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Home My WebLink About04-3302VERA $IRASKOVA, Plaintiff PETR JIRASEK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY COMPLAINT 1. Plaintiff is Vera Jiraskova, who currently resides at 19 Wood Lane, Carlisle, Cumberlmad County, Pennsylvania 17013. 2. Defendant is Petr Jirasek, who currently resides at is 511 Highland Court, Carlisle, Cumberland County, Pennsylvania 17013; however, his ctm'ent exact whereabouts are unknown. 3. Plaintiff seeks sole physical custody and sole legal custody of Petra Jiraskova, born April 13, 1992. The child was not born out of wedlock. Plaintiff and Defendant were married on September 13, 1991 and divorced on May 12, 2004, 4. For the past five years, Petra Jiraskova has resided at the following addresses: a. June 25, 2004 to present: 19 Wood Lane, Carlisle, PA 17013; b. September 1, 2003 to June 25, 2004: Nadrazni 112, Zamberk 56401, Czech Republic; c. Birth to September I, 2003: Tyrsova 33, Kostelec Nad Orlici, Czech Republic. 5. As of September 1, 2003, Petra Jiraskova has been in the custody of Plaintiff. 6. The relationship of Plaintiff to the child is that of mother. She is planning to marry Dale Taylor on July2 I, 2004 and she currentlyresides with him. The Plaintiffcurrently resides with the following: Name Relationship Petra Jiraskova Daughter Dale Taylor Fiancb 7. The Defendant has not had custody ofPetra Jiraskova since September 1, 2003. The Defendant is not married and is presumed to be living separately. 8. Plaintiffhas not participated in previous litigation concerning the custody of the child in this court or any other court. Plaintiff has no information ora 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 o fthe child or claims to have custody or visitation fights with respect to the child. 9. The best interest and permanent welfare ofPetra Jiraskova will be served by granting sole physical and sole legal custody to Plaintiff because she is best able to provide a stable and nurturing environment for Petra. Defendant acted to the detriment ofPetra Jiraskova when he made his whereabouts unknown and failed to contact Petra for several months. 10. All known parents whose parental rights to Petra Jiraskova have not been terminated and the person who has physical custody ofPetra Jiraskova, Plaintiffi have been named as parties to this action. WHEREFORE, Plaintiffrequests your Honorable Court to set a time and place for a hearing at which Plaintiff requests the Court to grant her the Custody Order. Pending said hearing, Plaintiff requests temporary custody. Date: /uly 8, 2004 MARTSON DEARDORFF WILLIAMS & OTTO By ~~' Carl C. Risch, Esquire Attorney I.D. No.: 75901 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff VERIFICATION I verify that the statements contained herein are tree and correct, I understand that raise statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904, relating to unswom falsification to authorities. July 8, 2004 Vera Jiraskova VERA JIRASKOVA : IN THE COURT OF COMIViON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. 04-3302 CIVIL ACTION LAW PETR J1RASEK : IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Monday, July 19, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear belbre JacLqueline M. Vern~y, Es .q~, the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, August 24, 2004 at 9:30 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. 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. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ ]acqueline M. Verney, Esq, mhc 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 l:he court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or bus/ness 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 ATI'ORNEY OR CANNOT APFORD 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 VERA JIRASKOVA PLAINTIFF V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : : 04-3302 CIVIL ACTION LAW PETR JIRASEK : iN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Monday, July 19, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear befbre Jacq~ueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, August 24, 2004 at 9:30 AM for a Pre-Heating 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 l~resent at the conference. Failure to appear at the cunference 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 Custody orders to the conciliator 48 hours prior to scheduled hearinl~. FORTHECOURT, By: /s/ .Iacqueline M. Verncy: Esq. 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 32 South Bedford Street Carlisle, Pennsylvania 1701:3 Telephone (717) 249-3166 VERA JIRASKOVA, Plaintiff V. PETR JIRASEK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2004-3302 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY TEMPORARY CUSTODY COURT AND NOW, this 7dt~ day of I/~' · . ~ _ r ¥ L~I/~',.~I ,2004, upon conszderat~on of the attached Custody Conciliation Re'port, it is ordered and directed as follows: 1. The Mother, Vera Jiraskova, shall have sole legal and physical custody of Petra Jiraskova, bom April 13, 1992. 2. Father may have periods of supervised visitation as agreed by the parties. 3. The parties may modify the terms of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control Father may request a conciliation conference within 90 days of the date of this Order. After ninety days, Father must file a Petition to Modify. J. cc'~ennifer Spears, Esquire, Counsel for Mother .~tr Jirasek, pro se 511 Highland Court Carlisle, PA 17013 q ~/ VERA JIRASKOVA, Plaintiff V. PETR JIRASEK, Defendant PRIOR JUDGE: None AUG 2 4 2004 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 2004-3302 CIVIL TERM : : CIVIL ACTION - LAW : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, thc undersigned Custody Conciliator submits thc following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME Petra Jiraskova DATE OF BIRTH April 13, 1992 CURRENTLY IN CUSTODY OF Mother 2. A Conciliation Conference was held in this matter on August 24, 2004 with the following in attendance: The Mother, Vera Jiraskova, with her counsel, Jennifer Spears, Esquire. Father did not attend the conference. The custody complaint was sent certified mail and first class regular mail. Father did not accept the certified mail, however, the first class mail was not returned. 3. Mother requested an Order of Court in the fo:tm as attached. Date emey, Esquire d Custody Conciliator