Loading...
HomeMy WebLinkAbout01-0646JOSEPH F. VAJDA, Plaintiff PATTI J. VAJDA, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN CUSTODY · NO. o/-(.~ ~ ~/-"~"~" COMPLAINT FOR CUSTODY Hill, PA 17011. The Plaintiff is Joseph F. Vajda, residing at 509 S. 18th Street, Camp 2. The Defendant is Patti J. Vajda, residing at 1209 Edinburg Circle, New Cumberland, PA 17070. 3. The parties have two children, Brandon Joseph Vajda, born March 13, 1985 and Brittany Nicole Vajda, born January 23, 1987. Plaintiff seeks shared legal custody in both parties, primary physical custody of Brandon Vajda, primary physical custody of Brittany Vajda in Defendant and times of partial physical custody in the non- custodial parent at times mutually agreed upon. The children were not born out of wedlock. Currently Brandon resides with Plaintiff and Brittany resides with Defendant at the above respective addresses. During the past five years, following persons and at the following addresses: Brandon Patti J. Vajda and Brittany N. Vajda Patti J. Vajda and Brittany N. Vajda Joseph F. Yajda and Stephanie E. Vajda 117 Shirley Drive Middletown, PA 17057 1209 Edinburg Circle New Cumberland, PA 17070 509 S. 18th Street Camp Hill, PA 17011 the children have resided with the 1/4/96 to 1/1/99 1/1/99 to 12/28/00 12/28/00 to the present Brittany Patti J. Vajda and Brandon J. Vajda Patti J. Vajda and Brandon J. Vajda Patti J. Vajda 117 Shirley Drive Middletown, PA 17057 1209 Edinburg Circle New Cumberland, PA 17070 1209 Edinburg Circle New Cumberland, PA 17070 1/4/96 to 1/1/99 1/1/99 to 12/28/00 12/28/00 to the present The mother of the children is Patti J. Vajda, currently residing at 1209 Edinburg Circle, New Cumberland, PA 17070. She is divorced. The father of the children is Joseph F. Vajda, currently residing at 509 South 18th Street, Camp Hill, PA 17011. He is married. 4. The relationship of Plaintiff to the children is that of Father. The Plaintiff currently resides his wife, Stephanie E. Vajda, his stepson, Jonathan David Driscoll, and his son, Brandon Joseph Vajda. 5. The relationship of Defendant to the children is that of Mother. The Defendant currently resides with the parties' daughter, Brittany Nicole Vajda. 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 has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 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 because: (a) Plaintiff desires to confirm with a Court Order the physical custodial arrangement that the parties are currently following; (b) Plaintiff will assure that Brandon spends time with the Defendant and with his sister. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff requests the court to grant shared legal custody of the children in the parties, primary physical custody of Brandon with him, primary physical custody of Brittany with Defendant, sharing of transportation and a schedule of partial physical custody in the non-custodial parent at times mutually agreed upon by the parties. TUCKER ARENSBERG & SWARTZ 111 North Front Street P.O. Box 889 Harrisburg, PA 17108-0889 (717) 234-4121 Aq-I'ORNEYS FOR PLAINTIFF VERIFICATION I, the undersigned, Joseph F. Vajda, acknowledge that the facts stated in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Dated: 35782.1 JOSEPH F. VAJDA PLAINTIFF V. PATTI J. VAJDA DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-646 CIVIL ACTION LAW IN CUSTODY ORDER OFCOURT AND NOW, this 6th day of February ,2001, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliat at 39 West Main Street, Mechanicsburg, PA 17055 on the 21st day of February ,2001, at 9:30 a.m. 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. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: /s/ Dawn S. Sunday, Es .~x 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 JOSEPH F. VAJDA, Plaintiff PATTI J. VAJDA, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN CUSTODY 'NO. ORDER OF COURT AND NOW, this ~*"J~' day of //t/Jk. stipulation of the parties, it is HEREBY ORDERED AND DECREED that: 2001, upon 1. The parents shall share legal custody of the children and each parent shall consult with the other concerning all major decisions affecting the children, including but not limited to, health, education and religion. 2. Father shall have primary physical custody of Brandon. Mother shall have primary physical custody of Brittany. 3. The non-custodial parent shall have times of partial physical custody at times mutually agreed upon by the parties. 4. The parties shall share holidays as they mutually agree. 5. The parties shall share transportation with the parent receiving custody being responsible for said transportation. 35855.1 BY THE COURT: JOSEPH F. VAJDA, Plaintiff PATTI J. VAJDA, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN CUSTODY STIPULATION AND NOW, this day of ,2001, Joseph F. Vajda, Plaintiff (hereinafter referred to as "Father"), together with his attorney, Sandra L. Meilton, and Patti J. Vajda, Defendant (hereinafter referred to as "Mother"), hereby inform your Honorable Court that they have amicably resolved to their mutual satisfaction the issues of custody with regard to their two children, Brandon Joseph Vajda, born March 13, 1985 and Brittany Nicole Vajda, born January 23, 1987, and do hereby stipulate that the following is the substance of their agreement respectfully requesting that your Honorable Court issue an appropriate Order of custody and visitation in accordance with their agreement and stipulation. The parties stipulate as follows: 1. The parents shall share legal custody of the children and each parent shall consult with the other concerning all major decisions affecting the children, including but not limited to, health, education and religion. 2. Father shall have primary physical custody of Brandon. Mother shall have primary physical custody of Brittany. 3, The non-custodial parent shall have times of partial physical custody at times mutually agreed upon by the parties. 4. The parties shall share holidays as they mutually agree. 5. The parties shall share transportation with the parent receiving custody being responsible for said transportation. Witness JOSEPH F. VAJDA, Plaintiff vs o · PATTI J. VAJDA~ Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-646 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY AND NG~, this 27th day of February, 2001, the Conciliator, being advised by Plaintiff's counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdictio~ in this case. The Custody Conciliation Conference scheduled for February 27, 2001 is canceled. FOR THE CCURT, Custody Conciliator