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HomeMy WebLinkAbout01-04869 KATHLEEN A. KARRASCH IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTOPHER J. KARRASCH • 01-4869 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, August 29, 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, Cumberland County Courthouse, Carlisle on Wednesday, September 26, 2001 at 8:30 a.m. for aPre-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. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Jacqueline M. Verne, Esq. 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 _.rs,,,i•-. r~ ,,;: ~~ :~3 ~ ~, ~~..;~~4 :,. ~~ , _ - _, - I n - ~ ~ tlln k 1 `+~I~ ~kh54fl1~.~FP5p1 I! KATHLEEN A. KARRASCH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - CHRISTOPHER J. KARRASCH NO. ~~ ~~~ Defendant IN CUSTODY ORDER OF COURT LAW 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 2001, 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 shall 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: Custody Conciliator SAIDIS SHUF$ FLOWER & LINDSAY ATiORNEYS•AT•LAW 26 W. High Street Carlisle, PA 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 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 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, Pennsylvania 17013 (717) 249-3166 KATHLEEN A. KARRASCH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW CHRISTOPHER J. KARRASCH, NO. Defendant IN CUSTODY ORDER OF COURT You, Christopher J. Karrasch, Defendant, have been sued in court to obtain custody, of the chilren: Daniel J. Karrasch and Scott M. Karrasch. You are ordered to appear in person at Court Room No. of the Cumberland County Courthouse, Carlisle, Pennsylvania on the day of 2001, at .m., for a hearing. You are further ordered to bring with you the children: Daniel J. Karrasch and Scott M. Karrasch. If you fail to appear as provided by this order or to bring the child, an order for custody, partial custody or visitation may be entered against you or the court may issue a warrant for your arrest. Pending the above hearing, custody of the said child shall SAIDIS SHUF$ FLOWER & LINDSAY ATTORNEYS•AT•LAW 26 W. High Sheet Carlisle, PA be placed in Kathleen Karrasch, natural mother. 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, Pennsylvania 17013 (717) 249-3166 BY THE COURT: J. 9 KATHLEEN A. KARRASCH, Plaintiff v. CHRISTOPHER J. KARRASCH, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. (3~- y~~R Cl~l IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Kathleen Karrasch, residing at 121A Third Street, Boiling Springs, Cumberland County, Pennsylvania 17007. 2. The Defendant is Christopher Karrasch, residing at 3 Butterchurn Lane, Boiling Springs, Cumberland County, Pennsylvania 17007. 3. Plaintiff seeks custody of the following children: Daniel J. Karrasch, date of birth 3/25/91 and Scott M. Karrasch, date of birth 3/23/95. 4. The child is presently in a shared custody situation with both parents, although the children primarily reside with the Plaintiff. 5. During the past five years, the children have resided SAIDIS SHUFF, FLOWER & LINDSAY ATTORNBYS•AT•LAW 26 W. High Stree[ Carlisle, PA with both parties at 3 Butterchurn Lane in Boiling Springs until March 5, 2001. From March 5, 2001 through August 1, 2001, the children have resided with the Defendant at 3 Butterchurn Lane. From August 1, 2001, through the present the children have resided on and off with both parties. i ~ 6. The mother of the children is the Plaintiff. She currently resides at 121A Third Street, Boiling Springs, Pennsylvania 7. She is married. 8. The father of the children is the Defendant. He currently resides at 3 Butterchiirn Lane, Boiling Springs, Pennsylvania. 9. He is married. 10. The relationship of Plaintiff to the children is that of mother. The Plaintiff currently resides with the following persons: None. 11. The relationship of Defendant to the children is that of father. The Defendant currently- resides with the following persons: None. 12. Plaintiff has not participated as a party or witness, SAIDIS SHUF$ FLOWER & LINDSAY ATTORW:YS•AT•LAW 26 W. High Street Cadiele, PA or in another capacity, on other litigation concerning the custody of the children in this or another court. The court, term and number, and its relationship to this action is: Not applicable. 13. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth.' The court, term and number, and its relationship to this action is: Not applicable. 14. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims I! , to have custody or visitation rights with respect to the children. The name and address of such person is: Not applicable. 15. The best interest and permanent welfare of the children will be served by granting the relief requested because the children have lived with Plaintiff all of their natural lives, with the exception of the past few weeks, which has been arbitrarily controlled by the Defendant. The Plaintiff has been their primary caregiver throughout their lives and has a stable home in the same school district along with Defendant. 16. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child 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 will be given notice of the pendency of this action and the right to intervene: None. WHEREFORE, Plaintiff requests the court to grant Plaintiff, SAIDIS t SH[IFF, FLOWER i & LINDSAY 26 W. High Streel Carlisle, PA Kathleen A. Karrasch, custody of the children, or in the alternative, to enter a shared legal and custody situation with the children. Respectfully SAIDIS, SHUF: John J. K Attorney I~ 26 West High Carlisle, PA Attorney for submitted, FLOWER & LINDSAY ecky, Es re . #53147 Street 17013 Plaintiff SAIDIS SHUF$ FLOWER & LINDSAY ATPOItN6Y$•AT•WW 26 W. High Street Carlisle, PA VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated: ~Iathleen A. K rrasch m°, ... ~ ~ ~ C ~l v) ~}, ~. ~ fi1 `~ - -Li ~, G k E d / ~. ~)~ U' i '1 `M1 -1 to _L` ~ .~ ! ~ ~: ~ SEP 2 ~ 20p1~ KATHLEEN A. KARRASCH, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : N0.2001-4869 CIVIL TERM CHRISTOPHER J. KARRASCH, :CIVIL ACTION -LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this 2~'` day of .S-c,oy~...4cr , 2001, upon consideration of the attached Custody Concih n Report, it is ordered and directed as follows: 1. The Mother, Kathleen A. Karrasch, and the Father, Christopher J. Karrasch, shall have shared legal custody of Daniel J. Karrasch, born March 25, 1991 and Scott M. Karrasch, born Mazch 23, 1995. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding her health, education and religion. 2. Father shall have primary physical custody of the children. 3. Mother shall have periods of partial physical custody of the children on the following schedule: A. Beginning October 13, 2001, alternating weekends from Saturday at 9:00 a.m. to Monday morning when Mother will put the children on the school bus. B. Every Sunday after church to Monday morning when Mother will put the children on the school bus. C. Every Wednesday after work to Thursday morning when Mother will put the children on the school bus. 4. The parties shall share the Thanksgiving holiday at times agreed by the parties. 5. The parties shall alternate the Christmas holiday. Block A shall be from 12:00 Noon Christmas Eve to 12:00 Noon Christmas Day and Block B shall be from 12:00 Noon Christmas Day to 12:00 Noon December 26. Father shall have Block A in odd numbered years and Block B in even numbered years. Mother shall have Block A in even numbered years and Block B in odd numbered years. y~~~yn~,tsrdr~~~ n., i~.~~,7 ~. i, , ~'._~ .. ~,_r i I ,... - +fat~~ a3 aex -s: enrr . ~'~stsA'.u,#9~3:'Ip4~4i .. .. . . _., 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 absence of mutual consent, the terms of this Order shall control. cc: Johnna J. Kopecky, Esquire, for Mother Thomas S. Diehl, Esquire, for Father BY THE COURT, SAP ~ 6 200 KATHLEEN A. KARRASCH, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :2001-4869 CIVIL TERM CHRISTOPHER J. KARRASCH, :CIVIL ACTION -LAW Defendant IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUli4MARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL EDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Daniel J. Karrasch March 25, 1991 Father Scott M. Karrasch March 23, 1995 Father 2. A Conciliation Conference was held in this matter on September 26, 2001, with the following individuals in attendance: Mother, Kathleen A. Karrasch, was present with her counsel, Johnna J. Kopecky, Esquire. Father, Christopher J. Karrasch, was present with his counsel, Thomas S. Diehl, Esquire. The parties agreed to an Order in the form as attached. Date ([~acq line M. Verney, Esquire Custody Conciliator