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Home My WebLink About09-6090LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo, Esquire PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: prusso(&-P*rlaw.com BRIAN BRZEZINSKI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW LINDSAY ZEIGLER, NO. 09- 609'6 CIVIL TERM Defendant IN CUSTODY NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the foregoing pages, you must take action within twenty (20) days after this Complaint and notice are served, by entering a written appearance personally or by attorney, and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE OR KNOW A LAWYER, THEN YOU SHOULD 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, PA 17013 717-249-3166 1-800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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. 2 BRIAN BRZEZINSKI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW LINDSAY ZEIGLER, NO. D 9- 6 b qz5 CIVIL TERM Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Brian Brzezinski, residing at 194 Wilcox Drive, New Cumberland, Cumberland County, Pennsylvania 17070. 2. The Defendant is Lindsay Zeigler, residing at 500 Ross Avenue, Apt. B, New Cumberland, Cumberland County, Pennsylvania 17070. 3. Plaintiff seeks custody of the following child: Name Present Residence Date of Birth Morgan Taylor Brzezinski 500 Ross Ave., Apt. B 8/07/2008 New Cumberland, PA 4. The child was born out of wedlock. 5. The child is presently in the custody of Lindsay Zeigler, who resides at 500 Ross Avenue, Apt. B, New Cumberland, Cumberland County, Pennsylvania 17070. 6. During the past five years, the child has resided with the following persons and at the following addresses: Persons Addresses Duration Brian Brzezinski 500 Ross Ave., Apt. B 8/07/08 - present Lindsay Zeigler New Cumberland, PA 3 7. The Mother of the child is Lindsay Zeigler, currently residing at 500 Ross Avenue, Apt. B, New Cumberland, Pennsylvania. She is single. 8. The Father of the child is Brian Brzezinski, currently residing at 194 Wilcox Drive, New Cumberland, Pennsylvania. He is single. 9. The relationship of Plaintiff to the child is that of father. The Plaintiff currently resides with the following persons: Name Relationship Bernard Brzezinski Father Gloria Brzezinski Mother 10. The relationship of Defendant to the child is that of mother. Defendant currently resides with the following persons: Name Relationship Morgan Taylor Brzezinski Daughter 11. 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: Not applicable. 12. Plaintiff has no information of any other custody proceeding concerning the child pending in a court of this Commonwealth or any other state. The court, term and number, and its relationship to this action is: Not applicable. 13. 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 rights 4 with respect to the child. The name and address of such person is: Not applicable. 14. The best interest and permanent welfare of the child will be served by granting the relief requested because: Father has cared for child since birth and is more likely to foster an open parent relationship. 15. Each parent whose parental rights to the child have not been terminated and the person who has physical 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: Name Address Basis of Claim Not applicable. Wherefore, Plaintiff respectfully requests the Court to grant him partial legal and physical custody of the child. Respectfully submitted, TER J. RUSSO, P.C. OFFICE 7Esuire i th Attorney I.D. No. 200139 Peter J. Russo, Esquire Date: ci 13) 0 ° Attorney I.D. No. 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Attorneys for Plaintiff VERIFICATION I, Brian Brzezinski, verify that the statements made in this Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: q 3 Oq Brian Brzezinski 6 End; SCE OF THE MOTHONOTARY 2W SEP -$ FM 1: 12 CUM .`,Lt4 wD GJUNN PENt SUANA *'(-0-6,50 RO A7T`Y Gk# 331(o e 6130a,90 BRIAN BRZEZINSKI IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. LINDSAY ZEIGLER DEFENDANT 2009-6090 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Monday, September 14, 2009 , 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 Friday, October 23, 2009 at 2:30 PM _..__........ .... -...... .. 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 entrv 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 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 OF IARY 59 20D9 SEP { x? i 1o: a LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo, Esquire PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: prussoA-Purlaw.com BRIAN BRZEZINSKI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW LINDSAY ZEIGLER, : NO. CIVIL TERM Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Ashley R. Sipe, hereby certify that on September 11, 2009 a copy of the Complaint for Custody was served upon the person(s) and in the manner indicated below: Certified Mail, Restricted Delivery, Return Receipt Requested and US Regular Mail: Lindsay Zeigler 500 Ross Avenue, Apt. B New Cumberland, PA 17070 Pro se Defendant Date: q I 1yIng 7 0 LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo, Esquire PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: prussoApirlaw.com BRIAN BRZEZINSKI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW LINDSAY ZEIGLER, NO. CIVIL TERM Defendant IN CUSTODY ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: L ze?c?NQ-r '?o b 94CS5 ? (4 V??. v4e.o C?rrnl n? A. S gnature X ? Agent ?y ? Addressee L i Neceived D RY (L?Irz Ct )18 I Delivery q D. Is delivery address different from item 1 ? ? Yes If YES, enter delivery address below: . ? No 3. Service Type e nr ?041WMed Mail ? Express Mail ? Registered 1ilaiietum Receipt for Merchandise ? Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number 7006 0810 0006 1052 6435 (Transfer from service labeq PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 ; 7 FILE L, 'I:i- E OF 7N_ R /RY .. 2009 S'E"t' 16 PH i * 42 GUIN BRIAN BRZEZINSKI PLAINTIFF V. LINDSAY ZEIGLER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2009-6090 CIVIL ACTION LAW IN CUSTODY PETITION TO 'T'RANSFER VENUE WHEREFORE COMES NOW Defendant, Lindsay Zeigler, pro se, this 24' day of November W9? and avers the following: 1. Plaintiff is Brian Brzezinski who resides at 194 Wilcox Drive, New Cumberland, York County, PA 17070-3072. 2. Defendant is Lindsay Zeigler who resides at 500 Ross Avenue, Apt. B, New Cumberland, York County, PA 17070-2602. 3. The Child who is the subject of this proceeding is Morgan Taylor Brzezinski (hereinafter "Child") who was born on August 7, 2008. 4. York County is the home county of the Child. 5. The parties have an existing child support order issued by the Domestic Relations Office in York County. ¢. The Child's physician is located in York County. 7. When necessary, childcare is provided by Karen Martin who resides in Ygrk County. 8. It is in the best interest of the Child that venue be transferred to York County, because the Child and both parties have significant connections with York County. WHEREFORE the Defendant respectfully requests that this Honorable Court transfer venue to York County, Pennsylvania pursuant to Pa. R. Civ. Pro. 1915.2(a)(1)- (2). vr? Lindsay Zeigler, se FtLELHDr;1CE ?H Fr' ?' . kO- TAW OF IE 20.,09 NOV 25 PH T,0 7 VL?tt ? `p , r1,. BRIAN BRZEZINSKI IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF V. LINDSAY ZEIGLER DEFENDANT 2009-6090 CIVIL ACTION LAW IN CUSTODY PRAECIPE FOR ENTRY OF APPEARANCE To the Prothonotary: Enter my appearance on behalf of Lindsay Zeigler, Defendant. Papers may be served at the address set forth below. ~~ D e Tabitha Phillips, Certified Legal Intern J. Palmer Lockard, Esquire, ID # 33681 Harrisburg Civil Law Clinic 3605 Vartan Way 2"d Floor Harrisburg, PA 17110 lawclinichb~a~,mail.widener.edu Telephone: (717) 541-0320 Facsimile: (717) 909-0442 ~~y Flt_~~- =~iv r Zafl9 (SEC - ! ~~~ i I ~ 23 a~