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Home My WebLink About10-3566 STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF 2 !G i., . , . .._, ir: f f : t c-" ?iUU KIM C. MIZERAK, Plaintiff V. DANIEL T. DEYO, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2010- 3JL6 CIVIL TERM : CUSTODY COMPLAINT FOR CUSTODY NOW comes the plaintiff, Kim C. Mizerak, by her attorney, Stacy B. Wolf, Esquire, and presents the following complaint for custody, representing as follows: 1. The plaintiff is Kim C. Mizerak, an adult individual residing at 68 W. Big Spring Avenue, Newville, Cumberland County, Pennsylvania 17241. 2. The defendant is Daniel T. Deyo, an adult individual residing at 24 Thornhill Court, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks sole legal custody and primary physical custody of the following child: Name Present Residence AAe Juliette S. Deyo 68 W. Big Spring Avenue D.O.B. 10/5/2008 Newville, PA 17241 19 Months 4. Plaintiff and defendant are the natural parents of the child. 5. The parties were never married. 6. The child is presently in the custody of plaintiff and has resided with plaintiff since birth. ?lri?73' 7. 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. 8. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 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 with respect to the child. 10. Mother has been the sole caregiver of the child since her birth. 11. The best interests and permanent welfare of the child will be served by granting the relief requested herein. WHEREFORE, for the reasons set forth herein, Plaintiff, Kim C. Mizerak, respectfully requests that the Court enter an order granting sole legal custody and primary physical custody of the child to the plaintiff. Dated: May o)-fs , 2010 Respectfully submitted, Stacy B. MA-II/ , Esquire 10 West High Street Carlisle, PA 17013 Supreme Court I.D. No. 88732 (717) 241-4436 Attorney for Plaintiff VERIFICATION I do hereby verify that the facts set forth in this complaint are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. X4904, relating to unsworn falsification to authorities. U r , 2010 C . Ki C. Mizerak STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF KIM C. MIZERAK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW DANIEL T. DEYO, : NO. 2010- CIVIL TERM Defendant :CUSTODY CERTIFICATE OF SERVICE I, Stacy B. Wolf, Esquire, have served a true and correct copy of Complaint for Custody upon the following person and in the matter indicated: SERVICE BY U.S. MAIL: Daniel T. Deyo 24 Thornhill Court Carlisle, PA 17013 WOLF & WOLF ? 2-R-) 2010 By: (ke - 14zv STAGY B. WOL , ESQUIRE Attorney for Plaintiff 10 West High Street Carlisle, Pennsylvania 17013 (717) 241-4436 Supreme Court I.D. No. 88732 ~ « Kim C. MIZERAK, ~~ Plaintiff vs. DANIEL T. DEYO, Defendant ~~ JUL ~8-2010 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.2010-3566 IN CUSTODY COURT ORDER NOW, this q ` day of July, 2010, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The mother, Kim C. Mizerak, and the father, Daniel T. Deyo, shall enjoy shared legal custody of Juliette S. Deyo, born October 5, 2008. 2. The mother shall enjoy primary physical custody of the minor child. 3. The father shall enjoy liberal periods of temporary physical custody of the minor child pursuant to a schedule as agreed upon by the parties. 4. In the event either party desires to modify this order and seek a more specific custody schedule, that party may petition the court to have the case again scheduled before the Custody Conciliator for a conference. BY THE COURT, cc: ~cy B. Wolf, Esquire ..~ Mr. Daniel T. Deyo * c `~ ~~4 / /O 2.OtD July. 9 CiVY14.Ipp~Y ~Q.VI(X. l,~s~ P~,nn~ Ivcr,~,ca~ U Kim C. MIZERAK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CNIL ACTION -LAW DANIEL T. DEYO, NO. 2010-3566 Defendant IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT 1N ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Juliette S. Deyo, born October S, 2008 2. A Conciliation Conference was held on July 8, 2010, with the following individuals in attendance: The mother, Kim C. Mizerak, with her counsel, Stacy B.Wolf, Esquire and the father, Daniel T. Deyo, who appeared without counsel. 3. The parties agree to the entry of an Order in the form as attached. Date: July ~ , 2010 Hubert X. Gilr ,Esquire Custody Co iliator