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HomeMy WebLinkAbout97-02043 i o """ .., -:!J . '" ~ I 3 \ - I E I ct \ " ............... "\ \ I ) , .' ~: - .J ~ Cj I . ~I APR 1 H 1997tlV ALBERT AMICO, JR. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW Defendant NO. 97- ;).04-3 c...~Tl'.A"'" IN CUSTODY KRlSTY HASLOCK ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before t'n...lr\ ,\.~! E"9.' the conciliator, at '~F1 W, Ma\['\~\- . Mcc h'r\'\(S,h.'-9 on the n"'day of _N,0'--j , 1997, 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 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. BY THE COURT, .J:SmiJl\. dJ~ [f4,. l.u~\-cu""l (U''\l.I h C\ f rt'D 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. COURT ADMINISTRATOR, 4th FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA TELEPHONE NUMBER: (717) 240-6200 n: n ('c.',- c:' .. . "t.:. -'''\' , "7;":r.:", ,., ,. . d,. ( .<:: " (q . .' I , .[' ':' , 1..,,,... 1;-"','" -,,,',;.'. . '''I ..I" ". I L,j'~ "., , ,< 'l.l>.t f) ~. td~ M~ -t ~ h~~ '/:J.'N.f/ 71t1i;;.(. ;~-0 -rz#( I/rJ;) "'/7 t~ /M.if.I -t: aq; d::'/~ ALBERT AMICO, JR. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA Plaintiff v. CIVIL ACTION - LAW KRISTY HAS LOCK ~ 'n- dvl3 IN CUSTODY NO. Defendant PETITION FOR PARTIAL CUSTODY AND NOW, this jq ~ day of April, 1997, comes Plaintiff Albert Amico, by and through his attorney, Michael D. Rentschler, Esquire, who files the within Petition of which the following is a statement: 1. The Plaintiff is Albert Amico, Jr., who currently resides at 9061h Sheffield Avenue, Mechanicsburg, PA 17055. 2. The Defendant is Kristy Haslock, who currently resides at 82 York Road, Carlisle, PA 17013. 3. Plaintiff seeks partial custody of the following child: NlImJ: Present Residence Date of Birth ~ Alex Haslock 82 York Road Carlisle, PA 17013 12/18/94 2 4. The child was born out of wedlock. The child is presently in the custody of Kristy Haslock, who resides at 82 York Road, Carlisle, Pennsylvania. The Plaintiff is the natural father of the child. 5. During the child's lifetime, the child has resided with the following persons and at the following addresses: , , !~ I fuml: Address I2a1l: Kristy Haslock & Companion (Unknown Male Believed to be named Dave) Sister - Brittany Haslock 82 York Road Carlisle, PA 17013 Spring 1996 to Present Kristy Haslock Brittany Haslock York Road Carlisle, PA 17013 December 1994 to Spring 1996 6, The mother of the child is Kristy Haslock, currently residing at 82 York Road, Carlisle, Pennsylvania. She is single. 7, The father of the child is Albert Amico, currently residing at 9061h Sheffield Avenue, Mechanicsburg, Pennsylvania. He is single. 8. The relationship of Plaintiff to the child is that of father, 9. The Plaintiff currently is residing at 9061/2 Sheffield Avenue, Mechanicsburg, Pennsylvania. 10. The relationship of Defendant Kristy Haslock to the child is that of mother. The Defendant currently resides with the following person: ~ Relationship Dave Companion 11, The Plaintiff is currently a party in a custody action which has been filed by Mary Elizabeth Amico, the paternal grandmother of the child. That custody petition is tiled in the Court of Common Pleas of Cumberland County and is docketed at 96-6045 Civil Term. The Plaintiff knows of no other litigation concerning the custody of the child in this or any other court. 12. Plaintiff has information of a custody proceeding concerning the child pending in a 2 I I court of this Commonwealth as stated in Paragraph II of this Petition. 13, The Plaintiff seeks partial custody/visitation with the minor child because: a. He is the natural father of the child; b. It is in the best interest of the child to have a loving relationship with his natural father; and . i c. The natural mother is interfering with Plaintiffs requests to visit with his child. WHEREFORE, the Plaintiff requests this Honorable Court award shared legal custody and partial physical custody on alternating weekends from Friday night at 5:00 p.m. until Tuesday morning at 9:00 a.m., and every Monday and Wednesday evening at 5:00 p,m. until the following morning at 9:00 a.m., except that on those Mondays following the weekend in which Plaintiff has had visitation with the child, then Monday evening at 5:00 p.m. until Tuesday morning at 9:00 a.m. Plaintiff also requests visitation with the child on alternate , , ~ , holidays, alternate birthdays and every father's day. Respectfully submiued, -----~. ~.~ ~- ~----- _~'/"'~'. ;d Michael D. Rentschler, Esquire 28 North 32nd Street Camp Hill, PA 17011 (717) 975-9129 Attorney ID #45836 Attorney for Plaintiff 3 I I I I, i I h .,....-..-.....--.. ~ 'l.'t.- I ."". . C. o.!.' (') , -.l -,-I h I -nl .., :; :!l t1. :',J . ,- -61 ..m () , :CJ CB ~ (. l;n ':6 e- 0\ .. \I: r I ::J:! 1:1. 0 :() (j\ ~ :,....( - :.)111 ..J ., ~. I ,- ~ 81 "-, 'l:J - c< \)l R 1- " . ,. ..' -----, ..' '. < ,. ,. , , ; ." L,..".,~-r,,'H ,.......,...;.... ..~.J1,1}.',-1'<<~t.dJ-;.1\.~Jr";')lr.-.._'< " .. ~N 1 3 1997 MARY ELIZABETH AMICO, Plaintiff vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 96-6045 Civil Tenn KRlSTY HASLOCK and : CIVIL ACTION - LAW ALBERT AMICO, Defendants : IN CUSTODY ALBERT AMICO, JR., Plaintiff vs, KRlSTY HA~LOCK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ~ No, 97-2043 Civil Tenn /" : CIVIL ACTION - LAW : IN CUSTODY RULE AND NOW, this ~ day of ~ tJvU2... , 1997, upon considemtion of the within Motion for Consolidation, a Rule is hereby issued upon Kristy Hasloek and MllI)' Elizabeth Amico to show cause why the above two cases should not be consolidated to Tenn No. 96-6045 Civil Tenn. Rule returnable ~ days from date of service. ~~~ ClM~ C.N'WJ~ thvJ- ~ ~ Jtk&;(' ~. ~~~ BYTH:SOUR;r/ ~ J, ./ O'<'\1/L.:J l -n L...l i.::, ql..-t...u'/-S 0l.uUL I (", 199 7 -.....,..."..7..... I I i I I MARY ELIZABETH AMICO, : IN TIlE COURT or COMMON PLEAS or , PlaintilT : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 96-6045 Civil Tenn KRlSTY HAS LOCK and : CIVIL ACTION. LAW ALBERT AMICO, Defendants : IN CUSTODY I i ALBERT AMICO, JR., : IN THE COURT OF COMMON PLEAS OF '" I PlaintilT : CUMBERLAND COUNTY, PENNSYLVANIA , I vs, : No. 97-2043 Civil Tenn KRlSTY HAS LOCK, : CIVIL ACTION - LAW Defendant : IN CUSTODY MOTION FOR CONSOLIDATION AND NOW, this ~day of .fk. ~ - , 1997, comes Michael D, Rentschler, U allorney for PlaintilT, Albert Amico, Jr., who files the within Motion for Consolidation of which the following is a statement: I. On November 4, 1996, Mary Elizabeth Amico filed a Petition in Custody against Kristy Haslock and Albert Amico docketed at No. 96-6045. Thereafter, on April 18, 1997, Albert Amico, Jr. filed a Petition in Custody against Kristy Haslock docketed at No, 97-2043, J., Kristy Haslock is the natural mother of the child Alex Haslock who was born on December 18, 1994 and presently resides with his mother at 82 York Road, Carlisle, PA. 3. Albert Amico, Jr" is the natural father of Alex Haslock. 4. Mary Elizabeth Amico is the maternal grandmother of the child Alex Haslock, 5. Mary Elizabeth Amico seeks partial custody of Alex Haslock in her Complaint for Custody. Albert Amico, Jr., seeks partial custody of his son Alex Haslock. MARY ELIZABETH AMICO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs, : No. 96-6045 Civil Tenn KRISTY HASLOCK and : CIVIL ACTION . LAW ALBERT AMICO. Defendants : IN CUSTODY ALBERT AMICO, JR., : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 97-2043 Civil Tenn J Plaintiff vs. KRISTY HASLOCK, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER AND NOW, this -<:1- day of ~ -tA)'l-' 1997, upon consideration of tile within Motion to Make Rule Absolute, pertaining to the Motion for Consolidation of the above two ChSes, and further that thrre .vas no answer filed by either Mary Elizabeth Amico or Kristy HasloLk, obje.:ting to the cor;solio.lati'ln of the two cU!;es to docket number 96-6045, Civii Tenn, IT IS HEREBY ORDERED AND DECREED, that the above two cases arc consolidated to tenn number 96-6045 C:vil Term. BY THE / ~'. 'J U I..JJ' , I i j,