The URL can be used to link to this page

Home My WebLink About04-0764LAW OFFICES OF PETER J. RUSSO, P.C. PETER J. RUSSO, ESQUIRE PA Supreme Court ]D: 72897 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 Attorney for Plaintiff RANDY BURCIL Plaintiff HEATI:IER BECHTEL, Defendant 1N ~ COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2oo4- CIVIL ACTION - LAW CUSTODY COMPLAINT FOR CUSTODY 1. AND NOW, COMES, the Plaintiff, Randy Burch, by and through his attorney, Peter J. Russo, Esquire, and respectfully submits the following in support of Plaintiffs Complaint for Custody: 2. The Plaintiff is Randy Butch, residing at I Creek Road, Camp Hill, Pennsylvania 170 t 1. 3. The Defendant is Heather Bechtel, residing at 1532 Green Street, 3~a Floor, Harrisburg, Pennsylvania 17110. 4. Plaintiff seeks custody of the following child: Name Present Residence DOB Tyler Jordan Burch 1 Creek Road 9/1/2000 1. The child was bom out of wedlock. 2. The child is presently in the custody of Plaintiff, who resides at 1 Creek Road, Camp Hill, Pennsylvania 17011 3. During the past five years, the child have resided with the following persons and at the following following addresses: PeFsons Plaintiff & Defendant Plaintiff & Defendant Plaintiff Address 712 Bosler Avenue 5D Pennsylvania Avenue 1 Creek Road Duration 9/1/00 - 7/1/01 7/1/01 - 10/15/02 10/15/02 - Present 1. The father of the child is Plaintiff, currently residing at 1 Creek Road, Camp Hill, Pennsylvania 17011. The mother is not married. 2. The mother of the child is Defendant, currently residing at 1532 Green Street, 3rd Floor, Harrisburg, Pennsylvania 17110. The father is not married. 3. The relationship of plaintiff to the child is that of father. The plaintiff currently resides with the following persons: Name Relationshio John J. Butch Father 1. The relationship of defendant to the child is that of mother. The defendant currently resides with the following persons: Name Relationshiv NONE 2. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. The court, term and number, and its relationship to this action is: 3. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 4. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation fight with respect to the child. 5. The best interest and permanent welfare of the child will be served by granting the relief requested because Plaimiff has been the primary caretaker of the child since birth or adoption. His best interest would be served be remaining in Plaintiffs care and custody. 6. Each parent whose parental fights to the child have not been terminated and the person who has physicai 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: Address Basis of Claim Name NONE WHEREFORE, Plaintiff requests this Honorable Court to order that primary physical and legal custody of the minor child, Tyler Jordan Burch, be placed with Plaintiff. Date: Respectfully submitted, LAW OFFICES OF PETER J. RUSSO, P.C. Attorney for Plaintiff LAW OFFICES OF PETER J. RUSSO, P.C. PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 Attorney for Plaintiff RANDY BURCH, Plaintiff HEATHER BECHTEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004 - CIVIL TERM CIVIL ACTION - LAW CUSTODY VERIFICATION I, Randy Bm'ch, verify that the statements made in the foregoing document are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904 relating to nn~wom falsification to authorities. RANDY BURCH, Plaintiff Vn HEATHER BECHTEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004 - CML TERM CML ACTION - LAW CUSTODY CERTIFICATE OF SERVICES I, Debm A. Micklo, hereby certify that I am on this day serving a copy of the foregoing docments upon the person (s) and in the manner indicated below; Service by First-Class Mail, Postage Prepaid, and Addressed as Follows: HEATHER BECHTEL 1532 Green Street, 3r~ Floor Harrisburg, PA 17110 /~ ~' -~ ~ .~ Debm A. Micklo, Paraiegat Defendant COMMONWEAUI~I OF ' PENNSYLVANIA COURT OF: ~c/I t COUNTY O1 : II~CRI_ MIN~L/EQUiTY ACTION: AFFIDAVIT OF SERVICE I, Roger C. Spitz, being duly sworn according to law, do hereby affirm that I am not a party to the action or otherwise interested in the subject matter in controversy, I am over 21 years of age and I am a Constable duly authorized under the laws of the C°mmon_w,eoalth of Pennsylvania; that on the o~'~ dav of ~'~ at ~'~ ~ -/~ ~ , a.m~., I served (document served) at(placeofservice) [.(~.~bt~$ ~i.,~t,7~$ /,~ ~)~,~ in the manner described below: Personally delivered it into the hands of the person ;o be served. Personally delivered it to an adult family member with Whom that person resides. The relationship to the person to be served is Personally delivered it to an agent or person in charge of the person's office or usual place of business. Personally delivered it to an agent in charge of the apartment building where the person resides. Other: _Descrintion of Recipien~ Sex: ,f~ Skin Color: Facial Hair: Height (approx.): U/ Hair Color: Weight (approx.): //0 Pennsylvania State Constable Cumberland County ID # B001517 RANDY BURCH : PLAINTIFF : : V. HEATHER BECHTEL : DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-764 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, March 02, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective cmmsel appear before Dawn S. Sunday, Esq. _, the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, March 25, 2004 at 8:30 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. All children age five or older may also be l~resent at the conference. Fa/lure to al~pear 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/ Dawn S. Sunday. 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 RANDY BURCH, Plaintiff V HEATHER BECHTEL, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2004 - 764 CIVIL TERM : : CIVIL ACTION - LAW : CUSTODY APPEARANCE PRAECIPE To the Prothonotary: Please enter my appearance as counsel for the defendant, Heather Bechtel in the above captioned case. Dated this 5th day of March, 2004. Camp Hill, PA 17011 (717)612-1660 RANDY BURCH VS. HEATHER BECHTEL Plaintiff Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-764 CIVIL ACTION LAW IN CUSTODY .ORDER AND NOW, this 25TM day of March 25 , 2004 the conciliator, being advised by Plaintiff's counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction. The Custody Conciliation Conference scheduled for today is cancelled. FOR THE COURT, Dawn S. Sunday, Esquire Custody Conciliator ,M_NfiOi1 I~ .,, :.., ~, ,3 ,kb',,/¢~OHtObld J-LL .JO RANDY BURCH, Plaintiff Vo HEATHER BECHTEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004- ~q CIVIL ACTION - LAW CUSTODY STIPULATED CUSTODY AGREEMENT AND NOW, COMES, the parties in the above-captioned matter, to wit, RANDY BURCH, and HEATHER BECHTEL, and request that the attached Order of Court be entered by the Court, by stipulation of the parties. NOW, THEREFORE, the parties hereto, each intending to be legally bound hereby, place their seal: Date: /ot~~L] ~Y BURCH HEATHER BECHTEL x~?SS FOR HEATHER BECHTEL Date: //J,//-d) (-// COMMONWEALTH OF PENNSYLVANIA ) :SS COUNTY OF f~ ~ ~ b ~ ~ ~ c~ ~c~l ) Onthis, the il'~' dayof /0o~'e~nboc ,2004, beforeme, a Notary Public, the undersigned officer, personally appeared RANDY BURCH, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my h~an~t and Notarial seal. My Commission Expires N otary Public / NOTARIAL SEAL SUSAN J. MILLER, Notary Public Camp Hill Boro, Cumberland County My Cornmisslon Expires Sept. 19, 2005 COMMONWEALTH OF PENNSYLVANIA ) :SS On this, the t[ t4a day of/k)(~tJCg&_~ef,. 2004, before me, a Notary Public, the undersigned officer, personally appeared HEATHER BECHTEL, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my~d and N~/ar~i~l 7r My Commission Expires /./ lqlotary Public NOTARIAL SEAL SUSAN J, MILLER, Notary Public Camp Hill Boro, Cumberland County MY Commi~ion E~pirse 8et~. 1~ ~005