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HomeMy WebLinkAbout07-4023L ~~ 1 ~ IN THE COURT OF CO~VIMON PLEAS OF CUMBERLAND COUNTY, ` PENNSYLVANIA JENNIFER R. MALti v. TRAVIS J. MALUCHNIK, ~', NO. C5'7 - yD~3 l: Gv ~L ~~2~ CIVIL ACTION -LAW CUSTODY You have been sued the following pages, you mi so, the case may proceed wi you by the Court. YOU SHOULD TA YOU DO NOT HAVE A I TELEPHONE THE OFFI CAN GET LEGAL ASSIS T -t. If you wish to defend against the claims set forth in prompt action. You are warned that if you fail to do >u and an Order for Custody may be entered against IIS PAPER TO YOUR LAWYER AT ONCE. IF ER OR CANNOT AFFORD ONE, GO TO OR T FORTH BELOW TO FIND OUT WHERE YOU and County Bar Association 2 Liberty Avenue Carlisle, PA 17013 ~pbone: (717) 249-3166 '~ ~ , IN THE COURT OF JENNIFER R. MAL v. TRAVIS J. MALUCHNIK, AND NOW, Plaintiff, Patrick O'Connor, Esquire, fil statement: 1. Plaintiff is Jen Columbia Road, Enola, Cuml 2. Defendant is T Creek Road, Shenmansdale, F 3. Plaintiff seeks Name Layla N. Maluchnik 1 The child was born out c The child is presently in E. Columbia Road, Enola, Cum divorced. PION PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA er CNIL ACTION -LAW ondent CUSTODY R. Maluchnik, by and through her attorney, G. plaint for Custody of which the following is a .. Maluchnik, Mother, who currently resides at 128 E. County, PA 17025. . Maluchnik, Father, who currently resides at 346 aunty, PA 17025. y of the following child/children: t Address Date of Birth Columbia Rd. September 25, 2000 PA 17025 tstody of the Mother, who currently resides at 128 d County, PA 17025. Mother and Father are ~ ~ ~ f L During the past five (5 following addresses: Persons Plaintiff Defendant Plaintiff Trevor Barninger (boyfri Plaintiff Trevor Barninger (boyfriend; Skyler Barninger (boyfriend' Plaintiff Plaintff Plaintiffs father (William V Plaintiff's mother (Sharon V The mother of the Columbia Road, Enola, The father of the Road, Shermansdale, Perry 4. The currently resides with the Vessa, Plaintiff's father; 5. The the child resided with the following persons at the Address 613A Geneva Drive Apt. 32 Mechanicsburg, PA 17055 632-C Enola Road West Fairview, PA 17025 Date March, 2003 to September, 2003 September, 2003 to March, 2004 417 E. Coover Street March, 2004 Mechanicsburg, PA 17055 to July, 2004 133 E. Columbia Rd. July, 2004 Enola, PA 17025 to September, 2004 128 E. Columbia Rd. September, 2004 Enola, PA 17025 to present Jennifer R. Maluchnik, who currently resides at 128 E. nd County, PA 17025. She is divorced. 'ravis J. Maluchnik, who currently resides at 346 Creek ~, PA 17025. He is divorced. Plaintiff to the child is that of mother. The plaintiff g persons: Layla N. Maluchnik, the child; William ~n Vessa, Plaintiff's mother. Defendant to the child is that of father. The defendant currently resides his fiance,~wh¢se name is unknown to Plaintiff. ~$ ' L. 6. Plaintiff has n in other litigation concerning Plaintiff has no in a court of this Petitioner and who has physical custody of respect to the child. 7. The best i granting the relief requested primary physical custody. 8. Each parent ~ the person who has physical All other person, named visitation of the child will intervene: (None) WHEREFORE, the parties joint legal Date: ~ ~~ ~~ rticipated as a party or witness, or in another capacity, astodv of the child in this or another court. of a custody proceeding concerning the child pending any other state. do not know of a party not a party to the proceedings gild or claims to have custody or visitation rights with permanent welfare of the child will be served by the Plaintiff is in the better situation to provide parental rights to the child has not been terminated and 3y of the child has been named as parties to this action. ho are known to have or claim a right to custody or i notice of the pendency of this action and the right to r respectfully requests that this Honorable Court grant the child and grant Plaintiff primary physical custody. Respectfully s fitted: By: G. atrick O'Connor, Esquire 3105 Old Gettysburg Road Harrisburg, PA 17011 717-737-7760 Attorney I.D. #64720 ATTORNEY FOR PLAINTIFF t I verify that the understand that false 4904 relating to unsworn ~., W o'~_ VERIFICATION made in this Complaint are true and correct. I in are made subject to the penalties of 18 Pa.C.S. § to authorities. ~. I hereby certify that party indicated below by Travis J. Maluchnik 346 Creek Road Shermansdale, PA 17025 DATE: ~ •~ ~ ~ ~TIFICATE OF SERVICE this day, served the herein Custody Complaint to the mail to the party named below: .Patrick O'Connor, Esquire Attorney No. 64720 3105 Old Gettysburg Road Camp Hill, PA 17011 (717) 737-7760 Attorney for Plaintiff ~~ !~ ~' o a ~~ t"l 4;. 1 ~._. =} ~__ ~~ N c !^ ~ J L~ ~,..._ 1 '~'~ -z7 G3 -~ r ~~~ :~ L .- f IN THE COURT OF ~ MON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER R. MALUCHN I~, NO. O'?'-- y0~ ~~~~~~ Plaintiff e~titi ner v. CIVIL ACTION -LAW TRAVIS J. MALUCHNIK, Defend pondent CUSTODY 1. The Petitioner is Jennife ~ . aluchnik, an adult individual who resides at 128 E. Columbia Road, Enola, erland County, PA 17025. 2. The Respondent is Travi aluchnik, an adult individual who resides at 346 Creek Road, Shermansdale, Pe unty, PA 17025. 3. The parties are the natur 1 p ents of daughter Layla N. Maluchnik, date of birth: September 25, 2000. 4. On Apri14, 2004, the p i i ~s ntered into a stipulation regarding custody, partial custody and visitation of e hild, which is attached hereto and incorporated herein as Exhibit "A." ~ 5. The best interest of the c i ~d ill be served by the Court's entering said custody stipulation as set forth as xh bit "A" as an Order of Court. .. ~ .~ WHEREFORE, Plai Miff Petitioner requests this Court to approve the foregoing stipulation and make it an O der f Court. ~ Respectfully submitted, DATED: /?'r! D `7~ -~~ ~~ 'G atrick O'Connor, Esquire 3105 Old Gettysburg Road ~I Camp Hill, Pennsylvania 17011 Telephone: 717-73 7-7760 I.D. No. 64720 '~, Attorney for Petitioner ,~,,. - '. THIS AG 2004, by and between JENN Pennsylvania, (hereinafter la TRAVIS J. MALUCHNIK, "Father"), PARTY OF THE WHEREAS, Mother of their minor child, LA known as "Child"); and NOW, THEREFO consideration of the bound hereby, it is agreed b; 1. CUSTODY AND VISIT A. Mother and the end that file minor Child. By decisions parties hereby dissolve the n~ Child or as to EXHIBIT "A" STODY AGREEMENT e and entered into this y~ day of ~~ , R. MALUCHNIK, of Cumberland County, as "Mother") PARTY OF THE FIRST PART, and nberland County, Pennsylvania, (hereinafter knoti~m as PART. Father are desirous of providing for the shared custody MALUCHNIK, born September 25, 2000, (hereafter AGREEMENT WITNESSETH that for and in covenants herein contained and intended to be legally between the parties hereto as follows: 1 have joint legal custody of the parties' minor Child to shall share jointly tree custodial responsibility for the iial responsibility, the parties shall share major iucation, medical care, and spiritual upbringing. The ,~ agree and state that it is not possible nor desirable to between the parties either as to the minor Therefore, the parties expressly state and agree that ,, •. . h w they wish to cony custody and upb~ B. The parties herel Child, subject to As a result of su make all day-to- the Child. Therf emergency medic ~ < events for said C i~d medical person to ~a C. During the period d~ f Father shall have ~s parties hereto. qt 2. LEGAL COUNSEL ', I The Mother is repres~rxt Father has been advised of hi IY parties agrees that he or she a~ understanding of the content 3. ORDER OF THE COUR ~, The parties agree that t~ shall continue in full force an ~ the parties. ~ be jointly, as well as severally, responsible for the of their Child. ;nate Mother to be primary physical custodian of said hts of partial custody in the Father, as stated below. gnation, Mother alone shall have the right and duty to •ental decisions and act as the primary care parent to Mother may, on her signature alone, authorize e for the minor Child, authorize absences and special school, and authorize the physician, dentist or other for said Child. ne when Mother is the primary physical custodian, ,tion at such times as mutually agreed upon by the shall not unreasonably withhold visitation. by the law office of G. Patrick O'Connor, Esquire. The ~t to seek legal counsel of his choice. Each of the itered into this Agreement with a complete ~eement shall be entered as an Order of Court and until [a] further Order of Court, or [b] stipulation of ~.. N 'V 4. ADDITIONAL INSTRU E Each of the parties s ~11 I acknowledge, and deliver to the reasonably required to give 11 5. APPLICABLE LAW The parties agree thal,.r Uniform Child Custody Juri c~i custody of the minor Child a 6. BINDING EFFECT ~ i This Agreement shal executors, administrators, su 7. ENTIRE AGREEMENT ', This Agreement cons iil any and all prior agreements ~I IN WITNESS THE J the day and year first above .,. ~ Iii TRAVIS . MALUCHNIK time to time, at the request of the other, execute, any and all further instruments that maybe and effect to the provisions of this Agreement. dless of the child's residence or provisions of the i Act, Pennsylvania shall retain jurisdiction over the as one or both parents reside with the Commonwealth. ng upon the respective parties, their heirs, and assigns. the entire understanding of the parties and supersedes ;otiations between them. the parties have hereunto set their hands and seals on (SEAL) ~ SEAL) ENNI R ALU HNIK ~'? ~ p ~,, f.___ r_c~ m - ~ -.~ c? -- CaJ '-~''i) r~ '}~ l .. e`` ...... ~ t~Sl ~~ ~7 w -~ ~,. ~u~ o 0 2oo~,,ny~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER R. MALUCHNIK, NO. Q~ . ~j/a~ CI~v ~~ ~~~ Plaintiff/Petitioner v. CIVIL ACTION -LAW TRAVIS J. MALUCHNIK, Defendant/Respondent CUSTODY ORDER AND NOW, TO WIT, this ~ day of x~1y , 2007, upon consideration of the attached Petition for Entry of Agreement, it is hereby ORDERED and DECREED that the custody agreement dated the 4th day of April, 2007, is adopted as an Order of Court and the parties are bound thereby. BY THE COURT: ~~ ~~ ~~ G 0 V 6S ~~ 'd 9- ~~';i' EQUI ,y { an. r'f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER R. MALUCHNIK, NO. 07-4023 Plaintiff/Petitioner v. CIVIL ACTION -LAW TRAVIS J. MALUCHNIK, Defendant/Respondent CUSTODY AMENDED ORDER AND NOW TO WIT this 23r~da of ~Jt y , 2~~7, upon consideration of the attached Petition for Entry of Agreement, it is hereby ORDERED and DECREED that the custody agreement dated the 4th day of April, 2004, is adopted as an Order of Court and the parties are bound thereby. BY THE COURT: r~ ~ ~ -c~ -~- U ~', ~: ^~ ...,G y" ~M~ Q L C`"` ~~ ~~ ~- "`/.