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HomeMy WebLinkAbout10-3910BRIAN JAMIOLKOWSKI, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION -LAW NO. l0 -3A10 ClvilT~~ SHARON JAMIOLKOWSKI. Defendant IN CUSTODY Cumberland County, Pennsylvania, 17011. 1. The Plaintiff is Brian Jamiolkowski, residing at 530 Fairway Drive, Camp Hill, 2. The Defendant is Sharon Jamiolkowski, residing at 2266 Old Hollow Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. Plaintiff seeks custody of the following children: Joshua M. Jamiolkowski, bom October 29, 2002, and Jacob M. Jamiolkowski, bom August 11, 2004. COMPLAINT FOR CUSTODY The children were not bom out of wedlock. The children are presently in the custody of Sharon Jamiolkowski, who resides at Old Hollow Drive, Mechanicsburg, Pennsylvania 17050. During the past five years, the child has resided with the following persons and at SAIDIS, FLOWER .SZ LIlVDSAY 26 West High Street Cazlisle, PA following addresses: NAME Plaintiff and Defendant Plaintiff ADDRESS 3 Countryside Ct. Camp Hill, PA 17011 2266 Old Holllow Drive Mechanicsburg, PA cn ~ `~ ._ ~ FROM/T~; ~-a _; ~- ~ ~, ~ 2005 -200~1#c '; ~ v' ~= ;.~ ~_ ~::.. fi ~`~ 2008-201 Q ~ L~ ~`•' , C ~' ~ The mother of the child is Sharon Jamiolkowski, currently residing at 530 Fairway Camp Hill, Pennsylvania. She is single. ~ 1~l'4. oo PD A' e~ a7sto3 I?~ ay3 Asa The father of the child is Brian Jamiolkowski, currently residing at 44 Devonshire Mechanicsburg, Pennsylvania. He is single. 4. The relationship of Plaintiff to the children is that of biological father. The currently resides with his current girlfriend, and her daughter, age 8; on a primary Pursuant to the terms of the parties' Agreement, Plaintiff exercises custody of the children evening overnight every week and alternating weekends from Friday through Monday morning. 5. The relationship of Defendant to the children is that of biological mother. Defendant currently resides with the children at issue on a primary custody basis pursuant the terms of the agreement dated June 2008, incorporated into the parties' Property Agreement. 6. Plaintiff has not participated as a party or witness, or in another capacity, in litigation concerning the custody of the children in this or another court. 7. Plaintiff has no information of a custody proceeding concerning the childre pending in a court of this Commonwealth or any other state. 8. Plaintiff does not know of a person not a party to the proceedings who physical custody of the children or claims to have custody or visitation rights with respect to children. 9. The best interest and permanent welfare of the children will be served FLOWER 6z LINDSAY 26 West High Street Cazlisle, PA granting the relief requested because: a. Plaintiff can best provide for the children's spiritual, physical emotional welfare. b. Since the parties' separation, Plaintiff has been providing for children's care on a frequent basis throughout the week and ~ Defendant's schedule permits. c. Plaintiff makes himself available to care for and to be available for children as often as possible because he believes it is in the child best interest to spend time with each parent more frequently. c. Since the parties' separation, Plaintiff has been equally involved in children's upbringing, including medical appointments, extracurric activities and day to day needs. d. Plaintiff believes that the children's best interests would be met if they the ability to spend more time with each parent on a consistent and st schedule. e. Plaintiff desires an expanded parenting schedule to share custodial with Defendant. 10. Each parent whose parental rights to the child have not been terminated and person who has physical custody of the child have been named as parties to this action. other persons, named below, who are known to have or claim a right to custody or visitation the child will be given notice of the pendency of this action and the right to intervene: None. 11. This is a new custody action and therefore, no Judge has been previously. 12. Plaintiff is represented by Maryann Murphy, Esquire and a copy of this has been provided to her at 39 West Main Street, Mechanicsburg, PA 17055. WHEREFORE, Plaintiff requests this Honorable Court to grant shared legal and s FLOWER 8z LINDSAY 26 West High Street Cazlisle, PA physical custody of the children to him. SAIDIS, FLOWER 8 LINDSAY Mar~laG yl~as, Esq~life ID No. g~~ 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing document are true and correct. FLOWER ~ LINDSAY 26 West High Street Cazlisle, PA understand that false statements herein are made subject to the penalties of 18 Pa. C.S. relating to unswom falsifications to authorities. Date: ~ / ~ ~~~ ~ 0 16 ,, r BRIAN .IAMIOLKOWSKI PLAINTIFF V. SHARON JAMIOLKOWSKI IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PI:;NNSY[.,VANIA 2010-3910 CIVIL ACTION LAW 1N CUSTODY [)I;FF:NUANT ORDER OF COUKT AND NOW, Wednesday, June 23, 2010 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. ,the conciliator, ax 4th Floor ,Cumberland Count _Courthouse, Carlisle on Thursda"y, July 29, 2010 __ a[ 10:30 AM for aPre-hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or i(~this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. I <liliir~ to appear at the conference may provide grounds for entry of a temporary or permanent order. "The court hercbv directs the parties to furnish any and all existing Protection from Abuse orders, Suecial Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ Hubert X. Gilroy, Esq. _ _ Custody Conciliator l~he Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For infor-nation about accessible facilities and reasonable accommodations a~"ailable to disabled individuals having business before the court, please contact our office. All arrangem ents must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled ci7n[~erence. or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. iF YOU DO NOT FIAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFF~fj.'E ~T FUR"T'II E3E1_.OV4' TO FIND OUT WHERE YOU CAN GET LEGAL HELP. ~ ca ~ R-,~; ~.-. Cumberland County Bar Association +~'_ - ~ ,. °2y '~~ C ~ ` ~~ -~ r~i-r?' 32 SOUth I3edf01"d StreeC r.~ ;'- ~ ^ (J ~~ ~ , ~ i. MQ~}'CL$ Carlisle, Pennsylvania 17013 ~ :`-~~. Telephone (717) 249-3166 ='~;-; -°~, ~ ~ ~ ~~ (o • a ~ • ~ p ~lac~e.a ',n (s' - < l~ o~'s ~ fie. ~~ (~ ~ f BRIAN JAMIOLKOWSKI, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW SHARON JAMIOLKOWSKI, NO. 2010-3910 Defendant IN CUSTODY ORDER AND NOW, this day of August, 2010, the Conciliator being advised the parties have reached an agreement, the Conciliator relinquishes jurisdiction. Hubert X. Custody C (~ f P^J ~.) ~ ~' -' , A ~ I f _ ~~ + ~ l ~~ invDS~ 26 West High Street Carlisle, PA J1UG 13 2010 BRIAN JAMIOLKOWSKI, Plaintiff SHARON JAMIOLKOWSKI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No. alplb-3glb IN CUSTODY ORDER OF COURT AND NOW, this ~ day of ~J ~ _, 2010, the attached Stipulation and Agreement for Custody is hereby made an Order of Court. cc: " Ma lou Matas, Es uire rY q Attorney for the Plaintiff Maryann Murphy, Esquire Attorney for the Defendant ~-O e pies' m.~c~ 8/~7~~v ~~ BY THE COURT: