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Home My WebLink About99-04962 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRADLEY A. WEVODAU, ) Plaintiff ) V. ) ANNETTE F. WEVODAU, ) Defendant ) NO.(?G - ?/ CIVIL CIVIL ACTION - LAW CUSTODYNISITATION ORDER OF COURT AND NOW, _A E- 1 1 , 1999, upon consideration of the attached complaint, it is hereby dire d that the parties and their respective counsel appear ?,b,,efore _tACJy1;tk L, Esquire, the conciliator, at S? 7 1> N T4 Pennsylvania, on the __J?A__day of QC?o1--C, 1999, at 6 o'clock p in. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to &solve 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. Either party may bring the child who is the subject of this custody action to the conference, but the child's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: 21(`.. G4_ . Custody Conciliator -,Nll) 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. 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 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 240-6200 FILFD-OFFICE OF' '';n );pa,OTARY 99 AUG 18 PM 3: 11 CUA1?EPiL;e?D COUMY NENiJSYL'?.+;?;;q 0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRADLEY A. WEVODAU, ) Plaintiff ) V. ) NO. I9 N9G,L CIVIL ANNETTEF. WEVODAU, ) CIVIL ACTION -LAW Defendant ) CUSTODYNISITATION COMPLAINT FOR CUSTODY AND NOW, Plaintiff Bradley A. Wevodau, by and through his attorney, Howett, Kissinger & Conley, P.C., files a Complaint for Custody against Defendant, Annette F. Wevodau, and in support thereof, avers the following: Plaintiff is Bradley A. Wevodau (hereinafter referred to as "Father"), who currently resides at 2900 Society Hill Drive, Apartment 3, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. Defendant is Annette F. Wevodau (hereinafter referred to as "Mother"), who currently resides at 1887 Douglas Drive, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff seeks custody of the following children: Name Present Address Date of Birth Rachel Y. Wevodau 2/26/88 Bradley A. Wevodau, Jr. 5/25/90 The children were not born out of wedlock. The children are presently in the custody of Defendant who currently resides at 1887 Douglas Drive, Carlisle, Cumberland County, Pennsylvania, 17013. During the past five years, the children resided with the following persons and at the following addresses: Person Addresses Dates Brad and Annette Wevodau 1345 Kuhn Road Boiling Springs, PA 1/98 to 7/99 Brad and Annette 151 State Road 8/91 to 12/98 Wevodau Mechanicsburg, PA The mother of the children is Annette F. Wevodau, who currently resides at 1887 Douglas Drive, Carlisle, Cumberland County, Pennsylvania, 17013. She is married. The father of the children is Bradley A. Wevodau, who currently resides at 2900 Society Hill Drive, Apartment 3, Camp Hill, Cumberland County, Pennsylvania, 17011. He is married. 4. The relationship of Plaintiff to the children is that of father. Plaintiff currently resides alone. 5. The relationship of Defendant to the children is that of mother. Defendant currently resides with the following persons: Name Relationship Rachel Y. Wevodau Daughter Bradley A. Wevodau, Jr. Son 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 interests and permanent welfare of the children will be served by granting the relief requested because primary physical custody in Husband will best facilitate the educational and emotional development of the children. 8. Each parent whose parental rights to the children have not been terminated and the persons who have physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff Bradley A. Wevodau respectfully requests that this Honorable Court enter an Order granting him primary physical custody of the children. Respectfully submitted, Date: F ? 9 Donald T. Kissinger, Es uire ` HOWETT, KISSINGER & CO Y, P.C. 130 Walnut Street P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Plaintiff Bradley A. Wevodau VERIFICATION I, Bradley A. Wevodau, hereby swear and affirm that the facts contained in the foregoing Complaint for Custody are true and correct to the best of my knowledge, information and belief and are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date: 4 / ey. W au } I cf Ln f i 7 s U=?? L7 i I t ( m U cn ?? U U - rv) ?? ^n 4 FF ??N:P o .d v o x ° UE H ? ¢ v ¢.y x ° m uW 3 wz?> o? Aov w WG7o"i ?O I U Ww WQ E. a 0? Q O a E U Z 94 3 3 ¢ ti '? o y w W O ZO ¢ w ` a ,ry a ! y a U U ¢ ¢ p . £ ?i z Cs7 [Hr W o z` F IziUV°z z raa ¢ 0 x HOWETT. KISSINGER & MILES, P.C. .,uG 17 1999 j?\L, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRADLEY A. WEVODAU, ) Plaintiff ) V. ) ANNETTE F. WEVODAU, ) Defendant ) NO. 99 - 4962 CIVIL CIVIL ACTION - LAW CUSTODYNISITATION AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I, Harry J. Gaab, being duly swom according to law, depose and say that I am a competent adult; that I personally served a certified copy of the Complaint in Divorce in the above-referenced matter on Defendant Annette F. Wevo onday, August 23, 1999. Harry J. SWORN to and subscribed before me this,?akday of rtz(;-:h, 1999. { C F- ' f_'f Lci P_ ?- C 1 at LL- C, J z a U F Q' w a i i O H N ? ma> ? W ¢ azO y W % m m Z Z z V ? 44 w 9W L) c ? j W U O ^3 ¢ v •N W [? H u . ?} 7 V y ` wEa O I OR. OA > > > q . a ? G r v a V1 '? ti E U z N [s W? ?77 3 3 W ,?' p m W a O aC-i .cm 7 <t w ¢ e 6 1 U U W rX ¢ rn W F ?7 s > z a Z i I •I v ? z° w ¢ x s= '-?, . BRADLEY A. WEVODAU, Plaintiff V3. ANNETTE F. WEVODAU, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4962 CIVIL TERM CIVIL ACTION - LAW CUSTODY/VISITATION ORDE AND NOW, this 51` day of 1999, upon review of the Conciliator's Report, it appearing that the parties have agreed to the terms and provisions of this interim Order which was dictated in their presence and approved by them and their counsel, it is hereby ordered and directed as follows: 1. The parties shall submit themselves to an evaluation to be performed by Reigler & Sheinvold Associates. Both parties will cooperate in ensuring that the evaluation is completed in a timely manner. The cost shall be pro- rated in accordance with the support order entered in this case. The parties shall agree to provide the evaluator with those proportionate shares and responsibilities. The evaluator shall provide both counsel and the conciliator with a copy of his recommendations. Vii`-'1'Ir.- i.F7 2. The parties shall reconvene for another custody conciliation before Michael L. Bangs, Esquire, on February 3 2000, at 10:00 a.m. 3. Pending said conciliation, the custodial arrangement for the children shall be in accordance with the following: A. The parties shall share legal custody of the minor children; Rachel Y. Wevodau, d.o.b. February 26, 1988 and Bradley A. Wevodau, Jr., d.o.b. May 25, 1990. B. Mother shall have primary physical custody of the minor children subject to periods of partial custody and visitation with Father as follows: (1) On alternating weekends from Friday at 5:00 p.m., at which time Father shall pick the children up from Mother's residence, until Sunday at 5:30 p.m., at which time Mother shall pick the children up from Father's residence. This alternating weekend shall commence on October 22, 1999. (2) On every Wednesday from 9:00 p.m. until Thursday at 9:00 a.m. Father shall take care of the transportation for this mid-week periods of partial custody. C. Mother shall have Thanksgiving in 1999. D. Mother shall have Christmas Eve until Christmas Day at 11:00 a.m. Father shall have Christmas Day at 11:00 a.m. until December 26`n at 5:30 p.m. Father shall provide transportation to effectuate this period of partial custody and visitation. 9. Such other times as the parties may agree. BY THE COURT, I, / Donald T. Kissinger, Esquire Attorney for Plaintiff Peter Russo, Esquire Attorney for Defendant mlb BRADLEY A. WEVODAU, Plaintiff V3. ANNETTE F. WEVODAU, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4962 CIVIL TERM CIVIL ACTION - LAW CUSTODY/VISITATION JUDGE PREVIOUSLY ASSIGNED: None. CUSTODY C0NCI1ZATTON ONFE=1CE S n r nm IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the children who are the subject of this litigation is as follows: NAME BIRTH DATE CURRENTLY IN CUST_ ODy O,g Rachel Y. Wevodau February 26, 1988 Defendant Bradley A. Wevodau May 25, 1990 Defendant 2. A Conciliation Conference was held on October 14, 1999, and the following individuals were present: the Plaintiff and his attorney, Donald T. Kissinger, Esquire; the Defendant appeared with her attorney, Peter Russo, Esquire. 3. Items resolved by agreement: See attached Order. 4. Issues yet to be resolved: See attached Order. 5. The Plaintiff's position on custody is as follows: See attached Order. 6. The Defendant's position on custody is as follows: See attached Order. 7. Need for separate counsel to represent children: Neither party requested. 8. Need for independent psychological evaluation or counseling: The parties shall submit themselves to an evaluation to be performed by Reigler & Sheinvold Associates. Both parties will cooperate in ensuring that the evaluation is completed in a timely manner. The cost shall be pro-rated in accordance with the support order entered in this case. The parties shall agree to provide the evaluator with those proportionate shares and responsibilities. The evaluator shall provide both counsel and the conciliator with a copy of his recommendations. Date: November 2, 1999 Michael L. Bangs Custody Conciliator , I - 0 1 OCT 2 0 2000 f BRADLEY A. WEVODAU, Plaintiff VS. ANNETTE F. WEVODAU, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-4962 CIVIL TERM CUSTODYNISITATION ORDER OF COURT AND NOW this /1/1?k day of 0t , 2000, having not heard from the parties for some time, the undersigned Conciliator assumes the matter has been resolved and hereby relinquishes jurisdiction of the case. If either of the parties wishes further proceedings in this action, they should petition the Court anew. FOR THE COURT, MI HAEL L. BANGS Custody Conciliator _ - _, ; >.- -? c; U PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 5010 E. Trindle Road, Suite 200 Mechanicsburg, PA 17050 (717) 591-1755 BRADLEY A. WEVODAU, Plaintiff V. ANNETTE F. WEVODAU Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4962 CIVIL TERM CIVIL ACTION - LAW CUSTODYNISITATION ORDER AND NOW, this -0 day of 2001, it is hereby ordered that a continuance in the above-captioned matter has been GRANTED. The hearing previously scheduled for March 9, 2001, is generally continued. The parties shall contact the Court to schedule a new hearing date and time, when all parties are prepared to proceed. Don Kissinger, Esquire Attorney for Plaintiff Peter Russo, Esquire Attorney for Defendant BY TH Edward E. Guido, Judge C? G ?? ,A M? Y. mgyp. MAR 5 2001 ATTORNEY AT LAW Suite 200. 5010 East Trindlc Road Mechanicsburg, PA 17050 PHONE: (717) 591-1755 FAX: (717) 591.1756 Offices in Carlisle, At Friday, March 2, 2001 The Honorable Edward E. Guido Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 RE: WEVODAU v. WEVODAU Dear Judge Guido, With the consent of opposing counsel. I write seeking a general continuance in the above-referenced matter. This matter was previously scheduled to be heard on March 9, 2001, at 1:00 p.m. An accountant has been retained to review all pertinent information, due to the fact that Mr. Wevodau is self-employed. Opposing counsel and I agree that the parties' experts will need additional time to prepare for the hearing. We will await your decision. Very truly yours, Peter J. Ru?so PJR/mmm cc: Donald T. Kissinger, Esquire Please Reply Tor MECHANICSBURG OFFICE