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HomeMy WebLinkAbout00-02112 ....~~ "~ -~-"''''" APR ~ 7 20~ ARAFATMASWADEH, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000 - ;UI;;l...... CIVIL TERM CIVIL ACTION - LAW VALERIE R. EWIDEH, Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of April, 2000 upon consideration of the Plaintiff's Petition for Custody, it is hereby ordered that this matter be scheduled before the Custody Conciliator. Pending that conference, the Defendant shall have temporary primary physical custody of the children. The Plaintiff shall have rights of reasonable visitation of at least two (2) afternoons per week as the parties may agree. In the event that they cannot agree, these periods of visitation shall occur each Monday and Thursday from 5:30 p.m. until 8:30 p.m. at a location of the Plaintiffs choosing and shall be unsupervised. Service of this Order shall be the responsibility of Plaintiff and his counsel. BY THE COURT, J. cc: James J. Kayer, Esquire Attorney for Plaintiff Valerie R. Ewideh, Pro Se ~. -" ~ ' . - .= ,~. "' -M. , ARAFATMASWADEH, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000 - C)..tt'J......... CIVIL TERM : CIVIL ACTION - LAW VALERIE R. EWIDEH, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this day of ,2000, upon consideration of the attached Petition, it is hereby directed that the parties and their respective counsel appear before -' Esquire, Custody Conciliator, on of , 2000, at o'clock _.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 the issues to be heard by the court and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: , Esquire Custody Conciliator 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~E1' - - ~ . Wi\ilj' AMERICANS WITH DISABILITIES ACT OF 1990 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 reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. James 1. Kayer, Esquire Attorney for Plaintiff 4 East Liberty Avenue Liberty Loft Carlisle, P A 17013 (717) 243-7922 cc: James J. Kayer, Esquire Attorney for Plaintiff Valerie R. Ewideh, Pro Se Defendant ..: ~O!>l.. ~~<"""n " .....:...-~-" II u <, ...'~~~'" " " ~~i: ! ARAFATMASWADEH, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000 - ..2//;2..., CIVIL TERM : CIVIL ACTION - LAW VALERIE R. EWIDEH, Defendant : IN CUSTODY PETITION FOR CUSTODY COMES NOW, Plaintiff, Arafat Maswadeh, by and through his attorney, James J. Kayer, Esquire and avers as follows: 1. Plaintiff is Arafat Maswadeh, an adult individual, residing at 335 N. West Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Valerie Ewideh adult individual, whose current address is: 11 Partridge Circle, Carlisle, Cumberland County, PA, 17013. 3. Plaintiff seeks custody of the following child: Name Present Residence Age Alexus Nor Maswadeh, 11 Partridge Circle, Carlisle, PA, 17013 born, 7/17/98,1 yr. Issac Maswadeh, 11 Partridge Circle, Carlisle, PA 17013 born, 6/1/97, 2 yrs. The children were born out of wedlock. The children are presently in the custody of the mother. During the past three years, the children have resided with the following person(s) at the below address( es): June 1997 until December 1998: With mother and father at 501 West North Street, Carlisle, PA. .. . ~ "", December 1998 until February 2000: With the mother and father at 335 North West Street, Carlisle, PA 17013. February 2000 until Present: With mother at 11 Partridge Circle, Carlisle, PA, 17013 4. The mother of the children is Valerie R. Ewideh, residing at, 11 Partridge Circle, Carlisle, PA, Cumberland County, PA, 17013. She is married. The father of the children is Arafat Maswadeh, residing at 335 N. West Street, Carlisle, Cumberland County, Pennsylvania,17013. He is married. 5. The relationship of Plaintiff to the children is that of father. The Plaintiff currently resides with the following person(s): Name None 6. The relationship of the defendant to the children is that of mother. The Defendant currently resides with the children and the following person(s): Name Relationship Michelle Logue Mother Linda Logue Sister 7. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child 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 child or claims to have custody or visitation rights with respect to the child. 8. The best interest and permanent welfare of the children will be served by granting Plaintiff Relationship '\ir ~ ~ '.........__i,; primary physical custody of the children as he has been the primary care taker of the children and has been denied access to the children for a month. 9. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, names below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name None WHEREFORE, Plaintiff requests the court to grant custody of the children to Plaintiff. Respectfully submitted, Address Basis of Claim ~ ~~ " " " , ...J n" - . . ,', ", VERIFICATION OF PLEADINGS The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. The language of the document may, in part, be the language of my counsel and not my own. I have read the statements made in this document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the statements are that of counsel, I have relied upon counsel in making this Verification. I understand that false statements herein are made subject to the penalties of 18 P A. C.S. 9 4904, relating to unsworn falsification to authorities. Date:c?4'- 1)- 000 (J~ ~Mit/'d('~ ~7 ~.~ "".... " - '~, . ~. -"~J5j I ~ APR - 7 20~ ARAFATMASWADEH, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000 - CIVIL TERM : CIVIL ACTION - LAW V ALERlE R. EWIDEH, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this day of April, 2000 upon consideration ofthe Plaintiff's Petition for Custody, it is hereby ordered that this matter be scheduled before the Custody Conciliator. Pending that conference, the Defendant shall have temporary primary physical custody of the children. The Plaintiff shall have rights of reasonable visitation of at least two (2) afternoons per week as the parties may agree. In the event that they cannot agree, these periods of visitation shall occur each Monday and Thursday from 5:30 p.m. until 8:30 p.m. at a location of the Plaintiffs choosing and shall be unsupervised. Service of this Order shall be the responsibility of Plaintiff and his counsel. BY THE COURT, J. cc: James J. Kayer, Esquire ~ Attorney for Plaintiff Valerie R. Ewideh, Pro Se . - ~' '~=,;,.' ".~, J' .', ",~.,'~ ~'~-IJlr":W; , . ARAFAT MASW ADEH, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000 - CIVIL TERM : CIVIL ACTION - LAW VALERIE R. EWIDEH, Defendant : IN CUSTODY ORDER OF COURT Esquire, Custody Conciliator, on of , 2000, at J j ] I H i , ~ i l :1 I 1 I I , I I I i I !1 :,j , AND NOW, this day of , 2000, upon consideration of the attached Petition, it is hereby directed that the parties and their respective counsel appear before o'clock _.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 the issues to be heard by the court and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or perman.ent order. FOR THE COURT, By: , Esquire Custody Conciliator 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717}249-3166 !" .' ~.. . ~ '-IKi! AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Acf of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. James J. Kayer, Esquire Attorney for Plaintiff 4 East Liberty Avenue Liberty Loft Carlisle, P A 17013 (717) 243-7922 cc: James 1. Kayer, Esquire Attorney for Plaintiff Valerie R. Ewideh, Pro Se Defendant ~4', ,.~ ""__"" . --: -- ." - " ,.......... " ~, . ,\! ARAFAT MASWADEH, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000 - CIVIL TERM : CIVIL ACTION - LAW Name Present Residence Age ;, ,1 I 'I :i " I ,I j 'I J ~ ,I il ~ I Ii 'i 'I , ,J ,I j 1 'I j [1 II II I' I ij 1'1 iJ Ii I' .' ii 'I ~ I ;1 'I Ii , j I I I I I I 1 ~ VALERIE R. EWIDEH, Defendant : IN CUSTODY PETITION FOR CUSTODY COMES NOW, Plaintiff, Arafat Maswadeh, by and through his attorney, James J. Kayer, Esquire and avers as follows: 1. Plaintiff is Arafat Maswadeh, an adult individual, residing at 335 N. West Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Valerie Ewideh adult individual, whose current address is: II Partridge Circle, Carlisle, Cumberland County, PA, 17013. 3. Plaintiff seeks custody of the following child: Alexus Nor Maswadeh, 11 Partridge Circle, Carlisle, PA, 17013 born, 7/17/98, I yr. Issac Maswadeh, 11 Partridge Circle, Carlisle, P A 17013 born, 6/1/97, 2 yrs. The children were born out of wedlock. The children are presently in-the custody of the mother. During the past three years, the children have resided with the following person( s) at the be:low address( es): June 1997 until December 1998: With mother and father at 501 West North Street, Carlisle, PA. ';:~~I&.. - ~..." ~" ~' '. ""'1\: December 1998 until February 2000: With the mother and father at 335 North West Street, Carlisle, PA 17013. i'! February 2000 until Present: With mother at II Partridge Circle, Carlisle, PA, 17013 r! f! i' n 4. The mother of the children is Valerie R. Ewideh, residing at, II Partridge Circle, Carlisle, PA, Cumberland County, P A, 17013. She is married. ',' ;; The father of the children is Arafat Maswadeh, residing at 335 N. West Street, Carlisle, Cumberland i: f-l b " 11 County, Pennsylvania,17013. He is married. j ~ !,: 5. The relationship ofPlaintiffto the children is that of father. The Plaintiff currently resides with the following person(s): Name Relationship None 6. The relationship of the defendant to the children is that of mother. The Defendant currently 1'1 , Ii [' resides with the children and the following person(s): Michelle Logue Mother I, I, ~; Ij Name Relationship Linda Logue Sister 7. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or. another court. Plaintiff has no information of a custody proceeding concerning the child 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 child or claims to have custody or visitation rights with respect to the child. 8. The best interest and permanent welfare of the children will be served by granting Plaintiff ~~""'-- ~".- -~ ~z primary physical custody of the children as he has been the primary care taker of the children and has been denied access to the children for a month. 9. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, names below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim None WHEREFORE, Plaintiff requests the court to grant custody of the children to Plaintiff. Respectfully submitted, Jame~1 . Kay Attofrley for Kaye~ & Bra 4 E. Yiberty Avenue Carlisle, P A 17013 Superior Ct. J.D. 50838 -"- c " ~.~- u ,_" :UIfl-! VERIFICATION OF PLEADINGS The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. The language of the document may, in part, be the language of my counsel and not my own. I have read the statements made in this document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the statements are that of counsel, I have relied upon counsel in making this Verification. I understand that false statements herein are made subject to the penalties of 18 PA. C.S. S 4904, relating to unsworn falsification to authorities. Date:<'ll.(-I)- ~oC> ()J~ /1Mit'W'ic4 1- :ll " ~ , 'ilIMliiiVj APR - 7 20~ ARAFATMASWADEH, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000 - CNIL TERM : CNIL ACTION - LAW VALERIE R. EWIDEH, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this day of April, 2000 upon consideration of the Plaintiffs Petition for Custody, it is hereby ordered that this matter be scheduled before the Custody Conciliator. Pending that conference, the Defendant shall have temporary primary physical custody of the children. The Plaintiff shall have rights of reasonable visitation of at least two (2) afternoons per week as the parties may agree. In the event that they cannot agree, these periods of visitation shall occur each Monday and Thursday from 5:30 p.m. until 8:30 p.m. at a location of the Plaintiff's choosing and shall be unsupervised. Service of this Order shall be the responsibility of Plaintiff and his counsel. BY THE COURT, J. cc: James J. Kayer, Esquire-.:- Attorney for Plaintiff Valerie R. Ewideh, Pro Se .. ':'c:"'>"'--- ,",' - ^ . ~~~,"': . ~~- .~\ ARAFATMASWADEH, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000 - CNIL TERM : CIVIL ACTION - LAW VALERIE R. EWIDEH, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this day of ,2000, upon consideration of the attached Petition, it is hereby directed that the parties and their respective counsel appear before Esquire, Custody Conciliator, on of ,2000, at_~ o'clock _.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 the issues to be heard by the court and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: , Esquire Custody Conciliator 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 '" "- '---'" ~.- " - ~"" '---I' ,~.:...:.. ~ C,\, AMERICANS WITH DISABILITIES ACT OF 1990 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 reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. James J. Kayer, Esquire Attorney for Plaintiff 4 East Liberty Avenue Liberty Loft Carlisle, PA 17013 (717) 243-7922 cc: James J. Kayer, Esquire Attorney for Plaintiff Valerie R. Ewideh, Pro Se Defendant w . , I ~wS ....rJ> ..... re....~ (nt"",... ;,O-:~ (n a ~'< '<>ES <,<,... ~ ~ 0 _.d ~ I>>(nz .... 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ARAFAT MASW ADEH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000 - 2112 CNIL TERM : CNIL ACTION - LAW VALERIE R. EWIDEH, Defendant : IN CUSTODY AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO Pa. R.C.P. 1920.4(a)(1)(ii) COMMONWEALTH OF PENNSYLVANIA : SS. COUNTY OF CUMBERLAND I, James 1. Kayer, Esquire, being duly sworn according to law, deposes and says that he is the attorney for plaintiff, VALERIE EWIDEH . and that he did serve a true and correct copy of the Petition for Custody that was filed in the above matter, by U.S. Mail, postage prepaid, certified with restricted delivery, return receipt requested, unto the Defendants, ARAF AT MASW ADEn on April 10,2000, The receipt form is attached hereto as Exhibit "A". 1 !kt~ Jam~, 1. Ka U / ore me this 11 TH day of April 2000. Notary Public NOT AAIAL SEAL DeNISE PINAMONTI. Notary Public Cerlisle BoroUllh~ C~mbarland_9"un\y i$si 1.2000, , . ..h_ . ',,,,--. "' -'''- ,--",. ~"'.' .,," ~3' ;.._ , ~. L<~"< Ii !! _ ate itemEi 1 andfor 2 for additional services. I also wish to receive the .. ~ tt_ a. 4e, and 4b. loIIaMng services (for .... ~ I -Print your name and address on the reverse ofthiB form 80 that we can retumthlt extra fee): ~w~~ . -Attach 1hia'torrn to the iron!: oHhe maI1pIece, or on1ha back It space does not 1. 0 Addressee's Address ~ permit: !: !! 'Wrfte'RslumReC81ptRoqUS8lSd'OlllhemallplecobeIOl\ltheBJtJcle1l\llllber. 2.ItlFl...lIIl;led DelIVery III ti -The Return Receipt wm showt lIle Icle ~8 deDvered and the date " a 5 dallvered, Consult postmaster for fes. 1 I \ii~dQ~:Q~dOC0J~ "'~ ~rtJy:Numbsr cP( ~. 81: \ \ ~~, 4b. Service Type ----I "U 0 Registered e-certJlied .. Ul ().--., '- I ~ . ~ \....... 01 ":> 0 Express Mell 0 Insured ~ ~ I \...:) 0 Retum Flecelptfor Men:hsndlSe 0 COD = 7. Date 01 De"vsry ol< -.J O.>() d ~ 8. dresses's Address (Only If rsqussterJ i and fee Is paid) ~ 102595-97"'-0179 Domestic Return Receipt 6. Signetu g, X J! .,,' ,. PS Fonn 3811, Decembsr 1894 ' ~ ,~~ -'''.--,.- ""-.- "" ",'''i'~",-',,;,;''', ,;-.;,,' ,_',_;o.:,_~ ,"-~"i "-'.',:-,~.._-,,';':",",,-_":-;___, ARAF AT MASW ADEH, Plaintiff, :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA -- :':tii ! , ~ i ~ ~ v, :CIVIL ACTION - LAW :IN CUSTODY VALERIE EWIDEH Defendant. :NO. 2000 - 2112 CIVIL TERM PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter the appearance of the Family Law Clinic on behalf of Valerie R. Ewideh, the Defendant in the above captioned matter. rl~~~ Brian 1. ugh Certified Legal i e r F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 ,ij-1iIIl' ~ ' "." I!!!!! N~=.."=~ .~"~ ,,"~^ ~"~,, Oil; .; ~ ; -"1iIi1i ,_ ,c,_ '" ~~,,_- 'T' ~7 / G_:,., ;S ,?0 c- :r--.?;" -"J -~, (' , ,~ ~,"-", . .. c_) c) ".-::: ~ "-"'.. {'-..,:~ -TJ- ,',' :.n