HomeMy WebLinkAbout10-3358
Thomas J. Williams, Esquire
MARTSON LAW OFFICES
I.D. 17512
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
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ANATOLIY A. VENSKYY
Plaintiff
v.
LEYSA A. VENSKYY,
Defendant
: IN THE COURT OF COMMON PLEAS Or'
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 10- 3 ~S'g
CIVIL ACTION -LAW
IN CUSTODY
PLAINTIFF'S COMPLAINT FOR CUSTODY
1. Plaintiff is Anatoliy A. Venskyy, an adult individual currently residing at 104 South
Orange Street, Carlisle Cumberland County, Pennsylvania.
2. Defendant is Leysa A. Venskyy, an adult individual currently residing at14465Ames
Street, Oregon City, OR 97045.
3. Plaintiff seeks custody of the children, Julie L. Venskyy (born March 2, 1008) and
Angela A. Venskyy (born March 2, 2008). The children were born in wedlock.
4. Since the children's birth, the children have resided with the following persons at the
following addresses for the following periods of time:
Time Period Persons Location
3/2/08-11 /30/08 Parties
11 /30/08-4/ 1 /09 Parties
4/1/09-5/1/09 Parties
5/ 1 /09-4/ 16/ 10 Parties
4/ 16/ 10-Present Mother
10840 SE Sunnyside Road, Clacames, OR
14465 Ames Street, Oregon City, OR
104 South Orange Street, Carlisle, PA
921 Forest Court, Carlisle, PA
14465 Ames Street, Oregon City, OR
5. The relationship of the Plaintiff to the children is that of Father. He is married and
living separately. The Plaintiff currently resides with his parents, Alla Venska and Alexsander
Venskyy.
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6. The relationship of the Defendant to the child is that of Mother. She is married and
living separately. The Defendant currently resides with her parents, Lubor Primachenko, Anatoliy
Primachenko, and the two children.
7. The parties have not participated in previous litigation concerning the custody of the
children in this court or any court.
8. The Plaintiff has no information of a custody proceeding cancerning the children
pending in any other court.
9. The best interest and permanent welfare of the children will be served by granting
shared custody to the parties.
10. On April 16, 2010, Defendant suddenly and without notice to or consent from
Plaintiff, left the marital residence with the children and relocated to Oregon. Since that time,
Defendant has acted peremptorily and uncooperatively with regard to the children so that Plaintiff
has not been able to exercise any custody rights since Defendant moved out of state.
11. Cumberland County, Pennsylvania is the home state and county of the children under
the Pennsylvania Uniform Custody Jurisdiction Act.
12. Plaintiff does not know of any person not a party to these proceedings who claims to
have custody or visitation rights with respect to the children.
WHEREFORE, Plaintiff requests your Honorable Court to set a time and place for a hearing
at which Plaintiff requests the Court to grant Plaintiff the Custody Order. Pending said hearing,
Plaintiff requests temporary shared custody.
MARTSON LAW OFFICES
~l ~/ ~.N~i~ w~.
By ,~.
Thomas J. Will' s, Esquire
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
Date: May ~~ , 2010
VERIFICATION
The foregoing Complaint for Custody is based upon information which has been gathered
by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and
not my own. I have read the Complaint and to the extent that the document is based upon
information which I have given to my counsel, it is true and correct to the best of my knowledge,
information and belief. To the extent that the content of the document is that of counsel, I have
relied upon counsel in making this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities, which provides that if I make knowingly false
averments, I may be subject to criminal penalties.
~p~
Anatoliy A. Venskyy
JUL 10 2010
ANATOLIY A. VENSKYY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
~'• : N0.2010-3358 CIVIL ACTION -LAW
LEYSA A. VENSKYY, .
Defendant : IN CUSTODY
ORDER OF COURT
AND NOW, this ~3 day of ~ , 2010, upon
consideration of the attached Custody ConciP atio eport, it is ordered and directed as
follows:
1. A Hearing is scheduled in Court oom No. oZ , of the Cumberland
County Court House, on the ~ day of ~ , 2010, at D!Da
o'clock, ~. M., at which time testimony will be taken. Forpurposes of this Hearing,
the Father shall be deemed to be the moving party and shall proceed initially with
testimony. Counsel for each party shall file with the Court and opposing counsel a
Memorandum setting forth each party's position on custody, a list of witnesses who will
be expected to testify at the Hearing and a summary of the anticipated testimony of each
witness. These Memoranda shall be filed at least five days prior to the Hearing date.
2. Pending further Order of Court or agreement of the parties, the following
shall remain in full force and effect.
3. The Father, Anatoliy A. Venskyy and the Mother, Leysa A. Venskyy,
shall have shared legal custody of Julie L. Venskyy, born March 2, 2008 and Angela A.
Venskyy, born March 2, 2008. Each parent shall have an equal right, to be exercised
jointly with the other parent, to make all major non-emergency decisions affecting the
Children's general well-being including, but not limited to, all decisions regarding their
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 children including, but
not limited to medical, dental, religious or school records, the residence address of the
children and 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. Both parents shall be entitled to full participation in
all educational and medical/treatment planning meetings and evaluations with regard to
the minor children. Each parent shall be entitled to full and complete information from
any physician, dentist, teacher or authority and copies of any reports given to them as
parents including, but not limited to: medical records, birth certificates, school or
educational attendance records or report cards. Additionally, each parent shall be entitled
to receive copies of any notices which come from school with regard to school pictures,
extracurricular activities, children's parties, musical presentations, back-to-school nights,
and the like.
4. Pending a hearing in this matter, the parties shall have shared physical
custody of the children. Mother shall have physical custody of the children until August
1, 2010 when she will be responsible for all costs of transportation to return the children
to Father. Father shall have physical custody of the children until the court hearing in
this matter.
5. The parties shall have reasonable telephone contact with the children and
visual Internet contact via Skype or other means.
6. Neither party shall do or permit a third party to do, or say anything that
would estrange the Children from the other parent, injure the opinion of the Children as
to the other parent, or hamper the free and natural development of the Children's love and
respect for the other parent.
7. 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,
/cc: Thomas J. Williams, Esquire, Counsel for Father
/ Sheri D. Coover, Esquire, Counsel for Mother
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ANATOLIY A. VENSKYY,
Plaintiff
V.
LEYSA A. VENSKYY,
Defendant
PRIOR JUDGE: None
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
N0.2010-3358 CIVIL ACTION -LAW
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 Children who are the subject of
this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Julie L. Venskyy March 2, 2008 Mother
Angela A. Venskyy March 2, 2008 Mother
2. A Conciliation Conference was held July 8, 2010 with the following
individuals in attendance: The Father, Anatoliy A. Venskyy, with his counsel, Thomas J.
Williams, Esquire, and the Mother, Leysa A. Venskyy, by telephone, with her counsel,
Sheri D. Coover, Esquire.
3. Father's position on custody is as follows: Father seeks shared legal and
primary physical custody. Father asserts that Mother relocated the children to Oregon
and he has not had physical contact since April 16, 2010. Father maintains that he was
the primary care giver of the children when Mother worked because he was unemployed.
Father denies any abuse of the children. Father has family in the area to assist him with
the care of the children. The children have lived in this area for one year.
4. Mother's position on custody is as follows: Mother seeks shared legal and
primary physical custody. Mother asserts that she relocated to Oregon where she has
family, when Father rubbed the children's faces with feces when they took off their
diapers and had an accident. Mother has concerns about Father's care of the children.
5. The Conciliator recommends an Order in the form as attached scheduling
a Hearing and entering an Order of Court providing for shared legal and shared physical
custody of the children. It is expected that the Hearing will require one day.
~'$-f~
Date
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acq ine M. Verney, Esquire
Custody Conciliator
' F:\FILES\CGents\13870 Venskyy\I3870.1.answal
Revisal: 7/29/10 0:35PM
ANATOLIY A. VENSKYY IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
~ -;-;
v• NO. 10-3358 c~_-.-"-. L ~ .~
CIVIL ACTION -LAW -~-.~ tyt ~ ~ `--° ~, ~z=~
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LEYSA A. VENSKYY,
Defendant : IN CUSTODY l ' - 'a ~ +
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PLAINTIFF'S ANSWER WITH NEW MATTER TO DEFENDANT'S ~ ~ ~ ~ ~~
PETITION FOR SPECIAL RELIEF PURSUANT TO ~~° s_--~ ~ r:
PENNSYLVANIA RULE OF CIVIL PROCEDURE RULE 1915 13 ~ W ~.J
AND NOW, comes the Plaintiff, Anatoliy A. Venskyy, by and through his attorneys,
MARTSON LAW OFFICES, and avers as follows in answer to Defendant's Petition:
1. Admitted. Plaintiff ("Father") filed a Custody Complaint as soon as he could after
Defendant ("Mother") removed the children from the marital residence without notice to, or
agreement of, Father.
2. Admitted.
3. Admitted; however, the Conciliator heard both sides on the recently raised issue of
"child abuse" and apparently felt there was nothing serious in the complaints.
4. Denied in general and in the specifics set forth below. For several months prior to
her removal of the children to the state of Oregon, Mother had been trying to convince Father to
move to Oregon, saying that she was unhappy in Pennsylvania and missed her family who lived in
Oregon. In trying to convince Father to move with her to Oregon, Mother never raised the issue of
his care of the children -Father had been the primary caretaker of the children as he was out of work
and Mother had a full time job as a pharmacy technician at Rite Aid on Hanover Street in Carlisle.
Exhibit "A" is a translated copy of text messages that Mother (referred to therein "Baby") and her
mother, the children's grandmother (referred to in the text messages as "Prima Mom"), in which she
begged and continue to beg for Father to move with her to Oregon. It is clear that Mother's
motivation in moving to Oregon was a matter of personal preference, and had nothing to do with the
children.
a. Denied. Father never injured the children, nor was any complaint ever made
by anyone about his injuring the children.
b. While Father, who was the primary caretaker of the children, would as any
parent, occasionally became irritated at the children's behavior, he never did
anything to cause them injury, and certainly never did anything to make them
throw up.
c. Denied. While Father, as the primary caretaker, would normally brush the
children's hair and occasionally there would be snags, this was never done
with an intent to cause injury or pain.
d. Denied. While Father, as the primary caretaker of the children, would have
to discipline them for such things as not putting their toys away, it was never
done in a manner to cause injury, and in fact, never did cause injury.
e. On one occasion, Father, while giving the children their bath, did step away
momentarily, and in that moment, one of the children slipped while seated in
the tub and her head went under water. Father immediately observed this and
righted the child. This is a minor incident that has probably happened to
every parent who has a bath tub.
f. Denied as stated. On one occasion, Father, while home alone caring for the
children, had to pick up something from his mother's house while the
children were taking their nap. He was out of the marital residence for only
several minutes as his parents live immediately nearby.
g. Denied. Father, who is the primary caretaker, always fed the children. The
children were healthy, happy and well nourished while in Father's care.
Exhibit "B" is a photograph of the children taken shortly before Mother
removed them from Pennsylvania.
h. Denied as stated. While one of the children did suffer minor injuries on two
occasions while in Father's care, these were the normal, growing-up type of
injuries of any child. On one of the occasions, the child was running, tripped,
and injured a tooth. On another occasion, one of the children, after being
warned and while Father's back was turned tending to the other child, wanted
to see for herself how hot the stove was. This resulted in an extremely minor
burn of one of her fingers. Exhibit "C" is a photograph of that "injury."
2
i. Denied. While Father may not have been the most dextrous person in
trimming small fingernails, it is denied that he caused any injury, nor that any
type of medical treatment whatsoever was needed.
Denied. Father never "beat" the children nor Mother.
6-7. Denied. There was one occasion when the children made a mess with their diapers.
This did anger Father and he did discipline them for it, though not harshly, nor did he cause any
injury.
8-10. Denied. Father has no knowledge of what Mother may have told her co-workers or
a hot line, and proof thereof, if relevant, is demanded. Father is not aware of any investigation of
him, past, present or future.
11. Denied. Mother never stated any concerns of Father's care of the children as a reason
for her desire to move to Oregon. Every time she asked Father to move to Oregon with her, it was
because she preferred Oregon to Pennsylvania, both because she just like the area better and because
her parents live there.. After Father (whose family lives in Carlisle) continued to refuse to move to
Oregon, Mother resorted to self-help with the children. Father has no knowledge of her travel
arrangements, nor when she made them. He does know that Mother cleaned out the parties' joint
bank account of its several thousand dollar balance (the remnants of a joint income tax return) the
day she left, leaving Father essentially destitute and forcing him to give up the marital residence and
move in with his parents here in Carlisle.
12. Denied. Father admits to being incredulous at Mother's reason for not following
through with Children and Youth Services, that being she was afraid they would take her children
from her. To Father's knowledge, there was never an investigation by CYS, and certainly nothing
has ever been adjudicated, nor was anything pending.
13. Denied. Father loves his children and has always done his best to take care of them.
Father was the primary caretaker and he was successful at doing that. The children are normal,
happy, well-adjusted and certainly comfortable in the custody of Father.
14. Denied. Father has no knowledge of any ear infection, nor any medical treatment in
the state of Oregon, and proof thereof, if relevant, is demanded.
3
15. Denied. Father has no .knowledge of Mother's employment and proof thereof, if
relevant, is demanded. Father does know that Mother is a pharmacy technician and was employed
full time at a pharmacy in Carlisle prior to her sudden departure. Father also knows that he has been
contacted by the Oregon Department of Child Support: David Ployer, 221 Molalla Avenue, Suite
223, Oregon City, OR 97045, with regard to child support. Mr. Ployer stated that Mother was
receiving medical assistance for the children and support against Father, docketed to Oregon CSP
OOSHM2341B41, a copy of which is attached as Exhibit "D."
16-17. Denied. Father took care of these two year old children for most of their lives. They
were always happy, healthy and well-adjusted while in his care. There is a strong father/child bond
that has been peremptorily broken by Mother when she moved them to the other side of the nation,
effectively moving them out of Father's life.
18. Denied. On the date of her departure, April 16, 2010, Mother cleaned out the parties'
joint account at Metro Bank in the amount of $7,218.00, which was the remnants of an income tax
return, leaving a balance in the account of $104.61. A copy of the pertinent bank account statement
is attached as Exhibit "E." Mother now states she has a job. In short, Mother is in a better financial
position than Father; nevertheless, Father has offered to pay the transportation costs with money he
saved and can borrow from his friends and family, if necessary. A copy of that offer contained in
a letter from Father's counsel is attached hereto and marked as Exhibit "F."
19. Admitted.
20. Admitted.
21. The recommendation of the Conciliator and the Order of Court is entirely justified.
Father, who was the primary caretaker of these children, has not seen them since Mother spirited
them away from Pennsylvania on April 16, 2010. These are pre-school children and deserve to be
in the care of both parents. If Mother's extrajudicial actions have made that impossible by moving
to the other side of the country, without the knowledge, consent or advance notice of Father, then
Mother should bear the transportation expenses.
21 (sic). The relief requested by both parties is temporary in nature. The best interest of the
children would have been to remain in the marital residence where they were living. If Mother found
that impossible, then she should have asked the Court for approval to move the children, especially
4
so far away, which has effectively taken the children out of Father's life.
22. Admitted. By way of further answer, the Custody Order was issued July 13, 2010.
Shortly thereafter, Mother's attorney told Father's attorney that she intended to file a Petition for
Emergency Relief. Instead of doing so promptly, the Petition was not filed until it was less than a
week before the children were to be returned to Pennsylvania, thus creating a time bind for the Court
and for Father, such that this important matter now seemingly has to be rushed. Moreover, as of this
writing, neither Father nor his counsel have not been served with the Petition. While Father and his
counsel knew generally that Mother was unhappy with having to defend custody from so far away,
Father did not know the specifics of her unhappiness, and this Answer to the Petition had to be
rushed.
WHEREFORE, Plaintiff/Father respectfully requests your Honorable Court to deny the
Petition for Emergency Relief and to allow Father to have custody of these children that he has
missed for so many months pending the hearing on October 20, 2010.
NEW MATTER
23. The averments of paragraphs 1 through 22 of this Answer are incorporated herein by
reference.
24. Self-help is not a form of relief favored by the law, especially when it was the result
of suddenly denying a parent of custody of his children, especially when that parent has been the
primary caretaker of the children.
25. It is completely improper of the Mother to wait to the last minute to file this Petition.
This is an important matter, containing serious, though false, accusations by Mother that deserve
serious consideration, rather than a rush to judgment. Mother has created unnecessary time pressures
for both Father and the Court in waiting so late to file this Petition, when she knew weeks ago that
she was going to do so.
26. Father believes and therefore avers that Mother has no intention of returning the
children to Pennsylvania, regardless of what this Court may Order. Her purpose here is delay and
creating substantial and unnecessary expense on the part of Father in an attempt to enforce this
5
Court's Order in the state of Oregon.
27. Father believes, and therefore avers, that the secret agenda of Mother is to get him
to return with her to Oregon. Mother and her family have made that clear both prior and subsequent
to the time she removed the children from Pennsylvania. They have begged Father to come to
Qregon to live there and it is Father's refusal to do so that motivated this Fetition. It is noteworthy
that Mother has not filed for divorce. In effect, Father believes that Mother is using the children for
her own personal reasons.
28. Mother has now had the children in her sole extrajudicial custody and control for over
three months. It is only fair that Father has a similar period of time prior to the hearing on
October 20, 2010.
WHEREFORE, Plaintiff/Father respectfully requests your Honorable Court to deny the
Petition for Emergency Relief and to allow Father to have custody of these children that he has
missed for so many months pending the hearing on October 20, 2010.
MARTSON LAW OFFICES
~- i;~ >~.Q..Q
Thomas J. Wil a)~s, Esquire
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff/Father
Date: July 29, 2010
6
Text massages
Esli ti bumagi otdasi to ya vizmu ditei I uidu
from: Baby Venskyy
10:58am 4/13/10
Za apartment
From: Baby Venskyy
12:05pm 4/13/10
If you will give the papers to the land lord I will
take the children and leave .
From: Baby Venskyy
10:58am 4/13/10
for apartment
From: Baby venskyy
12:05pm 4/13/10
Kuda nibud
From :Baby Venskyy
12:05pm 4/13/10
Any where
From: Baby Venskyy
12:05pm 4/13/10
Please, please please!!!! Let's go to
Oregon!!!!
From: Baby Venskyy
1:03pm 4/14/10
Tolichka I love u!! Priezhai Buda!!!
From: Baby venskyy
12:34pm 5/2/10
Tony I love you!! Came over here!!!
From: Baby Venskyy
12:34pm 5/2/10
Sorry honey no ya tebe suda zhdu!!!
From: Baby venskyy
12:37am 5/10/10
Tony, we are miss you here so much. I
rely hopping that you and Lisa will come to
some agreement. Come here, we love you, we
really want you and Lisa get together. We pray
and wish you blessings and wisdom from God.
You'll be always my son!
From: Prima Mom
3:14pm 5/12/10
Sorry Honey, but I am waiting for you
here.
From: Baby Venskyy
12:37am 5/10/10
EXHIBIT "A"
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. Oregon Department of Justice
Division of Child Support
John R. Kroger, Attorney General 221 Molalla Ave Suite 223
Mary H. Williams, Deputy Attorney General Oregon City, Oregon 97045
Telephone: (971) 673-6350
FAX: (971) 673-6351
TDD: (800) 735-2900
http://www.doj.state.or.us
July 6, 2010
TO: ANATOLIY A. VENSKYY
104 S ORANGE ST
CARLISLE, PA 17013
CSP #: OOSHM2341 B41
Obligor: Anatoliv A. Venskyy
Obligee: Levsa A. Venskyy
Child(ren): An¢ela Venskvv and Julie Venskyy
Public assistance has been paid to support the child(ren) listed above.
We are required by law to evaluate your ability to pay support.
Please fill out and return the enclosed document(s) by 08/05/2010.
If you do not respond to this request, legal action may be taken without further advance notice to you.
~ THIS OFFICE PROVIDES SERVICES ON BEHALF OF THE STATE OF OREGON. WE
CANNOT REPRESENT YOU OR GIVE YOU LEGAL ADVICE. YOU MAY CONTACT
YOUR OWN LAWYER AT ANY TIME.
David Ployer
Authorized Representative
The Child Support Program is able to provide our customers with information from forms and
other notices in their own languages free of charge. This also includes Braille, large print, and the use of
interpreters. To find out more, please contact your child support office.
Page 1 of 1 -INITIAL CONTACT LETTER
CSF OI 0101 (Rev. 07/25/06) \ dxp EXHIBIT "D"
.. Oregon Department of Justice
Division of Child Support
John R. Kroger, Attorney General 221 Molalla Ave Suite 223
Mary H. Williams, Deputy Attomey General Oregon City, Oregon 97045
Telephone: (971) 673-6350
FAX: (971) 673-6351
TDD: (800) 735-2900
http://www. doj.state. onus
July 6, 2010
TO: ANATOLIY A. VENSKYY
104 S ORANGE ST
CARLISLE, PA 17013
CSP #: OOSHM2341 B41
Child(ren): Angela Venskyv and Julie Venskyy
The Child Support Program is required to establish a child support order for the
child(ren) named above. We are sending this letter to request information from you. Fill out the
enclosed paperwork and return it to us within 10 days. 'The support calculation will be based on
the information you provide and on other resources available to the Child Support Program. If
you have questions, please contact me.
For information about Child Support Program services, online forms, and how to contact
local branch offices, visit our website at: www.doj.state.or.us and choose "GET HELP WITH
CHILD SUPPORT."
David Ployer
Authorized Representative ((971} 673-6350)
Enclosure
The Child Support Program can provide you with information from forms and other
notices in your own language free of charge. This also includes Braille, large print, and the use
of interpreters. To find out more, contact your child support office.
The Child Support Program (CSP) provides services for the State of Oregon. We cannot
represent you or give you legal advice. You may contact your own lawyer at any time. Low cost
legal services may be available. For information you may visit the CSP website at
www.doj.state.or.us and choose "GET HELP WITH CHILD SUPPORT."
Page I of 1 -OBLIGOR DISCOVERY LETTER
CSF O I OI Ol A (Rev. Ol /04/10)\ dxp
Oregon Department of justice
John R. Kroger, Attorney General
Mary N. Williams, Deputy Attorney General
July 6, 2010
TO: ANATOLIY A. VENSKYY
104 S ORANGE ST
CARLISLE, PA 17013
Division of Child Support
221 Molalla Ave Suite 223
Oregon City, Oregon 97045
Telephone: (971) 673-6350
FAX: (971) 673-6351
TDD: (800) 735-2900
http:/iwww. doj.state.or.us
CSP#: OOSHM2341B41
Obligor: Anatoliy A. Venslcyy
Obligee: Leysa A. VenslcyX
NOTICE OF MEDICAL SUPPORT REQUIREMENTS
ORS 25.323, OAR 137-050-0750, OAR 137-055-3340
Every child support order must include a medical support clause. Medical support means public or private
health care coverage (insurance) and/or cash medical support.
Both parents are required to provide medical support if it is appropriate and available. This includes when their
children are in state custody. Parents that earn Oregon Minimum wage or less are not required to provide medical
support.
Both parents must provide private Health Care Coverage (HCC) when it is available. However, the parties may
agree that only one parent will provide the coverage if the children are not receiving medical assistance.
If only the parent with custody of the children will provide private HCC, the other parent will be ordered to pay
cash medical support.
If no one can provide private HCC, the parent with custody of the children will be required to apply to enroll
them in public HCC and the other parent will be ordered to pay cash medical support.
When the order to provide private HCC is entered, the providing party's employer will be required to enroll the
children if appropriate HCC is available.
If you have private HCC available, you must give us proof of the cost to enroll yourself and the children on this
case. Use the enclosed "Uniform Income Statement" and attach the proof to the form.
For information about Child Support Program services, online forms, the guidelines calculator, and how to
contact local offices, visit our website at: www.doi.state.or.us and choose "GET HELP WITH CHILD SUPPORT."
Page 1 of 1 -NOTICE OF MEDICAL SUPPORT REQUIREMENTS
CSF O1 0230B (Rev. Ol/04/10)
~~ETRO
BANK
>06206 6332595 001 092140
LEYSA A VENSKYY
OR ANATOLIY A VENSKYY
921 FOREST CT
CARLISLE PA 17013
Metro Bank
3801 Paxton Street
Harrisburg PA 17111-1418
1-888-937-0004
mymetrobank.com
We're here 7 days a week, 24 hours a day at 1-888-937-000.
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~~ TOTALLY FREE CHECKING
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Transactions By Date
Date Description DebR Credit Bal4nce
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03/25/10 POS RITE AID CORP. 55.00 5358.55
RF#697065 03/25 131137 CARLISLE,PA
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03/29!10 CUSTOMER DEPOSIT S664.99 51,021.12
Q31~W1~~ PO$ YVAtNU'~'80TTC?IKSPr ~,''
; i4><a08 5972.1
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03/29H0 POS TARGET 72099 CAR 538.18 5933.98
RF8088793 03!27 122418 CARUSLE,PA
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03129!10 POS PETSMART INC 152 542.28 5849.50
RF#009508 03!28 203401 CARLISLE,PA
O~Al~lt' PO3~ TARCIET1`2091! CA~4 ' _ , ~ . ~" ~. ~.lS7<~. ~ 5841
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03129/10 POS TARGET 72099 CAR 582.78 5782.21
RF#889074 03!28 212247 CARLISLE,PA
03J29~FfiQ POS'S W/tL.NUS' BOTTOM Bp- _:~ `.' ~4.OQ Y71~'3'1~'
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03I29N0 POS WAL-MART #2574 51.84 5728.57
RF#770151 03!27 183500 CARLISLE,PA
03>zs~rtQ > ~~ ~ coarl-. ~ ~ ~ ~ 54Q1 ~7~:7~
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RF~130q 4312~:123QY8 CARU$~,p~K., ,~., M. .
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03/30!10 OR REVENUE DEPT TAX REFUND 5687.00 51,412.78
VENSKYY, ANATOLIY A
03pW't@ , , .. pYM'~' Oft Op ACC1r'~»;: , . ..~ r`` ~~: ' ~~ ~'' M ry ~i1,3$8.27°;~
03130H0 POS RITE AID CORP. 51.62 51,364.75
RF#480288 03!30 173152 CARLISLE,PA
031~11i~ YISIE QOL}SY MARKET LLG ~ ~ ~17.~5 51,347.58k~
F~F$9t10317$ 1~i041 MSW ~1~~~,Bl~ .
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03/31H0 POS WAL-MART #2574 538.78 51,308.79
RF#581799 03130 212300 CARLISLE,PA
23 Cycla EXHIBIT "E" Page 1 of 8 ~nerr~ar~o«
~~ETRO
BANK
Transactions By Date
Date Description Debit Credit Balance
03f8tliA VfSA HERSHEY" M-GAFH >IiLB'Q 51~~ 80
03!31/10 VISA WENDYSO402 51.79 51,299.11
RF#01641T 03129 220803 CARLISLE,PA
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03131110 POS RITE AID CORP. 128.99 51,268.33
RF11915601 03/30 191222 CARLISLE,PA
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03131/10 POS USPS 4111680013/ 577.00 ;1,241.34
RF4337653 03131 121913 CARLISLE,PA
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04101/10 POS RITE AID CORP. 512.98 51,060.05
RF11176395 04101 112201 CARLISLE,PA
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04102/10 CUSTOMER DEPOSIT 5700.80 51,737.23
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04/02N0 POS RITE AID CORP. 51.52 11,355.71
RFtt265385 04101 184830 CARLISLE,PA
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04/05!10 VISA TACO BELL 244200 52.43 51,350.85
RF#~015495 04/01 161338 CARLISLE,PA
0/10e~11 PQ>R ~~~~~ ~~~~; -s ~~ 1 51538,
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04/05/10 POS ROSS STORES #689 539.97 51,298.22
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04/05/10 VISA CEDAR CLIFF BP 535.00 51,258.71
RF*045030 04/04 233939 CAMP HILL,PA
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04108/10 POS RITE AID CORP. 520.22 51,235.71
RF11400481 04!05 205821 CARIISLE,PA
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04106/10 POS RITE AID CORP. 1886.58 5567.70
RFII840687 04/08 112904 CARLISLE,PA
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04/07/10 POS RITE AID CORP. 511.72 5553.98
RF#001833 04/08 190623 CARLISLE,PA
04IO7htf POD- R[T4 AtD CORD; '; ~ ~` 59:~ 5544.3
:, Rt•006294li 04/07` 111 $~;~~ _..._.. .. t _ ~ .. .. :, .
0410TH 0 POS TARGET 72099 CAR 521.23 5523.16
RF#927787 04/08 205542 CARLISLE,PA
0~7110v~ ~ ~. - PO$: KOHL'S #0183 ZZ4`~' . ~ ~ ; ~ ~ ~ i136:8i~~< 5337.215
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04/08/10 POS RITE AID CORP. 512.63 5324.65
RF4188587 04!08 131927 CARLISLE,PA
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VISA RITE AID STORES 51.52
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RF#p83491 04!07 060929 CARLISLE,PA
04103/t Q VISJ1 R1''E` A~ STORE ~' ~ 51.43 517!}.44
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Pane 3 of 8
Transactions By Date
Date Description Debit Credit Balance
OM09l10 US TREASURY 220 TAX REFUND 58,573.00 58,752.44
VENSKYY, ANATOLIY A 8
041gltlf~ PIr~TR~It8UR1~ C~IEPT' Ply R!#PUi!Jt! _: Sit#~10(~ 58„l~41'~
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04/12/10 CUSTOMER DEPOSIT S855.80 59,597.24
04112J1+~ V[~ HRi`M MI~C,~IlrIL ~~ :.~ ' ` ~ ~'
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04/12110 POS AT&T MOBILITY It 542.38 19,548.53
RF#965250 04110 014042 CARLISLE,PA
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04/12/10 VISA HERSHEY MEO-CAFE 54.68 59,473.93
RF#f1120070 04!09 231729 HERSHEY,PA
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04113/10 POS WALNUT BOTTOM BP S39.00 59,430.25
200400 CARLISLE,PA
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04/14N0 VISA RITE AID STORE 8 56.53 19,419.21
RFtM050122 04113 235311 CARLISLE,PA
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04N5/10 POS WAL-MART ~It2574 523.60 58,895.61
RFak473746 04!14 194400 CARLISLE,PA
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04/16/70 ATbT MOBILITY ONLINE PMT 5145.00 18,570.61
VENSKYY,LEYSA
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04118/10 BK OF AMER WMC ONLINE PMT 5500.00 (7,920.81
YENSKYY,LEYSA
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04l18H0 PP8~L ONLINE PMT 5158.00 ST,722.61
VENSKYY,LEYSA
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04N6l10 T-MOBILE ONLINE PMT 580.00 17,322.81
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04119H0 VISA STARBUCKS USA 00 54.51 5100.10
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Check Transactions
Number Date Amount Number Date Amount Number Date Amount
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Items denoted with an "E' are electronic entries and will not have a check Image. Items denoted with an "'" indicate processed checks out of sequence.
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~yETRO
BANK
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#1939275 20100419 $7,218.00
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Paaw 7 of A
Form 1040 2009 ANATOLIY A & LEYSA A VENSKYY 166-82-6100 Pa 2
38 Amount from line 37 (adjusted gross income) .............................................. 38 16, 4 2 0 .
Tax and 39a Check r 8 Youwere bom before Jan. 2,1945, 8 Blind. ~ Total boxes
Credits ~: L Spotree was bom before Jan. 2, 1945, Blind. checked - 38a
StandaM b If your spouse itemizes on a separate return or you were actual-status alien,
Deduction see instntctions and check here - 39b
for ~ 40a Ibmixed dsductlons (from Schedule A) oryour standaM deduction (see left margin) ...... 40a 11, 4 00 .
• People who b ityou am a
fleck any box tawse, «ae r o..., N~, ~ ~ w"aNac"} ~«.° { `e«~`n `msti,c~"on.j°~ v`~~' ......... - 40b
on Ilte 39a, 41 Subtred line 40a from line 38 .............................................................. 41 5 , 0 2 0 .
39b, or 40b or 42 Exemptions. If line 38 is 5125,100 or less and you dkt not provide housing to a Midwestern
who can ~ diaplsced individual, multiply 53,850 by the number on line 8d. Ofherwiae, see Instrudbns .. 42 14 , 6 0 0 .
chimed as a
dependent, 43 Taxable Income. Subtred line 42 from line 41. If line 42 is more than line 41, enter -0- ...... 43 0
See i~fr• 44 Tax (see inslrudiorta). Check if any tax is from: a ~ Form(a) 8814 b a Form 4972 .. 44
• ~ others: 45 Albmatiw minimum tax see inatrudbns . Attach Forth 6251 48
Single or ( ) ............................
Marled filing 48 Add lines 44 and 45 ................................................................... - 48
separetely, 47 Foreign tax credit. Attach Form 1118 if required ............ 47 '
55,700 `-~'
48 Crest for uwd and daparalerd care expenses. Agacti Form xe4t ..... 48
~n~ MIS 49 Edt~catbn credits from Form 8883, line 29 .......... ' }~
Qual ing 60 Retirement savings oontribudons credft. Attach Form 8880 .. 50
wMow(er), 51 Child tax credft (see instntctiorts) .......................... 51 ' . ,'
211,400 52 Credits from Forth: a 8 rose b B t>f~ c 8 sres 52
Head of ~ onar asap rom Form: a 3eoo b tteo~ c 53
hottaettold, -
E8,350 64 Add Imes 47 through 53. These are your total credits ...................................... 64
55 Subtract Noe 54 from line 48. If line 54 is more than line 48, enter -0- .................. - b5
Other ti8 Self-employment tax. Attach Schedu~ SE ................................................ 58
Taxes 57 Unreported sodal security and Medicare tax from Form: a ~ 4137 b ~ 8919 .... 57
58 Additional tax on IRAs, other qualified retirement plans, etc. Attach Fortin 5329 H required .. 58
58 Additional taxes: a ®AEIC payments b ~ Household employment taxes. Attach Sch. H 59 632 .
80 Add lines 55 through 59. This is yourtotal tax ........................................ - 80 632 .
Payments 81 Federal income tax withheld from Forma VIh2 and 1099 .... 81 37 7 .
82 ZOOIi sstlmatsd tax paymerMa and amount applied from 2000 rotum 52
K you have 8 83 MNdrq work pay and poverrrrrsnt ratkss ersdib. Attadt Settsdt9a M .... 83 8 0 0 . ~ ~.
qualifying chill, 84 a Earned income credk (EIC) .............................. 84a 5, 028. ` ;
attach Schedule b Noriwr.bi. comtrt ........ 84b `
EIC. ~' atacsan
65 Additional chtid tax cxedit. Attach Form 8812 ................ 85 2 , 0 0 0 .
88 Refundable educatbn credit from Form 8883, line 16 ...... 88 1, 0 0 0 . "
87 First-time homebuyer credit. Attach Form 5405 ............ 87
68 Amount paid with request for extension to file (see Inst.) .... 68 -J;
88 Excess nodal security and tier 1 RRTA tax withheld (a« ins.) 89 " ~'
70 Credits from Forth: a a2~s ba 4t3e c ~seor d~ eess 70
71 Add Imes 81,82, 83, 848 and 85 through 70. These are your total payrrtenta .......... - 71 9 , 2 0 5 .
Refund 72 If line 71 is more than line 80, subtract line 80 from Tine 71. This is the amount you overpaid 72 8, 573 .
Direct deposit? 73 a Amount of Iirte 72 ou want refunded to ou. If Form 8888 is attached, check here - ~ 73a 8 , 57 3 .
See instructions - b Rnum~ber - c Type: ~ Ctleckirtg ~ Savings
and flti in 73b,
73G and 73d, - d -
or Form 8888. ~ '`
74 anaan a Mrte n you wain applied to your 2010 estimated tax -_l 74 1_
___ _ __
Amount 75 Amount you owe. Subtract line 71 from line 80. For details on how to pay, see Inst. .... - 75
YOU OWe 78 Estimated tax penally (see inatructlons) .................... 78 `_' ~ -,
Thlfd Party Do you want to allow another person to discuss this return with the IRS (see inaUuctiona)? Yee. CompNb n» roAowinp. No
Designee msslpnee's Ptans Personal idantilkwon
,u,n. - ro- - ntN11tNM (PIN1 ~
Sign under perultles a perJtrry,l dedaro Ifat 1 haw sxamktsd thb retain and
be1Nr, tlny are We, comet, and eompleN. Dedaratlon a prsp arer (oche
Here Your signature Date
Joint retain?
See inatr. ~
Keep aCOPY / Spouse's signature. n e pint ream, botlr must sign. Date
for your
records.
Preparers
Paid awna~e /
Preparers Fkm•a ham. c«
use only y•d%
a~dpd~and /
BCA CopyrgM form aortware Dory, 2009 Universal Tax Syatsms, ins Ap hoha roserved
actxdukro and smtsments, and to the best a my knwdedpa and
la based on aN kdormatbn a which preparer has any knowlsdpe.
Your occupation Daytime phone number
NEMPLOYED 717-243-1713
Spouse's occupation
HARMACI TECH '-
Date Check If Preparet's SSN or PTIN
self-employed (1 S 2 5 01310 8
US1040S2 Rev.t
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Phone no.
Forth 7040 (2009)
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON
LAW OFFICES
1O T?A3T HIGH STREET
CARLISLE, PENNSYtvANIA 17013
TELEPHONE (717) 243-3341
FACSIMILE (717) 243-1850
INTERNET wwwmartsoniawcom
Sheri D. Coover, Esquire
44 Svuth Hanover Street
Carlisle, PA 17013
WILLIAM F MARTSON
JOHN B. FOWLER III
DANIEL K DEARDORPP
THOMAS J. Wn.r.rnMC*
No V. CrITO III
HUHERT X. GILROY
GEORGE B. FALLER JR.*
DAVm A. FPIZSIMONS
CHRISTOPHER E. RICE
JENNIFI3R L. SPEARS
SETH T. MosEBEY
KATIE J MAXWELL
R C. VANLANDINGHAM
*Boun Ceanmen Cmt Taut Srecuusr
July 23, 2010
RE: Anatoliy A. Venskyy v. Leysa A. Venskyy
Our File No. 13870.1
Dear Sheri:
I discussed with my client your statement that Mrs. Venskyy cannot afford to transport the
children to Pennsylvania as ordered by the Court. First of all, I would like to point out that
Mrs. Venskyy cleaned out the parties' bank account (several thousand dollars) on the eve of her
departure, leaving him dead broke. If she really does not have the money to transport the children
to Pennsylvania, it would be helpful to know what she did with that money, especially as she is
apparently staying with her parents, rent free.
In any event, despite the fact that the Court has placed the burden on transportation expense
on Mrs. Venskyy, Mr. Venskyy is willing to subsidize transportation if, in fact, she is broke as she
claims. Currently, he has about $300.00 saved from his unemployment checks that he is willing to
use to subsidize the transportation. So, if your client needs this money, I want you to know it is
available. If she needs more, I am willing to see if he can borrow it from his family.
Please let me know.
TJW/tde
cc: Anatoliy A. Venskyy
F:~FILES~CGm[s~13870 Venskyy~13870.1 sci
Very truly yours,
MARTSON LAW OFFICES
Thomas J. Williams
EXHIBIT "F"
INFORMATION • ADVICE • ADVOCACY sM
VERIFICATION
The foregoing Answer is based upon information which has been gathered by my counsel
in the preparation of the lawsuit. The language of the document is that of counsel and not my own.
I have read the Complaint and to the extent that the document is based upon information which I
have given to my counsel, it is true and correct to the best of my knowledge, information and belief.
To the extent that the content of the document is that of counsel, I have relied upon counsel in
making this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities, which provides that if I make knowingly false
averments, I may be subject to criminal penalties.
Anatoliy A. Venskyy
CERTIFICATE OF SERVICE
I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams Otto Gilroy &
Faller, hereby certify that a copy of the foregoing Answer was served this date by depositing same
in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows:
Sheri D. Coover, Esquire
44 South Hanover Street
Carlisle, PA 17013
MARTSON LAW OFFICES
Y `
a D. Eckenroad
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: July 29, 2010
ANATOLIY A. VENSKYY,
PLAINTIFF
V.
LEYSA A. VENSKYY,
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 10-3358 CIVIL
IN RE: DEFENDANT'S PETITION FOR SPECIAL RELIEF
ORDER OF COURT
AND NOW, this 30th day of July, 2010, upon consideration of the Defendant's
Petition for Special Relief and the Plaintiff s Answer thereto,
IT IS HEREBY ORDERED AND DIRECTED that an Emergency Hearing on the
matter will be held on August 9, 2010, at 8:30 a.m. in Courtroom No. 2 of the
Cumberland County Courthouse, Carlisle, Pennsylvania. Mother will be considered the
moving party and will have the burden of proof; the Mother is specifically ordered to
bring the children with her to this hearing.
IT IS FURTHER ORDERED AND DIRECTED that the Order of this Court dated
July 13, 2010, is modified to the extent that Mother may retain physical custody of the
children until the Emergency Hearing scheduled for August 9, 2010.
By the Court,
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heri D. Coover, Esquire ~ -~:
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ANATOLIY A. VENSKYY,
PLAINTIFF
V.
LEYSA A. VENSKYY,
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 10-3358 CIVIL
IN RE: DEFENDANT'S PETITION FOR SPECIAL RELIEF
ORDER OF COURT
AND NOW, this 10~' day of August, 2010, upon consideration of the Defendant's
Petition for Special Relief, the Plaintiff s Answer thereto, and after hearing,
IT IS HEREBY ORDERED AND DIRECTED that the Defendant's Petition for
Special Relief is DENIED. The parents will share joint legal custody of the children and
Father shall have primary physical custody of the children pending the full custody
hearing scheduled in this matter for October 20, 2010, at 10:00 a.m. in Courtroom No. 2
of the Cumberland County Courthouse, Carlisle, Pennsylvania.
IT IS FURTHER ORgERED AND DIRECTED that in the interim, Father shall
desist from using a belt in any form of physical punishment. Additionally, it is directed
that Cumberland County Children and Youth Services verify that the home of the Father
at 104 South Orange Street, Carlisle, is a suitable environment for the children. Father
shall participate in the PareritWorks program provided by Cumberland County Children
and Youth Services and comply with all conditions of the program. Cumberland County
Children and Youth Services is authorized to conduct any visits of Father's home they
feel appropriate to ensure the safety of the children.
Should the Mother establish a residence in Pennsylvania, the Court will entertain
a modification of this Order'to allow her shared physical custody.
By the Court,
~~
M. L. Ebert, Jr., J.
Thomas J. Williams, Esquire
Attorney for Plaintiff
/Sheri D. Coover, Esquire
Attorney for Defendant
Cumberland County Children and Youth Services ~,~5 g/~aJ~
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