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Home My WebLink About08-1293 ANN KRZYZOSIAK Plaintiff, V. STEVEN KRZYZOSIAK Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08- P-9 3 CIVIL TERM IN CUSTODY COMPLAINT FOR CUSTODY NOW comes the Plaintiff, Ann Krzyzosiak, by and through her attorney, Mark F. Bayley, Esquire, and presents the following complaint for custody, representing as follows: 1. The Plaintiff, Ann Krzyzosiak, an adult individual residing at 105 Willow Drive, Shippensburg, PA, 17257. 2. The Defendant, Steven Krzyzosiak, an adult individual residing at 137 Baldwin Blvd, Shippensburg, PA, 17257. 3. Plaintiff seeks custody of the following children: Name Present Residence Awe D/OB Dalton Joseph Krzyzosiak 105 Willow Dr., Shippensburg, PA 5 10-13-02 Dane Andrew Krzyzosiak 105 Willow Dr., Shippensburg, PA 3 12-6-04 4. The Children were born out of wedlock 5. The relationship of the Plaintiff to the children is that of natural mother. The Plaintiff currently resides with the children and her mother, Margaret Kehoe. She is married. 6. The relationship of the Defendant to the children is that of natural father. The Defendant currently resides with his cousin, Dawn Shoop. He is married. 7. Over the past five years the children have resided with the following: Name Relationship Address Date Ann Krzyzosiak Mother 105 Willow Drive 1/08-Present Shippensburg, PA 17257 Ann Krzyzosiak Mother 105 Wilow Drive Birth-1/08 Steven Krzyzosiak Father Shippensburg, PA 17257 7. The Plaintiff has not participated as a party or witness, or in another capacity in other litigation concerning the custody of the children is this or any other Court. 8. Plaintiff has no information of a custody proceeding concerning the children pending in any Court of this Commonwealth or any other state. 9. Plaintiff does not know of a person nor a party to the proceeding who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 10. The best interests and permanent welfare of the children require Plaintiff to have primary physical custody and for Defendant to have specified periods of partial physical custody which may be agreed upon at a conciliation or otherwise be determined by the Court. WHEREFORE, Plaintiff requests this Honorable Court to schedule a custody conciliation conference. Respectfully submitted, BAYLEY & MANGAN l ?'- Date: C) V U/??4 Mark F. Bayley, Es e 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court ID # 87663 Attorney for Plaintiff ANN KRZYZOSIAK : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW STEVEN KRZYZOSIAK : NO. 08- CIVIL TERM Defendant. : IN CUSTODY 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. Cons. Stat. § 4904 relating to unsworn falsification to authorities. Ann Krzyzo Plaintiff 7?5 Q (t? °`j 7 Q ` i I'M ANN KRZYZOSIAK IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. STEVEN KRZYZOSIAK DEFENDANT 2008-1293 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, March 07, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, April 11, 2008 at 10:30 AM 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. 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/ Hubert X. Gilro Es q. 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 -,V- IWT? 44w 47? < 4q !) o f,tf .v 4 • 11 WV 01 8vw BGBZ ,,,? d-,/,- r 3Hi JO ANN KRZYZOSIAK, Plaintiff V. STEVEN M. KRZYZOSIAK, Defendant TO THE PROTHONOTARY: : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 08-1293 CIVIL TERM : IN CUSTODY PRAECIPE Please enter my appearance on behalf of the Defendant in the above captioned action. DATE: 3Ir? 6 '?K? B e . G ' ie, Esquire GRIFF ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 r, ,V ?^?' } .? ?' '7'? ',., ?`-,, . `.t , r--. .? ?' 3 y? ?.L Z;.? _ n _ l """ :1V> ANN KRZYZOSIAK Plaintiff v STEVEN KRZYZOSIAK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-1293 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Dalton Joseph Krzyzosiak, born October 13, 2002 Dane Andrew Krzyzosiak, born December 6, 2004 2. A Conciliation Conference was held on May 8, 2008, with the following individuals in attendance: The mother, Ann Krzyzosiak, with her counesl, Mark F. Bayley, Esquire, and the father, Steven Krzyzosiak with his counsel, Bradley L. Griffie, Esquire. 3. The parties agree to the entry of an Order in the form as attached. Date: May 2008 1 ? ? kcz// Hubert X. G' oy, Esquire Custody Conciliator N C) c? 73 i ' a MAY 14 200 ANN KRZYZOSIAK IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW STEVEN KRZYZOSIAK, NO. 2008-1293 Defendant IN CUSTODY COURT ORDER AND NOW, this da of May, 2008, upon consideration of the attached Custody I -Or Conciliation Report, it is ordered and directed as follows: 1. The mother, Ann Krzyzosiak, and the father, Steven Krzyzosiak, shall have shared legal custody of Dalton Joseph Krzyzosiak, born October 13, 2002, and Dane Andrew Krzyzosiak, born December 6, 2004. 2. Physical custody shall be handled as follows: A. During the school year, father shall have custody from Friday until Monday on alternating weekends, with the times for exchange of custody to be agreed upon by the parties. Father shall also have custody of the minor children on every Wednesday through Thursday and at other times as the parties agree. Otherwise, the children shall be in the mother's custody during the school year. B. During the summer months, the schedule set forth in subparagraph A above shall be followed, except father shall also be afforded one week per month during June and July at times agreed upon by the parties with the understanding that father's week shall follow one of his normal weekends of custody. 3. Father shall give mother at least thirty (30) days notice as to which weeks he will be exercising in June and July. 4. The parties shall meet again with the Custody Conciliator for a conference on Thursday, July 24, 2008, at 8:30 a.m. At that time, the parties shall determine if they can reach a permanent agreement. If not, the matter will be scheduled for a hearing before the Court. cc: " Mark F. Bayley, Esquire ?Bradley L. Griffie, Esquire 5larlo& ANN KRZYZOSIAK Plaintiff v STEVEN KRZYZOSIAK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-1293 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the children who are the subject of this litigation is as follows: Dalton Joseph Krzyzosiak, born October 13, 2002 Dane Andrew Krzyzosiak, born December 6, 2004 2. A Conciliation Conference was held on May 8, 2008, with the following individuals in attendance: The mother, Ann Krzyzosiak, with her counesl, Mark F. Bayley, Esquire, and the father, Steven Krzyzosiak with his counsel, Bradley L. Griffie, Esquire. 3. The parties agree to the entry of an Order in the form as attached. Date: May 2008 a?= f Hubert X. G' oy, Esquire Custody Conciliator AUG 4 ANN KRZYZOSIAK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW STEVEN KRZYZOSIAK, NO. 2008-1293 Defendant IN CUSTODY COURT ORDER AND NOW, this day of August, 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Courtroom No. 1 of the Cumberland County Courthouse on the 1-1?-k day of j 2 ?_, 2008, at ' 30 _ +. m. At this hearing, the Father shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a Memorandum setting forth the history of custody in this case, the issues currently before the Court, a list of witness who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This Memorandum shall be filed at least five days prior to the mentioned hearing date. 2. Pending further Order of this Court, this Court's prior Order of May 20, 2008, shall remain in effect. cc: 7radley k F. Bayley, Esquire L. Griffie, Esquire BY THE COURT, VIINVAIISNN?d 3 i :z Nd ? I snv o9oz 3Hi JO A ANN KRZYZOSIAK, Plaintiff VS. STEVEN KRZYZOSIAK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2008-1293 IN CUSTODY Prior Judge: The Honorable J. Wesley Oler, Jr. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the children who are the subject of this litigation is as follows: Dalton Joseph Krzyzosiak, born October 13, 2002 Dane Andrew Krzyzosiak, born December 6, 2004 2. A Conciliation Conference was held on August 7, 2008, with the following individuals in attendance: The mother, Ann Krzyzosiak, who appeared with her counsel, Mark F. Bayley, Esquire, and the father, Steven Krzyzosiak, with his counsel, Bradley L. Griffie, Esquire. 3. The Conciliators conducted a conference in May of this year and entered a temporary Order. Circumstances have changed and the parties are at this time unable to agree upon a permanent Order. The Conciliator recommends a hearing be scheduled. 4. The Conciliator recommends an Order in the form as attached. Date: August 2008 (3 ubert X. ilroy, Esquire Custody nciliator ANN KRZYZOSIAK, Plaintiff VS. STEVEN KRZYZOSIAK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-1293 CIVIL TERM IN CUSTODY J. WESLEY OLER, JR., JUDGE MOTION FOR CONTINUANCE AND NOW, comes movant, Bradley L. Griffie, Esquire, and petitions the Court as follows: 1. Movant is counsel of record for the above named Defendant, Steven Krzyzosiak. 2. The parties to this proceeding have caused a hearing to be scheduled for December 15, 2008 at 1:30 p.m. in Courtroom Number 1 of the Cumberland County Courthouse on the issue of custody of the parties' two minor children. 3. With the hearing being scheduled for one-half day, it is the opinion of counsel for the parties that the hearing will not be concluded in that timeframe and, therefore, a continuance to allow this matter to be scheduled for a full-day hearing is in the best interest of the parties, counsel and the Court. 4. Movant has secured the consent of opposing counsel, Mark F. Bayley, Esquire, to this request for continuance. WHEREFORE, Movant requests your Honorable Court to reschedule the hearing currently scheduled for December 15, 2008 at 1:30 p.m. to a later date and schedule the matter for a full-day hearing. Respectfully submitted, Affie, Esquire )r Defendant Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 I verify that the statements made in the foregoing document 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 falsifica DATE: `? 11 I h 8 K ~ ANN KRZYZOSIAK, Plaintiff vs. STEVEN KRZYZOSIAK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-1293 CIVIL TERM IN CUSTODY J. WESLEY OLER, JR., JUDGE CERTIFICATE OF SERVICE I, Bradley L. Griffie, Esquire hereby certify that I did, the I I day of September, 2008, cause a copy of Defendant's Motion for Continuance to be served upon the Plaintiff, Ann Krzyzosiak, by serving her attorney of record by first class mail, postage prepaid, at the following addresses: Mark F. Bayley, Esquire Bayley & Mangan 17 West South Street Carlisle, PA 17013 DATE: el, I %I 6 Y- c r1l ia qt= rn?'r"c F / ANN KRZYZOSIAK, Plaintiff VS. STEVEN KRZYZOSIAK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-1293 CIVIL TERM IN CUSTODY J. WESLEY OLER, JR., JUDGE O- RDER OF COURT AND NOW, this j? ` `? day of September, 2008, upon presentation and consideration of the within Motion for Continuance, the continuance is granted. The hearing previously scheduled in this matter for December 15, 2008 at 1:30 p.m. is rescheduled for d , the I-Xt4 day of , 200 , at 30 o'clock ct,.m. in Courtroom Number 1 of the Cumberland County Courthouse. All other provisions of our prior Order of August 12, 2008 shall remain in full force and effect. Cc" Mark F. Bayley, Esquire Attorney for Plaintiff //. radley L. Griffie, Esquire Attorney for Defendant 9- 46 a? l_o i LS ma l L 9(7/60 BY THE COURT, VINVAIASNN9d •?.Lf tit !??ra ?; 1??i?..€ ?f ?'V 9Z •ZI WA L I dS BOOZ 3A JO 1 ANN KRZYZOSIAK, : Plaintiff V. STEVEN KRZYZOSIAK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-1293 CIVIL TERM ORDER OF COURT AND NOW, this 120` day of January, 2008, upon consideration of the attached letter from Bradley L. Griffie, Esq., attorney for Defendant, the hearing previously scheduled for January 12, 2009, is CONTINUED GENERALLY. Counsel are directed to notify the Court by motion if a hearing in this matter is required or when a settlement has been reached. BY THE COURT, -, Mark F. Bayley, Esq. Attorney for Plaintiff ? Bradley L. Griffie, Esq. Attorney for Defendant rc eoP« m????c h ?k 'v.r...+i.l no L M: II WV h 1 NVf 60OZ ? 1G u -L a ?G 301J, ?O-(Pllj .--» UiC, ?c r GluFFIE ,Q??AJSOCI_A?rES Attorneys and Counselors at Law Bradley L. Griffie, Esquire Hannah Herman-Snyder, Esquire Robin I Bassett Office Manager Kelly L. Perez Legal Assistant Reply to: Carlisle The Honorable J. Wesley Oler, Jr. Cumberland County Courthouse Fourth Floor, Judges' Chambers Courthouse Square Carlisle, PA 17013 January 9, 2009 RE: Krzyzosiak vs. Krzyzosiak No. 2008-1293 Dear Judge Oler: 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 100 Lincoln Way East, Suite D Chambersburg, PA 17201 (717) 267-1350 (800) 347-5552 Fax (717) 243-5063 Your calendar will reflect that a custody hearing is scheduled in the above captioned matter for Monday, January 12, 2009, to begin at 9:30 a.m. Please be advised that opposing coult'sel and I, and our clients, have reached an agreement in this matter. I am in the process 'otdocumenting that agreement such that we should have a signed Stipulation to you within the next week to ten days. I believe you will receive additional correspondence from opposing counsel, Mark F. Bayley, Esquire, confirming that an agreement has been reached. We would appreciate if you could simply enter an Order continuing this hearing generally to afford us the opportunity to present the signed Agreement to you. y yours, Griffie BLG/rjb Cc: Mark F. Bayley, ;Esquire (via fax/mail) Steven M. Krzyzosiak