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Home My WebLink About00-02925 , * \?obeA-\- \&oiCS\'c Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, : PENNSYLVANIA v. Defendant : CIVIL ACTION LAW ; NO.J1~ CIVIL :;)000 : CUSTODY VISITATION * L\)(\ \&o.')CS\ 'L ORDER OF COURT And now, this.2J..rSk1) upon consideration of the attached complaint, it is hereby directed that the above parties and their respective counsel appear before Esquire, the conciliator, at 30[ '-:) . i (\ ,~ \ , Pennsylvania, on tl}e C; day of '~)~ ,2000, at - @P.M., for a Pre-hearing Custody Conference. At su h 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 be present at the conference. Failure to appear at the conference may provide grounds for the entry of a , temporary or permanent order. FOR THE COURT: By: ~}'{\~, ~Ll((\~~ Custody Conciliator ~J '\ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 v I I: I' II I' " ii' II 'I Ii ! I I' "~>" ',="- ~- '" "I' ~, , ~ L .,,-_ -'~' - ,',,," - "'-rT--'~ ~-~' - " -'~ Rlt.o-QfF\C~ _\'~ 'r", ,.,r.\,-,Q1Ni'{ OF \,...:~::: :-;','_.' . -,~ ' "0 I' ~ \, \ 8 pr': 3: \ 8 \jj -;,.1\1 ' rr U" ,..vI I ;1\ ~'':''';'':':'I:;t ;~\,\~D vU \ 'I t \ eUI,JH...iL.- ,~I '1",')'11 . n-' l~lC''-{'\ 1.\\\;'1-' rC\'\(\'i<),L:!I""" , 5~/lf-OO &/. ~ ~ ~ 4 ~., 5'-/f-tJ/) ~ ~ d dfII. S:I<(-CJO ~ j1LC..JM ~'atf~ ,,_. ",." _1RI1ll!lJl1l' .",''''''''~"'''''<'I-='_.'_" """""",.,..~~_~~~_~,,,,,r.li~S:....,..,.,,,,,,",, 1'~-"". ~"...~ .J - <""."- - ~" . - MOY I ~l~ ROBERT KRAJCSIK, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSL VANIA ; NO, 06 - d.9.2S' Cud L4'ut v, : CMLACTION -LAW LORI KRAJCSIK, : IN CUSTODY Defendant ORDER You, Plaintiff, Robert Krajcsik, and Defendant, Lori Krajcsik, are ORDERED to appear in person in the Custody Mediation Office, , Pennsylvania on the _ day of , 2000, at 0' clock --,m, for a Custody Mediation Conference, If you fail to appear as provided by this Order or to bring the children, an Order for custody, partial custody, or visitation may be entered against you or the Court may issue a warrant for your arrest. YOU SHOULD TAKE TIllS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE CUMBERLAND COUNTY BAR ASSOCIATION OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LmERTY A VENUE CARLISLE, PA 17013 (717) 249-3166 BY THE COURT, , J, ROBERT KRAJCSIK, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSLV ANIA ; NO, 00 - .;l9<<.s Ctu ~C ~ v, : CIVIL ACTION - LAW LORI KRAJCSIK, : IN CUSTODY Defendant NOTICE YOU HAVE BEEN SUED IN COURT, lfyou wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are seIVed, by entering a written appearance per~onallY or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you, YOU SHOULD TAKE TIllS 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 LmERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 L , NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo aI partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en fonna escrita sus defensas 0 sus objectiones a las demandas en contra de su persona, Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 a1ivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 ostros derechos importantes para usted, ILEVE ESTA DEMANDA A UN ABODAGO lNMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME paR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAlO PARA AVERIGUAR DONDE SE PUEDE CONSEQUIR ASISTENCIA LEGAL, CUMBERLAND COUNTY BAR ASSOCIATION 2 LmERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 BY THE COURT, Custody Conference Conciliator , - . " 1_" u . .' Ai.L~' ROBERT KRAJCSIK, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSLV ANIA : NO, tHJ - .2 9.2S ~ I-LA-'- v. LORI KRAJCSIK, : CIVIL ACTION -LAW : IN CUSTODY Defendant COMPLAINT FOR CUSTODY 1, The Plaintiff is Robert Krajcsik residing at 656 Old York Road, Etters, York County, Pennsylvania, 17319, 2, The Defendant is Lori Krajcsik, residing at 1117 Columbus Avenue, Lemoyne, Cumberland County, Pennsylvania, 17043. 3, Plaintiff seeks custody of the following children: NAME Ashley Krajcsik Andrew Krajcsik PRESENT RESIDENCE 1117 Columbus Avenue, Lemoyne, PA, 17043 1117 Columbus Avenue, Lemoyne, P A, 17043 AGE Born 11/21/89, Age 10 Born 7/16/91, Age 8 4. The children were not born out of wedlock 5. The children are presently in the custody of Lori Krajcsik who resides at 1117 Columbus Avenue, Lemoyne, pennsylvania, 17043, 6, During the past five years, the children have resided with the following persons and at the following addresses: PERSONS ADDRESSES DATES ,.." ~- - "" .-J'.... ~- Parents, Robert Krajcsik and Lori Krajcsik Mother, Lori Krajcsik 37 Creek Rd" Camp Hill, PA, 17011 37 Creek Rd" Camp Hill, PA, 17011 3/1/95 - 5/96 5J96 - 7/98 Mother, Lori Krajcsik 305 Beacon Drive, Harrisburg, P A 7/98 -7/99 Mother, Lori Krajcsik 1117 Columbus Ave., Lemoyne, P A 17043 7/99 - present * *Except during times when Father is enjoying his rights of temporary physical custody, 7, The mother of the children is Lori Krajcsik currently residing at 1117 Columbus Ave., Lemoyne, Pennsylvania, 17043, She is divorced, 8. The father of the child is Robert Krajcsik currently residing at 656 Old York Road, Etters, Pennsylvania, 17319.. He is married to Gina Krajcsik, Robert Krajcsik and Lori Krajcsik were divorced by a Cumberland County Decree on March 4, 1999, 9. The relationship of Plaintiff to the children is that of Father. ThePlaintiffcurrently resides with the following persons: PERSONS RELATIONSHIP Gina Krajcsik His wife DanielleMurphy, age 14 Stepdaughter, daughter of Gina Krajcsik Jacqueline Murphy, age 12 Stepdaughter, daughter of Gina Krajcsik Christina Murphy, age 7 Y. Stepdaughter, daughter of Gina Krajcsik 10. The relationship of Defendant to the children is that of Mother, The Defendant . - .~ currently resides with the parties' children: Ashley Krajcsik and Andrew Krajcsik, 11, Plaintiff had 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, Plaintiff has no infonnation 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 to have custody or visitation rights with respect to the children, 12. The best interest and pennanent welfare of the children will be served by granting the relief requested because: A. The children have certain needs that are not being met by the present custodial parent; B, Defendant Mother promotes estrangement of the children from their father, C, Plaintiff loves his children and can offer a supportive and loving environment for them, 13, Each parent whose parental rights to the children have not been tenninated and the person who has physical custody of the children have been named as parties to this action, :;;.;.-,,"""< ~< WHEREFORE, Plaintiff requests the Court to grant custody of the children to him.. Attorney for Plaintiff Robert Krajcsik !'( ,,~.. ~ J, -, ,-" . , >C_ o . VERIFICATION I verifY that the statements made in this Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties oflS Pa,C,S, ~4904 relating to unsworn falsification to authorities, 5/8/00 Dale I , iIil.L ,,' mw..~""""~~r-'<I~""~~"llii~~--jjj ~"";." . ~~"..~ ". - ... - . . 7V ~ ~ ~ () <:::) c 0 <;;? \:t. 0 v.$': ..". GJ ,it ~ nl~l< ,~ '-I c., ~;;&: -~ :r :n n'1 8 0 r- .() ....... d VI (/)j.::. 0 -'()fT1 "- G D ;s;;;:. i~:50 ~ 6' I ::,:::::C:J "'tl --,6 I ~r) ~~l. - '.". (:)~ c...:. j:;'>."2 ....."" ::u V) c S~ iSm -- p:: z t ~ w 'i1 "-4 :0 J -< - , - .' I.. - ,~ ROBERT KRAJCSIK, : IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. : NO. 00-2925 CIVIL TERM : LORI KRAJCSIK, : CIVIL ACTION - LAW Defendant . IN CUSTODY . ORDER OF COORT AND lIDi, this t.r5" day of ~ consideration of the attached Custody Conc' ia ion and directed as follows: , 2000, upon Report, it is ordered 1. The parties shall submit themselves, their minor Children, and any other individuals deemed necessary by the evaluator, to a custody evaluation to be perfOrmed by Stanley Schneider, PhD. or other prOfessional selected by agreement of the parties. The purpose of the evaluation shall be to obtain independent professional recommendations concerning ongoing custody arrangements which will best serve the interests of the Children. The Father shall be responsible to pay 60%, and the Mother shall be responsible to pay 40%, of the costs of the evaluation which are not covered by insurance. The parties shall sign any authorizations deemed necessary by the evaluator in order to obtain additional information pertaining to the parties, the Children, or other related individuals. 2. The Father, Robert Krajcsik, and the Mother, Lori Krajcsik, shall have shared legal custody of Ashley K. Krajcsik, born November 21, 1989, and Andrew K. Krajcsik, born July 16, 1991. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. 3. Pending completion of the custody evaluation and further order of Court or agreement of the parties, the Mother shall have primary physical custody of the Children and the Father shall have partial physical custody in accordance with the following schedule: A. During the summer school break, the Father shall have custody of the Children on alternating weekends, beginning July 28, 2000, from Friday after camp through SUnday at 6:00 p.m. and for one weekday overnight period of custody from after camp until the beginning of camp on the following morning, with the specific days to be selected by agreement of the parties. B. During the school year, the Father shall have custody of the Children on alternating weekends from Friday after school through Monday morning when the Father shall return the Children to school and during one evening per week from 4:30 p.m. until 8:30 p.m., with the specific day to be selected by di*ii.iliilml""W~"JiIJliJl!;'lillil1~~.I.Iiiliiiifl!MiiIiItii~~~!i"i!llillIlm~g,;jl~.'lftIIdllil!llllil..' - -::> c:5 (\J 0." >- c-_ ;~?~ ~ :-:~- ~);'~. -'J~-"_ :)~?j r'~~? ::;;:'''- :::5 () ";:::;:: ',~) ~'\.t ~:: :::;::j . ~ ' - ~ ~il:II6io_~- .'~ .~C'--- - ~"- --, ~ . ", Ii i lj Ii I,! I: I, I ,I I: Ii - "' agreement of the parties. C. The Father shall have an extended period of custody with the Children for one week during the month of August, 2000, with the specific dates and times to be arranged by agreement of the parties. 4. The Father shall be responsible to provide transportation for all exchanges of custody, unless agreed otherwise by the parties. 5. Counsel for either party may contact the Conciliator, within two months from the date of the evaluator's written recommendations, in order to request the scheduling of an additional custody Conciliation Conference, if necessary. 6. This order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this order by mutual consent. In the absence of mutual consent, the terms of this order shall control. BY THE COURT, 4G- '44- / J. .~ t .~ ~ 00 '1':)~* cc: Jay R. Braderman, Esquire - Counsel for Father Edward J. weintraub, Esquire - Counsel for Mother .~ 'J.. ~-. . ROBERT KRAJCSIK, : IN THE COURT OF COMMON PLEAS OF plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. : NO. 00-2925 CIVIL TERM : LORI KRAJCSIK, . CIVIL ACTION - LAW . Defendant . IN CUSTODY . CUS'lOOY <XX\1CILIATIOO SUMMARY REPCm' IN ACXDRDANCE WITH CUMBERLAND COIlNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned CUstody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CORRENTLY IN CUS'lOOY OF Ashley K. Krajcsik Andrew K. Krajcsik November 21, 1989 July l6, 1991 Mother Mother 2. A COnciliation Conference was held on July 19, 2000, with the fOllowing individuals in attendance: The Father, Robert Krajcsik, with his counsel, Jay R. Braderman, Esquire, and the Mother, Lori Krajcsik, with her counsel, Edward J. Weintraub, Esquire. 3. The parties agreed to Date ~ c:k>) a-o&CJ I entry of an Order in the form as attached. Da~ CUstody Conciliator