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HomeMy WebLinkAbout09-7533MAIJA E. KRABER, Plaintiff V. WAYNE C. CRECELIUS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA. NO. 49. 2S3 3 ' .( 1z? CIVIL ACTION - LAW IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Maija E. Kraber, residing at 328 East Meadow Drive Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is Wayne C. Crecelius, residing at 75 Foxfire Lane, Lewisberry, York County, Pennsylvania 17339. 3. Plaintiff seeks primary physical custody of the following children: NAME PRESENT RESIDENCE D.O.B. Austin Tyler Crecelius 328 East Meadow Drive 10/19/1994 Mechanicsburg, PA 17055 Amanda Ellen Crecelius 328 East Meadow Drive 1/27/1997 Mechanicsburg, PA 17055 The children were not born out of wedlock. The children are presently in the custody of Plaintiff, Maija E. Kraber, who resides at 328 East Meadow Drive, Mechanicsburg, Pennsylvania. During the past five years, the children have resided with the following persons and at the following addresses: NAME RESIDENCE DATE Plaintiff 328 East Meadow Drive 8/21/2009 - present Mechanicsburg, PA 17055 It Plaintiff 2193 Bradford Drive 2001 - 8/21/2009 Mechanicsburg, PA 17055 The mother of the children is Plaintiff, Maija E. Kraber, currently residing at 328 East Meadow Drive, Mechanicsburg, Pennsylvania. She is divorced. The father of the children is Wayne C. Crecelius currently residing at 75 Foxfire Lane, Lewisberry, York County, Pennsylvania. He is married. 4. The relationship of Plaintiff to the children is that of Mother. The Plaintiff currently resides with the following persons: NAME RELATIONSHIP Austin Tyler Crecelius Son Amanda Ellen Crecelius Daughter Emily Kraber Daughter Walt Neveker Boyfriend 5. The relationship of Defendant to the children is that of Father. The Defendant currently resides with the following person/persons: NAME Payton Crecelius Wendy Crecelius RELATIONSHIP Son Wife 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. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested as, although the children have been primarily residing with Mother, a set schedule of partial physical custody with Father is necessary. Father has been unilaterally changing the schedule and a consistent schedule of partial custody is in the children's best interests. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children has been named as parties to this action. WHEREFORE, the Plaintiff, Maija E. Kraber, requests the court to grant primary physical custody of the minor children, Austin Tyler Crecelius and Amanda Ellen Crecelius, to her. Respectfully submitted, Dated: October 29, 2009 By: JAMES, SMITH, DIETTERICK & CONNELLY, LLP ?l Susan ade ,Esquire Attorney I.D. #44837 P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Plaintiff, Maija E. Kraber VERIFICATION I verify that the statements made in this Pleading 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 falsification to authorities. Date: 10 ' .,) 6, -0 `1 ? ,0 ?? ? ? ! '' aTARY 2Q'09 CC i UU P +1105.5o np A7T4 ao q4 opt (p (ZT# aSaill MAIJA E. KRABER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-7533 CIVIL ACTION LAW WAYNE C. CRECELIUS . IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, November 05, 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 Thursday, December 10, 2009 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. 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 Custodv orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ oft . 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 schedulec 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 FILED -OFFICE OF THE 2009 NOV - 6 A. I i: 'i F O&A - 46 m? s,. k"( COPY . 4 o W. C'J.Y ` LU.L , ?, J. fr k ?--