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Home My WebLink About98-06727 .J I z it . Jl 7 j'd ~ g ~ ~ J r-. d r ...3' 1).C ,'" ';no bfJ 1_ \, ;.' I, HI fJ1/c,hall J. /J1t111/7tfI IN TilE COURT OF COMMON PLEAS OF , Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. 9'?-I.O'" :j'1 CIVIL TERM v. t-Ifldq !I, /I1tl1~~fendant CUS'l'ODY ORDER OF COURT AND NOW, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before 'C',~ < . ',r, ~L\./\ I:: ~<i. , the conciliator, at . .3::1 \.J. \^o1C"\~\, \-A(t~"('l\'\ ',It (')'~~ the I:) day of 'Yr. (d -....l. 199~, at y.(j() o..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. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. By the court, cJ.:5nJ..G\\ ,~ 1\ lorr\~t\ .tli, . custody conciliator (J c-t6) 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. ClMBERLAND CXlUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE PA 17013 717 249 3166 lQ \~}~.~1~ \ I 1.1 .j; It ,iY ". c. . /~/IJ/!il~l/,' djP)' ~,;",~ -t~.' ./.f/(''''Y /J//"( L . / //J" .r/ t ;? F', 7,,(,~<'/Hd~fT ,." d rt-:..::J",.".-'!;'" ,..7 .Y .. ~ "': ~ '" I " /J1 fC,hcd.J if jl1(//l~f( / , Plaintiff III TilE COURT OF COMMON PLEAS OF CUMBERL7\ND COUlITY, PEllNSYLVANIA v. lIO. !lS-u/l 1'1 CIVIL TERM f.-./II ck //, /)1('( diM ~ Dcfcndant CUSTODY COMPr~rNT FOR CUSTODY L Thc Plaintiff is 1r!/f'h((f'1 J: Illa/IIM'" residing at 333 C/lle/l1: (qrltslr',I2. /7C'I5 JlO~ /~///1/br:'r/c(/1c1('iA~l7.i-y,C711):J</'1-8'.)-7S- 2. The Defendant is I-IlJdt1 1-1, /lko///a I , residing at , J J, I r. /,::;.,. r PL. . '1..fCr-L{ w- ll/ '3;;"" J . (partial custody) (visitation) of the following child(ren): NAME IY/q IIkw 0, ;J1q/1//0 t' PRESENT ADDRESS AGE '7j7'l1l IY/jll ftllln/' (;/f' H4rMr- M I! / The child ren) was/was nst born out of wedlock. The chi! (ren) is presently in the custody of L;/lch 1I/11a/l./7<? (' jYlcrfkr , who resides at 751,/11- !l1; 1/ (tfll Yc/' ;i;rf t</c;Y /l e.- :rth /-If.!;'7 During the past five years, the~hi~(ren) has resided with the following persons and at the following addresses: LIST ALL PERSONS ADDRESSES DATES m,~ha.e /;r: Il7ct/1/lcr / ,133 p11/~f/ Sf{//f/;;/e ~t(, /70/) 51,/1 I /nd~ J/ /)1a/117ai 333 Ill/en .)/6/'1// ~, 17m 7.9- ('[5 b,'c.- jJ1arlln ]3] 11&/1 .d- f;r,/rI? 11-c,17C/3 7-'1-tj't The mother of the~hi~ren) is L/ 'nctb /11 /nt:N7/7<'4: 26 . . currcntly reciding at '75'14P fY}1 / / (tl/l ((I 0rl tA0y1Je k, '1t.-?!:; , . ((:;J9)- q 73 -/;/ P ) She is (single)~rri~(diVorCCd). The father of the child(rcn) is rn I( h(Vo/ 'T. mt:l /J/Jf, I currently residing at 333 1!//el1 Sf. (1rlrir> .1i./7tf'/i'-:JrC!2- _\ ...r.:-~~~~ ' j' ('7/"1) Z(I'1-yS7J ) He is (single)~ (divorced). ~ 4. The relationship of Plaintiff to the child(ren) is ;S;r1Le~ The Plaintiff currently resides with: NAME .No tJ /J -e., RELATIONSHIP 5. The relationship of Defendant to the child(ren) is ;r10;t.lLRY/ The Defendant currently resides with: , . NAME / lImo II /J1a/l//a { '&('1; ):J, /J1aif/'/j RELATIONSHIP lYle/MY h/ofA2./r 6. Plaintiff ~(has not) participated as a party or witness, or in another capacity, in other litigation concerning the custody of this minor child(ren) in this or another court. The court, term and number, and its relationship to this action is: Plaintiff (~)(has no) information of a custody proceeding concerning the child(ren) pending in a court of this 27 'f I....". .......... . Commonwealth. The court, term and number, and its relationnhip to this action is: Plaintiff Cl'.R' al (doen not know) of a person not a party to the proceedings who has physical custody of the child(ren) or claims to have custody or visitation rights with respect to the ~hi~ren). The name and address of such person is: 7. The best interest and permanent welfare of the ~il~en) will be s~rved by granting the relief req~ested because: Il1tJlk/' /.1' Uti!::;' O/7c! /J1c'/ecl ('0/1-/ cJ~f- tfJ r sVa{e.., 8. Each parent whose parental rights to the~hi~(ren) have not been terminated and the person who has physical custody of ~he €~~en) have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child(ren) will be given notice of the pendency of this action and the right to intervene: NAME ADDRESS BASIS OF CLAIM fJ/l,ntf tt2J7?; tSoo sl. .JOe rJ I7fl1S/2.. S/5'..t.e-- . L '7 I .__ br~1'" 1/1 ,,1'1..,/ Gp (I r7 C'_ I<. /lJl -z../ ro rf lJ()ay tJ -e ]... /1 'It r;- 5J(fn a rn' <,..,./) ('7-/9- 9KY - '1.261 WHEREFORE, Plaintiff requests this court to grant ~(temporary custody) (visitation) of the~(ren) to the Plaintiff. Respectfully submitted, //-..20 Date rY ~~!'P?1Z~ 28 I verify that the ctatements made in this Complaint are true and correct. I understand that false statements herein are made subject to the pcnaltiec of 18 Pa.C.S. 54904 relating to unsworn falsification to authorities. 1/:f;-!&<</;' 7/!eM Plaintiff !/J ~a ' 29 f; ,\' l' J t( , , J M :' I I " (.l ~ -p (' '" ~ ~ Iii L ~ (-; . J -.:J (2) .... , 0 , lJl. \II U1 ., -, (; l)l '.'.) : ,.-; ", G <f1 i6- 1:> -''1 "', MICIIAEL J. MANNA I , Plaintif! IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 98-6727 CIVIL TERM CIVIL ACTION - LAW LINDA II. MANNA I , Defendant IN CUSTODY OODER OF COORT AND toi, this I e;~ day of ~~. consideration of the attached Custody Co ciliation and directed as follows: , 1999, upon Report, it is ordered 1. The Father, Michael J. Mannai, and the Mother, Linda II. Mannai, shall have shared legal custody of Matthew D. Mannai, born June 27, 1987. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of this paragraph, each parent shall be entitled to all records and information pertaining to the Child inclUding, but not limited to, school and rredical records and information. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. The Mother shall have primary physical custody of the Child. 3. The Father shall have partial physical custody of the Child for one weekend each month from Friday night through Sunday afternoon (or Monday afternoon if a school holiday immediately follows the weekend period of custody). The parties shall rreet half way between their respective residences in Indiana and Pennsylvania to exchange custody of the Child. 4. The Father shall have custody of the Child during one-half of the total number of weeks of the summer school break each year. The Father's weeks of custody under this provision shall be scheduled consecutively so that the Father has one extended period of custody during the summer. 5. The Father shall also have custody of the Child any time the Father travels to Indiana with the specific arrangements to be made by agreement of the parties. 6. The Christmas holiday shall be divided into Segment A, which shall run from the first day of the holiday school break through the midpoint of the school holiday, and Segment B, which shall run from the midpoint of the school holiday through the last day before school resumes. The Father shall have custody of the Child during segment A in odd numbered years and during Segment B in even numbered years. The Mother shall have custody of the Child during Segment A in even numbered years and during Segment B in odd numbered years. 7. /loth parties shall have liberal and reasonable telephone contact with the Child during the other party's periOds of custody. 8. The Mother shall provide sixty days advance notice to the Father of any intention to move the Child's residence outside the state of Indiana to permit the parties to negotiate 0'11 ternative custody arrangements or to submit the lTlatter to the Court if an agreement cannot be reached. 9. 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 n~tual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE~ ~"."/ ~ - cc: Michael J. Mannai - Pro Se Linda H. Mannai - Pro Se C";f':' 4- ""","Jd. 1/::.10/91 /.>.f' J. i 'i , I 1 I ) , . , MICIlAEL J. MANNAI I Plaintiff IN TilE COURT OF CO'IMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 98-6727 CIVIL TERM LINDA Il. MANNAI, Defendant CIVIL ACTION - LAW IN CUSTODY aJS'roDY cx:NCILIATIOO SlMIARY REPORT IN ACXDIDANCE WITH CUlIlERLAND <XXm'Y RULE OF CIVIL PROCEDURE 191s.3-8, the undersigned Custody Conciliato~ submits the following repo~t: 1. The pe~tinent information conce~ning the Child who is the subject of this litigation is as follows: ~ DATE OF BIRTH aJRRENl'LY IN CUSl'ODY OF Matthew D. Mannai June 27, 1987 Mothe~ 2. A Conciliation Conference was held on January 13, 1999, with the Fathe~, Michael J. Mannai, in attendance. The Fathe~ is not ~ep~esented by counsel in this matte~. The Mothe~, Linda H. Mannai, who ~esides in Indiana, participated in the Confe~ence by telephone. The Mother is not ~ep~esented by counsel in this matte~. 3. The parties agreed to entry of an Orde~ in the form as attached. It should be noted that the issue of jurisdiction was add~essed during the Confe~ence as the Mother and the Child have lived in Indiana for almost exactly six months. The Mothe~, howeve~, also wished to have a CUstody Orde~ entered at this time and ag~eed to the ju~isdiction of this Cou~t. . 10/)'"""""" /,~ It:ic; '7 Date I' De~~s;6 CUstody Conciliato~ - I , -i ~ ~. \ ,