HomeMy WebLinkAbout00-00086
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DAVID A. MANGAM,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. ~OOG- f'l- C-w t:l ~
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BOGUMILA MANGAM,
Defendant
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: CIV:p"c<ACTION
: .IN"CUSTODY
ORDER OF COURT /
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AND NOW,. ---1..1 \ ~ \ C> ()
of the attached complaint,
and the'r respective c uns
, upon consideration
it ,j;-!:l hereby directed that the parties
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I appear before
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on th
2000, at ~.m,
for a Pre-Hearing Custody Conference. At such conference, an
effort will be made to resolve the issues in dispute; or if this
cannot be accomplished, to define and narrow ~he 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 entr
of a temporary or permanent order.
FOR THE COURT,
By:
The Court of Common Pleas of Cumberland County is required
by law to comply with the Americans with Disabilities Act of
1990. For information about accessible facilities and reasonabl
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 LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TH
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
MEYERS, DES FOR, SALTZGIVER & BOYLE
410 NORTH SECOND STREET. P.O. BOX 1062 . HARRISBURG. PA 17108
(717) 236.9428 . FAX (717) 236-2817
, F!LED-or-BCE
OF THF: Ff::OTHONOTARY
00 JJlN 19 MIll: 54
CUM8f;RLAND COUNTY
PENNSYLVANIA
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DAVID A. MANGAM,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. :l- o-vv J?(. Cw-l ~
vs.
BOGUMILA MANGAM,
Defendant
CIVIL ACTION
IN CUSTODY
COMPLAINT FOR CUSTODY
1. Plaintiff is David A. Mangam, an adult individual residing
temporarily at the Hampton Inn, Mechanicsburg, Cumberland
County, Pennsylvania. Plaintiff is in the process of
securing a home.
2. Defendant is Bogumila Mangam, an adult individual residing
at 3818 Panay Drive, Mechanicsburg, Cumberland County,
Pennsylvania.
3. Plaintiff seeks custody of the following children:
Name
Present Address
Date of B'r
Caroline Angelica
Mangam
5/18/82
3818 panay Drive
Mechanicsbu~g, PA
Victoria Olivia
Mangam
3818 panay Drive
Mechanicsburg, PA
5/8/88
The children were not born out of wedlock.
The children are presently in the custody of Bogumila
Mangam, who resides at 3818 panay Drive, Mechanicsburg,
Cumberland County, Pennsylvania.
2
MEYERS, DESFOR, SALTZGIVER &. BOYLE
410 NORTH SECOND STREET. P.O. BOX 1062 . HARRISBURG. PA 17108
(717) 236-9428 . FAX (717) 236-2817
During the past five years, the children have resided with
the following persons and at the following addresses:
Plaintiff and
Defendant
Addresses
3818 panay Drive
Mechanicsburg, PA
Dates
Name
1993 to
present
The mother of the children is Bogumila Mangam, currently
residing at 3818 panay Drive, Mechanicsburg, Cumberland County,
Pennsylvania.
She is married.
The father of the children is David A. Mangam, currently
residing at 3818 Panay Drive, Mechanicsburg, Cumberland County,
Pennsylvania.
He is married.
4. The relationship of plaintiff to the children is that of
father. The plaintiff currently resides with the following
persons: None.
5. The relationship of defendant to the children is that of
Mother. The defendant currently resides with the following
persons:
Name
Relationship
Caroline A. Mangam
Victoria O. MAngam
daughter
daughter
6. Plaintiff has not participated as a party or witness, or in
another capacity, in other litigation concerning the custod
of the children in this or another court.
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MEYERS, DESFOR, SALTZGIVER & BOYLE
410 NORTH SECOND STREET. P.O. BOX 1062 . HARRISBURG, PA 17108
(717) 236.9428 . FAX (717) 236-2817
Plaintiff has no information of a custody proceeding
concerning the children pending in a court of this Commonwealth.
Plaintiff does not know of a person not a party to the
proceedings who has physical custody of the children or claims t
have custody or visitation rights with respect to the children.
7. The best interest and permanent welfare of the children will
be served by granting the relief requested because Defendant
has become more and more aggressive toward Plaintiff,
particularly in front of the parties' children. For
example, in December 1999, in an incident witnessed by the
parties' youngest daughter, Defendant became enraged at
Plaintiff, striking him in the face, gouging his skin until
he bled profusely. Further, Defendant has attempted to
alienate the parties' oldest daughter from Plaintiff. On
one occasion, also in December 1999, while the child was
being disciplined, the child lashed out at her father and
began kicking and verbally attacking him. Defendant
encouraged the chi.ld by yelling, "You go, girl," rather tha
interrupting the argument.
Plaintiff is the natural father of the children.
Defendant is interfering with his parental/custodial rights
to see the children. The children have indicated they wish
to live with Plaintiff.
8. Each parent whose parental rights to the children have not
been terminated and the person who has physical custody of
4
MEYERS, DESFOR, SALTZGIVER &: BOYLE
410 NORTH SECOND STREET. P.O. BOX 1062 . HARRISBURG. PA 17108
(717) 236.9428 . FAX (717) 236.2817
.
the children have been named as parties to this action.
WHEREFORE, Plaintiff David A. Mangam, respectfully requests
this Honorable Court grant custody of the children.
Respectfully submitted,
MEYERS, DESFOR, SALTZGIVER & BOYLE
By
Catherine A.
Attorney for Plaintif
Attorney ID No. 76328
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MEYERS, DESFOR, SALTZGIVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108
(717) 236-9428 . FAX (717) 236-2817
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MAR 1 4 200~
DAVID A. MANGAM,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
vs.
: CIVIL ACTION - LAW
: NO. 00-86
:
BOGUMILA MANGAM,
Defendant
:
: IN CUSTODY
aIDER OF c:c.uIlT
AND NCM, this 7th day of March, 2000, the Conciliator, being
advised by ccunsel that all custody issues have been resolved by agreement
of the parties, hereby relinquishes jurisdiction in this case. The cu~tody
Conciliation COnference scheduled for March 9, 2000 is canceled.
FOR THE COURT,
D{J~~&r
Custody COnciliator
ALED-OFFICE
OF THE PROTHONOTARY
00 MAR 15. i\H 10: 39
CUMBERI.AND CDlJNTY
PENNSYlVANIA
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DAVID A. MANGAM, : IN THE COURT OF COMMON PLEAS OF
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
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vs. No. 2000 - 86
:
BOGUMILA MANGAM, . CIVIL ACTION - AT LAW - CUSTODY
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Defendant . PREV ASSIGNED TO: J. OLER (PFA)
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AND NOW, this
CONSENT ORDER
'L~ (.l day of J, J c-~
2000, upon
consideration of the attached Stipulation of the parties in the
above-captioned matter, consisting of four pages and bearing the
written consent of the parties,
AND upon direction of this court that the parties need not be
present before the court in order to incorporate their Stipulation
into a consent order,
IT IS ORDERED that said Stipulation is incorporated herein by
reference as if set forth in full and approved as a Consent Order
pursuant to Pennsylvania Rule of civil Procedure, Rule 1915.7.
BY THE COURT:
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Distribution:
Catherine A. Boyle, Esq.
Matthew J. Eshelman, Esq.
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DAVID A. MANGAM, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
vs. . No~ '" 2000 - 86
.
:
BOGUMILA MANGAM, : CIVIL ACTION - AT LAW - CUSTODY
Defendant . PREV ASSIGNED TO: J. OLER (PFA)
.
STIPULATION
WHEREAS, the parties have born to them two children, namely
Caroline A. Mangam, born May 18, 1982, and victoria O. Mangam, born
~~ 8, 1988, the Children here~nafter; and
WHEREAS, the parties wish to enter into an agreement relative
to custody of the Children; and
WHEREAS, the Children have resided in Cumberland County,
Pennsylvania for the past six months, thus giving this Court
jurisdiction;
THEREFORE, this
day of March 2000, in consideration of
the mutual covenants, promises, and agreements as hereinafter set
forth, and intending to b_e legally bound, the parties agree as
follows:
1. The parties shall share legal custody of the Children.
2. The Mother, Bogumila Mangam, shall have primary physical
custody of the Children, subject to periods of partial physical
custody in Father as follows:
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a. Beginning January 14, 2000, Father shall have
periods of partial physical of victoria every other weekend,
from Friday after school until Sunday evening at 8:45 p.m.;
b. Beginning January 12, 2000, Father shall have
custody of victoria from after school until 8:45 p.m. and
every other Wednesday thereafter;
c. Beginning January 19, 2000, Father shall have
custody of Victoria from 6:00 p.m. until Thursday morning when
the child begins school and every other Wednesday thereafter.
3. The parties have agreed to a holiday schedule as follows:
a. Easter shall be spent with Mother every year;
b. Thanksgiving shall be spent with Father every year;
c. The parties have agreed to alternate the following
major holiday~: victoFia's birthday, Memorial Day, Fourth of
July, Labor Day, and New Years Day. This alternating holiday
schedule will occur such that Mother shall have Memorial Day
2000 (giving Father Victoria's birthday in 2000) and
alternating between the parties with each holiday in
succession thereafter.
d. Christmas holidays shall be shared in two segments:
Segment A shall occur from after school, when victoria is
desmissed for Christmas break, until 2:00 p.m. Christmas Day.
Segment B shall occur from 2:00 p.m. on Christmas Day until
6:00 p.m. December 27th. Father shall have Segment A in 2000
and all even numbered years thereafter; and Segment B in 2001
and all odd numbered years thereafter. Mother shall have
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Segment B in 2000 "an.d all ~ven numbered years thereafter; and
Segment A jn 2001 and all'odd numbered years thereafter.
e. Each year, Mother's Day shall be spent with Mother,
and Father's Day shall be spent with Father.
f. The parties acknowledge that Victoria shall have
other days off from school not specifically mentioned in the
agreement. '-The parties agree to alternate these days off
between them as holidays. The alternating schedule for days
off shall be distinct and independent of the alternating
schedule for major holidays. Mother shall provide a copy of
the children's school schedule to Father as soon as possible.
g. The time for the holiday custody periods shall be
from 9:00 a.m. until 8:30 p.m. In the event that a weekend
adjoining a holiday and the holiday itself are both scheduled
for a given parent, the two periods shall merge into a single
custodial peiod.
4. Each partysh~ll have three uninterrupted weeks through
the ,summer vacation, which weeks shall not be exercised
consecutively. Notice of when the party intends to exercise his or
her summer custody schedule shall be provided to the other party no
later than thirty days ahead of time.
5. Holiday schedules shall supersede both the regular
custodial schedule and the summer vacation schedules. Vacations
shall supersede the regular custodial schedule upon notice as
provided above.
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6. This Stipulation shall superseae paragraphs 7, 8, and
9 (1) - (8) of the prior court orders dated January 7, 2000, and
docketed at 99-7746 Civil Term (PFA) and 2000-81 Civil Term (PFA),
or' any other prior order of court with specific respect to the
custody, partial custody, and/or visitation of the Children.
7. It is the intention and desire of each of the undersigned
parties that this Stipulation be confirmed as an order of court,
without requiring their presence before the court, pursuant to Rule
1915.7.
WITNESS
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WITNES