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HomeMy WebLinkAbout96-03340 j ~ -:r:. " '\ I ! i' i i i I ! I , i I i I MART K. RAGA, I IN THE COURT or COMMON PLEAS Plaintiff I CUMBERLAHD COUNTY, PENNSYLVANIA I v. I NO. 96 -3.3~o CIVIL TERM I MARX O. RAGA, I CIVIL ACTION - LAW Defendant I CUSTODY ACTION ORDER or COURT AND NOW, upon consideration of the attached complaint, it is hereby directed that before Onw (1 the parties :J tl.'ld au , rtl t' (' J1 and their respective counsel . Esouire, the Conciliator, at appear - ECl iLl, mt.l.<A1 .,,+ jo day of II III. J Custody Conference. At /;':,30 ~ A f , 1996, at ~' , O. M., for a Pre-Hearing on the 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. Either party may bring the child who is the subject of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. For the Court, 0('1 ~< 1-'" /11 l-rrln , I /' B 1< c.~ , 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. OFFICE OF ,THE COORT ADMINISTRATOR COURTHOUSE, '4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 EXT 6200 MARY K. RAGA, I IN THE COURT OF COMMON PLEAS Plaintiff ; CUMBERLAND COUNTY, PENHSYLVANIA I v. . NO. 96 - CIVIL TERM . . . MARK O. RAGA, I CIVIL ACTION - LAW Defendant I CUSTODY ACTION CUSTODY COMPLAINT TO THE HONORABLE JUDGES OF SAID COURT; 1. The Plaintiff is Mary K. Haga residing at 1444 Apple Circle, Apartment 168, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is Mark G. Haga, who is a truck driver who uses the address of Twin x, Inc., 14324 21st Avenue North, Plymouth, MN 55447. 3. Plaintiff seeks legal and primary physical custody of the following children; IfIHI PRESENT RESIDENCE 1444 Apple Circle Mechanicsburg, PA 17055 ~ Alexander John Haga Kane Anders Haga 7/2/89 11/30/92 The children were born out of wedlock. The children are presently in the custody of Mary K. Haga, who resides at 1444 Apple Circle, Mechanicsburg, Pennsylvania. During the past five years, the children have resided with the following persons and at the following addresses; Persons Addresses Dates Mother 1444 Apple Circle Mechanicsburg, PA 173-A W. Vine Street Shiremanstown, PA 5/96 -present Mother 11/95 - 5/96 Mother & Father 173-A W. Vine Street 9/95 - 11/95 Mother & Father 9161 Dunlap Avenue 3/95 - B/95 Circle Pines, MN Mother & Father 1 South Chestnut Street 7/93 - 7/94 Dillsburg, PA Mother & Father Ash Stl'8et 7/92 - 7/93 Harrisburg, PA The mother of the children is Mary K. Haga, who lives at 1444 Apple Circle, Mechanicsburg, Pennsylvania 17055. She is married. The father of the children is Mark G. Haga, who is a truck driver who uses the address of Twin X, Inc., 14234 21st Ave North, Plymouth, MN 55447. He is married. 4. The relationship of Plaintiff to the children is that of mother. The Plaintiff currently resides with the following persons; IiIIIIJl Relationship Alexander J. Haga Kane A. Haga Anthony D. Kepner Eric Shaffer Son Son Son Friend 5. The relationship of Defendant to the children is that of father. The Defendant currently resides with the following persons: IiIIIIJl RelatlonshiD Unknown 6. Neither party has participated as a part or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 2 ,,,,~....... " Plaintiff does not know of a person not a party to the pro~eedings who has physical custody of the children or claims to have custody or visitation righte with respact to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: A. Plaintiff has participated in the primary care of the children throughout their lives. B. Plaintiff can provide a stable environment. c. Plaintiff can provide a loving home. a. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff requests this Honorable Court to grant her legal and primary physical custody of her children subject to specific periods of temporary physical custody to the Defendant. Respectfully submitted ~Mj). ~ Thomas D. GOUld, Esquire In #3650a 2 E. Main Street Shiremanstown, PA 17011 (717) 731-1461 Fax 761-1974 3 VERIFICATION I I Mary K. Haga, hereby certify that the foregoing CUSTODY COMPLAIRT is true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of Ie Pa, C.S. Section 4904 relating to unsworn falsification to authorities. DATED ;' I ' II I ," 1"')1 i /i-. , 1,1 Ii \ Iii I Mary' K. Haga plaintiff 4 li: :€ . )'J J V! ) .1/ f.J J;) I~ 11')('/ f) 1;) , -.... .I" " ~ -J.-o ~4~~ '" ' . " c) (~ c;, , , -r' ,) d 1( r' .~..{ p::!.' :,1.': J:t: ,,\ '~ ~r- ,~ . )~'i (X r" .t;., (.j 0 ,..... I, ,., o'l II) fi!'~ ,._'. ~ .. ..I,!t -.. . .~ U \1:' r ' !! II';) V) r;"l rY) i'" r_~ . .:!(l.. '"".i --<.- {.... C.... , 4, , -.. ''1 It, 'j U c. u '\A. ..., r ~ 1'-' ~ "c cJ , i',' , :!T/,OIlUlJ- (j). ~fj(J(I{,t ATTOHH[Y AT I.AW i! t MAIN SlU[[l SHmCMAN5l0WN. PA 17011 71?~7 .)1-1461 ~,JUi' 1 l ei J o ~ ... t:: .. ... .. ~ Is! ... iii -< t- Z ! >- Ul ~ I l&J Z 0 i'i ~ < fjj r;- o ~ ~ ~ 1::'" 2: .... < N ~ i: VI MARY K. HAGA, plaintiff IN THE COURT OF CCXo1MON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 96-3340 CIVIL TERM MARK G. HAGA, Defendant . . : IN CUSTODY 00DIlR Ol" <DJRT AND to, this s1L day consideration of the attached Custody and directed as follows; of il..a. ..,.,. , 1996, upon conctttil\~n"1epOr"t, it is ordered 1. The Mother, Mary K. Haga, and the Father, Mark G. Haga, shall have shared legal custody of Alexander John Haga, born July 2, 1989, and Kane Anders Haga, born November 30, 1992. 2. The Mother shall have primary physical custody of the Children. 3. The Father shall have reasonable periods of partial physical cuatody of the Children as arranged by mutual agreement of the parties. The Mother agrees to cooperate in scheduling periods of partial custody to coordinate with the Father's work schedule. 4. This Order is entered pursuant to an agreement reached by the parties at a CUstody Conciliation Conference. In the event either party desires to modify this order, that party may petition the Court to have the case again scheduled with the Custody Conciliator for a Conference. BY '::'HE COURT, cc: Thomas D. Gould, Esquire Mark G. Hags J. ~1.81'11 /c. .J!,,-5', vs. : NO. 96-3340 CIVIl, TERM MARY K. HAGA, Plaintiff IN THE COURT OF roIMON PLEAS OF CUMBERLAND COUNTY, PENNS'iL VANIA MARK G. HAGA, Defendant ; IN CUSTODY CU'1lOOY a:NCILIATI~ SlRIARY REl'OO'l' IN AaDUlANC8 WI'l'H CUlIl8RLAND aufl'Y RIJLB ()lI' CIVlL PIO.""'.IlB 1915.3-8, the undersigned Custody Conciliator sUbnits the following report: l. The pertinent information concerning the Children who are the subjects of this litigstion is as follows: IWlB BIR'1'HDP>TB aJRRBNl'[.y IN cumDY ()lI' Currently in primary Custody of plaintiffl Mother Currently in primary Custody of plaintiffl Mother Kane Anders Haga July 2, 1989 November 30, 1992 Alexander John Haga 2. A Conciliation Conference was held on July 31, 1996, with the following individuals in attendance: The Mother, Mary K. Haga, with her sister-in-law, Terry Hardy and her legal counsel, Thonas D. Gould, Esquire. The Father, Mark G. Haga, who is a truck driver currently residing in MiMesota, did not attend the Conference. The Conciliator spoke with the Father by telephone during the Conference and confirmed that the Father had received notice of the Conference date but was unable to attend. The Father explained his position on custody arrangements to the Conciliator by telephone. 3. The parties agreed to entry of an order in the form as attached. Av~i I, l'i'/(t &'u~.d.u-4ik1 Dawn S. Sunday, ESquIre custody Conciliator Date iim Ih; ~~ ~1{3 ~ 19 .... 1 t~ ..., " ~ <0( .... ~ ';1 . ~I "It, 'iI ,8 ": ila~ c ~ j./~rt!I;;'~ '... III J ' ~ ~ ~~ ~2! i J ,e '. ~'" ~ ~ J U; ~ ~;~ as ' ::'. . . l.: l:l ~ ~ : - . ".. ': I I:' c,'~/ .. ' {-, '~.' ,-, !!, - (....