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HomeMy WebLinkAbout04-2142LARRY J. FRICK, Plaintiff KRISTIN P. MARTZ, Defendant IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA No. 0¥' CiVIL ACTION- CUSTODY To the Judges of Said Court: Complaint for Custody AND NOW, this 13th day of May, 2004 comes LARRYJ. FRICK, Plaintiff above named, by and through his attorney, John M. Glace, Esquire, and respectfully presents the below Complaint for Custody, and, in support thereof, avers the following: 1. PlaintiffLARRY J. FRICK is an adult individual who resides 4~fl~8th Street, Apartment 1, New Cumberland, Cumberland County, Pennsylvania. 2. Defendant KRISTIN P. MARTZ is an adult individual who resides at 522 Marsh Run road, New Cumberland, York County, Pennsylvania. 3. Above parties are the biological parents of Kylar Benjamin Frick ( dob: 12/12/02) 4. Above parties are not married; nor have ever been married.. 5. Parties have recently separately; but minor child has always resided at mother's above address. 6. There have been no prior custody actions. 7. All parties having any custodial interest to the minor child are made party to this action 8. No named party is a present member of the armed forces of the United States of America. 9. Plaintiff father requests an established period of partial custody and joint legal custody of minor child. WHEREFORE, above Plaintiff IMRRYJ. FRICK. respectfully requests this Honorable Court to grant him partial physical within established periods of time and joint legal custody of Kylar Benjamin Frick with any terms and conditions deemed advisable by the Court.. Respectfully Submitted, Supreme 2aunt ID: 23933 132~134/ ia}hut Street Harr~g, PA 17101-1612 (717) 238-5515 Attorney for Plaintiffs CERTIFICATE OF SERVICE I HEREBY CERTIFY that this 13th day of May, 2004 1 have served a true and correct copy of thc foregoing Complaint for Custody, by hand delivery, upon: Kfistin P. Martz 522 Marsh Run Road New Cumberland, PA 17070 LAW OFFICES of JOHN M. GLACE e, Esquire  -]/3~ ~qalnut Street H~fi~r~] PA. 17101-1612 717) 238-5515 Identification No. 23933 Counsel for Plaintiff LARRY J. FRICK : 1N THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 04-2142 CIVIL ACTION LAW KRISTIN P. MARTZ : IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, May 20, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Meehanicsburg, PA 17055 on Tuesday, June 22, 2004 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an eflbrt 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 present at the conference. Failure to appear at the conference may provide g~ounds 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: /si Dawn S. Sunday, Esq. Custody Conciliator mhc 12ne 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 ATTORNF;Y 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 LARRY J. FRICK Plaintiff VS. KRISTIN P. MARTZ Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-2142 C, IVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this ____.__~ day of ( ,~,_~, ,.. , 2004, upon consideration of the attached Custody ~onciliation Report, it is Ordered and directed as-~ollows: 1. The Father, Lan'y J. Frick, and the Mother, Kristin P. Martz, shall have shared legal custody of Kylar Benjamin Frick, born December 12, 2002. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergancY decisions affecting the Child's general well-being including, but not limited to, all decisie,ns regarding his health, education and religion, pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 2. The Mother shall have primary physical custody of the Child. 3. The Father shall have partial physical custody of the Ctdld during the last three weekends of every month from Friday at 4:30 p.m. through Sunday at 7:30 p.m., and during every week on Tuesday and Thursday from 4:30 p.m. until 7:30 p.m. 4. The parties shall share having custody of the Child on ]holidays as arranged by agreement. 5. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall ,ensure that third parties having contact with the Child comply with this provision. 6. This Order is entered pursuant to an agreement of the parties at 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. cc: John M. Glace, Esquire - Counsel for Father Kristin P. Martz, Mother LARRY J. FRICK VS. Plaimiff JIJ~/O 2004. IN THE COURT OF COMMOI~LEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-2142 CIVIL ACTION LAW ICRISTIN P. MARTZ Defendant IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT. IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME. Kylar Benjamin Frick DATE OF BIRTH December 12, 2002 CURRENTLY IN CUSTODY OF Mother/Father 2. A conciliation conference was held on June 22, 2004, with the following individuals in attendance: The Father, Larry J. Frick, with his counsel, John M. Glace, Esquire, and the Mother, Kristin P. Martz, who is not represented by counsel in this matter. 3. The parties agreed to entry of an Order in the form as attached. Date Dawn S. Sunday, Esqmre Custody Conciliator