HomeMy WebLinkAbout01-1222 FX
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MICHAEL P. RADICH,
PLAINTIFF
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
LESLIE A. RADICH,
DEFENDANT
NO. 1)( - /;;;l::L;;). ~
IN CUSTODY
ORDER OF COURT
AND NOW, this
day of
, 2001, upon
consideration of the attached Complaint, it is hereby directed that the parties and their
respective counsel appear before
conciliator at
, Esquire, the
, Pennsylvania, on
the
day of
,2001, at
o'clock
.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 hard by the court, and to enter into a temporary order. Either party may bring
the child who is the subject of this custody action to the conference, but the chid's
attendance is not mandatory, 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 AFFORP 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
II
MICHAEL P. RADICH,
PLAINTIFF
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
LESLIE A, RADICH,
DEFENDANT
NO. b)-1m
IN CUSTODY
MOTION FOR EMERGENCY RELIEF
AND NOW comes the above-named Plaintiff, by his attorney, Samuel L. Andes, and
moves the court for emergency relief in the form of an interim order, based upon the
following:
1. The Petitioner herein is the Plaintiff, Michael P. Radich, an adult individual who
, resides at 6 Pamela Place in Mechanicsburg, Pennsylvania.
2. The Respondent herein is the Defendant, Leslie A. Radich, an adult individual who
resides at 1137 Franklin Street in Carlisle, Pennsylvania.
3. Plaintiff commenced this action by filing a Complaint for Custody at the same time
this Motion was filed. A copy of Plaintiff's Complaint for Custody is attached hereto and
marked as Exhibit A. The averments set forth in that Petition are hereby incorporated, by
reference, into this Motion.
4. Plaintiff requests interim relief in the form of an order by this court that the
parties' two children, Amy R. Radich, born 25 May 1982, who is currently a senior at
Carlisle High School and Kristen L. Radich, born 8 December 1983, who is currently a junior
at Carlisle High School, continue in the Carlisle School District until further order of court.
5. The order sought by Plaintiff is necessary because of the following events:
A. Both children have resided in the primary physical custody of
Defendant since Plaintiff and Defendant separated in 1999; and
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B. Plaintiff resides in the Cumberland Valley School District but the
children were enrolled in, and have attended the Carlisle School District, since
September of 1999, on the basis that the Defendant resided in the Carlisle
School District; and
C. Defendant has recently demanded that both children come to live
with her and has threatened to have them removed from the Carlisle School
District if they do not do so.
Plaintiff believes that the Defendant's action in this matter was not taken for legitimate
reasons or in the best interests of the children but merely represent an effort to force the
children to reside with her so that she can gain some economic advantage in the disputes
between Plaintiff and Defendant.
6. Interim relief is appropriate in this case for the following reasons:
A. Both girls have been enrolled in and have attended school in the
Carlisle School District for more than a year and a half; and
B. Both of the children are good students and are successful,
academically and socially, in the Carlisle schools; and
C. The children's extracurricular activities, social contacts, and
friendships, are primarily centered in the Carlisle School District; and
D. Removing them from their current schools in the midst of a school
year will work serious academic, social, and other harm and injury on the
children.
Defendant believes that, for these reasons, it is important that the children remain in the
Carlisle School District until such time as the court can review and determine the custody
issues between Plaintiff and Defendant.
7. The entry of an order directing the children continue in the Carlisle School
District will maintain the status QUo. Denying Plaintiff's request will work serious and
irreparable injury on the children.
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WHEREFORE, Plaintiff moves this court to enter an order directing that the children
remain in the Carlisle School District until further order of court, regardless of whether they
reside with Plaintiff or with Defendant.
~
Samuel L. Andes
Attorney for Plaintiff
Supreme Court ID # 17225
525 North 1 2'h Street
Lemoyne, PA 17043
(717) 761-5361
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COMMONWEALTH OF PENNSYLVANIA
SS.:
COUNTY OF CUMBERLAND
MICHAEL P, RADICH, being duly sworn according to law, deposes and says that the
facts set forth in the foregoing document are true and correct to the best of his knowledge,
information, and belief.
;7ILM pJ ILA/
MICHAEL P. RADICH
Sworn to and subscribed
before me this / s.f- day
of /J1~ ,2001,
'I LVAAn ~
il" Notary Public
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MICHAEL P. RADICH,
PLAINTIFF
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs,
CIVIL ACTION - LAW
NO.
LESLIE A. RADICH,
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW, this
day of
, 2001, upon
consideration of the attached Complaint, it is hereby directed that the parties and their
respective counsel appear before , Esquire, the
conciliator at
, Pennsylvania, on
the
day of
, 2001, at
0' clock
.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 hard by the court, and to enter into a temporary order. Either party may bring
the child who is the subject of this custody action to the conference, but the chid's
attendance is not mandatory. 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,
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CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166 ~
Exhibit
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MICHAEL P. RADICH,
PLAINTIFF
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO,
LESLIE A. RADICH,
DEFENDANT
IN CUSTODY
COMPILAINT IN CUSTODY
AND NOW comes the Plaintiff, MICHAEL P, RADICH, by his attorney, Samuel L,
Andes, and makes the following Complaint for Custody:
1. The Plaintiff is MICHAEL P. RADICH, an adult individual who resides at 6 Pamela
Place in Mechanicsburg, Cumberland County, Pennsylvania.
2. The Defendant is LESLIE A. RADICH, an adult individual who resides at 1137
Franklin Street in Carlisle, Cumberland County, Pennsylvania.
3. The Plaintiff and Defendant were married on 17 January 1980 and separated in
late August of 1999.
4. The Plaintiff and Defendant are the parents of two children, Amy R, Radich, born
25 May 1982, and Kristen L. Radich, born 8 December 1983,
5. This Petition involves legal and physical custody of the parties younger child,
Kristen L. Radich, who is still a minor, and the right of the older child, who is no longer a
minor, to continue her enrollment in the Carlisle School District.
6. The children were not born out of wedlock and are presently in the custody of the
Plaintiff.
7. During the past five years, the minor children have resided with the following
persons at the following addresses:
1 995 to August 1 999
6 Pamela Place
Mechanicsburg, PA
Plaintiff & Defendant
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August 1999 to present
6 Pamela Place
Mechanicsburg, PA
Plaintiff only
8, The father of the children is the Plaintiff who resides at the address set out
above, He is married to the Defendant.
9. The mother of the children is the Defendant who resides at the address set out
above. She is married to the Plaintiff.
10. The Plaintiff is the natural father of the children. Plaintiff currently resides with
the children.
11. The Defendant is the natural mother of the children. Defendant currently
resides alone,
12. The Plaintiff has not participated as a party or in any other way in any litigation
concerning the custody of the children in this or any other court.
The Plaintiff has no information of a custody proceeding concerning the children
pending in a court of this or any other jurisdiction.
Plaintiff knows of no other person not a party to this action already who has physical
custody of or claims to have custody or visitation rights to the said children,
12. When the parties separated in August of 1999, they enrolled the children in the
Carlisle School District because both children wished to attend that school district and both
parents felt that would benefit them, The enrollment was based upon the Defendant's
residence in Carlisle. The children continue to be enrolled at the Carlisle School District
where they do well academically and socially. Plaintiff wants very much to continue their
enrollment at the Carlisle School District until they complete high school.
13. Plaintiff seeks an award of primary legal custody because Defendant has
recently attempted to interfere with the education of the children. Her actions have included
threats to remove them from the Carlisle School District, and appearances at the school they
attend in which she repeated those threats in front of school officials, threats to report to
the school that the children do not reside with her and should not, lawfully, be enrolled in
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the school district, and a threat to resign her employment with Dickinson College so that the
parties' older daughter will not be able to attend that school under a tuition waiver program.
14. Plaintiff seeks an award of primary physical custody of the parties' minor
daughter, for the following reasons:
A, The daughter has expressed a strong preference to continue to live
with him; and
B. The Defendant has demonstrated her inability to provide a stable and
suitable home for the child; and
C. The Defendant has been abusive, emotionally and, in the past,
physically, toward both children and he fears that type of abuse will continue;
and
D. The Defendant has taken actions contrary to the best interest of the
children in an effort to gain advantage over Plaintiff in the economic disputes
the two of them are experiencing.
14, 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.
WHEREFORE, Plaintiff prays this court to award him primary legal and physical
custody of the parties' minor child, Kristen L. Radich,
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Samuel L. Andes
Attorney for Plaintiff
Supreme Court ID # 17225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361
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I verify that the statements made in this Complaint are true and correct, I understand
that any false statements in this Complaint are subject to the penalties of 18 Pa, C.S. 4904
(unsworn falsification to authorities),
Date:
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MICHAEL P. RADICH
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MICHAEL P. RADICH,
PLAINTIFF
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 0/ - /.;;?,;;),~ ;;J
LESLIE A, RADICH,
DEFENDANT
IN CUSTODY
ORDER
AND NOW this JVlrl day of vvt ? J I' ~ II ' 2001, lJpon
ne.llWtJ'PVt;, slot! fl!.""""Ve.
consideration of the attached Motion, it is hereb~ orderect.and Idlreci:e!~the parties'
TrDWl a1fVl d1?f!\ sd...", os
children, Amy R. Radich and Kristen L. Radich, 06I,tiRtI(; to atteAENse1:1 eol in the Carlisle
School District pending further order of court. This order shall rem~ in effect wheth:r.lthe
children reside prilT\a,rily with,thEl p~'nti.tf ~r ~e .oefeniant. .1.~C like]' p<;iJL wi ~ q.-s, 1
~ ,",c. v !l7A QJl jh c. t.m1lf)"Z 1 Q)) d IS <QJ e.J">.a VJCZ) 1''>.-\ w,rnl:. .s:.U.(d.0/~
All ot~r matters are referre to the c nciliator or further procee'el'ings, .
BY THE COURT,
J.
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MICHAEL P. RADICH,
PLAINTIFF
vs.
LESLIE A. RADICH,
DEFENDANT
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. Ci / ~ / d ;2:2 (!;;;J -'-:;-tA--
IN CUSTODY
COMPLAINT IN CUSTODY
AND NOW comes the Plaintiff, MICHAEL P. RADICH, by his attorney, Samuel L,
Andes, and makes the following Complaint for Custody:
1. The Plaintiff is MICHAEL P. RADICH, an adult individual who resides at 6 Pamela
Place in Mechanicsburg, Cumberland County, Pennsylvania.
2. The Defendant is LESLIE A. RADICH, an adult individual who resides at 1137
Franklin Street in Carlisle, Cumberland County, Pennsylvania,
3. The Plaintiff and Defendant were married on 17 January 1980 and separated in
late August of 1999.
4. The Plaintiff and Defendant are the parents of two children, Amy R. Radich, born
25 May 1982, and Kristen L. Radich, born 8 December 1983.
5. This Petition involves legal and physical custody of the parties younger child,
Kristen L. Radich, who is still a minor, and the right of the older child, who is no longer a
minor, to continue her enrollment in the Carlisle School District.
6. The children were not born out of wedlock and are presently in the custody of the
Plaintiff .
7. During the past five years, the minor children have resided with the following
persons at the following addresses:
1995 to August 1999
H
6 Pamela Place
Mechanicsburg, PA
Plaintiff & Defendant
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August 1999 to present
6 Pamela Place
Mechanicsburg, PA
Plaintiff only
8. The father of the children is the Plaintiff who resides at the address set out
above. He is married to the Defendant.
9. The mother of the children is the Defendant who resides at the address set out
above. She is married to the Plaintiff.
10, The Plaintiff is the natural father of the children. Plaintiff currently resides with
the children.
11. The Defendant is the natural mother of the children. Defendant currently
resides alone.
12, The Plaintiff has not participated as a party or in any other way in any litigation
concerning the custody of the children in this or any other court.
The Plaintiff has no information of a custody proceeding concerning the children
pending in a court of this or any other jurisdiction.
Plaintiff knows of no other person not a party to this action already who has physical
custody of or claims to have custody or visitation rights to the said children.
12. When the parties separated in August of 1999, they enrolled the children in the
Carlisle School District because both children wished to attend that school district and both
parents felt that would benefit them. The enrollment was based upon the Defendant's
residence in Carlisle. The children continue to be enrolled at the Carlisle School District
where they do well academically and socially. Plaintiff wants very much to continue their
enrollment at the Carlisle School District until they complete high school.
13. Plaintiff seeks an award of primary legal custody because Defendant has
recently attempted to interfere with the education of the children. Her actions have included
threats to remove them from the Carlisle School District, and appearances at the school they
attend in which she repeated those threats in front of school officials, threats to report to
the school that the children do not reside with her and should not, lawfully, be enrolled in
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the school district, and a threat to resign her employment with Dickinson College so that the
parties' older daughter will not be able to attend that school under a tuition waiver program.
14. Plaintiff seeks an award of primary physical custody of the parties' minor
daughter, for the following reasons:
A. The daughter has expressed a strong preference to continue to live
with him; and
B. The Defendant has demonstrated her inability to provide a stable and
suitable home for the child; and
C. The Defendant has been abusive, emotionally and, in the past,
physically, toward both children and he fears that type of abuse will continue;
and
D. The Defendant has taken actions contrary to the best interest of the
children in an effort to gain advantage over Plaintiff in the economic disputes
the two of them are experiencing.
14. 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,
WHEREFORE. Plaintiff prays this court to award him primary legal and physical
custody of the parties' minor child, Kristen L. Radich.
&- 0fP (L
Samuel L. Andes
Attorney for Plaintiff
Supreme Court ID # 17225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361
II
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.
I verify that the statements made in this Complaint are true and correct. I understand
that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S, 4904
(unsworn falsification to authorities).
Date:
/ /J1 AA-cJ, ;Z en:> I
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MICHAEL P. RADICH
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MICHAEL P. RADICH
PLAINTIFF
v.
LESLIE A. RADICH
DEFENDANT
IN TIIE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V ANlA
01-1222 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Monday, March 12, 2001 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumherland County Courthouse, Carlisle on Wednesday, April 11, 2001 at 2:30 p.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 TIIE COURT,
By: Isl
Jacqueline M. Verney. Esq.iIJ
Custody Conciliator
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
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SHUFF, FLOWER
& LINDSAY
ATIORNEYS-A,..LAW
26 W. High Street
Carlisle, PA
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. MICHAEL P. RADICH,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
No. 01-1222 CIVIL TERM
vs.
LESLIE A. RADICH,
Defendants
IN CUSTODY
PRAECIPE TO WITHDRAW APPEARANCE
TO THE PROTHONOTARY:
Please withdraw my appearance on behalf of the Defendant, Leslie A. Radich,
in the above captioned case.
SAIDIS, SHUFF, FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
By:
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Car .~
I D# 469
26 igh Street
Carlisle, PA 17013
(717) 243-6222
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APR 1 2 2001 f'J!J
MICHAEL P. RADICH,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYL VANIA
CIVIL ACTION - LAW
V.
LESLIE A. RADICH,
Defendant
: NO. 2001-1222 CIVIL TERM
: IN CUSTODY
ORDER OF COURT
AND NOW, this (;.r; day of v3.-l r<, ( ,2001, upon
consideration of the attached Custody Conciliati Report, it is ordered and directed as
follows:
1. A Hearing is scheduled in Court Room No. / , of the CumJ?erland
County Court House, on the ..70 y.( day of . a ' 2001, at / J 3 ()
o'clock, -/;, M" a~ which time testimony w/1 be taken. For purposes of this Hearing,
the Father shall be deemed to be the moving,party and shall proceed initially with
testimony. Counsel for each party shall file 'with the Court and opposing counsel a
Memorandum setting forth each party's position on custody, a list of witnesses who will
be expected to testify at the Hearing and a summary of the anticipated testimony of each
witness. These Memoranda shall be filed at least ten days prior to the Hearing date.
2, Pending further Order of Court or agreement of the parties, the prior Order
of Court dated March 2, 2001 shall continue in full force and effect.
3, Father, Michael P. Radich and Mother, Leslie A. Radich, shall share legal
custody of the child, Kristen 1. Radich, DOB December 8,1983, Each parent shall have
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 her health, education, except that nothing shall be inconsistent
with the Order of Court of March 2, 200 I, and religion.
4. Father shall have primary physical custody of the child.
5, Mother shall have periods of partial physical custody as Mother and
daughter agree, Substantial periods of partial physical custody are encouraged,
6. The parties shall keep each other advised immediately relative to any
emergencies, medical or otherwise, concerning the child, During such illness or medical
emergency, each party shall have the right to visit the child as often as he/she deems
consistent with the proper medical care of the child,
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7, Neither party shall do anything that may estrange the child from the other
party, or injure the opinion of the child as to the other party, or may hamper the free and
natural development of the child's love or affection for the other party.
BY THE COURT,
J.
cc: Samuel 1. Andes, Esquire - Father
P, Richard Wagner, Esquire - Mother
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MICHAEL P. RADICH,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLV ANIA
V.
CIVIL ACTION - LAW
LESLIE A. RADICH,
Defendant
: NO.2001-1222 CIVIL TERM
: IN CUSTODY
PRIOR JUDGE: J. WESLEY OLER, JR.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator subrnits the following
report:
I. The pertinent information concerning the Child who is the subjects ofthis
litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Kristen 1. Radich
December 8, 1983
Father
2, A Conciliation Conference was held April 11 , 2001 with the following
individuals in attendance: The Father, Michael P, Radich, with his counsel, Samuel 1.
Andes, Esquire, and the Mother, Leslie A. Radich, with her counsel, P, Richard Wagner,
Esquire.
3, The Court previously entered an Order on an Emergency Petition, dated
March 2, 2001, which prohibits either party from removing either child (the other child is
Amy R. Radich, DOB 5/25/82, who is already 18 years of age.) from attending school in
the Carlisle School District. The parties were unable to reach an agreement on the issue
of legal and physical custody and therefore it will be necessary to schedule a hearing.
4, Father and both children live in Mechanicsburg, where the children would
attend Cumberland Valley School High School. In August, 1999, Mother rented an
apartment in Carlisle and the children began attending Carlisle High School at the
beginning of the school year, Mother however did not separate from Husband and leave
the marital home until February 2001. Apparently both parties were in agreement for
both children to attend Carlisle High School during the 1999-2000 school year and part of
the 2000-2001 school year in order for the girls to play on the soccer team.
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5. When Mother separated from Father in February, 2001, she informed
Carlisle School District that the children were living primarily with Father and should not
be attending Carlisle Schools without paying tuition, Carlisle School District informed
the parties that the children could stay in the school as long as a court order was in place.
On March 2, 2001, The Honorable J. Wesley Oler, entered an order prohibiting either
party from removing the children from Carlisle Schools.
6, Father's position on custody is as follows: Father seeks primary legal
custody and primary physical custody with Mother having periods of partial physical
custody but not including overnights. Father requests Mother obtain counseling,
7. Mother's position on custody is as follows: Mother seeks shared legal
custody and shared physical custody. If that were to occur she would agree that the child
would continue to attend Carlisle High SchooL
8. The child was interviewed by the Conciliator. She indicated a preference
to live with her Father and visit her Mother as agreed by Mother and daughter, She
wanted to continue to attend Carlisle High School where she will be a senior during the
2001-2002 school year,
9. The Conciliator recommends an interim custody Order and the scheduling
of a Hearing in the form as attached, It is expected that the Hearing will require one half
day,
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Date
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acq line M. Verney, Esquire a
Custody Conciliator
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MICHAEL P, RADICH,
Plaintiff
v.
LESLIE A. RADICH,
Defendant
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IN TIIE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
NO, 01-1222 CIVIL TERM
ORDER OF COURT
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AND NOW, this 14th day of June, 2001, upon consideration of the attached letter
from P. Richard Wagner, Esq., attorney for Defendant, the hearing previously scheduled
for June 20, 2001, is cancelled.
Samuel L. Andes, Esq.
525 North 12th Street
Lemoyne, PA 17043
Attorney for Plaintiff
P. Richard Wagner, Esq.
2233 North Front Street
Harrisburg, P A 17110
Attorney for Defendant
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BY THE COURT,
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LAW OFFIC;ES
MANCKE, WAGNER, HERSHEY & TULLY
.JOHN S. M'ANCKt.
P. RcJCHARD WAGNER
DAV1D .E. HERSHEY
WILUAM T. TULLY
2233 NORTH FRONT STREET
HARRISBURG, PA 171 to
PHONE (717) 234~7051
FAX (7 1"7) 234"~7oeO
Jillle 13,2001
The Honorable 1. Wesley, 01er, Jr.
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
Re: Radich v. Radich
. NO: 2001-122
Dear Judge Oler:
This letter will serve to confirm my telephone call to your office on Jillle 12,
2001, regarding the above-captioned matter.
My client desires not to have this matter proceed forward.
The daughter in question, Kristen, is soon going to be 18 years of age (DOB
12/08/83).
An Order of April16, 2001, provides in pertinent part:
Mother shall have periods of partial physical
custody as mother and daughter agree . . .
My client has authorized me to indicate that she is agreeable to have continue
in effect that provision of the Court Order and therefore does not wish to proceed to
a custody hearing.
JUN 1 4 2001
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The Honorable J. Wesley Oler, Jf.
Re: Radich v. Radich
June 13,2001
Page 2
By copy of this letter to Sam Andes, counsel for the father, I am advising that
the matter is now settled consistent with the Order of April 16,2001.
Your attention is appreciated.
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L Rich
PRW/dks
cc: Samuel L. Andes, Esq.
Ms. Leslie Radich