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ALICIA NOVAK
PLAINTIFF
V.
LAWRENCE NOVAK
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
00-8605 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 15th day of December, 2000, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mechanicsbur2, PA 17055 on the 4th day of January, 2001 , at 11:00 a.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: Isl
Dawn S. Sunday, E-:it
Custody Conci]iato .
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of ]990. For information about accessible facilities and reasonable accommodations
availab]e 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.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HA VB AN ATTORNEY 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
Carlis]e, Pennsylvania 17013
Te]ephone (717) 249~3] 66
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ALICIA NOVAK,
Plaintiff
:
v.
NO. OO-'ilP05'
Civil Term
LAWRENCE NOVAK,
Defendant
:
IN CUSTODY
ORDER OF COURT
AND NOW, upon consideration of the attached Complaint, it is
hereby directed that the parties and their respective counsel
appear before , the Conciliator, at
on the day
of , 2000, 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. Failure to appear at the Conference
may provide grounds for entry of a temporary or permanent Order.
BY THE COURT:
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, PA 17013
(717) 249-3166
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 the office set forth above. 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.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ALICIA NOVAK,
Plaintiff
.
.
NO. tJ1; - ~(. 05
Civil Term
v.
.
.
LAWRENCE NOVAK,
Defendant
:
: IN CUSTODY
COMPLAINT FOR CUSTODY
AND NOW comes the Plaintiff, ALICIA NOVAK, by and through her
attorney, Maryann Murphy, Esquire, of Legal Services, Inc., and
respectfully files this Complaint for Custody, and in support
thereof avers as follows:
1. The Plaintiff is ALICIA NOVAK who currently resides at
324 Eutaw Avenue, New Cumberland, Cumberland County, Pennsylvania.
2. The Defendant is LAWRENCE NOVAK who currently resides at
549 South Front Street, Harrisburg, Dauphin County, Pennsylvania.
3. The Plaintiff seeks primary physical and legal custody of
the following child:
RILEY NOVAK, born January 3, 2000
4. The child was born out of wedlock. He currently resides
with Plaintiff and her daughter.
5. During the lifetime of the child, he has resided at the
following addresses with the following persons:
Time
Address
wi th Whom
birth-8/1/00 102 Oak Knoll Rd. Plaintiff/Defendant
New Cumberland, PA Plaintiff's daughter
8/1/00-9/13/00 324 Eutaw Ave. Plaintiff/Defendant
New Cumberland, PA Plaintiff's daughter
9/13/00-present 324 Eutaw Ave. Plaintiff/Plaintiff's
New Cumberland, PA daughter
6. The father of the child is LAWRENCE NOVAK. He is married
to Plaintiff.
7. The mother of the child is ALICIA NOVAK. She is married
to Defendant.
8. The child currently resides with Plaintiff and her
daughter.
9. The Plaintiff has not participated as a party or witness,
or in any other capacity, in other litigation concerning the
custody of the child in this or any other Court, except as set
forth above.
10. The Plaintiff has no information of a custody proceeding
concerning the child pending in a Court of this Commonwealth.
11. The 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.
12. Each parent whose parental rights to the child have not
been terminated, and the persons who have physical custody of the
child, have been named as parties to this action. There are no
other persons known to have or claim a right to custody or
visitation of the child and therefore, no further notice of the
pendency of this action and the right to intervene shall be given,
other than to the parties named herein.
13. The best interest and permanent welfare of the minor
child will be served by granting plaintiff primary physical and
legal custody.
WHEREFORE, Plaintiff requests this Honorable Court to
grant her primary physical and legal custody of RILEY.
Respectfully submitted,
Maryan Murphy,
Legal Services,
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
LD. # 61900
Attorney for Plaintiff
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VERIFICATION
I, ALICIA NOVAK, verify that the statements made in the
foregoing Custody Complaint are true and correct.
I understand
that false statements herein are made subject to the penalties of
18 Pa.C.S. 4904, relating to unsworn falsification to authorities.
f1i<~~
ALICIA AK/
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ALICIA NOVAK,
Plaintiff
.
.
.
.
v.
NO.
civil Term
:
LAWRENCE NOVAK,
Defendant
IN CUSTODY
CERTIFICATE OF SERVICE
I, Maryann Murphy, Esquire, do hereby certify that on the
day of
, 2000 I served a true and correct copy
of the foregoing Custody Complaint on the Defendant, LAWRENCE
NOVAK, at the address set forth below, by placing a copy of same in
the United States Mail, postage prepaid, certified/restricted
delivery.
Lawrence Novak
549 South Front Street
Harrisburg, PA 17104
Respectfully submitted,
ry
Maryann urphy,
Legal Services,
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
LD. # 61900
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ALICIA NOVAK,
Plaintiff
: NO. 9-00tJ -f00S-
v.
: IN CUSTODY
LAWRENCE NOVAK,
Defendant
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kind]y al]ow, ALICIA NOVAK, Plaintiff, to proceed in forma pauoeris.
I, Maryann Murphy, Esquire, of Legal Services, Inc., attorney for the party proceeding
in forma oauoeris, certify that I believe the party is unable to pay the costs and that I am providing
free legal services to the party. The party's affidavit showing inability to pay the costs of
litigation is attached hereto.
~'ESqUire
Lega] Services, Inc.
8 Irvine Row
Carlis]e, PA 17013
(717) 243-9400
LD. # 61900
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CML ACTION - LAW
ALICIA NOVAK,
Plaintiff
: NO.
v.
: IN CUSTODY
LA WRENCENOV AK,
Defendant
AFFIDAVIT IN SUPPORT OF PETITION
FOR LEAVE TO PROCEED IN FORMA PAUPERIS
1. I am ALICIA NOVAK, the Plaintiff in the above matter and because of my financial
condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action
or proceeding.
2. I am unable to obtain funds from anyone, including my family and associates, to pay
the costs of litigation.
3. I represent that the information below relating to my ability to pay the fees and costs
is true and correct.
(a) Name: ALICIA NOVAK
Address: 324 Eutaw Ave. New Cumberland. PA 17070
(b) Socia] Security Number: 171-70-5778
If you are presently employed, state N/A
Emp]oyer: N/A
Address: N/ A
Salary or wages per month: N/A
Type of work: N/A
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If you are presently unemployed, state
Date of last employment:
March 2000
Salary or wages per month:
$1000.00
Type of work:
CNA
(c) Other income within the past twelve months
Business or profession: -0-
Other self-employment: $300.00
Interest: -0-
Dividends: -0-
Pension and annuities: -0-
Socia] Security benefits: -0-
Support payments: -0-
Disability payments: -0-
Unemployment compensation and
supplemental benefits: -0-
Workman's compensation: -0-
Public Assistance: -0-
Other: -0-
(d) Other contributions to household support
(Wife)(Husband) Name: N/A
If your (husband) (wife) is employed, state
Emp]oyer:
N/A
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Salary or wages per month: N/A
Type of work: N/A
Contributions from children: -0-
(e) Property owned
Cash: $20.00
Checking Account: -0-
Savings Account: -0-
Certificates of Deposit: -0-
Rea] Estate (including home): N/A
Motor vehicle: Make HondaAccord
Cost $2.000.00
-0-
-0-
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Stocks; bonds:
Other:
Year 1989
Amount owed -0-
(t) Debts and obligations
Mortgage: N/A
Rent: -0-
Loans: -0-
Monthly Expenses: . $600.00
(g) Persons dependent upon you for support
(Wife) (Husband) Name: N/A
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Children, if any:
Name: RILEY
Age:
11 months
Name: GABRIELLE
Age:
6 years
4. I understand that I have a continuing obligation to inform the court of improvement in
my financial circumstances which would pennit me to pay the costs incurred herein.
5. I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn
falsification to authorities.
Date: !~/;4/ 10
a t;h~;;P~
ALICIA! VAK
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ALICIA NOVAK, : IN THE OOURT OF OOMMON PLEAS OF
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. : NO. 00-8605 CIVIL TERM
.
.
LAWRENCE NOVAK, . CIVIL ACTION - LAW
.
Defendant . IN CUSTODY
.
<ElER OF COORT
AND 1.01, this ~i- day of ~ ~
consideration of the attached CUstody Conciliation Report,
and directed as follows:
, 2001, upon
it is ordered
1. The Mother, Alicia Novak, and the Father, Lawrence Novak, shall
have shared legal custody of Riley Novak, bom January 3, 2000. Each
parent shall have an equal right, to be exercised jointly with the other
paJ:'ent, to make all major non~mergency decisions affecting the Child's
general well-being including, but not limited to, all decisions regarding
his health, education and religion.
2. The Mother shall have primary physical custody of the Child.
3. The Father shall have partial physical custody of the Child on
altemating weekends from Friday at 5:30 p.m. through Sunday at 5:30 p.m.
In addition, during weeks preceding the Father's periods of weekend
cootody, the Father shall have custody of the Child on Wednesday from 5:30
p.m. until 9:00 p.m.
4. The parties shall share having custody of the Child on holidays as
art'anged by mutual agreement.
5.
exchanges
parties.
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 absenc al consent, the terms
of this Order shall control.
The Father shall be responsible to provide transportation for all
of custody under this Order, unless otherwise agreed between the
J'y
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cc: Maryann Murphy, Esquire - COunsel for Mother
Patrick W. Quinn, Esquire - Counsel for Father
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ALICIA NOVAK, . IN THE COURT OF COMMON PLEAS OF
.
plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
vs. . NO. 00-8605 CIVIL TERM
.
.
.
LAWRENCE NOVAK, . CIVIL ACTION - LAW
.
Defendant : IN CUSTODY
CUSTODY CCI!ICILIATI<l!l' SUMMARY REP<m'
IN ACCCIIDANCE WITH CUMBERLAND COONTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned CUstody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
NAME
DATE OF BIRTH
CURRElilTLY IN CUSTODY OF
Riley Novak
January 3, 2000
Mother
2. A conciliation COnference was held on January 4, 2001, with the
following individuals in attendance: The Mother, Alicia Novak, with her
counsel, MaryaM Murphy, Esquire, and the Father, Lawrence Novak, with his
counsel, Patrick W. Quinn, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
J tJhU-<."(J
Date
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Dawn S. Sunday, Esquire 7
CUstody conciliator