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Home My WebLink About08-3630SOTIRIOS NTZANIS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLANDCOUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW JESSICA RADONOVICH, : No. 08 - 36-30 CIVIL Defendant : IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Sotirios Ntzanis, residing at 1009 S. Waterford Way, Cumberland County, Mechanicsburg, Pennsylvania 17050. 2. The defendant is Jessica Radonovich, residing at 4242 Valley Road, Perry County, Shermansdale, Pennsylvania 17090. 3. Plaintiff seeks custody of the following child: Name Present Residence DOB Age Isaiah Ntzanis 4242 Valley Road 12/27/07 5 months Shermansdale, PA 17090 The child was born out of wedlock The child is presently in the custody of Jessica Radonovich, who resides at 4242 Valley Road, Perry County, Marysville, Pennsylvania. During the past five years, the children have resided with the following persons and at the following addresses: List All Persons Kendra Radonovich List All Addresses 222 Reigle Road Marysville, PA Dates Birth to April, 2008 Thomas and Anna Ntzanis Sotirios Ntzanis 1009 South Waterford Way Mechanicsburg, PA 100 Appleton Drive Marysville, PA April - May 2008 May - June 2008 The mother of the child is Jessica Radonovich, currently residing at 4242 Valley Road, Shermansdale, PA. She is unmarried. The father of the child is Sotirios Ntzanis, currently residing at 1009 S. Waterford Way, Mechanicsburg, PA. He is unmarried. 4. The relationship of plaintiff to the child is that of Father. The plaintiff currently resides with the following persons. Name Relationship Thomas Ntzanis Father Anna Ntzanis Mother 5. The relationship of defendant to the child is that of Mother. The defendant currently resides with the following persons. Name Relationship Kendra Radonovich Mother Mike Radonovich Father 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. The court, term, and number, and its relationship to this action is: Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does know of a person not a parry to the proceeding that has claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the child will be served by granting the relief request because: Plaintiff has undertaken and performed the primary parental responsibilities for the children. Plaintiff is best able to provide the care and nurture which the children need for healthy development. Plaintiff desires to maintain the family household which has been established, and the continued stability of the household is in the best interest of the children. A Court Order of custody and structured visitation is desired so that the Plaintiff and the child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children 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 children will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim N/A WHEREFORE, Plaintiff requests this Court grant him primary physical custody with agreed upon visitation in Defendant. Respectfully submitted, ROMINGER & ASSOCIATES Date: _ 1 E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff VERIFICATION I verify that I am the petitioner and that the statements made in the foregoing Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904, relating to unworn falsification to authorities. Date: (? - \ ' U Z - Sotirios Ntzanis/Plaintiff ? ? 6` `=n ? ? ? Q(? Cl ? f .ai"" - .- /? r Q,? y D '" r ' <°3 i°?' ^? :_ : h3 C? ' Y? C SOTIRIOS NTZANIS IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JESSICA RADONOVICH DEFENDANT 2008-3630 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, June 20, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, July 31, 2008 at 9:00 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/ ohn . Man an r. Es o. 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 i00?- V u/ -7`x Api I'V' -r ° 17 d7 Y,? 4 SOTIRIOS NTZANIS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. ' DOCKET No.: 2008-3630 JESSICA RADONOVICH, Defendant IN CUSTODY PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please mark the above case as settled and discontinued as an agreement was reached in the Perry County Court and the same being docketed at Perry County Doc ket No.: FC-2008-154. Respectfully submitted, Rominger & Associates Date: September 2, 2008 Karl Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for plaintiff .I 4 SOTIRIOS NTZANIS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET No.: 2008-3630 JESSICA RADONOVICH, Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Plaintiff, do hereby certify that I this day served a copy of the Praecipe to Discontinue upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Barbara Wevodau, Esquire 26 East Main Street P.O. Box 459 New Bloomfield, Pennsylvania 17068 John J. Mangan, III, Esquire Conciliator 17 West South Street Carlisle, Pennsylvania 17013 Respectfully submitted, Rominger & Associates Date: September 2, 2008 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff l °: v'x ° C 1 f, ?/t '?? ,,,, .....-. t t i ? Ki ?' ? ', tip, / ?.3