HomeMy WebLinkAbout00-02112
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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
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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
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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
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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.
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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
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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
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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
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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
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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
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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
!"
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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
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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
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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.
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December 1998 until February 2000: With the mother and father at 335 North West Street, Carlisle,
PA 17013.
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February 2000 until Present: With mother at II Partridge Circle, Carlisle, PA, 17013
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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.
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The father of the children is Arafat Maswadeh, residing at 335 N. West Street, Carlisle, Cumberland
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County, Pennsylvania,17013. He is married.
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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
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resides with the children and the following person(s):
Michelle Logue
Mother
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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
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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
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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>
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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
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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
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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
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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".
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Jam~, 1. Ka
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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
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-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
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7. Date 01 De"vsry ol<
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102595-97"'-0179 Domestic Return Receipt
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ARAF AT MASW ADEH,
Plaintiff,
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
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: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.
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Brian 1. ugh
Certified Legal i e
r
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
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