4. Plaintiff and Defendant were married on November 27, 2004, in Cumberland County, Pennsylvania. 5. The parties have been separate and apart within the meaning of the Pennsylvania Domestic Relations Code since October 27, 2005. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Plaintiff avers that the marriage is irretrievably broken. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the court require the parties to participate in counseling. Plaintiff does not desire counseling. WHEREFORE, Plaintiff respectfully requests that this Court enter a Decree of Divorce and grant such other relief as this court deems just and proper. Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER Dated: • 4 0 (Y Li da A. Clotfelter, Esquire At rney ID No. 72963 5 1 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 (717) 796-1930 Telephone (717) 796-1933 Facsimile Attorney for Plaintiff MATTHEW N. GUIDO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 06-1168 CIVIL TERM DONNA S. GUIDO, : CIVIL ACTION - LAW Defendant : IN DIVORCE AND CUSTODY VERIFICATION I, MATTHEW N. GUIDO, verify that the statements in the foregoing AMENDED COMPLAINT UNDER SECTION 3301(C) OR 3301(D) OF THE DOMESTIC RELATIONS CODE are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date:, 11,1f, G'7 ATTHEW N. GUIDO c-' - I. 1 MATTHEW N. GUIDO IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 06-1168 CIVIL ACTION LAW DONNA S. GUIDO Defendant IN CUSTODY ORDER AND NOW, this 4th day of April, 2006 , the conciliator, being advised by plaintiff's counsel that the parties have reconciled, hereby relinquishes jurisdiction. The custody conciliation conference scheduled for today, is cancelled. FOR THE COURT, Dawn S. Sunday, Esquire Custody Conciliator RFC`rMI TEIL) APR 0 8 2006 i ? .? ? - u ?;'??J i:? : _ .. 1.?. _?. b MATTHEW N. GUIDO, Plaintiff V. DONNA S. GUIDO, Defendant AC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-1168 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE AND CUSTODY CEPTANCE OF SERVICE I, Joanne Harrison Clough, Attorney for the Defendant, DONNA S. GUIDO, accept service of the Complaint for Divorce, Amended Complaint for Divorce, Complaint for Child Custody, and Order of Court Scheduling Conciliation Conference docketed to the within term and number, on this the ? day of 2006, and certify that I am authorized to do so. e?I4amson Clou Esquire 24 N. 32nd Street Camp Hill, PA 17011 717.737.5890 telephone 717.737.5892 facsimile Attorney for Defendant Donna S. Guido r MATTHEW N. GUIDO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 06-1168 CIVIL TERM DONNA S. GUIDO, : CIVIL ACTION - LAW Defendant : IN DIVORCE AND CUSTODY CERTIFICATE OF SERVICE AND NOW, this J at' day of 2006, the undersigned hereby certifies that a true and correct copy of the foregoing ACCEPTANCE OF SERVICE was served upon the opposing party by way of United States first class mail, postage prepaid, addressed as follows: Joanne Harrison Clough, Esquire 24 N. 32nd Street Camp Hill, PA 17011 Attorney for Defendant Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER L da A. Clotfelter, Esquire A orney ID No. 72963 5921 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 (717) 796-1930 telephone (717) 796-1933 facsimile Attorney for Plaintiff L.:`„? ?:? ? t.t_, C_" rM"7 --- ??:_ =, , C"'7 .' ?:) i.__ --- t ? .- ?. _j ?. C?1 _.. e_c? <°?s w` MATTHEW N. GUIDO, Plaintiff/Movant VS. DONNA S. GUIDO, Defendant/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-1168 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY MOTION TO SCHEDULE A CONCILIATION CONFERENCE AND NOW, comes Movant, Matthew N. Guido, by and through his counsel, Linda A. Clotfelter, Esquire, who files this Motion to Schedule Conciliation Conference, respectfully stating as follows: 1. Movant is Plaintiff in the above captioned matter, Matthew N. Guido and Respondent is Donna S. Guido, Defendant in the above captioned matter. 2. Movant initiated a divorce and custody proceeding to the above-referenced docket number on March 1, 2006. 3. A conciliation conference was initially scheduled to take place on April 4, 2006, however, upon agreement of the parties the conference did not take place. 4. Movant wishes to pursue custody and requests that a conciliation conference be scheduled with Dawn S. Sunday, Esquire, Conciliator. WHEREFORE, comes Movent, Matthew N. Guido, who respectfully requests that this court schedule a conciliation conference with Dawn S. Sunday, Esquire. Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER y: JAI /11? "14* 10(41 nda A. Clotfelter, Esqui ttorney ID No. 72963 5021 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 (717) 796-1930 telephone (717) 796-1933 facsimile MATTHEW N. GUIDO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 06-1168 CIVIL TERM DONNA S. GUIDO, : CIVIL ACTION - LAW Defendant : IN DIVORCE AND CUSTODY CERTIFICATE OF SERVICE AND NOW, this day of October, 2006, the undersigned hereby certifies that a true and correct copy of the foregoing Motion to Schedule Conciliation Conference served upon the opposing party by way of United States first class mail, postage prepaid, addressed as follows: Joanne Harrison Clough, Esquire 24 N. 32°d Street Camp Hill, PA 17011 y: Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER L' da A. Clotfelter, Esquire torney ID No. 72963 5021 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 (717) 796-1930 telephone (717) 796-1933 facsimile fJ j uj V h lY I-J CM G.` CZ) V ....54. 4Y ?L? MATTHEW N. GUIDO IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 06-1168 CIVIL ACTION LAW DONNA S. GUIDO IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Monday, November 06, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, December 05, 2006 at 0:00 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in ispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a t mporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse ord rs, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ Dawn S. Sunda Es q. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Am( 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 arran en must be made at least 72 hours prior to any hearing or business before the court. You must attend the ch conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO 1` HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE Sl 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 I Hd L" '4ON 9001 1o- 4 • // W e- -I / l'1 '??t i'I `:` Ct aE'i ?Vl 2 _i, 1. 1?D ?? DEC 0 8 200Y MATTHEW N. GUIDO Plaintiff vs. DONNA S. GUIDO Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 06-1168 CIVIL ACTION LAW : IN CUSTODY ORDER OF COURT 2? AND NOW, this ' ? day of , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Matthew M. Guido, and the Mother, Donna S. Guido, shall have shared legal custody of Smaya Lee Guido, born July 14, 2005. 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 her health, education and religion. Each parent shall be entitled to equal access to all records and information concerning the Child, including, but not limited to, all medical and school records and information. 2. The Mother shall have primary physical custody of the Child. 3. The Father shall have partial physical custody of the Child on all weekends from Friday at 5:00 p.m. through Sunday at 5:00 p.m. with the exception of the first full weekend of each month, during which the Mother shall have custody of the Child. 4. The parties shall share having custody of the Child on holidays as follows: A. Thanksgiving: The Thanksgiving holiday period of custody shall run from Thanksgiving Day at 9:00 a.m. through the Friday following Thanksgiving at 5:00 p.m. In even- numbered years, the Father shall have custody of the Child for Thanksgiving and in odd-numbered years, the Mother shall have custody of the Child for Thanksgiving. B. Christmas: The Christmas holiday shall be divided into Segment A which shall run from 9:00 a.m. until 9:00 p.m. on Christmas Eve and Segment B which shall run from Christmas Eve at 9:00 p.m. through Christmas Day at 9:00 p.m. In even-numbered years, the Father shall have custody of the Child during Segment A and the Mother during Segment B. In odd-numbered years, the Mother shall have custody of the Child during Segment A and the Father shall have custody during Segment B. C. Easter: The Easter holiday period of custody shall run from the Friday before Easter at 5:00 p.m. through Easter Sunday at 5:00 p.m. The Father shall have custody of the Child for Easter in odd-numbered years and the Mother shall have custody in even-numbered years. D. Independence Day: The parties shall alternate having custody of the Child from July 4 at 9:00 a.m. through July 5at 5:00 p.m., with the Mother having custody in odd-numbered years and the Father having custody in even-numbered years. E. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 5. Each party shall be entitled to have custody of the Child for one week (seven consecutive days) during the summer each year upon providing at least 30 days advance notice to the other party. The party providing notice first shall be entitled to preference on his or her selection of vacation dates. Neither party shall schedule vacation custody under this provision over the other parent's regular weekend period of custody without that parent's consent. 6. Unless otherwise agreed between the parties, all exchanges of custody under this Order shall take place at a police station selected by agreement between the parties. 7. 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. Edward E. Guido J. cc: a A. Clotfelter, Esquire - Counsel for Father , Xoanne Harrison Clough, Esquire - Counsel for Mother A o l '' €1 9COZ r MATTHEW N. GUIDO Plaintiff VS. DONNA S. GUIDO Defendant Prior Judge: Edward E. Guido IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 06-1168 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Smaya Lee Guido July 14, 2005 Mother 2. A custody conciliation conference was held on December 5, 2006, with the following individuals in attendance: the Father, Matthew M. Guido, with his counsel, Linda A. Clotfelter, Esquire, and the Mother, Donna S. Guido, with her counsel, Joanne Harrison Clough, Esquire. 3. The parties agreed to entry of an order in the form attached. Date Dawn S. Sunday, EsquireOr Custody Conciliator MATTHEW N. GUIDO, Plaintiff VS. DONNA S. GUIDO, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-1168 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY PRIOR JUDGE: EDWARD E. GUIDO, J. CONCURRENCE: DENIED. SEE PARAGRAPH 4. EMERGENCY PETITION FOR SPECIAL RELIEF IN CUSTODY AND NOW, comes Petitioner, Matthew N. Guido, (hereinafter referred to as "Plaintiff"), by and through his counsel, Linda A. Clotfelter, Esquire, who files this Emergency Petition for Special Relief and Custody respectfully stating as follows: 1. Petitioner is Matthew N. Guido, (hereinafter "Petitioner") an adult individual who resides at 23 Peebles Road, Newburg, Cumberland County, Pennsylvania, 17240. 2. Respondent is Donna S. Guido, (hereinafter "Respondent"), an adult individual who resides at 502 E. Elmwood Avenue, Mechanicsburg, Cumberland County, Pennsylvania. 3. Because a custody transfer is scheduled for tomorrow, April 13, 2007, Petitioner seeks an expedited Emergency Order stating that custody exchanges occur at the Carlisle State Police Barracks, absent mutual agreement otherwise. 4.. Counsel for Petitioner sought concurrence of opposing counsel by telephone and opposing counsel, Joanne Harrison Clough, Esquire indicated that she does not concur. 5. Counsel for Respondent refused to agree to Petitioner's request that the Carlisle State Police Barracks be used for the exchanges and demanded the Mechanicsburg Police Station, be used absent an Order of Court. A true and correct copy of counsel's correspondence of this date is attached hereto as Exhibit "A" and is incorporated herein. 6. An Order of Court dated March 26, 2007, in civil action number 06-2966, a Protection From Abuse proceeding involving these parties, requires Edna Guido ("Grandmother") to facilitate custody issues. A true and correct copy of the Order of Court is attached hereto as Exhibit "B" and is incorporated herein. 7. Grandmother has been facilitating custody transfers, as ordered. 8. During the custody transfer on Friday, April 6, 2007, Grandmother was terrified when Respondent made hostile, loud, and threatening comments to her at the Mechanicsburg Police Station. 9. At the time of the custody transfer, there were no police officers present and Grandmother was unable to enter the building to seek refuge or assistance because it was locked. 10. Grandmother requested that the Sunday custody transfer (April 8`h) take place at the Carlisle State Police Barracks and Respondent agreed. 11. During the Sunday transfer, Respondent again loudly verbally assaulted Grandmother while inside the building. 12. Respondent's conduct was so outrageous that Trooper Adam Thomas intervened and directed her to leave the building. 13. Grandmother was able to remain within the building in the presence of a state trooper until Respondent left the premises. 14. The state police authorities permit individuals to await custody transfers inside the building where a state trooper is always present. 15. Counsel for Respondent has indicated in her letter dated April 11, 2007, that if "your client is unhappy with the Mechanicsburg Police Department location, then we would need to select a new police station located an equal distance between the parties' residences". 16. The Carlisle State Police Barracks is approximately equidistant from the two premises. Respondent must travel 14.3 miles and Grandmother must travel 19.6 miles. A true and correct copy of a Mapquest search relative to the Carlisle State Police Barracks at 1538 Commerce Avenue, Carlisle, Pennsylvania, is attached hereto as Exhibit "C" and is incorporated herein. 17. The Mechanicsburg Police Department at 36 West Allen Street, Mechanicsburg, Pennsylvania, is approximately 1.1 miles from Respondent's residence and approximately 31.95 miles from Grandmother's residence. A true and correct copy of the Mapquest search for same is attached hereto as Exhibit "D" and is incorporated herein. 18. Grandmother truly fears for her safety during custody exchanges at the Mechanicsburg Police Department. A true and correct copy of an Affidavit executed by Grandmother is attached hereto as Exhibit "E" and is incorporated herein. 19. Petitioner, through counsel, now seeks to have this court enter an Emergency Order mandating that all exchanges of custody under this order take place at the Carlisle State Police Barracks, absent mutual agreement of the parties indicating otherwise. WHEREFORE, Petitioner, Matthew N. Guido, by and through his counsel, respectfully requests that this Court enter an Order, requiring that all custody exchanges take place at the Carlisle State Police Barracks unless otherwise mutually agreed by the parties until further Order of Court. Respectfully submitted, Dated: A LAW FIRM OF LINDA A. CLOTFELTER Y: v `t%vv'--' `? v a A. Clotfelter, Esquire Lf A ne y ID No. 72963 A1021 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 (717) 796-1930 telephone (717) 796-1933 facsimile Attorney for Petitioner MATTHEW N. GUIDO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 06-1168 CIVIL TERM DONNA S. GUIDO, : CIVIL ACTION - LAW Defendant : IN DIVORCE AND CUSTODY VERIFICATION I, Linda A. Clotfelter, counsel for Petitioner/Plaintiff, verify that the statements in the foregoing Emergency Petition for Special Relief in Custody are true and correct to the best of my knowledge, information and belief, based upon conversations with interested parties. As counsel, I am making this verification for Petitioner/Plaintiff be cause his verification cannot be obtained within the appropriate time. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date: u l inda A. Clotfelter, Esquire ttorney ID No. 72963 5021 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 (717) 796-1930 telephone (717) 796-1933 facsimile Attorney for Plaintiff ATTORNEY AND COUNSELOR AT LAW JOANNE HARRISON CLOUGH, PC 24 N. 32nd STREET CAMP HILL, PENNSYLVANIA 17011 717-737-5890 TELEFAX 717-737-5892 Joanne Harrison Clough Esquire Email: ihcocAyerizon.net April 12, 2007 Via Facsimile 796-1933 Linda Clotfelter, Esquire 5021 E. Trindle Road Mechanicsburg, PA 17050 RE: Guido v Guido Custody exchanges to take place in Mechanicsburg Dear Linda: The December 13, 2006 Court Order clearly provides that "all exchanges of custody under this Order shall take place at a police station selected by agreement between the parties." The parties agreed to the Mechanicsburg Police Station. My client will not agree to your client's request that this be changed to the Carlisle State Police Barricks. Until such time as the parties both agree to a new location for custody exchanges, or the Court Orders a specific location, the custody exchanges shall take place at the Mechanicsburg Police Station. That is where the custody exchanges shall take place this weekend. JHC/pc Cc: Donna Guido EXHIBIT "A" DONNA SMAYA GUIDO, Plaintiff V. MATTHEW NICHOLAS GUIDO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06--2966 CIVIL TERM CIVIL ACTION - LAW PROTECTION FROM ABUSE ORDER OF COURT AND NOW, this 26th day of March, 2007, the Defendant is released from the parole detainer on the specific condition that he have no contact with the victim of this Order other than through counsel or through his own mother to arrange for visitation or deal with other issues regarding the children. If the Defendant violates these conditions, he shall be taken into custody immediately and brought before this Court on a parole revocation. Edward E. Guida, J. Matthew P. Smith, Esquire Office of the District Attorney A D. Weitzman, Esquire o r the Def endant Probation Sheriff . Victim - Witness srs EXHIBIT "B" ¦ MAP?4ESr Do you know YOUR Score? Your Your Credit Score Interest Rate Find out instantly! Directions Distance 502 E Elmwood Ave, Mechanicsburg, PA 17055-4214 1: Start out going WEST on E ELMWOOD AVE toward ALISON AVE. 0.5 miles 2: Turn RIGHT onto S MARKET ST/PA-114. 0.4 miles 3: Turn LEFT onto W MAIN ST/PA-114/PA-641. Continue to follow PA-641. 8.3 miles 4: Turn LEFT onto FAIRFIELD ST. 0.4 miles 5: Turn LEFT onto YORK RD/PA-74. <0.1 miles 6: Merge onto 1-81 S toward CHAMBERSBURG. 3.8 miles 7: Take the PA-465 exit- EXIT 44- toward PLAINFIELD. 0.1 miles 8: Turn LEFT onto PA-465/ALLEN RD. 0.2 miles 9: Turn LEFT onto COMMERCE AVE. 0.2 miles 10: End At 1538 Commerce Ave, Carlisle, PA 17015-9161 Estimated Time: 25 minutes Distance: 14.30 miles 1538 Commerce Ave, Carlisle, PA 17015-9161 1: Start out going WEST on COMMERCE AVE toward ALLEN RD/PA-465. 0.2 miles 2: Turn RIGHT onto ALLEN RD/PA-465. 0.2 miles 3: Merge onto 1-81 S via the ramp on the LEFT toward CHAMBERSBURG. 6.9 miles 4: Take the PA-233 exit- EXIT 37- toward NEWVILLE. 0.1 miles 5: Turn RIGHT onto PA-233. 4.0 miles 6: Turn LEFT onto W MAIN ST/PA-641. Continue to follow PA-641. 7.8 miles 7: Turn RIGHT onto PEEBLES RD. 0.1 miles 8: End At 23 Peebles Rd, Newburg, PA 17240-9369 Estimated Time: 28 minutes Distance: 19.60 miles 23 Peebles Rd, Newburg, PA 17240-9369 Total Estimated Time: 52 minutes Distance: 33.90 miles EXHIBIT "C L4+-- / " -- I m .. ti„-f nnm /m ?r?c_r?ira?tinnc/ an 1/7nn7 Mr?PnuES? one fun thing Directions Distance 502 E Elmwood Ave, Mechanicsburg, PA 17055-4214 ........................ 1: Start out going WEST on E ELMWOOD AVE toward ALISON AVE. 0.5 miles 2: Turn RIGHT onto S MARKET ST/PA-114. Continue to follow S MARKET 0.5 miles ST. 3: Turn LEFT onto W ALLEN ST. <0.1 miles 4: End At 36 W Allen St, Mechanicsburg, PA 17055-6257 .......... ....... Estimated Time: 4 minutes Distance: 1.19 miles B 36 W Allen St, Mechanicsburg, PA 17055-6257 1: Start out going WEST on W ALLEN ST toward N FREDERICK ST. 0.1 miles 2: Turn LEFT onto N YORK ST/PA-114. <0.1 miles 3: Turn RIGHT onto W MAIN ST/PA-641. Continue to follow PA-641. 8.0 miles 4: Turn LEFT onto FAIRFIELD ST. 0.4 miles 5: Turn LEFT onto YORK RD/PA-74. <0.1 miles 6: Merge onto 1-81 S toward CHAMBERSBURG. 10.9 miles 7: Take the PA-233 exit- EXIT 37- toward NEWVILLE. 0.1 miles 8: Turn RIGHT onto PA-233. 4.0 miles 9: Turn LEFT onto W MAIN ST/PA-641. Continue to follow PA-641. 7.8 miles 10: Turn RIGHT onto PEEBLES RD. 0.1 miles 11: End At 23 Peebles Rd, Newburg, PA 17240-9369 Estimated Time: 47 minutes Distance: 31.95 miles 23 Peebles Rd, Newburg, PA 17240-9369 Total Estimated Time: 51 minutes Distance: 33.14 miles EXHIBIT "D" ---f- n/?lYl ?lTt•]Y\C`_111YP!"`tl lln C`? d/1 )/?nn7 MATTHEW N. GUIDO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 06-1168 CIVIL TERM DONNA S. GUIDO, : CIVIL ACTION - LAW Defendant : IN DIVORCE AND CUSTODY AFFIDAVIT I, Edna Guido, after being duly sworn deposed hereby swear that the following statements are true: 1. I am required to facilitate the custody transfers of my granddaughter, Smaya Lee Guido, born July 14, 2005, by Order of Court dated March 26, 2007, filed in the Protection From Abuse proceeding docketed at 06-2966 civil term. 2. I live in Newburg, Cumberland County, a distance of approximately forty-three (43) miles from Defendant, Donna S. Guido's, (hereinafter "Mather"} home. 3. On Friday April 6, 2007, I facilitated a custody transfer at the Mechanicsburg Police Station. During the transfer Mother hatefully yelled at me, calling me "stupid," "old lady," "vicious," "mean," and several other insults in a vociferous manner. 4. Due to the time of the custody transfer, there were no police officers present at the Mechanicsburg Police Station; it was locked; and I was unable to enter the building. I felt very unsafe at the Mechanicsburg Police Station during the altercation with Mother. 5. Mother agreed to conduct the Sunday, April 8, 2007, custody transfer at the Carlisle State Police Barracks on Commerce Avenue in Carlisle, Pennsylvania. 6. During the custody exchange on Sunday, April 8, 2007, Mother again yelled vicious insults at me and became so loud that Trooper Adam Thomas ordered Mother to leave the building and instructed me to remain inside until she left. 7. I am truly fearful of the next transfer on Friday, April 13, 2007, if I must do it at the Mechanicsburg Police Station. I feel much safer facilitating the custody transfers at the Carlisle State Police Barracks because it is always open, I am able to wait inside the building; and there is always a state trooper present. I, verify that the statements above are true and correct to the best of my knowledge, information and belief and I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unworn falsification to authorities. Date:441 / -1 1 Z2 ti zdv? " -- EDNA GUIDO EXHIBIT "E" MATTHEW N. GUIDO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 06-1168 CIVIL TERM DONNA S. GUIDO, : CIVIL ACTION - LAW Defendant : IN DIVORCE AND CUSTODY CERTIFICATE OF SERVICE AND NOW, this 1 J1 to day of April, 2007, the undersigned hereby certifies that a true and correct copy of the foregoing Emergency Petition for Special Relief and Custody was served upon the opposing party by way of United States first class mail, postage prepaid, addressed as follows: Joanne Harrison Clough, Esquire 24 N. 32"a Street Camp Hill, PA 17011 Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER inda A. Clotfelter, Esquire tto 5rney ID No. 72963 021 East t Trindle Road, Suite 100 Mechanicsburg, PA 17050 (717) 796-1930 telephone (717) 796-1933 facsimile Attorney for Petitioner APR 1 2 2007 MATTHEW N. GUIDO, Plaintiff VS. DONNA S. GUIDO, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-1168 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY ORDER AND NOW, this 13 day of April, 2007, upon consideration of Plaintiffs Emergency Petition for Special Relief in Custody, it is hereby ORDERED that the custody exchanges shall take place at the State Police Barracks in Carlisle, Pennsylvania, unless otherwise mutually agreed by the parties until further Order of Court. IJ wme-4j? f? By the Court, Distribution: Linda A. Clotfelter, Esquire, for Plaintiff Joanne Harrison Clough, Esquire, for Defendnat 41 A ,17, :Z l-g -6 E i ?1111 IJ"I, L'U 2z MATTHEW N. GUIDO, Plaintiff, V. DONNA S. GUIDO, Defendant. TO THE PROTHONOTARY: : IN THE COURT OF COMMON PLEAS : M4BERUU??D COUN'T'Y, PnINSYLVANIA ? NO: 2006-1168 CIVIL ACTION -LAW IN DIVORCE & CUSTODY PRAECIPE Please withdraw the appearance of the S. Guido, in the above-captioned action. Date: - 2_ as counsel for the Defendant, Donna Joanil:YClough, EN- ul I.D. #?c I ?7 II 2+N. 4'm cf a 3 !J Camp Hill, PA 17011 (717) 737-5890 lL,'Vs t Please enter the appearance of the undersigned counsel for the Defendant, Donna S. Guido, in the above-captioned action. Wagner, Esquire I.D. #23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Defendant Date: \ ter, pNC) r5 1 C -i 9n rn c -- -Toy "4 j R . C r MATTHEW N. GUIDO, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff/Respondent, V. DONNA S. GUIDO, Defendant/Petitioner NO: 2006-1168 CIVIL ACTION -LAW IN CUSTODY PETITION FOR CO-PARENTING COUNSELING AND NOW, comes the Petitioner, Donna S. Guido, by and through her attorneys, Mancke, Wagner, Spreha & McQuillan, and files the following Petition For Co-Parenting Counseling: 1. Your Petitioner, Donna S. Guido, is the Defendant in the above-captioned matter. 2. The Respondent, Matthew N. Guido, is the Plaintiff in the above-captioned matter. 3. A Custody Order was entered on the 13' day of December, 2006, a copy of which is attached hereto, incorporated herein by reference, and marked as Exhibit A. 4. Since the inception of the Order, the Petitioner believes and therefore avers that the parties have been unable to reasonably discuss and/or decide issues on behalf of the child. 5. On one telephone communication from the Respondent, the Respondent indicated that he would not f ing participate in any kind of co-parenting counseling. 6. The relationship between Petitioner and Respondent is that of Mother and Father. 7. Petitioner believes and therefore avers that it is in the best interests of the parties for the Court to order co-parenting counseling on behalf of the child. WHEREFORE, Petitioner prays this Court to order co-parenting counseling for the parties on behalf of the child. Respectfully submitted, Mancke, Wa er, Spreha & McQuillan P. Richard Wagner, Esquire I.D. #23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Petitioner Date: 411g -2- CERTIFICATE OF SERVICE I, Debra K. Spinner, secretary in the law firm of Mancke, Wagner, Spreha & McQuillan, do hereby certify that I am this day serving a copy of the foregoing document to the following persons and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing the same in the United States Mail, Harrisburg, Pennsylvania, with first class postage, prepaid, and addressed as follows: Linda A. Clotfelter, Esquire 5021 E. Trindle Road Suite 100 Mechanicsburg, PA 17050 By Debra K. Spinner, ecretary Mancke, Wagner, Spreha & McQuillan 2233 North Front Street Harrisburg, PA 17110 P. Richard Wagner, Esquire Attorney for Petitioner Date:,;?F Ca rv Cr) _t 4 co y MATTHEW N. GUIDO, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 2006-1168 . DONNA S. GUIDO, CIVIL ACTION - LAW Defendant/Petitioner ACTION FOR CUSTODY C-) a RESPONSE TO DEFENDANT'S PETITION G 9 -" FOR CO-PARENT COUNSELLING m.." c F AND NOW, comes Respondent, Matthew N. Guido, (hereinafter "Respon f?'), lad, anc fT? through his counsel, Linda A. Clotfelter, Esquire, who files this Response to Defenda'Ms P tiotV Z a.; -c for Co-Parent Counselling, respectfully stating as follows: 1. through 3. Admitted. 4. Admitted in part and denied in part. It is admitted the parties' communication is lacking, however it is denied that this can be corrected by co-parent counselling. In further answer, Petitioner obtained a Protection from Abuse ("PFA") Order against Respondent and also made allegations that resulted in his incarceration for contempt of the PFA. It is Petitioner who is known for her loud and violent outbursts including several at the Carlisle State Police Barracks during custody transfers with the paternal grandmother which have at times resulted in Petitioner being asked to leave the premises. Due to Petitioner's conduct, Respondent will not have contact with her until the PFA Order expires in June, 2009. Respondent does not want to be forced to violate the PFA Order; he does not trust Petitioner nor does he want to have contact with her; and he truly fears further incarceration. Thus, Petitioner asks this court to strongly consider his concerns when deciding this issue. 5. Denied. Respondent does not recall using offensive language when speaking to p Petitioner about co-parent counselling and it is Petitioner who often uses expletives when confronting Respondent. Again, Respondent does not want to have contact with her due to the PFA Order. 6. Admitted. 7. Denied. See response to paragraph 4, above. WHEREFORE, Respondent, Matthew N. Guido, requests that this Honorable Court deny Petitioner's Petition for Co-Parent Counselling and grant such other relief that this court deems just and proper. Date: 1 D Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER Li da A. Clotfelter, Esquire At orney I.D. No. 72963 1 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 Attorney for Defendant (717) 796-1930 Telephone (717) 796-1933 Facsimile i 1 % r MATTHEW N. GUIDO, PLAINTIFF VS. DONNA S. GUIDO, DEFENDANT : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-1168 CIVIL ACTION -LAW ACTION FOR CUSTODY CERTIFICATE OF SERVICE AND NOW, on this d) lay of July, 2008, the undersigned hereby certifies that a true and correct copy of the foregoing RESPONSE TO DEFENDANT'S PETITION FOR CO- PARENT COUNSELLING was served upon the interested parties by United States First Class Mail, postage prepaid and addressed as follows: P. Richard Wagner, Esquire Mancke, Wagner, Spreha & McQuillan 2233 North Front Street Harrisburg, PA 17110 Respectfully Submitted, LAW FIRM OF LINDA A. CLOTFELTER Sg?1 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 (717) 796-1930 telephone (717) 796-1933 facsimile MATTHEW N. GUIDO, V. Plaintiff/Respondent, DONNA S. GUIDO, Defendant/Petitioner. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO: 2006-1168 : CIVIL ACTION -LAW IN CUSTODY PETITION FOR CO-PARENTING COUNSELING AND NOW, comes the Petitioner, Donna S. Guido, by and through her attorneys, Mancke, Wagner, Spreha & McQuillan, and files the following Petition For Co-Parenting Counseling: 1. Your Petitioner, Donna S. Guido, is the Defendant in the above-captioned matter. 2. The Respondent, Matthew N. Guido, is the Plaintiff in the above-captioned matter. 3. A Custody Order was entered on the 13'f' day of December, 2006, a copy of which is attached hereto, incorporated herein by reference, and marked as Exhibit A. 4. Since the inception of the Order, the Petitioner believes and therefore avers that the parties have been unable to reasonably discuss and/or decide issues on behalf of the child. 5. On one telephone communication from the Respondent, the Respondent indicated that he would not f ing participate in any kind of co-parenting counseling. 6. The relationship between Petitioner and Respondent is that of Mother and Father. 7. Petitioner believes and therefore avers that it is in the best interests of the parties for the Court to order co-parenting counseling on behalf of the child. 8. Judge Edward E. Guido has entered an Order in a Protection From Abuse action in this matter as well as an Order regarding custody in this matter. 9. Petitioner sought concurrence for co-parenting counseling by letter to counsel for the Respondent dated May 12, 2008 to which no response has ever been made. WHEREFORE, Petitioner prays this Court to order co-parenting counseling for the parties on behalf of the child. Respectfully submitted, Mancke, Wagner, Spreha & McQuillan Ylt-Effa-ri-dWagner, Esquire I.D. #23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Petitioner Date:: -2- CERTIFICATE OF SERVICE I, Debra K. Spinner, secretary in the law firm of Mancke, Wagner, Spreha & McQuillan, do hereby certify that I am this day serving a copy of the foregoing document to the following persons and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing the same in the United States Mail, Harrisburg, Pennsylvania, with first class postage, prepaid, and addressed as follows: Linda A. Clotfelter, Esquire 5021 E. Trindle Road Suite 100 Mechanicsburg, PA 17050 By Debra K. Spinner, "Secretary Mancke, Wagner, Spreha & McQuillan 2233 North Front Street Harrisburg, PA 17110 P. Richard Wagner, Esquire Attorney for Defendant/Petitioner Date: i???? y MATTHEW N. GUIDO, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 2006-1168 DONNA S. GUIDO, CIVIL ACTION - LAW Defendant/Peddoner : ACTION FOR CUSTODY ORDER AND NOW, this day of )914614L/ , 2008, upon consideration of Defendant's Petition for Co-Parent Counselling and Plaintiff's response thereto, -0 is herebr wkBERF-iP that BefevWm0s Petition for A t16A /Zr 4 --SiPvzmi1x 4AL 91-10 A. BY THE COURT: ?,1111164 d-00 Go w?^S d", r,.,, ) Edward E. Guido, Judge 91 'C d 61 onv ocoz 1Wit N0H'.iU d aHi JO ?01 °C-03IIA MATTHEW N. GUIDO, Plaintiff/Respondent V. DONNA S. GUIDO, Defendant/Petitioner: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-1168 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this 25th day of September, it appearing to the Court that the almost pathological inability of the parents to cooperate is threatening the emotional well-being of their child, this matter is referred to Cumberland County Children and Youth Services for investigation and provision of services. The parties contact information will be attached to Children and Youth Services' copy of this order. ? Linda A. Clotfelter, Esquire For the Defendant/Petitioner P. Richard Wagner, Esquire For the Plaintiff/Respondent CCC&YS - Chris Roland -- `ot, srs cc t f..vl en !a t LL 10-9146 tz.-Y? +.', f? LN '2 V ZS 0 d R d3S BQDZ l? lit eau -f_? ?' 3RL JO MATTHEW N. GUIDO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 06-1168 CIVIL DONNA S. GUIDO, : CIVIL ACTION - LAW Defendant : IN DIVORCE AND CUSTODY AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on March 9, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees and expenses 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. Section 4904, relating to unsworn falsification to authorities. Date:-/-Q,/-/l Lax29 IMATTHEW . dl J160, Plaintiff C` tom' ' c a ' r, MATTHEW N. GUIDO, Plaintiff VS. DONNA S. GUIDO, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-1168 CIVIL : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER & 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of 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. § 4904 relating to unworn falsification to authorities. 0 Date: a 'WATTHIM-WGUID0, IDO, Plaintiff ?? ?? ?' '+ i.7 Q ?3 ?? "°? ' i t7 -... r-- ;_,? ? ? - ?.k :, _ ?. ? ,TM{ ^?C' - ..n ..Y?. .,?. 0 MATTHEW N. GUIDO, Plaintiff VS. DONNA S. GUIDO, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-1168 CIVIL CIVIL ACTION - LAW IN DIVORCE AND CUSTODY AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on March 9, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees and expenses 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. Section 4904, relating to unsworn falsification to authorities. Date: td -;U '6 9 rv 8 FTi +f -< 0 MATTHEW N. GUIDO, Plaintiff VS. DONNA S. GUIDO, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-1168 CIVIL CIVIL ACTION - LAW IN DIVORCE AND CUSTODY WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER & 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of 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. § 4904 relating to unsworn falsification to authorities. Date: W 121V -0 ONNA S. 11 O, a endant rs) C C d C ? ' . r a 0 MATTHEW N. GUIDO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 06-1168 CIVIL DONNA S. GUIDO, : CIVIL ACTION - LAW Defendant : IN DIVORCE AND CUSTODY PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. The ground for divorce is irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. The Complaint was filed on March 1, 2006 and an Amended Complaint was filed on March 9, 2006. 3. Date and manner of Service of the Complaint and Amended: March 15, 2006, by Acceptance of Service filed on October 13, 2006. 4. The Plaintiffs Affidavit of Consent was executed by the Plaintiff on October 11, 2008, and filed on October 17, 2008. The Defendant's Affidavit of Consent was executed on October 20, 2008, and filed on November 5, 2008. 5. Plaintiff executed a Waiver of Notice of Intention to Request Entry of a Divorce Decree under 3301 (c) of the Divorce Code on October 11, 2008, and said waiver was filed on October 17, 2008. Defendant executed a Waiver of Notice of Intention to Request Entry of a Divorce Decree under 3301 (c) of the Divorce Code on October 20, 2008, and said waiver was filed on November 5, 2008. 6. There are no related claims pending. Respectfully submitted, FIRM OF LINDA A. CLOTFELTER Date: Ib '9 / io r21021 A. Clotfelter, Esquire ey I.D. No. 72963 East Trindle Road, Suite Mechanicsburg, PA 17050 (717) 796-1930 telephone (717) 796-1933 facsimile r-2 I- ?t y? ? IN THE COURT OF COMMON PLEAS OF MATTHEW N. GUIDO : CUMBERLAND COUNTY, PENNSYLVANIA V. DONNA S. GUIDO NO. 06-1168 DIVORCE DECREE 65???3 o?r3.40fjo. AND NOW, oo ` , it is ordered and decreed that MATTHEW N. GUIDO , plaintiff, and DONNA S. GUIDO , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. By the Attest: J. Prothonotary ?o d7- 6a- <?-) °(- P. Richard Wagner, Esquire PA Supreme Court I.D. #23103 Mancke, Wagner, Spreha & McQuillan 2233 North Front Street Harrisburg, PA 17110 Telephone (717) 234-7051 Fax (717) 234-7080 Attorney For Defendant MATTHEW N. GUIDO, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff/Respondent, : NO: 2006-1168 V. DONNA S. GUIDO, Defendant/Petitioner. : CIVIL ACTION - LAW : IN CUSTODY PETITION FOR SPECIAL RELIEF AND NOW, comes the Petitioner, Donna S. Guido, by and through her attorneys, Mancke, Wagner, Spreha & McQuillan, and files the following Petition For Special Relief: 1. Your Petitioner, Donna S. Guido, is the Defendant in the above-captioned custody action. 2. The Respondent, Matthew N. Guido, is the Plaintiff in the above-captioned custody action. 3. The parties are the natural parents of Smaya Lee Guido, born July 14, 2005. 4. The parties have a Custody Order dated December 13, 2006, a copy of which is attached hereto, incorporated herein by reference, made a part hereof, and marked as Exhibit A. 5. Since the inception of that Order, the Petitioner herein has encountered extreme and grave difficulties in implementing the Order, coordinating the pick up and delivery and otherwise has encountered countless numbers of confrontations at the point of time of pick up and delivery of the child. 6. The difficulties between the parents are so severe that pick up and delivery is at a police station. 7. The Petitioner herein filed a Petition with the Court of Common Pleas of Cumberland County seeking co-parenting counseling. 8. The Petition for co-parenting counseling was based upon the difficulty in communicating with the Respondent, and as was indicated in the Petition, the Respondent indicated that he would not f ing participate in any kind of co-parenting counseling. 9. As a result of that Petition, the Court conducted a hearing on September 25, 2008 that resulted in a conference wherein the Court directed the involvement of the Cumberland County Children and Youth Services for investigation and provisions of their services. A copy of said Order is attached hereto, incorporated herein by reference, made a part hereof, and marked as Exhibit B. 10. The Petitioner herein cooperated fully with Children and Youth Services in furtherance of the Order of Court of September 25, 2008. 11. Petitioner has been advised that the Respondent has not cooperated with Children and Youth Services, and moreover, has refused to cooperate with Children and Youth Services, all of which is not in the best interests of the parties' child. -2- 12. Given the course of conduct of the Respondent, in refusing to participate in co- parenting counseling, and as a matter of fact, suggesting that he would not f ing participate, in his refusal to cooperate with Children and Youth Services as per Court Order of September 25, 2008, and the constant difficulties experienced by the Petitioner in trying to implement the existing Court Order, Petitioner believes and therefore avers that it is in the best interests of the child for the Petitioner to receive sole physical and sole legal custody of their daughter. 13. Petitioner believes and therefore avers that it is in the best interests of the child and that any further unsupervised periods of partial custody by Respondent continues to threaten the emotional well-being of the child. 14. Petitioner believes and therefore avers that the Court should grant sole physical custody and sole legal custody of the child unto the Petitioner, subject to periods of supervised visitation in the Respondent, to continue until such time that the Respondent has fully cooperated with Children and Youth Services, and has filly exhibited the necessary parenting skills in order to resume periods of partial custody. 15. Because of the constant failure of and absolute refusal of the Respondent to participate, the Petitioner has incurred legal costs for the preparation and filing of the Petition For Co-Parenting, and this Petition, including attendance at various hearings, in the amount of $1,500.00 for which Petitioner seeks reimbursement from the Respondent. -3- 16. The Honorable Edward E. Guido has heard this matter in the past. WHEREFORE, Petitioner prays this Court to grant the relief as requested. Respectfully Submitted, -; Richard W?gn , Esquire I.D. #23103 2233 N , ront Street Harrisburg, PA 17110 Attorneys For Petitioner Date: ? "e -4- VERIFICATION I verify that the statements made in the foregoing document are true and correct. 1 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: (' _ 2?' i i i i j f j 1. i S'R or COIRM i AMNOW,9"' ? dvy Of' GuxWY CoaWgsdan ' 2005, codeidera Report, it is wdacad dad directed eei folioa+a; ' . 1. 'I'hs Facer, w I?IJ tittidv, ?d t? ri?ait?er, `S. Ciu': sherd =90dYof SwAp Lea GdAa, bm. Tiny 14, 2.003: p iarrt? ll :?6 bi ecwa+dsd joiattyw;th the other gareart,u mntce1 ntarnaa-ac?a sag t Cad' i weit beo?g iirac U1 n„t llrnited tc, as dect?dot?et r' l' het, edi and re oa. Bach peran# t be br #lai i.c equal ado ' e to an is aWs add "nfion e MiK inolud'it?, but VAt bMiUd to, 811 roedicdl and th Whool r" ab and k%sinWan. Z. The Motiur ehslY f ta *W pr?muy au vdy oftha P 3. The Ftgior e i have pardai;ph) Z I ?r l+a 4?lldcut S:OQ P?Bb Y at SO, p.ia. i?ntY wc' oeption oftb $?t fallwa keW of4acs mg duriiz? i?hfch the A till hawa a?ad; of the G'hild. j4. The "Wn mill;ahm Wmick au offt Childoahdklayr a fo"a: A. An 71M u tiaewrog b"y podod of cudody ?hjwil ran ffm Dory at 9.0 a sn. tlu+oaagh tbes Frtda y ktl mbS Thaw jvbX ex Sg o pm. In an m is bared ymmves Ow Fstiua'shall hms "t !4k ; Ofdw M 1br yam t1?e ll+i eba11 baud T in ad"= cuato4y of xha Child for nacki : . i ?. : T9ae trbrledmi ie hnJdayailudt bis dI*W into Sqpimt A which flm 00 am. erAil 9:00; p n?. on t" iar(ma t 8ve a t B; a hictt rnd Baca Christ at 9 00 1 P.M. at 0:00 p,'m. In bow yews, the T her lu ca ndy dwelt S dot A' and the Mo it duties aat 8, ra odd-= bcrcd Modes shall hat custody of fm cbjw w n j SeSmot A amd the Ps&w shall have cudody, C. $l: The B"W hvifd typerW o.f.euetody dWl tea f m tau fday boi of s not e.aL rt,> Ea rr 5uaday 9 Sego P= t6 lOt*At bwe or-p?? . cwcoay 4: hChild J yore dad g*Mootheor sbal l hkve om6dy m ovea m =abmvd years. r t i i , MATTHEW N. GUIDO, IN T'1Ex COUR'T' O? COMMON PLEAS OF Plaintiff' C`UAIDEM ANO COUNTY, PENNSY1f ANIA I vs• NO. W1168 CWL TERM DONNA S. GUIDO, Civl) u ACTION,- LAW, Defendant IN DIVORCE AND CUSTODY AND NOW, this Q day of 2006, tht undersi!3 ?mby certifies that; a true and correct copy of the foregoing AC""EPTANCIa OT` SERVIPE was s4rved upon the opposing party by way of United States first class mEll,'postage dad4esoed as fo11?wS: i I Joanne Iiarrison t ;lough, Esquire ` 24 N.'32° t S$+eet Camp Hill, l'A'17011 'i Attotney for Defendant 17especm t11y submitted, t i S I LAW FU M OF LINDA A. CLOTFELTER L da A. t'lotfetter, l?squim reiey l D]! o. 72961 5 1 East Tibuile B1164 State 100 h4nict bog, PA j 7056, ( +17) 7'96.190 telephone (7;17)'796-1933 faesii file ; i Allonvy for Plaintiff ' i i " f MATTHEW N. GUIDO, Plaintiff/Respondent V. DONNA S. GUIDO, Defendant/Petitioner: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-1168 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this 25th day of September, it appearing to the Court that the almost pathological inability of the parents to cooperate is threatening the emotional well-being of their child, this matter is referred to Cumberland County Children and Youth Services for investigation and provision of services. The parties contact information will be attached to Children and Youth Services' copy of this Order. Edward E. Guido-,j . Linda A. Clotfelter, Esquire For the Defendant/Petitioner Richard Wagner, Esquire For the Plaintiff/Respondent CCC&YS - Chris Roland srs a? FILEU OF THE 2EC-9 Aliti I i pt§ I- U 6 h, se PE #?O. ©o PO ATTY CV,* 5g59 PJ4 aalsg7 JUN 12 2009 P. Richard Wagner, Esquire PA Supreme Court I.D. #23103 Mancke, Wagner, Spreha & McQuillan 2233 North Front Street Harrisburg, PA 17110 Telephone (717) 234-7051 Fax(717)234-7080 Attorney For Defendant MATTHEW N. GUIDO, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff/Respondent, NO: 2006-1168 V. DONNA S. GUIDO, Defendant/Petitioner : CIVIL ACTION - LAW : IN CUSTODY ORDER AND NOW, this day of 2009, upon Petition of Donna S. Guido, a hearing is set for the day of 2009, at U o'clock A m. in Courtroom No. 3 of the Cumberland County Courthouse, Carlisle, Pennsylvania, for purposes of determining whether primary custody of the parties' daughter, Smaya Lee Guido, born July 14, 2005, should not be vested with the Petitioner herein, tom` ?y V (/ su sed visitation in a Respondent. W L fW ---{ uk%ZrA D??'bution: ?P. Richard Wagner, Esq., 2233 North Front St., Harrisburg PA 17110 J. da A. Clotfelter, Esq., 5021 E. Trindle Rd., Suite 100,Mechanicsburg PA 17050 Court Administrator tr l?11 / C `G / 1 1ES /11L1,7 L -S-1 or t Af S ii'd LOZi 116 )- J. f 1L ED f ns ??.+}? OF THE P.7,-.:'. 2009 JU 115 FIM [ : O3 ,,; CUI'vi T ?OM & Ku l UI AKIS Michelle L Sommer, Esquire Attorny LD. No.: 93034 2 lY?est High Street Carlisle, Pennsylvania 97093 (797) 249-0900 MATTHEW N. GUIDO, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA dif . DOCKET NO. 1168 CIVIL TERM DONNA S. GUIDO, CIVIL ACTION -LAW Defendant IN CUSTODY TO THE PROTHONOTARY OF SAID COURT: PRAECIPE TO WITHDRAW APPEARANCE Please withdraw my appearance on behalf of the Plaintiff, Matthew N. Guido, in the above- captioned matter. submitted, DATE / / P / L nda A. Clotfelter, Esquire Ajtomey ID No. 72963 021 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 (717) 796-1930 PRAECIPE OF ENTRY OF APPEARANCE Please enter my appearance on behalf of the Plaintiff, Matthew N. Guido, in the above- captioned matter. Respectfully submitted, DATE - I9R_ 10 61 Awm & KUTULAKis, L.L.P. Michelle L. Somm , Esquire Attorney ID No. 93034 2 West High Street Carlisle, PA 17013 (717) 249-0900 CAFT?-E D,``, ?tE? QTY 2009 JUL 28 A t I un. 4 4 MATTHEW N. GUIDO, Plaintiff V. DONNA S. GUIDO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-1168 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this 31st day of July, 2009, by agreement of the parties, the Petition for Special Relief is held in abeyance until October 7, 2009, at 1:00 p.m. Pending said continued hearing, the prior custody Order shall remain in full force and effect. Pending said hearing, the parties are directed to correspond on a daily basis by e-mail to discuss the well-being of their daughter. The e-mail is to be initiated by the custodial parent and responded to by the non-custodial parent. Copies of e-mails shall be preserved and presented to this Court as an exhibit at the next hearing. This authorization supersedes anything in our prior Protection from Abuse order or terms of probation. Michelle L. Sommer, Esquire Attorney for Plaintiff ? P. Richard Wagner, Esquire Attorney for Defendant srs Cap I' .E •},l3 r/mar, tzeil By the Court, Edward E. Guido, J. OF THIE P`-" 2 0 0 9 Jk L 31 Pvh t, I I N,{ MATTHEW N. GUIDO, Plaintiff V. DONNA S. GUIDO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-1168 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this 31st day of July, 2009, a Rule is issued upon the Plaintiff, Matthew N. Guido, to show cause why he should not be held in contempt for failing to abide by our Order. Said Rule is returnable on October 7, 2009, at 1:00 p.m. By the Court, 1 Edward E. Guido, J. ,/Michelle L. Sommer, Esquire Attorney for Plaintiff ./ P. Richard Wagner, Esquire Attorney for Defendant srs C,TQ,I (, Fill n,F THE' 201x9 JU 31 it 60 1 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 Defendant MATTHEW N. GUIDO, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff/Respondent, : NO: 2006-1168 v. DONNA S. GUIDO, CIVIL ACTION - LAW : IN CUSTODY Defendant/Petitioner. ORDER AND NOW, this/ day of O 6&4-k , 2009, upon request of the Defendant, with concurrence of the Plaintiff through counsel, the hearing of October 7, 2009 at 1:00 p.m. is hereby continued until th? 7 day of PAC? , 2007, at I t'VV o'clock m. in Courtroom No.s'?-of the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. BY COURT: J. /Distribution: ? DeRichard Wagner, Esq., 2233 North Front St., Harrisburg, PA 17110 Michelle L. Sommer, Esq., 36 South Hanover St., Carlisle, PA 17013 Court Administrator w &es ,-yu-,t lL P 101/s/07 'L-? F I L ED OFF t"-'E OCT 15 AN 1 ! : 02 MATTHEW N. GUIDO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-1168 CIVIL TERM DONNA S. GUIDO, CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this 2nd day of February, 2011, our Order of December 13, 2006, is amended to provide as follows: The father is to have no contact with mother whatsoever. Any contact regarding the child, Smaya, shall be through father's mother. Mother and grandmother shall exchange cell phone information immediately. Grandmother or grandmother's designee shall appear at the agreed-upon exchange place to effectuate visitation. In all other respects, our Order of December 13, 2006, shall remain in full force and effect. ? Matthew N. Guido Plaintiff, Pro se ? Abraham Prozesky, Esquire For the Defendant srs By the Court, Edward E. Guido, J. ?Opo M?led ["I arb S? O 6 a 1<iLfD-OFFiCF F THE PROTHONOTARY 2011 MAY 26 AM 11: 12 CI! PENNSYLVANIA TY P. Richard Wagner, Esquire Attorney ID No. 23103 Mancke, Wagner & Spreha 2233 North Front Street Harrisburg, PA 17110 Telephone (717) 234-7051 Fax (717) 234-7080 Attorney for Defendant MATTHEW N. GUIDO, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO: 06-1168 CIVIL TERM DONNA S. GUIDO, : CIVIL ACTION - LAW Defendant. : IN CUSTODY PETITION FOR SPECIAL RELIEF AND NOW, comes the Petitioner, Donna S. Guido, by and through her attorneys, Mancke, Wagner & Spreha, and files the following Petition For Special Relief as follows: 1. Your Petitioner is the Defendant in the above-captioned matter. 2. The Respondent is the Plaintiff in the above-captioned matter. 3. The Court entered an Order on December 13, 2006, a copy of which is attached hereto and marked as Exhibit "A". 4. The Petitioner herein has the opportunity to go to Disney World in Florida from June 13, 2011 to June 22, 2011 with the parties' daughter, Smaya Guido, born July 14, 2005. 5. Petitioner has requested of the Respondent on several occasions the Q?Iw?s10. 00 P4 4110\ opportunity to take the child to Disney World. ck ?. to s%, (0 R 25T7 s 6. Having received no response, Petitioner through counsel sent a letter to Respondent's counsel, a copy of which is attached as Exhibit "B", on April 12'h requesting the opportunity to go to Disney World indicating a willingness to trade a weekend in order to facilitate the trip to Disney World. 7. There has been no response from Respondent, nor Respondent's counsel. 8. Petitioner's counsel has called Respondent's counsel and has received no return phone call concerning the same. 9. Petitioner believes and therefore avers that it is in the best interest of the child to permit the opportunity to go to Disney World as set forth above. 10. Petitioner is willing to trade a weekend in order to not conflict with the Father's scheduled periods of partial custody. 11. Judge Guido has had prior dealings with this case. WHEREFORE, Petitioner prays the Court to grant the relief as requested. submitted, f Ric Wagner, Esquire 23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Dated: May 25, 2011 Attorney for Defendant _2_ 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 unsworn falsification to authorities. J Date: ( 1j )' ?) ( Page 1 of 1 Dre 0 8 MATI' iEW N. GF[JIUO v nm G'omt OF CqWAON FLE PI GCtA+L WLAINi Ij CpVIdTYIP ? CTIVM i vs• : Ot l158 ! ACT6.W r,Aw I DOMA S (uII?o i , Deb', 11 fit : IN !tTOY ' 04 ;IRR OF i 3#4? AM NOW, dwl d'tY of 2005, upda oausddeft, C ody Conduhtton Rgczt it is ?rrdw>rod tlnd .sd psi Willows: tid1. 110 Fa&r, M?mvw x Mido, wad 1126 I at cnoo y ofS mqx Lee Guide6 bossy Jolt' 14, 2.005. St h patiantlt it b '?a bE aat:et?dsd jointly wigt the otter pare:rt, to a.dEp sg n?oa-aaaRet g t owl= Cad's; pwa weU being ino W ut t ?mi6d to, an decisions l r edi and Breton. Suh palraat tail be added i a sus to ell rw ds and fon COW the Child,, induft, butts bmited to, rll I:aedtW old ichool and ' ?2. Tha Modes have prmmery P hY M1?ody'°f the id. 3. The Fwr deal have alp des l muw#y oft to C h ildon all ansefcetada ftm P i s:vQ p.m d=ugh Om by it 5:00 p.m witl tea wmWtiou ofthe fita fb11 wedtvi6d of mob mi durltg *hid tha Ma0w *a hm atmWd; - of dw Gild. 4. Us vutiee d>tuil smote ou A. ttodY of** Child as halm a fol?ra. air Tbju k*vitsg 1toliday ofausiody mart $ozr , Day at 9:110 a.m. tht+ougb the Frldrt j $ at 5:D4 p?m. In e+ n u ibe ed yeses, to pea* sha11 have mmu dyoftbe dud '1lmksgtvk$ wd in od&nm YMIM the MG&W dtlatl hive vustc4y a the Wd far H. admiu.. The Cbrletrni a lirlalyAAff b e di into A which flrou't 91,00 L= and 9:04, p m. on Cbtirlut 13" wd $4,Staeat B v??kiclt ' ? ftm c rw at 9Oa m, ?of the Witinu Dm* at 0:00 p,r?t. In'e?raon-numbered y?aare, the "or &W1 ht ? 3? CbM dutig SWLeat A and the Mohr dwli g Smoot B. In odd-munhased Modw mall have aostody of the Cbiid dar ng Sspnwd A aid the Fa&w shsU have custody ? C. &M Th4 I h*Hd;YPwd af.caetody "I tun ftm tin Nday boi at 5;00 p,m. tbwq* Ewft, 5uadey at s-00 p-nL tl' OWher dtdi have mwWy 4the Child i in odd labetW 3+en'e and't , ytofiter sha' l hiLve custody ht even u=berod yetirs. EXHIBIT JOHN B. MANCKE P. RICHARD WAGNER EDWARD F. SPREHA. JR. LAW OFFICES MANCKE, WAGNER & SPREHA 2233 NORTH FRONT STREET HARRISBURG, PA 17110 April 12, 2011 Michelle L. Sommer, Esquire 36 South Hanover Street Carlisle, PA 17013 Re: Guido v. Guido Dear Michelle: PHONE (717) 234-7051 FAX (717) 234-7080 I have recently met with Donna Guido concerning a vacation to Disney World for the parties' daughter. The last correspondence I have suggested that your office was representing Matthew. Donna has been advised that the father is refusing to trade a weekend to enable the parties' daughter to enjoy a weekend at Disney World. I trust that you will impose upon him and work this arrangement so as to avoid the necessity of going to court. Quite bluntly, if we have to file a Petition with the Court, I am going to ask for counsel fees because the position of the father to deprive the daughter the opportunity to go to Disney World is without foundation. Your attention is appreciated. Sincerely, P. Richard Wagner PRW/dks cc: Mrs. Donna Guido Hess EXHIBIT MATTHEW N. GUIDO, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent: CUMBERLAND COUNTY, PENNSYLVANIA V. DONNA S. GUIDO, CIVIL ACTION - LAW Defendant/Petitioner: NO. 06-1168 CIVIL TERM ORDER OF COURT AND NOW, this 10th day of June, 2011, Michelle L. Sommer, Esquire,, is granted leave to withdraw as Defendant's counsel. P. Richard Wagner, Esquire For the Petitioner Michelle L. Sommer, Esquire For the Respondent :lfh By the Court, 4;;; Edward E. Guido, J. Owes " CZ3 Z w? ?a to ?`? c`?> MATTHEW N. GUIDO, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent: CUMBERLAND COUNTY, PENNSYLVANIA V. DONNA S. GUIDO, CIVIL ACTION - LAW Defendant/Petitioner: NO. 06-1168 CIVIL TERM IN RE: PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 10th day of June, 2011, after hearing, the petition is granted and father's weekend visitation on June 17, 18, and 19 is cancelled. It shall be made up on the first weekend of July 2011. By 4;;Cou Edward E. Guido, J. Ew. ?:S ?Y j `XT C P P. Richard Wagner, Esquire tea- ..-. ? y.? ??y M -. i For the Petitioner ' Matthew N. Guido e,5 C 23 Peebles Road Y -- Newburg, PA 17240 t Ma, :rt :lfh ???