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Home My WebLink About01-0646 FX r-.'" ~'"'__~~_~ "".~" - .-. .- ,,-~, ",' f ,-"",~" -, ",,- ~ _'~"'~=','h-''''-.,'';:, ,'_'r- '.L."-,:"',"",,-, '-',',.4$' ,. ,,,,,,,.,;,,, .-'hc""~i",,,,,,,,",;/'''''''".(-!.l~",,,:;;'';i ,,' '-''-'.1":"$;;, JOSEPH F. VAJDA, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PATTI J. VAJDA, Defendant IN CUSTODY /i)>L, .",....~ NO. DI-{,'1C. ~ I" COMPLAINT FOR CUSTODY 1. The Plaintiff is Joseph F. Vajda, residing at 509 S. 18th Street, Camp Hill, PA 17011. 2. The Defendant is Patti J. Vajda, residing at 1209 Edinburg Circle, New Cumberland, PA 17070. 3. The parties have two children, Brandon Joseph Vajda, born March 13, 1985 and Brittany Nicole Vajda, born January 23, 1987. Plaintiff seeks shared legal custody in both parties, primary physical custody of Brandon Vajda, primary physical custody of Brittany Vajda in Defendant and times of partial physical custody in the non- custodial parent at times mutually agreed upon. The children were not born out of wedlock. Currently Brandon resides with Plaintiff and Brittany resides with Defendant at the above respective addresses. ,,==,- >">- - "-~ ,~ - ." ~~- ~'~~ .~" ,~=.. ~.~,~~, ',n_> "0<' ',' '~""'k! During the past five years, the children have resided with the following persons and at the following addresses: Brandon Patti J. Vajda and Brittany N. Vajda 117 Shirley Drive Middletown, PA 17057 1/4/96 to 1/1/99 Patti J. Vajda and Brittany N. Vajda 1209 Edinburg Circle New Cumberland, PA 17070 1/1/99 to 12/28/00 Joseph F. Vajda and Stephanie E. Vajda 509 S. 18th Street Camp Hill, PA 17011 12/28/00 to the present Brittany Patti J. Vajda and Brandon J. Vajda 117 Shirley Drive Middletown, PA 17057 1/4/96 to 1/1/99 Patti J. Vajda and Brandon J. Vajda 1209 Edinburg Circle New Cumberland, PA 17070 1/1/99 to 12/28/00 Patti J. Vajda 1209 Edinburg Circle New Cumberland, PA 17070 12/28/00 to the present The mother of the children is Patti J. Vajda, currently residing at 1209 Edinburg Circle, New Cumberland, PA 17070. She is divorced. The father of the children is Joseph F. Vajda, currently residing at 509 South 18th Street, Camp Hill, PA 17011. He is married. 4. The relationship of Plaintiff to the children is that of Father. The Plaintiff currently resides his wife, Stephanie E. Vajda, his stepson, Jonathan David Driscoll, and his son, Brandon Joseph Vajda. - - ,,- -~ =.. n ~..,"~. ~'~ '~-'" ,-. ~., ""' '0__ >'<'"." __ ","'- -' ..", '.~- "<.;_~, '~"",--;,"""'~-'-'"~-"'""..-~--,,;J-' .'" ,",_..,) __ c 'c<-~;;;-"';,i~ 5. The relationship of Defendant to the children is that of Mother. The Defendant currently resides with the parties' daughter, Brittany Nicole Vajda. 6. Plaintiff has 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 information 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. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: (a) Plaintiff desires to confirm with a Court Order the physical custodial arrangement that the parties are currently following; (b) Plaintiff will assure that Brandon spends time with the Defendant and with his sister. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. _ d'~'" ' ." _"~_""~', _'~" WHEREFORE, Plaintiff requests the court to grant shared legal custody of the children in the parties, primary physical custody of Brandon with him, primary physical custody of Brittany with Defendant, sharing of transportation and a schedule of partial physical custody in the non-custodial parent at times mutually agreed upon by the parties. -j~?Jk~ Sandra L Meilton, Esquire TUCKER ARENSBERG & SWARTZ 111 North F rant Street P,O, Box 889 Harrisburg, PA 17108-0889 (717) 234-4121 ATTORNEYS FOR PLAINTIFF " . - .~- - .- ",-,._,",-",,~- .",--, "j -, - '1'-.' . , VERIFICA lION I, the undersigned, Joseph F. Vajda, acknowledge that the facts stated in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to the penalties of 18 Pa. C.SA Section 4904 relating to unsworn falsification to authorities. ~dad-CJP Dated: r - ~ 3- ~t:> ( 35782.1 'Ii . JOSEPH F. VAJDA PLAINTIFF V. PATIIJ. VAJDA DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-646 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 6th day of February, 2001, upon consideration of the attached Complaint, it is hereby dir.ected that the parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliat at 39 West Main Street, Mechanicsburg, PA 17055 on the 21st day of February ,2001, at 9:30 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 defme 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 TIlE COURT, By: /s/ The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE 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 Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ;';W~.'Iii1ll1~ilJi~~JiIf'hl~iH.c"r,,,ia;f,,~~~~~.5%ffi5~~:lL".s0b:O!illL;!-,"'''.l',d!J;,''',.;tk!~l#:,B.';;\~~ ~~ -''''''--''''.''- ,~.<^ ,,- >~. ~. . .!tii.lll;& " ~._'- ~>-?AffVp . ~ ;f' ,"'."" 4,; ~/~ ~~~ 7t/. yv,,> {?:" ..~ ~ 4 -n >>~ ~ ".,.~. ,.~..-'?,~~~ 'j>"'<'~ ',,' e,,,,'" "~.~.,,,,,,.,,I iIINVAlJ )J.Nnco d'r{}Y:'gd -.,...I,h",llno ~ . . '-'/ ! If:: '5 . I,,)~' Q< , ,"-'~J'IO "".J.J I' ";';) - ="' .~-;. / t?}!. C' Ie? J>. C' IC?<::$'C .. , Ii1I!ilU --, - ..' .~"" -n: . ,.- " L- , , ' \.".J: .iJ." '.t"."",, '- ,~-- JOSEPH F. VAJDA, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNlY, PENNSYLVANIA : CIVIL ACTION - LAW PATTI J. VAJDA, Defendant IN CUSTODY NO. 0/- G Cj&, AND NOW, this ORDER OF COURT $"~ day of Jfl.J , 2001, upon stipulation of the parties, it is HEREBY ORDERED AND DECREED that: 1. The parents shall share legal custody of the children and each parent shall consult with the other concerning all major decisions affecting the children, including but not limited to, health, education and religion. 2. Father shall have primary physical custody of Brandon. Mother shall have primary physical custody of Brittany. 3. The non-custodial parent shall have times of partial physical custody at times mutually agreed upon by the parties. 4. The parties shall share holidays as they mutually agree. . , "b_, . ~ ~ , _" _..w",-"",;~,"__~ -'".~,o_~_ _~ -, 5. The parties shall share transportation with the parent receiving custody being responsible for said transportation. 35855.1 BY~EC~ J~ . -1f\ \ . ~~O ~ S ~. . '" ~'-l__ <_"'_"'-' "'-'.,>i ,_'~_ '.. 'j-\_,~O_~ "'''-.-, _;~~ 1- ,~ ~- , .. JOSEPH F. VAJDA, Plaintiff v. : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PAlTl J. VAJDA, Defendant : IN CUSTODY . ,/_ : NO. 01- G Y'w STIPULATION AND NOW, this day of ,2001, Joseph F. Vajda, Plaintiff (hereinafter referred to as "Father"), together with his attorney, Sandra L. Meilton, and Patti J. Vajda, Defendant (hereinafter referred to as "Mother"), hereby inform your Honorable Court that they have amicably resolved to their mutual satisfaction the issues of custody with regard to their two children, Brandon Joseph Vajda, born March 13, 1985 and Brittany Nicole Vajda, born January 23, 1987, and do hereby stipulate that the following is the substance of their agreement respectfully requesting that your Honorable Court issue an appropriate Order of custody and visitation in accordance with their agreement and stipulation. The parties stipulate as follows: 1. The parents shall share legal custody of the children and each parent shall consult with the other concerning all major decisions affecting the children, including but not limited to, health, education and religion. ~ "I " ,-i _ '0 _, - ",', C ~ _ ~,___"' -ff' 2. Father shall have primary physical custody of Brandon. Mother shall have primary physical custody of Brittany. 3. The non-custodial parent shall have times of partial physical custody at times mutually agreed upon by the parties. 4. The parties shall share holidays as they mutually agree. 5. The parties shall share transportation with the parent receiving custody being responsible for said transportation. ~~ -Sandra L. Meilton Witness , ".' ,~, . ~ R! , .., , .....__,M_.~," .,~ ,- .... ~= \ ~:,.:.~~..,~:..~ :r~'( ;(, ~ r' -~. (~ . r,\.:, " " ~ :' "1 " i-d' " .",_..-~ - ~...~ ~' ,~ 'I-_~~""i'l!!'I!;.;'!;Jr"l%,1lf!i'j~IlJII;<..,__,.-"",.-=",_~,,,,,,,.,,,,",-I!1M~'~~l;IlI:<1;_'ff""~,.' _~ ~~ ~ .-'_.L " "~ Ir->l1 "__..~__~~' '0"- I - .........~~ MAR 0 7 20~ JOSEPIl F. VAJDA, : IN TIlE COURT OF COMMON PLEAS OF plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. . . NO. OI-646 CIVIL TERM . . . : CIVIL ACTION - LAW PATTI J. VAJDA, . . Defendant : IN CUSTODY ClIDER OF COURT AND NOW, this 27th day of February, 200l, the Conciliator, being advised by Plaintiff's counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction in this case. The custody Conciliation Conference scheduled for February 27, 2001 is canceled. FOR THE a::URT, Da~ Custody Conciliator I II !:'11 -' -,'- ~ ' - ~.- - .,- A"= -, - . ~ "~%":"I"_"'" ,-".,=- 'c;." ,. '-" ~,I' , ',--"",""" RLED-OfFICE "Jc "",)'n 'n' 'o'rARv l Jr 1"':',\ 'rl\.."j'l II I 01 MAR -8 PM 12: 53 CUMSEI?.lAND COUNTY PENNSYLVANIA --~ ,~ '~_'''''''<'''W !_ ~~~~>Ji!i"~*,_i<.;.;W~l~~~IIIil!'i!m _~~_:m~~ -- -.. ~ "?I' W~_~_,_ ==.,~,~'^_""~_~' ^,'~_" ,___,.<_,.,,;~ JOSEPH F. VAJDA, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PATTI J. VAJDA, Defendant IN CUSTODY NO. 0/- !&''-I~ Ctc->.~ ( ~~ 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 Custody Conference Officer, on the day of , 2001, at a.m.lp.m. at , Pennsylvania, 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. Children need not be present at the Conference unless their presence is requested by the Custody Conference Officer. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT, Date of Order: By: Custody Conference Officer 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 Telephone No. (717) 249-3166 or 800-990-9108