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Home My WebLink About09-0602CHARLES L. HUSS, Plaintiff V. VICTORIA MUKALIAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :NO. 0 9- 6, CIVIL TERM : IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Charles L. Huss, an adult individual currently residing at 502 Mahanow Valley Road, Duncannon, Perry County, Pennsylvania. 2. Defendant is Victoria Mukalian, an adult individual currently residing at 199 Beagle Club Road, Carlisle, Cumberland County, Pennsylvania. 3. The parties are the natural parents of one (1) child, namely, Cassidy L. Huss, born February 26, 2008. The child was born out of wedlock. 4. For the past five (5) years, or since the child's birth, the child has resided with the following persons at the following addresses for the following periods of time: NAME Victoria Mukalian Denise Thompson David Thompson Charles L. Huss Cassidy L. Huss Victoria Mukalian ADDRESS DATES 199 Beagle Club Road August 2008 to Carlisle, Pennsylvania Present 35 North Fourth Street July 2008 to Newport, Pennsylvania August 2008 Cassidy L. Huss Victoria Mukalian Charles L. Huss Cassidy L. Huss Victoria Mukalian Charles L. Huss Cassidy L. Huss Victoria Mukalian Ronald Huss Karen Huss Leah Huss 35 North Fourth Street Newport, Pennsylvania 35 North Fourth Street Newport, Pennsylvania 502 Mahanow Valley Road Duncannon, Pennsylvania May 2008 to July 2008 April 2008 to May 2008 Birth to April 2008 The natural mother of the child is Victoria Mukalian who resides as aforesaid. 5. 6. 7 She is not married. The natural father of the child is Charles O. Huss who resides as aforesaid. He is not married. The relationship of the Plaintiff to the child is that of natural father. Plaintiff currently resides with his parents Ronald Huss and Karen Huss and his sister Leah Huss. The relationship of the Defendant to the child is that of natural mother. The Defendant currently resides with her Aunt Denise Thompson and her husband David Thompson. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning custody of the child. 8. Plaintiff has no information of any custody proceedings concerning the child pending in any Court of this Commonwealth. VERIFICATION 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 falsifications to authorities. DATE:l tin ?11. CHARLES LJIUSS, Plaintiff CHARLES L. HUSS, Plaintiff V. VICTORIA MUKALIAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. CIVIL TERM IN CUSTODY CERTIFICATE OF SERVICE I, Bradley L. Griffie, Esquire hereby certify that I did, the 5 day of February, 2009, cause a copy of Plaintiff's Complaint for Custody to be served upon the Defendant, Victoria Mukalian, by serving her by first class mail, postage prepaid, at the following address: Victoria Mukalian 199 Beagle Club Road Carlisle, PA 17013 DATE: 2 .516 fie, Esquire me or Plaintiff C1 C' ?, .a -n cii ? T Y' CHARLES L. HUSS, Plaintiff VS. VICTORIA MULAKIAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 6 9 G ? 2 CIVIL TERM : IN CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Charles L. Huss to proceed in forma pauperis. I, Bradley L. Griffie, Esquire, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Respectfully submitted, Date: -,214161 Griffie, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 C ? t == K3 t CHARLES L. HUSS PLAINTIFF V. VICTORIA MUKALIAN DEFENDANT IN THE COURT OF COMM N PLEAS OF CUMBERLAND COUNTY, ENNSYLVANIA 2009-602 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Monday, February 09, 2009 , upon considerat it is hereby directed that parties and their respective counsel appear before John J. at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, Mai for a Pre-Hearing Custody Conference. At such conference, an effort will be made if this cannot be accomplished, to define and narrpw the issues to be heard by the c order. Failure to appear at the conference may' provide grounds for entry of a temp The court hereby directs the parties to furnish any and all existing Pro Special Relief orders, and Custody orders to the conciliator 48 hours prior to FOR THE COURT, By: /s/ john j. Mangan, r., l Custody Conciliator The Court of Common Pleas of Cumberland County is required by 1 with Disabilites Act of 1990. For information about accessible facilities and n available to disabled individuals having business before the court, please cont? must be made at least 72 hours prior to any hearing or business before the cou7 conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPI FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Associatiot 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 of the attached. Complaint, ingan, Jr., Esq. , the conciliator, 20, 2009 at 10:00 AM resolve the issues in dispute; or t, and to enter into a temporary ry or permanent order. from Abuse orders, ed hearing. to comply with the Americans onable accommodations our office. All arrangements You must attend the scheduled CE. IF YOU DO NOT IE THE OFFICE SET 1 : (! WV 6- 833 6601 Advio;.'M',?,Hli 6:31 3fli E10, J CHARLES L. HUSS, Plaintiff V. VICTORIA MUKALIAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 09-602 CIVIL TERM : IN CUSTODY AFFIDAVIT OF SERVICE I, Bradley L. Griffie, Esquire, counsel of record for Plaintiff, state that a true and attested copy of a Complaint for Custody and resulting Order of Court was sent to Defendant, Victoria Mukalian, at her address of 199 Beagle Club Road, Carlisle, Pennsylvania, by certified mail, restricted delivery. A copy of said receipt is attached hereto indicating service was made on February 13, 2009. Gri, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 Sworn and subscribed to before me this ? tb day of , 2009 NOTARY BLIC NotatlF pwft Now J. MoQ17. . NpN?lYOM, 1E'A t CERTIFIED MAIL R ECLIPT M M (Domestic Only; Provided) G" ALS CgIV IE07 ti Postage $ PEtU S? ?` Cerefled Fee G A rJ O Retum Receipt Fee ?i O (Endorsement Required) .r 0 Reatrkied Delhrery Fee (Endoreemem Required) ? r (u Total Postage & Fees $ 868g, O Sent To N orPO-Afo. (q_R__ aA ------------------ l°?tAh ?a?irl ----------- X K Received by (P?trrr.d Mire C. Date d D. Is d*iwy addreee dMewit *orn hem 1? ? yes If YES, order dNirary address below 0 No C,A& k5 Y A* 176 /-y & TMell 3F; oaew ?91Nied ? RNM Receipt for MerdriffKee O kwow man 0 C.O.D. 4. Ro"An'ad DaMry? (Bftr" free 2r 7007 022'0 0002 2526 5530 PS Form 3811, Fetmwy 3W tlsara ft Raba R - to 1t -*1540 ; ¦ Conokis Nerve `i, 2, and & Also cwnpiets hem 4 h RsNticled Odwary Is desired. ¦ Prim ==, ddress the reverse so that the card to; ¦ this card to the back of the maNpW^ or og the front N space permits. 1. Article jAddraeeed tD: 1 w r ? } JUN 0» 2009 f? CHARLES L. HUSS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 09-602 CIVIL ACTION LAW VICTORIA MUKALIAN, IN CUSTODY Defendant ORDER OF COURT AND NOW this 10;"' day of June 2009, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. Legal Custody: The Father, Charles Huss, and the Mother, Victoria Mukalian, shall have shared legal custody of Cassidy L. Huss, born 02/26/2008. The parties shall have an equal right to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody: Mother shall have primary physical custody of the Child subject to Father's physical custody as follows: a. In week one, Father shall have physical custody of Cassidy on Sunday from 1:00 pm until 5:00 pm. Paternal grandmother shall be present at all times for Father's periods of physical custody and paternal grandmother shall assist in transporting the Child. Absent mutual agreement otherwise, the exchanges shall occur at the Shermansdale Plaza at the appointed times. b. In week two, Father shall have physical custody of Cassidy on Saturday from 1:00 pm until 5:00 pm. Paternal grandmother shall be present at all times for Father's periods of physical custody and paternal grandmother shall assist in transporting the Child. Absent mutual agreement otherwise, the exchanges shall occur at the Shermansdale Plaza at the appointed times. C. Father shall have physical custody of the Child at such other times as the parties may mutually agree. 3. Father is directed to provide to Mother information/documentation regarding his mental health status/treatment and SSI documents. 4. The non-custodial parent shall have liberal telephone contact with the Child on a reasonable basis. 5. Holidays: The parents shall arrange a holiday schedule as mutually agreed. In the absence of agreement, a holiday schedule shall be established at the status update conference with the assigned conciliator. 6. In the event the custodial parent should take the Child out of state, the custodial parent shall notify the non-custodial parent within twenty-four hours of departure of the intended destination and a telephone number at which they can be reached. 7. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other party, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Child. 8. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 9. During any periods of custody or visitation, the parties shall not possess or use controlled substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 10. A status update conference with the assigned conciliator is hereby scheduled for July 07, 2009 at 8:30 am at the Court of Common Pleas, Carlisle, PA 17013. 11. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. By the Court, ?? ?4 J. Distribution: Aradley Griffie, Esquire ?gamuel Andes, Esquire --4ohn J. Mangan, Esquire 12apt ks .rMLECIL CHARLES L. HUSS, Plaintiff V. VICTORIA MUKALIAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 09-602 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT 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 pertaining to the Child who is the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Cassidy L. Huss 02/26/2008 Primary Mother 2. A Conciliation Conference was held with regard to this matter on April 8, 2009 with the following individuals in attendance: The Mother, Victoria Mukalian, with her counsel, Samuel Andes, Esq. The Father, Charles Huss, with his counsel, Bradley Griffie, Esq. 3. The parties agreed to the entry of an Order in the form as attached. 161- - Date John J , Esquire Cust dy Conciliator BLED-O F-CE OF TNc PC rY'+:"4CTA€?Y 2009 JUN 10 AM 11: 15 CUMi.JL.•'?Ll 1 l'OUIt S R rEIN S LVNNIA