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Jeffrey A. Keiter, J.D.
Attorney 1.0. 15966
Attorney for Plaintiff
226 West Chocolate Avenue
Hershey, PA 17033
(717)533-8889
Attorney for the Plaintiff/Petitioner
MARGARET M. READER, formerly
MARGARET AGRUSa
Plaintiff/Petitioner:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
JOSEPH J. BECHARA
NO. 634 CIVIL 1992
Defendant/Respondent: CIVIL ACTION - CUSTODY
PETITION FOR SPECIAL RELIEF AND FOR CONTEMPT
AND NOW, this 4th day of October, 2006, the Plaintiff,
Margaret M. Reader, formerly, Margaret Agruso, by her attorney,
Jeffrey A. Keiter, Esq., files this Petition for Special Relief
and for Civil Contempt, on the following grounds:
1. The Plaintiff, Margaret M. Reader (herein called the
"Petitioner"), resides at 5023 Mauretania Avenue, Harrisburg,
Dauphin County, Pennsylvania 17109.
2. The Defendant (herein called the "Respondent"), Joseph
J. Bechara, resides at 22 Crab Ave., Lynbrook, Nassau County,
New York, 11563.
3. The Petitioner and the Respondent are the natural
mother and father, respectively, of Matthew J. Bechara, age 16,
born December 20, 1989.
4. On June 3, 1992, this Honorable Court, J. Wesley Oler,
Jr. presiding, entered an Order of Court, dated June 3, 1992
(herein called the "Order of June 3, 1992"), granting the
Petitioner "primary physical custody" of the minor child,
Matthew J. Bechara (herein called the "Child"). Said order was
the initial determination of the custody of the Child In
Pennsylvania or any jurisdiction, including the State of New
York, where the Respondent then resided and has continued to
reside.
5. Said Order of June 3, 1992, also granted the
Respondent "partial custody," as set forth in said order.
6. On September 7, 1995, upon the petition of the
Petitioner herein, the Order of June 4, 1992 was modified by
Order of Court of this Court, dated September 7, 1995 (herein
called the "Order of September 7, 1995") with the Petitioner
retaining "primary physical custody" of the Child and
Respondent's schedule of partial custody being modified.
Respondent's Petition for Contempt, filed in response to the
Petitioner's petition to modify custody was also denied on
September 7, 1995.
7. On November 22, 1995, this Court entered another Order
of Court, dated November 22,1995 (herein called the "Order of
November 22, 1995) whereby the parties agreed to modify the then
existing custody order insofar as the Respondent's rights to
partial custody of the Child. The Petitioner again retained
"primary physical custodyU of the Child.
8. On August 9, 1996, this Court again issued an Order of
Court dated August 9, 1996 (herein called the "Order of August
9, 1996U) whereby the Respondent herein was held in contempt of
court and, in addition, the Court modified the terms of
Respondent's partial custody of the Child.
9. No other orders pertaining to the determination of the
custody of the Child have been issued in any other Court or
jurisdiction.
10. Beginning In the summer of 1995 and occurring
sporadically thereafter, the Child became increasingly
discourteous and disrespectful to the Petitioner and defiant and
disobedient towards the Petitioner.
11. On or about September 24, 2006, after another episode
when the Child was disrespectful and disobedient, Petitioner
contacted the Respondent and demanded that the Respondent assist
her in controlling and disciplining the Child and placed the
Child on a train to the Petitioner's residence in Lynwook, Long
Island, New York, which is situate in Nassau County, New York.
12. At no time did the Petitioner indicate to the
Respondent that she intended to relinquish primary physical
custody, except on a temporary basis, until the crisis with the
Child was resolved. Petitioner also withdrew the Child's
enrollment at Central Dauphin High School in Dauphin County,
later to re-enroll the Child on or about September 29, 2006.
13. When the Petitioner learned that the Child could not
be enrolled in high school in Long Island because of this
Court's custody orders and after a disagreement between the
Petitioner and the Respondent over the discipline of the Child
and what was in the Child's best interest, the Petitioner
demanded that the Respondent return the Child to Petitioner's
residence in Dauphin County, PA. Petitioner also explained to
the Respondent that she had received a truancy notice and that
the Child was required to attend public school In Pennsylvania
if he could not be enrolled in a public school in New York.
14. The Defendant refused the request of the Petitioner
and defiantly refused to return the Child to the Petitioner.
15. As a result of the Respondent's actions, the Child has
not attended public school, or any school, since on or about
September 25, 2006.
16. In the meantime, on or about September 28, 2006, the
Respondent, acting pro se, filed a petition to modify the
custody of the Child, but in said petition, did not indicate
that this Court had issued several custody orders in Cumberland
County, PA. Attached hereto, marked Exhibit "A," is a true and
correct copy of a Rule to Show cause, dated September 28, 2006,
entered by the Family Court of Nassau County, New York, together
with a copy of the petition for modification filed by the
Respondent, where by the said Family Court set a hearing (which
the Petitioner has since learned may be a conference before a
hearing officer) for this Thursday, October 5, 2006 at 9:00 a.m.
in the Nassau County Family Court.
17. Petitioner intends to attend such hearing/conference,
acting pro se, since she is unable to obtain counsel in New
York, nor is she able to afford counsel there, to contest the
subject matter jurisdiction of the court in New York on the
grounds that under the UCCJA, PAKA (Parental Kidnapping
Prevention Act) and the UCCJEA, Pennsylvania is the "home state"
of the Child and, thus, the Nassau County Family Court should
decline to exercise subject matter jurisdiction to modify the
custody orders entered in Cumberland County, which orders should
be afforded "Full Faith and Credit" by the Court in New York.
18. Attached hereto are true and correct copies of the
orders of this Court, as set forth above.
19. Based on information given to the Petitioner, she has
been informed by court personnel and by the attorney In New York
appointed as the "guardian" for the Child, that this Court's
determination of the custody of the Child has no force and
effect in the State of New York.
SPECIAL RELIEF
20. Based on the averments set forth in paragraphs 1-19
hereof, the Petitioner respectfully requests that the Honorable
Court issue appropriate process directing that the Child
forthwith be brought before this Court, otherwise comply with
the Court's determination of the custody of the Child, as
modified by the Court, and directing the Respondent not to
remove the Child from the custody of the Petitioner or the
Commonwealth of Pennsylvania.
WHEREFORE, the Petitioner respectfully request the Court to
order the Respondent to forthwith bring the Child before the
Court; comply with the Court's orders regarding the custody and
partial custody of the Child; and not thereafter remove the
Child from the custody of the Petitioner in Pennsylvania until
further order of the Court.
CONTEMPT OF COURT
21. The averments set forth in paragraphs 1-17 hereof are
incorporated herein by reference.
22. The Respondent has intentionally, voluntarily and
willfully failed to comply with this Court's determination of
the custody of the Child and the orders entered pursuant thereto
in that the Respondent has refused the demand of the Petitioner,
the primary custodian of the Child, to comply with this Court's
orders and return the Child to her in Pennsylvania after the
Petitioner's relinquishment of temporary physical custody of the
Child to the Respondent for the purposes and the reasons set
forth herein.
23. As a result of the Respondent's actions, the
Petitioner has been forced to retain legal counsel in
Pennsylvania and has, as of the date hereof, incurred legal fees
and expenses in the amount of approximately $1,500 and will
incur additional reasonable and necessary counsel fees and
expenses in an effort to enforce the orders of this Court.
WHEREFORE, Petitioner respectfully requests that Respondent
be held in contempt of Court and be ordered to pay the
Petitioner reasonable
enforcement
of the Court's orders regardin
Jef A. Ke ter, .D.
Att I.D. 15966
Attor e for Plaint'ff
226 West Chocolate Avenue
Hershey, PA 17033
(717)533-8889
Attorney for the Plaintiff
Jeffrey A. Keiter, J.D.
Attorney 1.0. 15966
Attorney for Plaintiff
226 West Chocolate Avenue
Hershey, PA 17033
(717)533-8889
Attorney for the Plaintiff
MARGARET M. READER, FORMERLY
IN THE COURT OF COMMON
PLEAS
CUMBERLAND COUNTY,
MARGARET AGRUSa
PENNSYLVANIA
Plaintiff,
v.
JOSEPH J. BECHARA
NO. 634 CIVIL 1992
Defendant,
CIVIL ACTION - CUSTODY
VERIFICATION
I verify that the statements made In this PETITION FOR
SPECIAL RELIEF AND FOR CONTEMPT 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.
Oed. If, o.,.DO ~
~~
ORMERLY
General Fonn 1
(Order to Show Cause)
I
19/2004
FAMILY COURT OF THE STATE OF NEW YORK
COUNTY OF
.. . . .. " .. .. .. .. .. .. . .. .. .. . .. .. .. .. .. .. . .. .. .. . .. .." . . .. .. .. .. .. .. . . .. . .. . .. . .. .. .. .. .. .. .. .. .. .. ... .. . .. .... .. ~.. .. ~ .. .. .. .. .. .. .. .. . .
o -/03 lV' o~ /ffb-k
Docket No.
In the Matter of a Proceeding under
Article of the Family Court Act
JO~~ -S ~ rc., Petitioner
ORpER TO SHOW CAUSE
against
~a.~@('Q~ !\' r End~r
Ci \i:c. ('(\0 f'qa r~\ r0 ((".f"U S~espondent
.. .. .. .. .. .. .. . .. .. .. .. .. .. .. ~ .. .. .. .. .. .. .. .. .. . .. .. .. .. .. .. .. .. .. .. . .. .. ... .. .. .. .. .. .. .. .. .. .. .. .. . .. .. .. .. .. . .. .. . .. .. .. ... .. .. . .. .. .. .. .. .. .. .. .. .. ..
Uponthepetitionof . C5C~Q~~.~ ~~
day of Se~Sr :l.C:., ~oo(; , annexed hereto, it is
verified the
~r'
ORDERED that \l'G.r<tG~ \("(\ 4~O g.~_ }~~"u~ore this Court
at NewYork,onther:5''day~ ~'clockinthe 0
morning 0 afternoon of that day, or as soon thereafter as the parties can be heard, why an
order should not be made as fol1ow~: o..&~\'~ .\0 Sc.~ \ - ':! QQ;'~ \...J.-Xll'\t-
"",,,,~ ~~ ~Q ~ (1Q9 \aca.-\~d . "
and why such other and further relief should not be
is further
anted as the c~o t may determine, ~d it '
~~ r.Z
-----
,./CfRDERED that service by ti a copy of this order tot7F-ther tJ'
. the papers upon which it is granted upo~ffl-e . o~ or before the c:?
day Of~ be deemed sufficient service. K.P~ /4 5 ;. .
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F.CA. 9~ 652, 654
FAMILY COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
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page 1 of3
Foml4-11cv
(Custody ,Visitation)
12/91-NS/200S
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In the Matter of a Proceeding for CUSTODYNISITATION
under article ~ Of the Family Court Act
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Petitioncr(1) -so~\.."
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Pditioncr (2)
(if applicable) First
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PETITION FOR MODIFICAtJON
OF ORDER MADE nv:
. -=.1
o NASSAU FAMlLY COURt:.
a ANOTHER COURT ( ~,',J
(.....'l
-AGAlNST.
Respondent (lL \'<"\o.:c\G~ ~~ f'
F lcst Mol. Last
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Respondent (2) '-"
(if applicable} ~~~}~ ~ \J ~ Q
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(Court use on.ly)
T.O THE FAMILY COlJRT:
The undersigned Petitioner respectfully shows that:
1a. PETITIONER'S (1) INFORMATION:
NAME (1) ~-S~\.o.r~
S.S.# Ob~- 5l.(-,\ ~J
D.O.R \ \. / ~C\, I \'1 57
Address ')'), C '("0..\0 o...~
h'l~~rc:o\.<. ~ \ 15b~
b. PETITIONER'S (2) INFORMATION:
(If applicable)
I /
2a. RESPONDENT'S (1) INFORMATION: b.RESPONDENT'S (2) INFORMATION:
(If applicable) .
NAME (I) \0G.~f'~ ~Ql~r ~\t::~ ~~ut"~~ Gt~('us.a
S.S.#
D.O.B. I I I /
Address 50).~ <'f""QUN2. \G~ \~ O\J..Q.
\-\G~r,~b ,Q~ \,\C!1
I
Sv.ecify address or indicate if ordered to be kept confidential fursuaot to Fam.ily Court Act ~ 154-
b(2) or the Domestic Relations Law, Sect. 254. If confidcntia , address MUST be indicated on In
sheet.
~
l 'M lqlO 'oN
Hili ~')^ W~~I:} Qnn7 '{'7 'dac:
pnge 2 of 3
3. CHILD(REN)'S INFORMATION:
NAME (OLDEST CHtlD FIRST, THEN NEXT OLDEST, ETC)Please list the names and
infoID,ation on the children.
NAME (print clearly) SEX D.O.B CURRENT ADDRESS
1. .~C\ ~~ ~ ~\.o~ \rr\ \4- I~ I ~ ~~ CN~(juq, \'Yn~ r-.'i ll~ 1,.
2. I I
3. I I
4. I I
S. I I
~
4. A (judgement) (order) (support order) dated I !
was entered in ~(p,",,,,,~ C~ , in tbe County of ()(b~\j
(specifY type of court) (specify county)
, index #
, state of () '/ .
(specify state)
A true copy of the order is annexed hereto and made part o~ hereof.
a. Did the Court retain exclusive jurisdiction for the order stated above? 0 YES lXNO
b. The terms of slkid order directed the (Respondent) (Petitioner) to (specify terms):
CU~\o~'1 f c.,. ~t'\-~. ~~
5. Since t~ entry of said order, there bas been a change ()f.circumstances in that:
~G~~~~ ~G~ COrN? ~ \\.JQ w~ f'r'\.Q... ~-J\\ ~\,,!,.Q..
('('\r~~,.. ~\c.:c.. ~~~ Q~"\JSo ~ \..~n-. ~ ,.......,.,..'1 (u s~~y
6. By reason of said subsequent change of circumstances, the order should be modified as
follows: ')0 ell:, ..., )<;>~.. ~4 \ <.0 ~ \)~S. \ c (,.1 C Ul..W;1
7. Has there been an application made to any Court for the reliefbereiu requested? 'iQ~
If yes. please specify: \ ~ \ ~ rs.. 0.." 0 Cq~~ro~, fV'\~~
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page 3 of3
DATED: CA \~ ~6
~~-
TI ER(l) Signature
'S~~~ S ~~~~~
P T NAME
PETITIONER(2) Signature
PRINT NAME
VERlFICA TION
STATE OFNEWYORK)
COUNTY OF NASSAU )
:ss.:
Petitioner, being duly sworn, states: I have read this petition and its contents are true to my
own knowledge, except to matters alleged to be on information and belief and, as to those
matters, I believe them'to be true.
PETITIONER(2) Signature
SWorn to before me this
day ~o~ - ~6 200--k
Ifu/( J}pr '7 MI"
AIHOK 8APfIA
PUlUC STATE OF HeW '10M
NO. O1SM1a171t
QUALIfIED IN NAlSAU COUNTY
cOll.~1I11ON UPtRES AUG at....
Notary Public
V 'd 19l0 'oN
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MARGARET AGRUSa,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN CUSTODY
JOSEPH J. BECHARA,
Defendant
634 CIVIL 1992
IN RE: CUSTODY
ORDER OF COURT
AND NOW, this 3rd day of June, 1992, upon
consideration of the custody complaint filed by Plaintiff
mother, Margaret Agruso, with respect to the parties' child,
Matthew J. Bechara, born December 20, 1989, and following a
hearing, it is ordered and decreed as follows:
~ (1) Primary physical custody of the child shall
be in the Plaintiff mother, Margaret Agruso~~iA ·
(2) Partial physical custody of the child shall
be in the Defendant father, Joseph J. Bechara, on alternate
weeks, commencing at 11:00 a.m. on Thursday and concluding at
6:00 p.m. on Sunday. The first such period of partial custody
shall occur in the week of this Order. By agreement of the
parties, because of Defendant's presence in Pennsylvania on this
3rd day of June, 1992/ for the hearing in this matter, the
partial custody exercised by Defendant this week shall commence
immediately instead of tomorrow morning.
Partial custody of the child shall also be in the
Defendant for the last two weeks of August during each summer.
Plaintiff shall effect the transfer of the child
to and from Defendant through Natale Agrusa, or on the rare
occaSlon that Mr. Agruso is not available, through Ann Marie
LoPinto, the Plaintiff's father and sister respectively, at 112
Swatara Circle, Jonestown, Lrbanon county, Pennsylvania.
Plaintiff shall not be present at the times of
transfer of the child to and from the Defendant.
Defendant shall be responsible to provide
transportation at the commencement and conclusion of each period
of temporary custody.
(3) For purposes of the parties' exercise of
custody and partial custody rights under this Order, the party
having custody or partial custody shall provide a telephone
number where he or she can be promptly reached directly or
indirectly in the event of a medical emergency. No
communication shall be made by either party directly or
indirectly with the other, with a member of the other's family,
or with the other's employer or co-workers, except in the event
of a medical emergency or through legal counsel.
(4) The time periods for the exercise of custody
and partial custody and the parties' rights to such exercise,
provided for in this Order, shall not be abridged by either
party, without Court approval or written agreement of the
parties submitted to the Court for ratification.
(5) This Order shall be reviewed by the Court ln
approximately two months, and a hearing for this purpose will be
set by the Court, with notice to counsel of the date and time.
At that hearing, the Court will hear evidence as to the parties'
compliance with the Order in the interim and as to whether the
Order appears to be function~ng in the best interest of the
child.
By the Court,
J.
.,/
J9A~~AREY, ESQUIRE
~~gal Services, Inc.
~ For the Plaintiff
JAMES M. BACH, ESQUIRE
For the Defendant
TRUE COpy F~O,M'RE~OR~nd
In Test!n-lony whef~lOt ! ~lf}HHlf)to set my .'
.~....1 thO .. ~I of ~~d C0"'J11 at Carnsie. ~~..
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MARGARET AGRUSO, njkja
MARGARET READER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
634 CIVIL 1992
JOSEPH BECHARA,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
IN RE: PLAINTIFF'S PETITION FOR MODIFICATION OF CUSTODY
ORDER OF COURT
AND NOW, this 7th day of September, 1995, upon
consideration of the Plaintiff's Petition for Modification of
Custody and following a hearing, it is ordered and directed as
follows:
. 1. The parties shall share legal custody of their
mlnor child, Matthew J. Bechara, born December 20, 1989.
_~ 2. During the school year, the child shall be In the
primary physical custody of the mother, and the father shall
have the following periods of temporary custody:
(a) One weekend per month during the school
~ year to be exercised by the father giving the mother forty (40 ),*'"
days advance notice of the weekend he will have the child; and
~ (b) The period from noon on December 26th through
noon December 30, eachyear;:t
(c) The child's entire vacation from school in
the sprlng of each year (in the event the child has two separate
vacations from school, the father shall be entitled to have the
child for the longer of the two but not both).
,/.
/'
3. From noon on the second Saturday following the
child's dismissal from school each summer until noon on the
second Friday before school resumes in fall. The Child shall be
in the primary physical custody of his father at his home in New
York. Mother shall have seven (7) consecutive days of custody
of the child, to be exercised on dates selected by the mother to
which she will give the father written notice no later than the
15th day of April each year.
4. The parties will share transportation for a~l
custodial exchanges equally by selecting a mid-point between
1f their homes for purposes of exchange. Unless the parties agree
otherwise, that midpoint will be at the border between
Pennsylvania and New Jersey on Interstate 78, and will be at
8:00 p.m. on Friday evening at the beginning of the father's
.~ weekends, and 7:00 p.~. on Sunday at the end of those weekends.
5. The party having custody or' partial custody shall
provide a telephone number where he or she can be promptly
reached directly or indirectly in the event of a medical
emergency..~NO communication shall be made by either party
directly or indirectly with the other, with the member of the
other's family, or with the other's employer or co-workers
except in the event of a medical emergency or through legal
counsel.jf
By the Court,
J
MARGARET AGRUSa, n/k/a
MARGARET READER,
Plaintiff
v.
JOSEPH BECHARA,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
634 CIVIL 1992
CIVIL ACTION - LAW
IN CUSTODY
IN RE: DEFENDANT'S PETITION
ORDER OF COURT
AND NOW, this 7th day of September, 1995, upon
consideration of the Defendant's Petition for Contempt, the
\
\
Court finds that the Plaintiff, Margaret Agruso-Reader, has not
committed a violation of the Order, and she is consequently not
adjudicated in contempt.
~ry J. Katshir, Esquire
For the Plaintiff
James J. Kayer, Esquire
For the Defendant
lt
By the Court,
TRUE COpy Fr:Oiv1 RECORD
In T"st:r;l~' ' c. .
".. ",:,':/ \'iFI~:"::.'.1 I" r:' ',-"'"1 "ct my hand
and the seii! or S(dCI~,-;r't'~t Ca~;i-sf:.~ Pa
. . A:J.. -, .
This. ...l':f.... day of ~.r.r J2,~~
................".~:.~ ....a......o:?~-L/
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025 h-' Prothonotary
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MARGARET AGRUSO, n/k/a
MARGARET READER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
634 CIVIL 1992
JOSEPH BECHARA,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
IN RE:
CUSTODY
ORDER OF COURT
AND NOW, this 22nd day of November, 1995, following a
conference in chambers with counsel for the Plaintiff, Gregory
J. Katshir ,.Esquire, and counsel for the Defendant, James J.
Kayer, Esquire, and both counsel having requested that certain
issues be resolved by the Court on an emergency basis, it is
ordered and directed as follows:
1. Telephone access to the child shall be permitted by
the Plaintiff, Margaret Agruso Reader, for the Defendant, Joseph
Bechara, on Wednesdays at 8:00 p.m., at which time the father
shall call the child and the child shall be permitted to answer
the phone without the mother's intervening.
*-2.
Pursuant to an agreement of the parties through
counsel, when a weekend chosen by the father for his partial
custody sha12 be a three-day weekend (i.e., having a school
holiday falling on a Friday or Monday), the father's visitation
shall extend to that vacation day.
* 3 . With respect to the father's Christmas vacation
period of temporary custody with the child in this year (1995),
the father's weekend custody period for that month shall occur
either at the end of the Christmas vacation period by the taking
. /.5~
of two additional days or at another time during the month in
J( December, at the father's option, but not the weekend commencing
December 22.
4. Because of. the impending birth of the mother's.
child, the weekend commencing January 12, 1995, shall not be
available for the father's partial custody, and he shall select
another weekend for that period.
The hearing previously scheduled for January 3, 1996,
shall remain as scheduled unless counsel cancel the same.
By the Court,
J
~Gregory J. Katshir, Esquire
Counsel for Plaintiff
James J. Kayer, Esquire
Counsel for Defendant
:slr
QPY FROM RECOR~nd
lRUE C. t \ Mieun\O~nry
\n lcstimOiW Wh~~ cc..u11 at ear\\s\oe. ~. rj
aOd~~R~~. t~', .
pr othon<rtaf'f
08~68-1996 12:53
717 2406462
CUt18ERLAND COURT ADt1
P.0l
MARGARET AGRUSO n/k/a
MARGARET READER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACT10N - LAW
JOSEPH J. BECHARA,
Defendant
NO. 9.-0634 CIVIL TERM
ORDER 0' COURT
AND NOW, this 9th day of Augu~t, 1996, upon
consideration of Pla1ntiff/~ Petition tor Emergency Special
Relief/Contempt of Court, and following a hearing at which the
Plaintiff appeared and wa~ represented by Gregory J. Katshir,
Esquire, and at which the Defendant did not appear but was
represented by James J. Kayer, Esqulre,the Court tinds that the
Defendant has intentionally, voluntarily, and willfully tailed
to comply with the Order of court heretotore entered in this
case, and he is consequently adjudicated in contempt.
The Defendant is directed to pay a tine in the
amount ot $300.00, and rea.onable attorney's fee. to Plaintiff's
counsel in the amount of $150.00, and to cause the return ot the
parties' child to the Plaintiff on Sunday, August 11, 1996, at
12 noon at the entrance to Lowe's department store 1n Altoona,
Pennsylvania, on 17th street. Ourinq the forthcoming sohool
1r year, the Defendant's periods of partial custody are reduced to
one weekend every other month pending further Order of court,
and Defendant's periOd of partial custOdy during thQ summer of
1997 and each summer thereatter pending further Order of Court
L
---------------------------------
. ~ 00--09-1996 12:54
~
717 2406462
CU~18ERLANO COURT ADM
P.02
is reduced by an additional two weeks, giving the Plaintiff a
total of three weeks primary custody with the child.
In the event that the Defendant fails to return
the child at the specified time on Sunday, August 11, 1996, to
the Plaintiff, the court will entertain a request tor a sanction
of imprisonment.
J
GREGORY J. KATSHIR, ESQUIRE
900 Market street
Lamoyna, PA 17043
For the plaintiff
JAMES J. KAYER, ESQUIRE
4 Liberty Avenue
earliele, PA 17013
For the Defendant
Way
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Jeffrey A. Keiter, J.D.
Attorney I.D. 15966
Attorney for Plaintiff
226 West Chocolate Avenue
Hershey, PA 17033
(717)533-8889
Attorney for the Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
MARGARET M. READER, FORMERLY
MARGARET AGRUSO
Plaintiff,
v.
JOSEPH J. BECHARA
NO. 634 CIVIL 1992
Defendant,
CIVIL ACTION - CUSTODY
ENTRY OF APPEARANCE
TO THE PROTHONTARY:
PLEASE enter the appearance of Jeffrey A. Keiter, Esq. in
behalf of the Plaintiff, Margaret M. Reader, formerly, Margaret
Agruso, in the above-captioned c
J.D.
Avenue
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