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Home My WebLink About02-1707 NICHOLAS J. GIAMBILIS and AMELIA G. GIAMBILIS, h/w Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 02- Ij67 CIVIL ACTION - LAW KELLY GIAMBILIS - INGRAHAM, and DAVID P. INGRAHAM, Defendants IN CUSTODY PLAINTIFF'S COMPLAINT TO CONFIRM CUSTODY 1. Plaintiffs are Nicholas J. Giambilis and Amelia G. Giambilis, adult individuals currently residing at 7 Graham Road, Newville, Cumberland County, Pennsylvania. 2. Defendant Kelly Giambilis - Ingraham is Plaintiffs' daughter, an adult individual who resides at 107 North East Street, Carlisle, P A 17013. 3. Defendant David P. Ingraham is an adult individual whose current residence is unknown. 4. Plaintiffs seeks custody ofthe child, Amelia Ingraham, who was born on November 24,2000. The child was not born out of wedlock. 5. The child is presently in the custody ofthe Plaintiffs who reside at the above address. 6. During the past five years, the child has resided with the following persons and at the following addresses: Persons Address Dates Defendant and David Ingraham 160 S. Pitt Street, Carlisle Birth to 3/10/01 Plaintiffs and Defendant 7 Graham Road, Newville 3/10/01 to 8/01 Defendant 107 North East Street, Carlisle 8/01 to 11/01 Plaintiffs and Defendant 7 Graham Road, Newville 11/01 to 3/10/02 Plaintiffs 7 Graham Road, Newville 3/10/02 to present 7. The relationship of the Plaintiffs to the child is that of maternal grandparents. They are married. The Plaintiffs currently reside with the following: Name Relationshio Angela Giambilis Amelia Ingraham Granddaughter Granddaughter 8. The mother ofthe child is Defendant Kelly Giambilis-Ingraham. She is residing at 107 North East Street, Carlisle, P A 17013. It is unknown with whom she is residing. She is married and living separately. 9. The father ofthe child is David P. Ingraham. It is unknown where and with whom he is residing. He is married and living separately. 10. The parties have not participated in previous litigation concerning the custody ofthe child in this court or any court. 11. The Plaintiffs have no information of a custody proceeding concerning the child pending in any other court. 12. The best interest and permanent welfare of the child will be served by granting custody to Plaintiffs because: they will best be able to provide a stable, nurturing and loving environment for their granddaughter. WHEREFORE, Plaintiffs request your Honorable Court to set a time and place for a hearing at which Plaintiffs request the Court to grant them the Custody Order. Pending said hearing, Plaintiffs request temporary custody. MARTSON DEARDORFF WILLIAMS & OTTO By~~F Edward L. Schorpp, squire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs Date: April 4, 2002 VERIFICATION I verity that the statements contained herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. g4904, relating to unsworn falsification to authorities. ~ LJ4 ~ t!~, lcholas J. ~bdls ~ ,g ~. , ) (I. ~-<J-- Amelia G. Giambilis Dated: ~ S, 260 Z ~ ~~ D ::r~ - - ~ a- - ~ ,S) -C- ~ - C> C> 8' elL (') c s: "'0 l'P Q)'~ zr-:- cn4 "< -<.. kC ~8 ::P~ ~ ~ -L. ~ V f' ~ o '-' o N ):>> -0 :;.0 I CO ~ .-1 ;1=-,"':::J "r -:rID "J9 ()6 ::::.:j-Tt 5~ ""~ S ~ -< :r>- -"'" -- "P. U1 (,.) F:\FILES\DA TAFILE\Gendoc.cur\to4 183.pet.l!tde Created: 01/03/01 11:49:45 AM Rcvisqi: 04/08/0202:57:46 PM 10418.3 NICHOLAS J. GIAMBILIS and AMELIA G. GIAMBILIS, h/w PlaintiffslPetitioners IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 02- 1707 CIVIL ACTION - LAW KELLY GIAMBILIS - INGRAHAM, and DAVID P. INGRAHAM, Defendants/Respondents IN CUSTODY PETITION FOR SPECIAL RELIEF AND NOW, comes the Plaintiffs, Nicholas J. Giambilis and Amelia G. Giambilis, by and through their attorneys, MAR TSON DEARDORFF WILLIAMS & OTTO, who respectfully request special relief, pursuant to Pa. R. C. P. 1915.13 upon the following: 1. Petitioners, Nicholas J. Giambilis and Amelia G. Giambilis (herein, "Grandparents"), are adult individuals who reside at 7 Graham Road, Newville, Cumberland County, PA 17241. 2. Respondent, Kelly Giambilis - Ingraham (herein, "Mother"), is an adult individual who is believed to reside at 107 North East Street, Carlisle, Cumberland County, P A 17013. 3. Respondent is David P. Ingraham (herein, "Father") an adult individual whose address is unknown to Petitioners. 4. Respondent Kelly Giambilis - Ingraham is the mother of Amelia Ingraham (herein, "Amelia") who was born November 24, 2000. 5. Respondent David P. Ingraham is the father of Amelia amd has never had custody of Amelia. 6. Grandparents are the maternal grandparents of Amelia. 7. There has been no prior custody action initiated with regard to Amelia. 8. Grandparents are the guardians of Mother's oldest daughter, Angela, pursuant to Order of Court dated April, 1994. 9. Mother is a habitual drug user and has been in and out of rehabilitation. 10. Mother placed Amelia in the care of Grandparents on and off periodically since Amelia's birth, but since March 10, 2002, Grandparents have had Amelia continuously in their custody and care. 11. On March 15, 2002, prior to their leaving for a vacation, Mother promised Grandparents that she would check herself into the White Deer Run Rehabilitation Center in Lancaster for counseling and treatment for her drug abuse. 12. On or about March 24, 2002, Grandparents returned home from their vacation to discover that Respondent did not check herself in the rehabilitation center as she promised. 13. Despite their search for Mother, including checking with the rehab center, Grandparents have been unable to locate her. 14. Grandparents work and are afraid to return Amelia to her current babysitter, as Mother, who is presently unfit to care for Amelia, may return to the babysitter and take Amelia without prior notice to Grandparents. 15. Grandparents are unable to change the daycare provider without an Order of Custody. 16. Mother has demonstrated that she is incapable of providing Amelia with the most basic and essential care, and has failed to provide adequate physical facilities to house her. 17. It is in the best interests of the minor child to remove her from the nonexistant parental care and concern of Mother and place her in the full physical and legal custody of your petitioners. WHEREFORE, Petitioners pray Your Honorable Court to issue an Order immediately granting Petitioners request for custody of Amelia pending a further hearing to held in this matter. MARTSON DEARDORFF WILLIAMS & OTTO B~~ Edward L. Schorp, sqUIre Ten East High Street Carlisle, P A 17013-3093 (717) 243-3341 Attorneys for Petitioner Date: VERIFICATION I verify that the statements contained herein 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. Dated: t1 ~ Z{" 2A;L ~~~ ichola . lamblhs I Ci,J;~ J ~t~ Amelia ~. Giambilis G-. ?9~ ("':) ~ ~ - ~ ~ C7 ..-- ~ -1' -5:) oQ ~ {j> (Z ~ Z ~ 0- (') c $: -0 co I'T1 fn z:n Zr; ~';: !;20 ?fQ ;;0 c: ~ o N ;po -0 :::0 I Q:) o --n :po ::x I.f? Ul s:- ...,., r..:c i3t2 ::;:!~~ ?'s3l ~::~A>' (') ,:5 rn ~ -< NICHOLAS J. GIAMBILIS and AMELIA G. GIAMBILIS, h/w Plaintiffs/Petitioners IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 02-1707 CIVIL ACTION - LAW KELLY GIAMBILIS - INGRAHAM, and DAVIDP. INGRAHAM, Defendants/Respondents IN CUSTODY ORDER AND NOW, this tD'*"" day Of~ ,2002, upon consideration of the attached Petition, it is ordered that the visitationlcustodyrights of the Respondents Kelly Giambilis- Ingraham and David P. Ingraham be and are hereby suspended pending further hearing in this matter. The minor child, Amelia Ingraham, shall remain in the full and exclusive custody of Petitioners, Nicholas J. Giambilis and Amelia G. Giambilis pending hearing on their Petition. Hearing on the within Petition shall be held at /: 30 o'clock LM., on r{t ~ ) ~ I ~ , 2002, in Courtroom No. r, Cumberland County Courthouse, Carlisle, Pennsylvania. 'o;;/'rr;j to: -Ke.\~ Gia..~\\\iS- IM~~/~O-'(Y\ cD:t:J . <:)~OfPf I 2.3~, VINVAlJ..SNN3d AINnoQ GW1838l^1m 2'1 :8 ~ld 0 I ~dV 20 II "'lOt I'''' "',,,, ~.,' '0 ^{JV, "'U1" i.U.....\JQ ...J1'11 j' 3:)1::1:10-0311:1 NICHOLAS J. GIAMBILIS and AMELIA G. GIAMBILIS, husband and wife, Plaintiffs/Petitioners IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 02-1707 CIVIL TERM KELLY GIAMBILIS-INGRAHAM and DAVID P. INGRAHAM, Defendants/Respondents IN CUSTODY ORDER OF COURT AND NOW, this 15th day of April, 2002, pending further hearing in this matter, the minor child, Amelia Ingraham, shall remain in the full and exclusive custody of Petitioners, Nicholas J. Giambilis and Amelia G. Giambilis. Visitation with Mother shall be as supervised by the grandparents. By the Court, Edward E. Guido, J. Edward L. Shorpp, Esquire Attorney for Plaintiffs Kelly Giambilis-Ingraham 107 North East Street Carlisle, PA 17013 Defendant, Pro se . ~ 1_/(,.0;- ~ q- srs VIMt,\lASNN3d AlNn08 ONYl,llj8VVno fjU:/ IoId 91 (Jd~ 20 'l::I""c'"'', '(", '" '1' "'0 ^ 1;".,L :<,'..h'i":-\/',,:,.;, ;:J!'1 .:J ~J:)I :HO-QjlLl SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-01707 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GIAMBILIS NICHOLAS J ET AL VS GIAMBILIS-INGRHAM KELLY ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT GIAMBILIS-INGRAHAM KELLY but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - CUSTODY , NOT FOUND , as to the within named DEFENDANT , GIAMBILIS-INGRAHAM KELLY PER POST OFFICE, MOVED LEFT NO FORWARDING. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 3.45 5.00 10.00 .00 36.45 . Tomas Kline Sheriff of Cumberland County MDW&O 04/16/2002 Sworn and subscribed to before me this I~ It day of Of.'~ J..u.o ;L A . D . ~()~ Proth n tary ltvio, , ~ I~/- ~ NICHOLAS J. GIAMBILIS AND AMELIA G. GIAMBILIS, H/W IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYL VANIA V. 02-1707 CIVIL ACTION LAW KELLY GIAMBILIS-INGRAHAM AND DAVID P. INGRAlfAMDEFENDANT : IN CUSTODY ORDER OF COTJRT AND NOW, Monday, April 22, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tbursday, May 09, 2002 at 11:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to defme 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 honrs prior to scheduled hearing. FOR THE COURT, By: Isl Jacq.ueline M. VernlO'_ Esq. mlo.<- 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 .7!' ~ fp :-- ~ 4?6; r'(J'~f./1 -~ ~ ~ ~IL, f'<?-[e'A c//"?'t1;>">-Y '?- ~ ~ ';P1l ~'Ee./t VtNV/\lASNN3d I "'no'" rWVl\J:<g'Mn..... 1\i.J'I .J \,,;,.,., I.."", V, Iv S'l:Z t'~d 8Z lJdV ZO AlNlOi\I-):~~(>L: ~o 3::11i1{}U]-j!.:l ;;~;":.' :,',./: MAY 1 0 ZOUt b NICHOLAS GIAMBILIS and AMELIA G. GIAMBILIS, HIW Plaintiffs V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002-1707 CIVIL TERM KELLY GIAMBILIS-INGRAHAM: CIVIL ACTION - LAW And DAVID P. INGRAHAM, Defendants : IN CUSTODY ORDER OF COURT at\ AND NOW, this I ~ day of /'t",. , 2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. and effect. The prior Order of Court dated April 15, 2002 shall remain in full force 2. The Conciliation Conference is continued generally and any party may contact the Conciliator to schedule another Conciliation Conference. 3. This Order is entered pursuant to an agreement of the Grandparents and counsel for Mother. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms ofthis Order shall control. BY J. cc: Edward L. Schorpp, Esquire, Counsel for Grandparents > Joan Carey, Esquire, MidPenn Legal Services, Counsel for Mother ~<<f u':' 11'1-"'<' ;I~( f,./"I-o;L ~ - FILEo-OfFV'E Of' Ti-"- '"""Y\'Nfl"'\':j~)"'liny '. "--';'1:._//_,_ Inn 02 HA Y I 3 ,~N 9: 49 CUMBERi..AlvD COUlvry PENNSYLVANIA NICHOLAS J. GIAMBILIS and AMELIA G. GIAMBILIS, H/W Plaintiffs V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : 2002-1707 CIVIL TERM KELLY GlAMBILIS-INGRAHAM: CIVIL ACTION _ LAW And DAVID P. INGRAHAM, Defendants : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent infonnation concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Amelia Ingraham November 24, 2000 Grandparents 2. A Conciliation Conference was held in this matter on May 9, 2002, with the following individuals in attendance: The Grandparents, Nicholas J. Giambilis and Amelia G. Giambilis, with their counsel, Edward 1. Schorpp, Esquire. Service of the complaint and notice of the conference was not obtained on Father as his whereabouts are unknown. Mother had notice of the conference but did not appear, although her counsel, Joan Carey, Esquire of MidPenn Legal Services did appear on her behalf. 3. A prior Order of Court was entered dated April 15,2002 in which the grandparents were granted exclusive custody of the child. 4. Counsel for Mother requested a general continuance of the conference. Grandparents were not opposed to a general continuance. 5. The Grandparents and counsel for Mother agreed to the entry of an Order in the fonn as attached. 5'-9-{)).. Date ~A.b' c eline M. Verney, Esquir Custody Conciliator , F: IFlLES\DA T AFlLEIGeneral\CufTent\ 1 0418,3 ,custody pet Created 1O/13/047:59AM Revi,ed 10127104 SAlAM NICHOLAS J. GIAMBILIS and AMELIA G. GIAMBILIS, h/w Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 02-1707 CIVIL ACTION - LAW KELLY GIAMBILIS - INGRAHAM, and DAVID P. INGRAHAM, Defendants IN CUSTODY PETITION TO MODIFY CUSTODY ORDER AND NOW, comes the Petitioners, Nicholas J. Giambilis and AmeliaG. Giambilis, husband and wife, by and through their attorney, Edward L. Schorpp, Esquire, who petition your Honorable Court to modify the prior custody Order of April 15,2002, upon the following: I. Petitioners are Nicholas J. Giambilis and Amelia G. Giambilis, adult individuals and maternal grandparents of the child, who reside at 7 Graham Road, Newville, Cumberland County, Pennsylvania. 2. Respondent Kelly Giambilis - Ingraham is Petitioners' daughter and mother of the child, and resides at 141 I East King Street, Apt. #1, Lancaster, Lancaster County, Pennsylvania 17602. 3. Respondent David P. Ingraham is an adult individual and father of the child, whose current residence is unknown. 4. Respondent Kelly Giambilis-Ingraham is not represented by counsel in this matter. 5. Petitioners seek to modifY a prior custody Order of this Court dated April 15,2002, concerning the child, Amelia Ingraham, who was born on November 24, 2000 (herein, the Prior Order). The child was not born out of wedlock. 6. Pursuant to the Prior Order, the child was placed in the primary physical custody of Petitioners. 7. During the past six months, the child has resided with her mother, respondent Kelly Giambilis-Ingraham at the address set forth in paragraph No.2 above. Prior to that time, the child resided with Petitioners at the address set forth in paragraph No. I above. 8. The father of the child is David P. Ingraham. It is unknown where and with whom he is residing. He is married and living separately. 9. The parties have participated in previous litigation concerning the custody ofthe child which resulted in the Prior Order. 10. The petitioners now believe that the best interest and permanent welfare of the child will be served by modifying the Prior Order to grant primary physical custody to Respondent mother as she has remediated the conditions which led to the prior litigation and, over the past six months, has demonstrated a desire and ability to provide a stable, nurturing and loving environment for her daughter. 11. There is attached to this Petition and marked as Exhibit "A," an Agreement and Stipulation whereby the parties have agreed to provisions relating to the custody of the minor child. 12. There is attached to this Petition and marked as Exhibit "B," a copy of the Prior Order. WHEREFORE, Petitioners request your Honorable Court to enter an Order modifying the Prior Order pursuant to the Agreement and Stipulation attached to this Petition. MARTS ON DEARDORFF WILLIAMS & OTTO -) VERIFICATION I verify that the answers and statements contained herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. g4904, relating to unsworn falsification to authorities. ffi4~~J~' Nicholas J. Giambilis Dated: 5 )Jh Jar-" I verifY that the answers and statements contained herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. g4904, relating to unsworn falsification to authorities. 1\ ..' } U.kd ~C\ ,yf yl...."Lk, 1/,../ Amelia G. Giambilis F \FILES\DA T AFlLEIGeneral\Currenll I 0418.3 _ cuslodystiporder Created 10/13104721AM Revised ]0/14/046.42AM NICHOLAS J. GIAMBILIS and AMELIA G. GIAMBILIS, h/w Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 02-1707 CIVIL ACTION - LAW KELL Y GIAMBILIS - INGRAHAM, and DA VID P. INGRAHAM, Defendants IN CUSTODY AGREEMENT AND STIPULATION THIS AGREEMENT AND STIPULATION entered into the day and year hereinafter set forth, by and between KELLY GIAMBILIS - INGRAHAM (hereinafter referred to as "MOTHER") and NICHOLAS J. GIAMBILIS and AMELIA G. GIAMBILIS, husband and wife (hereinafter referred to as "MATERNAL GRANDPARENTS"). WHEREAS, the parties wish to enter into an agreement relative to custody and partial custody of the child, Amelia Ingraham, born November 24,2000; NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth, the parties agree as follows: I. The parties will have shared or joint legal custody of the child, meaning the parties shall confer with each other on all matters of importance relating to the child's health, welfare, maintenance and education with a view toward obtaining and following a harmonious policy of the child's best interest. Each party shall keep the other informed ofthe progress of the child's education and social adjustments. Each party shall keep the other informed at all times as to their present whereabouts and shall give prior notice as to an intended move from their present residences, which notice shall be in writing and shall provide the new address, including street name and number, city and state. Each party shall at all times provide the other with a current phone number. 2. MATERNAL GRANDPARENTS shall have physical custody of the child as the parties shall mutually agree. 3. MOTHER shall have primary physical custody of the child at all other times. 4. The parties will keep each other advised immediately in the event of serioLls illness or medical emergency concerning the child and shall further take any necessary steps to ensure that the health and well being of the child is protected. During such illness or medical emergency, both parties shall have the right to visit the child as often as each desires consistent with the proper medical care of the child. S. Neither party shall do anything which may estrange the child from the other party, or injure the opinion of the child as to the other party, or which may hamper the free and natural development of the child's love or affection for the other party. 6. Any modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing, executed with the same formality as this Stipulation and Agreement and entered by further Order of Court. 7. The parties desire that this Stipulation and Agreement be made an Order of the Court of Common Pleas of Cumberland County, thereby modifying an Order ofthat court dated AprillS, 2002, and further acknowledge that the Court of Common Pleas of Cumberland County does, in fact, have jurisdiction over the issue of custody of Amelia Ingraham, the minor child, and shall retain such jurisdiction, should circumstances change and either party desire or require further modification of said Order. 8. The parties agree that in making this Agreement, there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 9. The parties acknowledge that they have read and understand the provisions of this Agreement. Each party acknowledges that the Agreement is fair and equitable and that it is not the result of any duress or undue influence. IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms hereof, set forth their hands and seals the day and year herein mentioned. WITNESS: -~~~ ( Ca)t:~ l~~bL- I C~''-J'~ Date: <:O-/Id,)- '-j/' .7(} AL~'. / I / DateJ.,j/.1'5 Date: '. COMMONWEALTH OF PENNSYLVANIA ) . SS. COUNTY OF CUMBERLAND ) . ""1/~ .:lJ:O'J (.' 0 On this, the / If/, day of JlL/Lcyl ,.zooz( before me, the undersigned officer, personally appeared Nicholas J. &mbilis, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. co~~t1\"W;S& Wm~~2JiA I hereunto set my hand and official seal. Notarial Seal 1.)1 .' 11 ('J . MaryM, Price, Notary Public I, -'I<. '[ ,~tUc-' Carlisle Bora, Cumberland County . My Commission ExpiresAug.1B, 2007 otary Public (SEAL) MelT'h01. , "'-'I'!~' A<;soci<ltion ot Notaries COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND) ~ ~{!5-,mv 0 On this, the 3 J ,fJi:; day of C\t \1....HV~ ,.J..OO"f,' before me, the undersigned officer, personally appeared Amelia G.~ambili9,known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. ~)Y6J~J~~I~Il:YlWM9L~J\~I~ereunto set my hand and official seal. Notarial Seal r {fit (J ~ Mary M. Price, Notary Public " 7 ,---.h kV Carlisle Bora, Cumberland County . My Commission Expires Aug. 18, 2007 otary Public (SEAL) Member, P~nns\f"<l.nla Ass.ocii:',l\Qf\ 01 No\aries COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF LanCL1s-fetL SS. ) On this, the /# day of Ot!.-..fobeL , 2004, before me, the undersigned officer, personally appeared Kelly Giambilis - Ingraham, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. \J?~, ()r;~f" o?ary Public I (SEAL) NOTr"IRIAL SEP.L PEGGY A. E~IGIEHr, NO 'AUI Pl18UC CITY OF l.M!CASER, LAN2.!'\S: Ell CGU!'-JTY MY COf'"H,iISSIOI') D',G:i!LS ://,y l~- 2~'U6 '. NICHOLAS J. GIAMBILIS and AMELIA G. GIAMBILIS, husband and wife, Plaintiffs/Petitioners v. KELLY GIAMBILIS-INGRAHAM and DAVID P. INGRAHAM, Defendants/Respondents IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1707 CIVIL TERM IN CUSTODY AND NOW, this 15th day of April, 2002, pending ORDER OF COURT further hearing in this matter, the minor child, Amelia Ingraham, shall remain in the full and exclusive custody of Petitioners, Nicholas J. Giambilis and Amelia G. Giambilis. Visitation with Mother shall be as supervised by the grandparents. L/(Edward L. Shorpp, Esquire Attorney for Plaintiffs Kelly Giambilis-Ingraham 107 North East Street Carlisle, PA 17013 Defendant, Pro se srs By the Court, TRUE COpy FROM RECORD In Testimony whnroof, I hero unto set my hand :1M ll,n ""11 ,., ...;., ('....l", 'I"".;'~i," Pa II.",' o_lc:N ....0 .""U\\'! ~\,,._;l ,Q vu.>;tt,JIXl!. .. Ihls I ~ ~ d.IY, ot (t; ~. 'f;,e>o :z.., L~'" Un.;':' ~ r , Prothonotart' CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent of MARTS ON DEARDORFF WILLIAMS & OTTO, hereby certify that a copy ofthe foregoing Petition to Modify Custody Order was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Kelly Giambilis-Ingraham 1411 East King Street, Apt. #1 Lancaster, P A 17602 MARTSON DEARDORFF WILLIAMS & OTTO By ~'j) '!t , (;)i~~ ~ary M. Price Ten East High Street Carlisle, PA 17013 (717) 243-3341 Date: May 26, 2005 RECEIVED MAY 311.tll1SY NICHOLAS J. GlAMBILIS and AMELIA G. GIAMBILIS, h/w Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 02-1707 CIVIL ACTION - LAW KELLY GIAMBILIS - INGRAHAM, and DAVID P. INGRAHAM, Defendants IN CUSTODY ORDER OF COURT AND NOW, this ~ day of ~ ~ ' 2005, upon Petition of the Parties and upon agreement of the parties, the attached Stipulation and Agreement is hereby made an Order of Court, and the prior Order dated April 15, 2002, is hereby vacated. J. ~ r~ 1X\~riJ 0'J'V IS:8 I!J 1- t1nr SDJZ :10 - NICHOLAS J. GIAMBILIS and IN THE COURT OF COMMON PLEAS OF AMELIA G. GIAMBILIS, h/w, :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. KELLY GIAMBILIS-1NGRAHAM, : NO. 2002 -1707 CIVIL TERM And DAVID P. INGRAHAM, Defendants ORDER OF COURT AND NOW, this 18TH day of JUNE, 2010, after consultation with the Honorable David R. Workman we are satisfied that this case is now properly with the Lancaster County Court of Common Pleas, LANCASTER, PENNSYLVANIA. .~ Honorable David R. Workman 50 North Duke Street Chambers # 9 Lancaster, Pa. 17602 ~dward L. Shorpp, Esquire 35 South Thrush Drive Carlisle, Pa. 17013 Michael Marinaro, Esquire 53 North Duke Street Suite 1 Lancaster, Pa. 17602 Richard Gromen, Jr., Esquire 3121 C Mt. Joy Road Mt Joy, Pennsylvania 17552 :sld t ~~s `Yt~. t, Co ~.V~iv .~~ Edward E. Guido, J. c ~~ ~ ~~~; ~' F~ <c: N d c.._ c .c- -v 3c N !~ c~ `'"n ~~ ~.~5 ~ -G