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Home My WebLink About95-06934 " " , " , 'I t,! , " " I 'I ," " I " , " ," 'I " ,. '-I I, I ,Ii " II " , I, , ' ,.,',')' , , " , , , ':1' " " "I" " I, , " " " 1'\ " , , d' " " , !" " , ' " /, " , , '/ I ,\ '1' II " ,i, ., '" i" ,I / ,I " " ,1 I II' " I' " ", " ,I r!f ,.1 III " " ,II \ ", "I " " " , , ' ",I " " , II " , "'II .: ,1 ! , " ,>I , I II;' , '" L : ,I; j: "I ., , " .1 , , I' " " " " " ;.i' , " , , , , , " , , ,I , " I " " I' I , , ," . .-' .. .. ... ... ~~'!f'_"!:_'!O:~ ~...:~~~~~,~:..~~:~ :*.:'-::~!-:'::I!;- ... .. .._~ . . : IN THE COURT OF COMMON PLEAS · , . . OF CUMBERLAND COUNTY · . . . .~ . , STATE OF ~_ PENNA. . . . . . . MARY JO VERBOSKY. * . plaintiff No.~~~&~H, """",,,,,,19 . . .. Vl'l'~lIS ~ . . JOHN A. VERBOSKY. . . Defendant · ! " . ' . DECREE IN * . . . DIVORCE : _ AND NOW, ' ." ' , , , , " ,~nl, , , , /,q~" " 19.96"" it is ordered and ! . decreed that, ,Mary, ,010, V,Ell;hPIl,k,y, , . , .. , , , , , , , " , " , , " , , ., . '. plaintiff, ~ ~ and ' .. .. . " " , ,!o,t~n , ~....~e~'b,~BkY " " " " , " , " " " .. '" defendant. : . are divorced from the bonds of matrimony. . . M . The c;ourl retains jurisdiction of the following claims which have ~ . been raised of record in this action for which a final order has nol yet ~ . been entered; ~ : ' , , , , . , , , !1.Ql)fil, , , , , , , . , , , , , . , , . , , , . , , , . , , . . , , , , , , , . , , , , , , , , , , , , , , , , , , , , , , , , ! ~ . """,."."""","""""""""""""",.,""'; , ~ . .. D yr. c" u (I : ~ . ~,/-lld- ~ . All.. ~cItJ.~ {f tt..k~f, ~~"''''~J? J. I~ ~ ~tjt!t,~c: *'- ~I f 1AL I" .1 ' "/7Prothono.nry IlJ l~ . I. ____............ --. ~~""__"~'" ' M ._--------~~.~~~-_._,*._'~.,~'~~'~.~~~ . ~11-1& t1r./ "J''I' />J ~ 4, .r.1f ~f II'?~ /1~/~-r; df ~ I, , , " 'I , . " ~ .. . , MARY JO VERBOSKY, plaintiff IN THE COURT OF COMMON PLBAS OF CUMBBRLAND COUNTY, PENNSYLVANIA 95-6934 CIVIL TERM v. JOHN A. VERBOSKY, Defendant IN DIVORCE PRAEC~PE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified and Restricted mail on December 8, 1995. (see Exhibit "A"). 3. (Complete either paragraph (a) or (b): (A) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: By the Plaintiff: April 2, 1996 By Defendant: March 20, 1996 (B) (1) Date of Execution of the Plaintiff's Affidavit required by Section 330l(d) of the Divorce Code: 8A1DIS, GUIDO, SHUFF " MASLAND 26 W, HI'" Slml CIIII.Ie. PA (2) Date of Servir.e of the Plaintiff's Affidavit upon the Defendant: 4. Related claims pending: none (',," .~ t.n r,. ',. ~c 'N' 1;:r 0.; ~I) ~r ' .,<j- :;:~' . ':,," " ., I, ;;:..~ ~' ,..:1' 1,~1 , ,/J. , ;uj. fI.t' {:: "':;: C' c.'., , lr\l' t!, Il.;,-: : !'.J_ (J ", ,,,) ,1.')1; t.J 1,1 I, I, , , " '.. In '.- lr.~ N ". ., r.~ " :',... ~i ,,;) 'J;';J ..... ').", , . ...., ~" ,I) ~ j 51," .' ,. , .,:1' .; ;-'1 :-11.- I '..~" tL' (, HI) f', 'U04 " oJ;.. " \'~. .,1 <.> 0) (,J " " " , \ t', " " \ " " " \'1, WHEREFORE, plaintiff requests Your Honorable Court to enter a decree in divorce. Respectfully submitted, Datedl 11-19-".1 MAS LAND Johnn<< 26 W . gh Carl sle, PA 17013 (71'1) 243-6222 Attorney for the plaintiff SAlDIS. GUIDO, SHUFF A MASLAND 16 W, HI'" S...., CarlIII.. PA " I, . COMMONWEALTH or PINNIYLVANIA. COUNTJ' OP Ct./MlEJU.MD . II X verify that the atate.enta .ade in tbi. Complaint are true and correct. I under.tand thet fal.e .tatament. herein are made .ub~ect to the penaltie. or II Pa. C.B. .ection 4'0., relating to un.worn fal.irication to .uthoriti... DATED. --1J-'o?~- q~ ~~.~~a~1 " , , , ' ""J ("i ' .. I , << . ~ ~ ,,1. . ' I - , ) " ',' " ,--' ." " ,1;'1 ') I' " , I Q ~ Q ^ M ~ I~ ~ g=.l \!l , ..- ~ -:'~ V) ~ ~4~j ~ lO :~~; '" !'of) , ,~ It! (~., ~ uJ ~,:\f] \ F II ,Ii: 0 .' ~ ~ ~ VI a <1' " MARY JO VERBOSKY, PLAINTIFF I IN TilE COURT OF COMMON PLBAS I CUMBERLAND COUNTY, PBNNSYLVANIA I I I 95-6934 CIVIL TERM I I I IN DIVORCE VB. JOHN A. VERBOSKY, DEFENDANT JSm'RY OP APPRARAHCB To the ProthonatarYI Please enter my appearance on behalf of John A. VerboBky, Defendent in the above-captioned matter. Respectfully submitted, Date I I/If"/'(C Bri J. puhala, Sr., Esquire Law Offices of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, pennsylvania 17011-4706 108 72655 Tel. (717) 763-1800 CBRTIFICA'l'B OF SBRVICB I hereby certify that I am this day serving a copy of the foregoing ENTRANCE OF APPEARANCE upon the person, and in the manner, indicated below, which service 8atiBfiee the requiremente of the Pennsylvania Rule8 of Civil Procedure, by depositing a copy of the lIame with the united Statea Poet Office at Camp Hill, Pennsylvania, through firet class mail, prepaid and addres8ed ae follows I Johnna Deily, ~squire 26 West High Street Carlisle, PI. 17013 Respectfully submitted, /-j J (}~ , Brian ~. puhala,' Sr., E8quire Law Office8 of Patrick F. Lau~r, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011..4706 lot 52677 Tel. (7\7) 763-1800 Date I I/'~;'i? " " ,,' ", t 0'1 i~ (\J ~ Q :~J <':5$ if .~ r,.I:-.: ~ ", r...~ n ....':.:;, " '\.' ~.,. ~,l'.;-/) , Q:; (\J J--' - .0 ff~I,! -~ fl",." -. "IfE j:!: 411t'.. ", -' J "'r.: ". 'Q {3 0 0\ " 'i " MARY JO VERBOSKY, Plaintif f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 95-6934 CIVIL TERM v. JOHN A. VBRBOSKY, Defendant IN DIVORCE PLAINTIFF' S AFFIDAVIT OF CONSENT ANQ WVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CQDE 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on December 5, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final decree of divorce without notice. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not clai them before a divorce is granted. 5. I understand that I will not be divorced until a divorc decree is entered by the Court and that a copy of the decree wil be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit ar 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 authorfties. DATED: if-] .9"- 'WIlNoJ hl/~ '~;;;. 9:idv~rbosk}', d PlaintTIf SAlDIS, GUIDO, SHUrr " MASLAND 26 w, HI'" SIJIOI c.rt...., PA ,I, I " , 1 , " ,- In ~ u~ . ,"-I to. co :-1) !~ ,....t: ,.- J.!!"" . ' ~ .I :~~ r. "- l~J , . . ..:1' -"1:':] I,. I ,!,,~ /iI, (',.: ""f'll , c. ,;' ~ C.l- ..:: 11., <f) ',; (" Cfi () " " , , " I, I' " MARY JO VERBOSKY, plaintiff IN THE COURT OP COMMON PLBAS OP CUMBERLAND COUNTY, PBNNSYLVANIA 95-6934 CIVIL TBRM v. JOHN A. VERBOSKY, Pefendant I IN DIVORCE OEFBNDANT' S aFP~~A~:.: O,! CONSENT. ACCEPTANCE OF SERVICB AND Mll!!R QP NOTICE OP INTENTION TO REOUEST ~NTRY OF A DIVORCE DECREE UNDER a~ON 3301 (cl OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on December 5, 1995. 2. Defendant acknowledges and accepts service of the Complaint on December 8, 1995. 3. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decr.ee of divorce without notice. 5. 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. 6. 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. 7. I have been advised of the availability of marriage counselling and understand that I may request that the court re~lire counselling. I do not request that the court require couIIselling. SAIDIS, GUIDO, SHUFF Ie MASLAND 16 W, HI&h 5"..., Cull,I.. PA I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made subject to the penalties of 18 Pa. C.S. Secti 4904 relating to unsworn falsifica n aut 0 it es. DATED I 3 /2.0 I q f.. ant are ", ',I' " ~ I,(') t., 0;'..1 ';';; " e, , -i ~~' ')~ c;L .t" ~.', ~.; I.:' .r-J I'. -,p ;'111 fa~~ I : t!(l [CI' ,. " ':';1 " ., ";1,;. { ~.'~ >: ", lI')' '.~I ' ' (.I t,n ()O ,- :7"":'::> c;::::ll { .-' ~ I\;,~ ~~"I . - ;) ,'-i) -, \0. . ~ ,,' ~:,:... i, :.:~ "" "I '" ,:.\ L:~ ;',.::1., . ..:--/) .. I MARY JO VERBOSKY, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 95-6934 CIVIL TERM CIVIL ACTION - AT LAW CUSTODY VB. JOHN A. VERBOSKY, Defendant ORDER OF COURT AND NOW, this -fJ.J) \. \ f1',J-, \o;;l.l~ upon consideration of the , attached complaint, it is hereby directed that the parties and their re~pective counsel ap~ear before JDI(,h~~~:3~~, ~, the concl.Hator, at 3() J, 'YIl.l-j.,t1 IfflL-::'JL.1.'.P. ~, on the ~ day of f/j,-,'{ , 1996 at {f:oot/ .m., for I a Prehearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute 1 or if this cannot be accomplished, to define and narrow the iesues to be heard by the court, and to enter into a temporary order. Either party may bring the child who is the subject of this custody action to the child/children's attendance is not II the conference, but II I' mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. , FOR THE COURT I I 4 ~~ I By:-f1l.u-AuL- Dt'~ ' II Custody Concilia~r ' . YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU ~ I I NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPBONE THE I OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. I I I OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, FOURTH FLOOR CARLISLE, PA 17013 (717)240-6200 I I \ , . j I I \ i \ I I MARY JO VER~OSKY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 95-6934 CIVIL TERM : : CIVIL ACTION - AT LAW : CUSTODY v.. JOHN A. VERBOSKY, Defendant COMPLAINT FOR CUSTODY The Defendant, John A. Verbosky, by and through hi. attorneys, The Law Offices of Patrick F. Lauer, Jr., file. this Complaint for Custody against the Plaintiff, Mary Jo Verbosky, and avers the following in support thereof: " " 1. The Plaintiff is Mary Jo Verbosky, an adult individual ;' " and the natural Mother, who currently reeides at 18 Rockaway Drive, Camp Hill, Cumberland County, Pennsylvania 17013. 2. The Defendant is John A. Verbosky, an adult individual and the natural Father, who currently resides at 40 Mallard Court, Mechanicsburg, Cumberland County, Pennsylvania 17055. I,) 3. The Defendant seeks custody of the following children: , ~ Present Address &lil 13 , , , i Gregory A. Verbosky 18 Rockaway Drive Camp Hill, PA 17Qll D.O.B. 3/2/83 "~,I Sarah M. Verbosky 18 Rockaway Drive Camp Hill, PA 17011 O.O.B. 7/16/93 2 " 1"1 The children were not born out of wedlock. , ' 4. The children are presently in the custody of Mary Jo Verbosky, who currently resides at 18 Rockaway Drive, Camp Hill, Pennsylvania 17011. S. During the past five years, the children reaided with the following persons and at the following addreasesl l!.A.lllg, Addreee Dates Mary Jo Verbosky 18 Rockaway Drive 12/9S-present Camp Hill, PA 17011 Mary Jo Verbosky 18 Rockaway Drive birth-12/95 John A. Verbosky Camp Hill, PA 17011 6. The Mother of the children is Mary Jo Verbosky, who currently resides at 18 Rockaway Drive, Camp Hill, Cumberland County, Pennsylvania 17011, with the subjects of this petition and with her son and daughter. The Father continues to be married to the natural Father, although an action for divorce is presently pending. 7. The Father of the children is John A. Verbosky, who currently resides alone, at 40 Mallard Court, Mechanicsburg, Cumberland County, Pennsylvania 17055. The Father continues to be married to the natural Mother. 8. The Defendant has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 9. The Defendant has no information of a custody proceeding concerning the children currently pending in any court of this Commonwealth. 10. The Defendant does not know of a person not a party to the proceedings, who has physical custody of the children or claims to have physical custcdy or visitation riqhh with respect to the children. 11. The best in.terests and permanent welfare of the children will be served by qranting the relief requested to the Defendant. WHEREFORE, Plaintiff respectful:y requests that this Honorable Court enter an Order granting custody, partial custody, or visitation of the children to the Petitioner and natural Father, John A. Verbosky. Respectfully submittod, J anne H. Berezn cki, Esquire W OFFICES OF PATRICK F. LAUER, JR. 2108 Market Street, Aztec Buildinq Camp Hill, Pennsylvania 17011-4706 S.Ct. ID# 68735 Tel. (717) 763-1800 DATED I '/, II' ft. MARY JO VERBOSKY, I IN THE COURT OF COMMON PLEAS OF plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I VI. I No. 95-6934 CIVIL TERM I JOHN A. VEIl20SKY, I CIVIL ACTION . AT LAW Defen.1lant I CUSTODY VBRIPICATIO!l I, John A. Verbosky, state that I am the Defendant in the above-captioned case and that the facts set forth in the above Complaint for Custody are true and correct to the best of my knowledge, information, and belief. I realize that false statements herein are subject to the penalties for unsworn falsification to authorities under 18 Pa. C.S. S 4940. I@~~ Datel ~fjtj? MARY JO VERBOSKY, I IN THE COURT OF COMMON PLEAS OF naintiff I CUMBERLAND COUNTY, PENNSYLVANIA I va. I No. 95-6934 CIVIL TERM I JOHN A. VERBOSKY, I CIVIL ACTION - AT LAW Defendant I CUSTODY CERTIFICATE OF SERVICE I, Jeanne H. Bereznicki, Esquire, do hereby hereby certify that a true and correct copy of this COMPLAINT FOR CUSTODY was served upon Plaintiff by first class mail on the below date by placing same in the united States Mail at Camp Hill, Pennsylvania, and addressed as followbl Johnna J. Deily, Eequire P.O. Box 560 Carlisle, PA 17013 DATBDI f /I- 91 a:~AflY '" 96 JUN -5 PH 1.122 CUMt1Et'U;;~iJ COUNTY fENNSYUtMl.\ ," , " , ',. .' .. Mil, , fj'J ~F " MARY JO VERBOSKY, Plaintiff VS. ) I ) I ) ) ) I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA r JOHN A. VEABOSKY, Defendant CIVIL ACTION. LAW NO. 95-6934 CIVIL TERM I" '" :.1' JUDGE PREVIOUSLY ASSIGNED: None (No Judicial Conflicts) CUSTODY CONCILIATION CONFERENCE SUMMARY REPOR"( ,I,' I',' IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL I" 1'1 PROCEDURE 1915.3-8/bl, the undersigned Custody Conciliator submits the " 1 following report: 1. The pertinent information concerning the child/ren) who l!l/ara) the subject of this IIligatlon is as follows: NAME BIRTHDATE CURRENTLY IN CUSTODY OF Gregory A. Verbosky Sarah M. Verbosky 2 March 1983 16 Julv 1993 Plaintiff Plalnliff 2. A Conciliation Conference was held on 30 May 1996, and the following individuals were present: the Plaintiff and her attorney, Jeanne B. Wigbeils, Esquire; Ihe Defendant appeared wilh his attorney, Johnna J. Deily. Esquire. 3. Items resolved by egraement: See attached Order. 4. Issues yet to be resolved: An ullimate custody and visilation schedule. 1 6. The Plalntlff'l position on custody Is as follows: 5tie ettached Order. 6. The Defendsnt's position on custody Is as follows: See attached Order. 7. Naed for separate counsel 10 represent children: Neither perty requested end the Conciliator does not believe any Is necessar'f'. 8. Need for Independent psychological evaluation or couneellng: None requested. Date: 3 Juna 1996 . ,? j} I. Mlcheel L. Bangs Custody Conciliator 2 I ! ,I I' ," MARY JO VERBOSKY / Plaintiff I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I I No. 95-6934 CIVIL TERM I I CIVIL ACTION - AT LAW I CUSTODY VB. JOHN A. VERBOSKY/ Defendant II 'I I I I I , I , I I I ORDER OF COURT AND NOW, thia~^{L day of ~/ 1996/ upon request of the Defendant/ it is hereby directed that the parties and their respective counsel appear before Michael Bangs / Esquire, the conciliator, at 302 South 18th Street/ Camp Hill, pennaylvania, on the .Y1IJ-, day of ((.l'-5Iud / 1996/ at _ J:Wf .m./ for a re-conciliation conference. At such conference, an effort will be made to resolve the issue in dispute; or if this c~nnot be accomplished, to define and narrow the issues to be heard by the court/ and to enter into a tempol'ary order. Either party may bring the children who '! are the subject of this custody action to the conference / but the children'. attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. BYI FOR THE COURTI , J... 1:) ~ . I~l.t' (;l I.. . ~__. Ji'L, .tV ) Michael Bangs, Es~ir'i 1'-' eCI Jeanne B. Wigbels, Esq., for the Defendant Johnna J. Deily, Esq., for the Plaintiff .\;1 ", FILEo-oFrlCE OF IV"~ ITr-1 ""'trlTfP.Y " 96 JUI. -0 Pi\ ,,: \ '.5 CIJ"'.I' ".,," l'ill.il:itJ.i. J u ,J...llf ( PENi ~~YLVi:,i~1A ., ..;, ? ..9~ tAj. '0/7 /11Jvt .~ fiI1 y~ ~ J I?.,k'~ '1. 9 . 9to '1l~ /I,,,,:il?/ ~ 4 ,(Ld. .., ,. I} . 9t ~;dM.fkl':" 111. ~ P , , " ' I " I , . " . ; .. \i III :1 il I \ \' I I I \ I I II I - '. MARY JO VERBOSKYr . IN THE COURT OF COMMON PLEAS OF plaintiff . CUMBERLAND COUNTY, PENNSYLVAtlIA . VB. I NO. 95-6934 CIVIL TERM . JOHN A. VERBOSKY, . CIVIL ACTION - AT LAW Defendant . CUSTODY CBRTIFICATE OF SBRVICB I hereby certify that I am this day serving a copy of the foregoing Order upon the person, and in the mannsr, indicated bolow, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of the same with the united states Post Office at Camp Hill, pennsylvania, through first class mail, prepaid and addressed as follows I \' Johnna J. Deily, Esquire Attorney for Plaintiff 26 West High Street Carlisle, PA 17013 Respectfully submitted, I 1\ , ,~f ( J anne B. wigbeIs, Esquire Law Offices of Patrick P. Lauer, Jr. 2108 Market Street, Aztoc Building Camp Hill, Pennsylvania 17011-4706 Tel. (717) 763-1800 Date. . . " ."YfJl/\ V~rf)/l5~ v ." {Yltift) J0 (j,'rhc,)<.iJD f d It CI en ant Plaintiff r IN 'l'HB COUR'l' Oz.' COMMON PLEAS OF rCUMBERLA1m COUNTY, PENNSYLVANIA r :CIVIL AC'l'ION - LAW . . :NO. (,'I '),,/ CIVIL : CUSTODY /VISITATION 19r/5 ORDER OF COURT AND NOW, this 17fl, (date) III IV , upon consideration of the attached complaint, it is hereby directed that the parties and theil" respective counsel appear before, / II I I' lit) Y / /)iJ,I III)'} --' the conc;f.li4tor, at ~(.I J .' I II (/ Iii) I I!' / ',' on the QCJ III _day of" , l' , at ,(t) l'iYl M., for a prehearing CU tody 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. Ei ther party may bring the child who is the subject of this custody action to the conference, but the child/children's attendance is not mandatory. Failure to appear at the cOllference 'may provide grounds for entry of a temporary or penuanent order. FOR 'l'HE COUR'l': By:!) IIi1 A~i ( flU I,l<i.v //11' Custody ConcIliator YOU SHOULD 'l'AKE 'l'HIS PAPER 'l'O YOUR LAWYER AT ONCE. IF YOU DO NOT HAVB A LAWJfER OR CANNO'l' AFFORD ONE, GO TO OR 'l'ELEPHONE THE OZ."FICE SE'l' FOR'l'H BELOW 'l'O FIND OU'l' WHERE YOU CAN GE'l' LEGAL HELP. OFFICE OF 'l'HE COURT ADMINIS'l'RATOR COUR'l'HOUSE, FOUR'l'H FLOOR CARLISLE PA 17013 (717) 240-6200 I \ I I " I , I II \ , i' JOHN VER20SKY, Petitioner I IN THB COURT 011' COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I I CIVIL NO. 95-6934 I VS. PETITION FOR CIVIL CONTEMPT MARY JO VERBOSKY, Respondent ~OTICB AND ORDBR TO APPBAR Legal proceedings have been brought against you alleging you have wilfully disobeyed an order of court for visitation. If you wiah to defend againat the claim set forth in the following pages, you may but are not required to file in writing with the court your defenses or objectiona. Whether or not you file in writing with the court your defenee.. or objectiollr Vn\1 muet appear in pers9n in court on ~~~rtr~~I~o.d~~ ~~~~t~mb8ria~~9~~u~~i~~urthoCs~~' in IF YOU DO NOT APPEAR IN PERSON, THE COURT MAY ISSUE A WARRANT FOR YOUR ARREST. I I I \ 'I If the court finds that you have wilfully failed to comply with its order for visitation, you may be found to be in contempt of court and committed to jail, fined or both. 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. I il \1 Court Administrator 4th Floor, Cumberland County Courthouse One Courthouee Square Carlisle, PA 17013 phonel (717) 240-6220 BY THE COURTI '2.4Lt-~J. ~/~ r-f1 J. JOHN VERBOSKY, I IN THE COURT OF COMMON PI.EAS OF Petitioner I CUMBERLAND COUNTY, PENNSYLVANIA , I ve. I CIVIL NO. 95-6934 I MARY JO VERBOSKY, PETITION FOR CIVIL CONTEMPT Respondent PBTITION J"OR CIVIL CON'rBMPT FOR DISOBBDIBNCE OF PARTIAL CUSTODY/VISITATION ORDBR AND NOW Gomes the Petiti.oner, John A.. Verbosky, by and through his attorney, Jeanne B. Wigbels, Esquire, and l'espectfully represents the following in support of this Petition. 1. That on June 5, 1996, the Honorable Edgar B. Bayley entered an Order awarding Petitioner visitation of the minor children, Greg and Sarah Verbosky. A true and correct copy of the Order is attached to this Petition. 2. Respondent, Mary Jo Verbosky, has willfully failed to abide by the Order in that she refuses to allow Petitioner access to his children on the dates and times submitted to her by him pursuant to the Order. True and correct copies of Petitionerrs work schedule and visitati.on schedule are attached to this Petition. (a) Petitioner submitted a visitation schedule and work schedule to Respondent for the period of June 17, 1996 through June 24, 1996, in accordance with the Order. (b) Respondent received the schedules and illllllediate1y informed Petitioner that he had to meet with her on June 1, 1996, to discuse the visitation schedule he had prepared. I I I I I I I I I I I i I I i I I She indicated that all drop off and pick up times and visitation days must be discussed and appr.oved by her prior to her allowing him visitation with the children. (c) During their June 1, 1996 meeting, Respondent stated that she did not approve of the schedule. An argument ensued and Respondent ordsred Petitioner off the property in front of their son, Greg. (d) Petitioner called Respondent later that evening and she informed him that he would not be allowed to see the ohildren until her attorney reoeived a copy of his work schedule and visitation schedule. (e) Copies of the schedules were forwarded to Respondent's attorney by undersigned counsel on June 3, 1996. (f) The children were soheduled for visitation with Petitioner June 24-25, 1996, but Respondent indicated that the echedule WAS too hard on the ohildren and that Greg did not want to go to Petitioner's on those scheduled dates. (g) The children were scheduled for visitation Idth II Petitioner June 26-27, 1996, but neither the children nor 'I I Respondent were home at the scheduled pick-up time. Respondent later informed Petitioner that she took the children to her parents for dinner and that they wanted to go swimming. (h) Respondent withheld visJ.tation scheduled with Petitioner July 2, 3, 4, 5 and 8, 1996. . , WHBR!lFORB, Petitioner reque.tl th,l. Honorable Court to hold R.lpondent in oontempt of oourt and that appropriate men.unl b. taken to prevent future violation. of the Order. Re.peotfully lubmitted, Datel 7/7/96 (;} L ~ nne B. wigbe s, Blquire 08 Market Street, Azteo Building Camp Hill, Pennsylvania 17011-4706 PA S.Ct. I.D. No. 68735 Phonel (717) 763-1800 " I I ,\ I II' I ! JOHN VBRBOSKY, Petitioner . ;tN THB COURT OF COMMON PLBAS OF . CUMBERLAND COUNTY I PENNSYLVANIA . . CIVIL NO. 95-6934 . . PETITION FOR CIVIL CONTEMPT . VB, MARY JO VERBOSKY, Respondent II II \ I I I I I i I CERTIPICATE OP SERVICe I hereby certify that I am this day serving a copy of the foregoing Petition upon the person, and in the manner, indicated below, which service satisfios the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of the same with the United States Post Office at Camp Hill, Pennsylvania, through first class mail, prepaid and addresoed as follows I Johnna J. Deily, Esquiro Attorney for Plaintiff 26 West High Street Carlisle, PA 17013 Respectfully submitted, J anne B. Wigbel , Esquire w OfficeR of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 Phone I (717) 763-1800 Date. ;:;11 qc " . 3. Mothlr Ihlll hlvl thl chlldrln for two Ilplrltl wllkl of vloltlon, on. to oocur from Junl 8th to June 18, Ind the othlr to ooour lome time during the month of Augult. Mother will provide Flther with thet Ipeclflc week thirty daYI In advance. 4. The partlel Ihlll Ittempt to work out a Icheciul. over the . lohool year. In the event that the partl.. cannot work out a Ichedull for the Ichool year, either party may petition the court for anothlr conciliation. BY THE COURT, Lf ~ 11. 13a.~ J. Johnna J. Deily, Elqulre Attomey for Plaintiff Jelnne B. Wlgbelll, Eaqulre Attorney for Defendent mlb '1111"11, " 11/, , \ I " , "."'1 ) " , " ;' . . .' '} /' , '--) \ TRUE f>>f'Y PROM ,.i!CiMID ' In T" whnlf~,1 "'" unto-1irItMI ....~~~~. .alce..; ~. ~,,,'" f " ,., .' .. ... '. . ." ., ".' 15. Th. PI.lntlff'. po.ltlon on cu.tody I. I' follow.: S..ettlchld Order. ~:", . " e. Th. Defendln~'. pOlltlon on cu.tody I. a. followl: S.. attlchld Ord.r. .. 7. N.ed for IIplrate coun.el to repr...nt children: N.lther Plrty requ.tted and the Conciliator do.. not b.lI.ve Iny I. n.c....ry. 8. N.ed for Ind.pend.nt p.ychologlcll .v.lultlon or counllllng: " ,.,.~ " , , requ..ted. . ~~'..~' ,. Non. . Dete: 3 Jun. 1 996 I Mlchlll L. Bing. Cu.tody Conclllltor , , " , . ' 2 N G . WORK SCHED~LE v1 A A E MENT "10~~'" ~f-I ~ ..... L,,;., ~/Y POIITION DAT HAM. ~ .....IV T......y WeoI_V ThunRy "lIItv lIi"IY . ( t ,. J.. . '%'I/' '&~' i. I t$' ;Z~ 2..7 Z/r ~: 'T5~ DAaN~\..\... S-'- (,.-'-' '1-. '9-(., I "1 -, q., .",' u. )(. . -- ~'~~lI: r NAil ~ -:r /:I", 10-(1) 'I.. {.., - c. (... . '-- ~. (,. I '""" I' )( _'T71&.-l..--J '" -f- <.:j.(.. cr - G,. II-I ''''i'''-'-' \, ,.J... x. x "'i-I? c::. .. I(fi)~' ~~;.~ c~.... ("'&\'I .,It l~ -3 n~\,l(), ...~<" b z;. DA~~l.. I \0 ~:" t.-' <- ')<. ~ 1-7 '9-7 s.c:.- . .M" Q.. c::_:tA 'M. "'1.(" 1-G::, "'1-7 s-/ ><. Q.7 )( .- _""tI)I~ 5-c. )( I (...- '- -~( b' c.. ~-c. ~ ~fl.NtlL MAILL'iA -"",')...1 ~ ..., ~ <'f /nC! ill::! 11"-- I.:!. LA..." //- I S-(. t:.-L Mr:t;T.~ <"/-7 Cf-c.. 5-1'7 ')( IO-l!. )<. G...L ",.c:.- >< "'1-7 ')(, "l-,"," '7'.(.... ')(,.' ~ -<:::. ,". '- S-:-c. .. 14 /~ I~ 1-(.) I~ I.f'-' Z-'l:l\J!l DAl2-::l GI--L )<,. '1- '" (d' L It:..- c:... -,< "1-(.. '1.7 A A ^, f2-.aA IO-A ')( '1.(", '1-G::. q-" .1- \ )( .5.1", ..:::Jb ~ e:,.(... ".,- ")( )( (.,.. '- (",.C- 5~C- \\'J z.. T' zz.. 2..3 2'-1 Z~ .e ~ 'Z. -7/ DAr.2J..l Co I ID - B (..-(.. x ole,.) (. - L .<;"- c:.. """TJT'. I ~ .. (.. t'\A;L.GTA )( 'l -(.. '--{,. " . c:.. '><' ~.,", 10(-7 . -...:ro~ S-C- .1 - 1 )( 'X ""l-b <:j.t. '1-~ '5"-I"l.. - l:Zr >~ 3DCfJ (;.,-, 'lI ::5 2.lj z. ~Aa~Gl.L-- .5'~ X "'-'- _/:."'S'" 1\-\ <J., (.. -t'o _-5-,"2. "'- M Ar<.t..I.A 1C)''6 "l.(, ')(. '>t!':'~, <'I -b "'/- ~ ...,-7 [VALl j.roJ ~ '-- '"t'D ~ )( I_-C.!G,,-C G.-to \I. t:,,-c. '5-c:.. ft'cJuP J.1>~oP 6Fi--~A~u(e.. ... 7..q 'j)/Ij)f (} F,r.;.lt : IS' p,i.k. t..r- " " 'IS- 2~ Dl1.i:for,;q: /, f,'d up" L" ',yS- J\ .l~ D(l..CfOFf~t:6'5 fici- ur-~W5 ji zq; ~p.or oFf- /0:.30111>>'1 l." fltt.. "p ~: OC> RCLtf oFF,/:30 ljJe, ~o Pic)< oe ~: 30 Df2-q) DJ-( '1.'30 'iJI'IJsJ p,q..up"3no . TYlo{JO FF .JliJy tD 5;~) , ,., u-Iy 3R~ f,'c:.klJp- ,'3 ~'3 c>' .." p.. . . Daoe DFF 'I,' 3 0 .::July '1"1\ ft"C}:. op 1'6:30 . D(lop M-r. ~; 3 0 UJys1/.. P;'[((JI~ ~:3() l.Y~oFF 5;,D 6U1yb1t ~"().\)(.)~jJO t'fJ.cf (J f1"P .J\1ly '6 ~ 'A:!) ~ f,'cj.l)e -(D;v'5" .:JlJl'( 91'\ ()(1.ofDr{"'6~5"' Pll~I)P-6:~) ~(/.l)f6Fr-::.1J'tI^ 5:w ..:rv1y11, P;c.KoP-g,"'D liA~foFF -5":30 4vl 13/1, flil~j.(Vr-~:30 Y/)tbfoFP- '1,'3(.) . . , , 'I .. , , not heve coneecullve days off and those days off occur during the school week, then ha shell heve the children from when they are released from school unlll 8:00 p.m. B. In Ihe evsnt that Iha Falher has days off on tha weekends that are consecullve, Ihen he shall havEl Iho children 'rom 8:30 a.m. unllllhe following day at 8:00 p.m. 3. Mothar tradillonally works every third weekend of the month. During the weekends thaI MOlher works, Father shall hava the children, if he is avallsble and nol at work, from 8:30 a.m. until 6:16 p.m., at which lime he will return the children 10 Mother's residence. 4. During Ihe school week, jf Falher is available and off from work, he may pick up Sarah at Ihe day care and return her to MOlher's house no later Ihan 6: 16 p.m. Father shall confirm that he plans 10 pick up Sarah from day care by lelephoning MOlher and leaving I!I message at work. This will also, of course, bo confirmed by his work schedule which will be dealt wilh hereinbelow. 6. The parties will altern ale the major holidays, Ihose holidays being defined as Thanksgiving, Easter, Memorial Day, Fourth of July, and Labor Day. This allernating schedule will begin with Mother having Thanksgiving in 1996 and shall alternate Ihereafter. e. The Christmes holldey will be divided Into two segmente. Segment A shsll be from 12:00 noon on 24 December until 12:00 noon on 25 December, while Segment B shall be from 12:00 noon on 25 Decernber until 12:00 noon on 26 December. Mother shall heve Segment A in 1996 end all even-numbered yeers thereefter and Segment B in 1997 end all odd. numbered years Ihereafler. Father shall have Segment B In 1 996 and all even-numbered years thereafter and Segment A In 1997 and all odd-numbered years thereafter. 7. The parties understand that this schedule Is based upon Father's work schedule. Father will provide Molher with his work schedule as soon as illo available to him. l EDGAR B. BAYLE ,J. Johnna J. Deily, Esquire Attorney for Plaintiff ~"-.... m~...l...( I Cfllo 1%. ...\,f, Jeanne B. Wigbells, Esquire Attorney for Defendant mlb mm'OFFlCE cr' n Ii "'0 '?'()I.:OT/J1Y % ~rl' -6 t.il 9: ~I, '-'lJI" " 'j ,', '! "Y "" ',;! :'':I~. I ~ ,I ,~\...h\;1 "'.;I ,i~~ YLVN~I,'\ I , , , , ',' , , " " , , , " , , , MARV JO VERBOSKV, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 95-6934 CIVIL TERM JOHN VERBOSKY, Defendant ClJSTODY /VISIT A nON JUDGE PREVIOUSLY ASSIGNED: The Honorable Edgar B. Bayley CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Concilietor submits the following report: 1. The pertinent Informallon concerning Ihe child(ren) who Is(are) the subject of this litigation Is as follows: NAME BIRTHDATE CURRENTLY IN CUSTODY.QE Gregory A. Verbosky Sarah M. Verbosky 2 March 1983 1 6 July 1993 Plaintiff Plaintiff 2. A Conciliation Conferenee was held on 29 August 1996, and the following individuals were present: the Plainliff and her attorney, Johnna .J. Deily, Esquire; the Defendant appeared with his attorney, Jeanne B. Wigbells, Eequlre. 3. Items resolved by agreement: See attachad Order. 4. Issuea yet to be rasolved: See attached Order. 1 VB. I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I I No. 95-6934 CIVIL TERM I I CIVIL ACTION - AT LAW I CUSTODY MARY JO VERBOSKY, Plaintif f JOHN A. VERBOSKY, Defendant ORDBR OF COUR'!' AND NOW, this -..J l," 1'1,1'\" J , upon consideration of the attached Requeet for Re-Conciliation, it is hereby directed that the parties and their respective counsel appear before (VII (~..t I L. g.. , the conciliator, at '.~() J " Is .Ih <)1, ("1111' 11'// -- -, I) , on the J~11, day of {,', ),r'-lC,r '/ , 1997 at ,J ,(VI, . , .m., for a prehearing 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 issuea to be heard by the court, and to enter into a temporary order. Either party may bring the children who are the subject of this custody action to the conference, but the children's attondance is not mandatory. Failure to a,ppear at the conference may provide grounds for entry of a temporary or permanent order. ~~~ TH~/l~~:;// / ~"H~klt 'J< 4- O~i./ Custody Conciliator I~I YOU SHOULD TAKB THIS PAPBR TO YOUR LAWYBR AT ONCB. IF YOU DO NOT HAVE A LAWYBR OR CANNOT AFFORD ONB, GO TO OR TBLEPHONB THB OFFICB SIT FORTH BBLOW TO FIND OUT WHllRS YOU CAN GBT LEGAL HBLP. OFFICB OF THB COURT ADMINISTRATOR COURTHOUSB, FOURTH FLOOR CARLISLE, PA 17013 (717) 240-6200 , . "I;, I I ! MARY JO VBRBOSKY, plaintiff IN THE COURT OF COMMON PLBAS OF CUMBBRLAND COUNTY, PBNNSYLVANIA No. 95-6934 CIVIL TERM VB. JOHN A. VBRBOSKY, Defendant CIVIL ACTION - AT LAW CUSTODY RBOUBST FOR RB-CONCILIATIOH The Defendant, John A. VerbosKY, by and through his attorney, Jeann~ B. Wigbels, Esquire, files this Request for Re-Conciliation of the above-captioned Action in CustodYI 1. The Plaintiff ie Mary Jo VerbosKY, an adult individual and the natural Mother, who currently resides at 18 Rockaway Drive, Camp Hill, cumberland County, Pennsylvania 17013. 2. The Defendant ie John A. Verbosky, an adult individual \ I I and the natural Father, who currently resides at 113 South Third \\ II 1\ \i ,I II I' II ! , \1 II i I. Ii I; Street, Apt. 1, Lemoyne, PA 17043. 3. The Defendant seeks re-conciliation regarding following children I ~ Present Address A9!l Gregory A. VerboBky 18 Rockaway Drive Camp Hill, PA 17011 O.O.B. 3/2/83 13 Sarah M. VerboBky 18 Rockaway Drive Camp Hill, PA 17011 D.O.B. 7/16/93 3 The children were not born out of wedlock. the 4 . The children are prelently in the cU8tody of Mary Jo Verb08ky, w~o currently reside8 at 18 Rockaway Drive, Camp Hill, Pennlylvania 17011. 5. During the past five years, the children resided with the following persons and at the following addresse81 lf~ Addreu Dates Mary Jo Verbosky 18 Rockaway Drive l2/95-pre8ent Camp Hill, PA 17011 Mary Jo Verbosky 18 Rockaway Drive birth-12/95 John A, Verbosky Camp Hill, PA 17011 6. The Mother of the children is Mary Jo Verbosky, who ourrently resides at 18 Rockaway Drive, Camp Hill, Cumberland County, Pennsylvania 17011, with the subjects of this petition, her son and daughter. The Mother is divorced from the Father. 7. The Father of the children is John A. Verb08ky, who ourrently reside8 alone, at 113 South Third Street, Apt. 1, Lemoyne, Cumberland County, Pennsylvania 17043. divorced from the natural Mother. The Father is 8. The moat recent Order of Court regarding this matter is dated September 6, 1996 (attached). II I 9. The following changes in circumstance have occurred slnce the September 6, 1996, Order of Courtl (al Defendant's work schedule has changed 8ubstantially. I I (bl Plaintiff has refused visitation on various Clccasions. " , , I MARY JO VERBOSItY, I IN THE COURT OF COMMON PLBAS OF plaintiff I CUMBBRLAND COUNTY, PBNNSYLVANIA I v.. I No. 95-6934 CIVIL TBRM I JOHN A. VERBOSI<.Y, I CIVIL ACTION - AT LAW Defendant I CUSTODY VJRIPICATION I, John A. Verbosky, state that I IlI\I the Defendant in the above-captioned case and that the facts set forth in this document are true and correct to the best of my knowledge, information, and belief. I realize that false statements herein are 8ubject to the penaltie8 for unsworn falsification to authoritie8 under 18 Pa. C.S. S 4940. ..t..l to/'ll " ~1 ~. , . ... ,,\ I '~.' _' ., tjj' , '''1''',1 1il"',I:'\ l){~,\:A".l ~H ..,',~" h.~ II' "{i'.(.'~ ' l ' MARY JO VERBOSKY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 95-6934 CIVIL TERM CUSTODY /VISITATION va. JOHN VERBOSKY, Defendant AND NOW, this . ~ ORDER day of ~f-t.A.""" 1996, upon receipt of the Conciliator's Report, It appoarlng Ihat the porties have agreed to the terms end provisions of this Order which was dictated in their presence and approved by them and thalr counsel, it is hereby ordered and directed as follows: 1. The partlea shall share legal custody of their minor children, Gregory A. Verbosky, d.o.b. 2 March 1983, and Sarah M. Verbosky, d.o.b. 16 July 1993. 2. Mother sholl have primary physical custody of the children subject to periods of partial custody and visitation with Father in accordance with the following: A. Father shall have the children on his days off from work. In the event that the days off are consecutive end during the school week, then he shall have the children from when they are released from school overnight and will return them the following day to school or day care. If Fatrer does , ' ~, , " '.. -\ " ~lll . ,'1'1' .',".,; \'1 ';/i~ '" I. :;,~" ,;,!I,~"", '.. 'I "/,' ~Ji\~, "\' ..~\o~".!J ,.J rr\~'r..J'\'\7<'''' ,,'""l :i\c'J'. ..'- l' ", .I" "I, i ' ~, not heve consecutive deye off end those days off occur during the achool week, then he shell have the children from when thay ere released from school until 8:00 p.m. B. In the event that the Father has days off on the weekends that are consecullve, then he shall have the children from 8:30 a.m. unlil the following day at 8:00 p.m. 3. Mother traditionally work'} every third weekend of the . month. During the weekends that Mother works. Father shall have the children, if he is available and nol at work, from 8:30 a.m. until 5: 15 p.m., at which time ha will return the children to Mother's residence. 4. During the school week, if Father is available end off from work, he may pick up Sarah at the day care and return her to Mother's house no iater than 5: 15 p.m. Father shall confirm that he plans to pick up Sarah hom day care by telephoning Mother and leaving a message at work. This will also, of course, be confirmed by his work schedule which will be dealt with hereinbelow. 5. The parties will alternate the major holidays, those holidays being defined as Thanksgiving, Easter, Memorial Day, Fourth of Juiy, end Labor Day. This alternating schedule will begin wllh Mother having Thanksgiving in 1996 and shall alternate thereaftor. r po; \ ,.,,'~ '.', "" , ,"r,' . " ,'I '.,t'J'rJ:, '; ,'"I. "'',c,''('',j,,, , {ti"j"l/:\j,'l. . 'X,) ,~,', ,." I '.",il.1 <tJI!~lt, j \~, ,'I. ,.' l:i)\~,I" .~l);,: " ' 8. The Chrl.tmee holldey will be divided Into two aegmentl. Segment A Ihell be from 12:00 noon on 24 December until 12:00 noon on 26 December, while Segment B shall be from 12:00 noon on 25 December until 12:00 noon on 26 December. Mothar ehall heve Segment A In 1996 and all oven-numberad vaars thareafter end Sagment B In 1997 and all odd-numbered years thereafter. Fether shall have Segment B in 1996 end all evan-numbered years thereafter . and Segment A in 1997 end all odd-numbered years thereafter. 7. The parties understand that this schedule Is based upon Father's work schedule. Father will provide Mother with his work schedule as soon as It Is available to him. BY THE COURT, 151~~'~ EDGAR . BAYLEY, ~. Johnna J. Deily, Esquire Attorney for Plaintiff .Jeanne B. Wlgbells, Esquire Attorney for Defendent TRUE COpy FROM RECORD': In Testimony '.,h ". of, I h.,c unto set my hand and 'he seal of SJ;d Court at Carlisle, Pa. This """I...~. day of. J,.rt.. 19tJ/ -- ,. ..." .~.~. '-~~".~~;h~ti~~' "" mlb MARY JO VERBOSKY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA va. NO. 96.6934 CIVIL TERM JOHN A. VERBOSKV, Defendant CIVIL ACTION - LAW CUSl'ODY ORDER AND NOW, this "2-g day of Jilwcu..... , , 1 997, upon receipt of the Conciliator's Report, It eppearlng that the parties have agreed to the terms end provisions of this Order which was dictated in their presence and approved by them and their counsel, It is hereby ordered and directed as follows: 1. The parties shall share legal custody of their minor children, Gregory A. Verbosky, d.o.b. March 2, 1983, and Sarah M. Verbosky, d.o.b. July 16, 1993. 2. Mother shall have primary physical custody of the minor children subject to periods of partial custody and visitation with Falher In sccordance with the following: A. Every other weekend from Saturday at 2:30 p.m. until Sunday at 8:30 p.m. This alterneting weekend schedula will begin on February 15, 1997, and will alternate thereafter. It Is the intllntion thallhis allernating weekend echedule will coincide with the weekonds in which Mother is working. B. Father ahall have! both children every Tuesday evening from 4:30 p.m. until 8:30 p.m. C. Every Thursday evening, Father shall pick Gregory up end have him from 4:30 p.m. until 9:30 p.m. D. Father is also enlitled to pick up Gregory in order to take him to practice and will return Gregory after practice on any other day that is not covered by Paragraph 21A). IB). or IC). 3. The parties' son Gregory is to be confirmed on April 19, 1997. Father shall have Gregory and Sarah from after the confirmation service until 4:00 p.m., at which time he will return the children to Mother's residence. 4. The parties will alternate Ihe major holidays, those holidays being dafined as Easter, Memorial Day, Fourlh of July, Labor Day, and Thanks(}ivlng. This alternating schedule will begin with Father heving Easter in 1997, and shall allernate Ihereafter. 6. The Christmas holiday will be divided into two segments. Segment A shall be from 12:00 noon on December 24th until 12:00 noon on Christmas Day, while Segment B will be from 12:00 noon on Christmas Day until 12:00 noon on December 26th. Mothar shell , . have Segment A in 1 998 and all even-numbered years thereafter and Segment B In 1997 and all odd-numbered years thereafter. Father shall have Segment A in 1997 and all odd-numbered years thereafter and Segment B In 1998 and all even-numbered years thereafter. 6. The parties egree that they will make every effort not to smoke in the presence of their doughIer. 7. The parties are also directed to make Ihemselves and their minor child Gregory availeble for counseling/mediation sessions with Stanley E. Schneider, Ed.D. The purpose of these sessions is to determine en appropriate schedule for Gregory and to work out any difficulties that the parties are having and Gregory is having with the custodial arrangement. The costs of Ihis counseling/mediation is to be shared equally by the parties. BY THE COURT, /l , Johnna Deily, Esquire _ ~.... ~tl .;J/:llll'l1. Jeanne' B. Wig bells, Esquire .J. f' mlb MARY JO VERBOSKY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA va. NO. 95-6934 CIVIL TERM JOHN A. VERBOSKY, Defendant CIVIL ACTION - LAW CUSTODY JUDGE PREVIOUSLY ASSIGNED: The Honorable Edgar B. Bayley CUSTODY CONCILIATION CONfERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(bl. tha undersigned Custody Concilialor submits the following report: 1. The pertinent information concerning the chlld(ren) who is(are) the aubject of this litigation is as follows: NAME BIRTHDA TE CURRENTLY IN CUSTODY OF Gregory A. Verbosky Sarah M. Verbosky March 2, 1983 July 16, 1993 Plaintiff Plaintiff 2. A Concilialion Conference was held on February 13, 1997, and the following individuals were present: the Plaintiff and her attorney, Johnna Deily, Esquire; the Defendant eppeared with his attorney, Jeanno' B. Wigbells, Esquire. 3. Items resolved by agreement: See attached Order. 4. Issues yet to be resolved: See ellached Order. ~~1t~~YIVli!tHn,,1.':-,' ",/"111'-(,,,' .'tH',T' ,"(_qJ,!ltJitl:-~~~;tt.,V'\i;'d:,';}--_'_-lTf , - . / - '1"'I;-"-:"'r';;_I'r::".i--;:}~I~---'~--'-;';-- ,i,i"l_-f',t 'I , . 6. The Plalntlff/8 p081tlon on cU8tody 18 a8 follows: See attached Order. 6. The Defendant/s p081tlon on custody Is as follows: Sea attached Order. 7. Need for 8eparete counsel to represent chlld(ren): Neither party reque8tlld. 8. Need for Independent p8ychologlcel evaluation or counseling: None reque8ted and the Conciliator does not b"lIeve any Is nece88ary. Date: February 25, 1997 ~. , . ",,('" {kvt.'"V (I-" c~r') Mlc sel L. Bang8 CU8tody Conciliator ,-I, I. (i 10,,', ' 1;'-;, L':- i.i.' {! /.;;.\ l;'1~-~ r. '. I, ' , , . ~ , . .t.' ~. , , "" ." , ." '1 4 F '" 'I I He~e~ .!li!~~ :Iii E'E .. ~!~! ~ I . ~g !Un ~ Uu " ' J;. 'f, , ,. , . '. . . ,J ~.:.r AUli ~:; i991 . '" ~ . , MARY JO VERBOSKY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERI,AND COUNTY; PENNSYLVANIA NO. 95-6934 CIVIL TERM CIVIL ACTION - LAW CUSTODY v. JOHN A. VERBOSKY, Defendant ORDER AND NOW, this _l~ rlay of 1/1 14[- __.1.~______..____. , 1997, upon consideration of the attached Stipulation, it is hereby ordered and directed that legal custody of the minor children, Gregory A. Verbosky and Sarah M. Verbosky shall be joint, and the periods of physical custody and partial physical custody shall be directed as provided in the attached Stipulation. BY THE COURT, SAlDIS, GUIDO, SHUrr Ie MASLAND 16 W, Hip 5_1 C,t1lJlo.PA .., CUlv1: :" 1',;, '{\11' ~,;\ l<; ;l,/{l.'d,\' FllJn ()rnCl: OF 'W" ,''''I''''JTfIW "\ 'rt MH~ If. rI'\ :1; ~\5 , , \ " " .. SAJDIS, GUIDO, SHUrr a MM..AND 26 W, HI'" S....I Carll.... PA ", MARY JO VERBOSKY, Plaint i ff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-6934 CIVIL TERM v. JOHN A. VERBOSKY, Defendant CIVIL ACTION - LAW CUSTODY STIPULATED CUSTOD:i....AGREEMENT AND NOW COMES the Plaintiff, Mary Jo Verbosky and Def9r.dRnt. J"h.. A. Vel'buoJ.y who hereoy f!tiplllates as follows: 1. The Plaint- iff is Mary Jo Verbosky an adult individual residing at 18 Rockaway Drive, Camp Hill, Cumberland County. Pennsylvania and is the natural Mother of the children. 2. The Defendant is John A. Ver'bosky an adult individual residing at and is the natural Father of the children. 3. The parties are the natural parents of Gregory A. Verbosky D.O.B. 3/2/83 and Sarah M. Verbosky D.O.B. 7/16/93. 4. The parties agree that thp.y shall share legal custody of the minor children. 5. The Mother shall have primary physical cUEltody of the minor children subject to periods of partial custody and visitation with the Father, as f.ollows: a. One weekend per month. provided that Father shall give two weeks notice of his intent to exercise his period of visitation; in the event that Mother has plans for a particular weekend, then Mother shall provide Father with three weeks advance notice of a conflict in 1;11 F "'1 ""(.. '" I :;' ~ \)' '3<J (;I/r, II r: I :t: I, l! CU;. I;' r "r!'j'/ I \:; H':~j'l L\" i. \ f'II'f~ &v/. 1~/11;l-4 ~ 4 ~ 111'~'~ '71~ /1I?jj,~ '3 dj ~ f'lI.tJ9 (1~ ~~ .... jU.,<!J~ p. " , , , , '. . . , . . . I' " ~. 'i , ~_f I ;. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order ,. '1' ICbcduIina . conciUation conference regarding this matter, Respectfully submitted: i; ;n ~ 8, Igbels, Esquire BELS & WELCH 1400 N, Second Street Harrlsburg, P A 17102 PA Supreme CI, 10 No, 68735 Phone: (717) 221-0900 i\/ ,I; 'jl k fL, -il }l t '" ", , ~' I (, );" DATED: 1/~/1f ,I' -'I. '1' !! r!'/' , , JOHN A, VERBOSKY, Defendant : CIVIL ACTION - AT LAW : CUSTODY " MARY JO VERBOSKY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No, 9S-6934 CIVIL TERM VS, YERIFICATION I, John A. Verbosky, state that 1 am the Defendant in the above-captioned case and that the facts set forth in this document are true and correct to the best of my knowledge, information, and belief. 1 realize that false statements herein are subject to the penalties lor unsworn falsification to authorities under 18 Pa, C,S. ~ 4940, Date: g. YfI , . . MARY JO YOUNG (VERBOSK'i) I IN THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBBRLAND COUNTY, ) PENNSYLVANIA VI!, ) ) NO, 95-6934 CIVIL TERM JOHN A. VERBOSKY, ) Defendant ) CIVIL ACTION - LAW ) CUSTODY/VISITATION 911DB AND NOW, this ~ day at _._ ~ '"' , 1999, upon review of the Conciliator'::l Report, it ,appearing that the parties have agreed to the terms and provisions of this Order which was dictated in their presence and approved by them and their cOunsel, it is hereby ordered and directed as follows: 1. Ail prior Orders entered in this case are VACATED. 2, The parties shall share legal custody of their minor children; Gregory A, Verbosky, d.o.b. March 2, 1983, and Sarah M, Verbosky, d.o.b. July 16, 1993. 3. Mother shall have primary physical custody of the minor children subject to periods of partial custody and visitation with Father as follows: A. On the second weekend of every month, this schedule to commence with the first weekend in November, the parties shall meet off the Breezewood exit at a piace thCit they mutually agree between 7: 30 p,m. , and 8:00 p,m, on Friday evening and shall aqain meet on Sunday between 4:00 p.m. and 4:30 p.m, at the Braezewood e~it for exchange of custody. The purpose of this visitation is for Father to have visitation with his children. The Father must be off from work in order to exercise these periods, B. li'ather shall have two (2) non-consecutive wE;leks during the summer provided he gives Mother thirty (30) days advance notice of his intent to exercise this period of visitation, 4, Father shall be afforded soma time over the Christmas holidaY. In 1999, Father shall have the period from Thursday, December 30th, when the parties shall meet at the Breezewood exit betwep.~ 7:30 p,m. and 8:00 p,m. until January 1'" wherein the parties should meet at the Breezewood exit between 4:00 p.m. and 4:30 p,m, for purposes of exchanging custody, fl\.tP-9':tGE ~ "'c r...."\\";.....,~.1'1II "" H I.. I'" ....ll'fJlrn' ~90C' '7.6 M\ B\ \9 CUMb\;.hYO (}')I.)Nt'l r\:.Nt\G~l.\lN~\~ ,I t' " , " /, ' , , , MARY JO YOUNG (VE~BOSKY) plaintiff IN TilE COU~T OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO, 95-6934 CIVIL TERM JOHN A. VERBOSKY, Detendant CIVIL ACTION - LAW CUSTODY/VISITATION JUDGE PREVIOUSLY ASSIGNED: The Honorable Edgar B, Bayley CU8TClDY CCHC:J:L:J:Jl.T:J:ON t"nID'aIlmCll StMGJ\Y RIIllORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 19l5,3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the children who are the subject of this litl.gation is as tollows: ~ lJIRTHDATE CURRENTLY IN CU~TOOY OF Gregory A, Verbosky Sarah M. Verbosky March 2, 1983 July 16, 1993 2. A Conciliation Conference was held on October 7, 1999, and the fo1J.owing il1dividuals were present: the Plaintiff and her attorney, Johnna Deily, Esquire; the Defendant appeared with his attorney, Jeanne B. Wigbels, Esquire, 3. tt.ems resolved by agreement: See attached Order. 4. Issues yet to be resolved: See attached Order. , , J \ , ) I 5. The Plaintiff's position on custody is as follows: See attached Order. i . 6. The Defendant's position on custody is as follows: See attached Order. 7, Need for separate counsel to represent children: Neither party requested. 8. Need for independent psychological evaluation or counseling: None requested and the Conciliator does not believe I any is necessary. . Date: October 11, 1999