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HomeMy WebLinkAbout01-4869 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA KATHLEEN A. KARRASCH, Plaintiff CHRISTOPHER J. 1. The Third Street, 17007. 2. Butterchurn Lane, Pennsylvania 17007 3. Plaintiff Daniel J. Karrasch date of birth 3/23/95. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : IN CUSTODY KARRASCH, Defendant COMPLAINT FOR CUSTODY Plaintiff is Kathleen Karrasch, residing at 12lA Boiling Springs, Cumberland County, Pennsylvania The Defendant is Christopher Karrasch, residing at 3 Boiling Springs, Cumberland County, seeks custody of the following children: date of birth 3/25/91 and Scott M. Karrasch, 4. The child with both parents, the Plaintiff. 5. During is presently although the in a shared custody situation children primarily reside with the past five years, the children have resided with both parties at 3 March 5, 2001. From March 5, children have resided with the From August 1, 2001, through resided on and off with both parties. Butterchurn Lane in Boiling Springs until 2001 through August 1, 2001, the Defendant at 3 Butterchurn Lane. the present the children have SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA 6. The mother of the children is the Plaintiff. She currently resides at 12lA Third Street, Boiling Springs, Pennsylvania 7. She is married. 8. The father of the children is the Defendant. He currently resides at 3 Butterchurn Lane, Boiling Springs, Pennsylvania. 9. He is married. 10. The relationship of Plaintiff to the children is that of mother. The Plaintiff currently resides with the following persons: None. 11. The relationship of Defendant to the children is that following of father. The Defendant currently resides with the persons: None. 12. Plaintiff or in another custody of the term and number, applicable. has not participated as a party or witness, capacity, on other litigation concerning the children in this or another court. The court, and its relationship to this action is: Not proceedings 13. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth[' The court, term and number, and its relationship to this action is: Not applicable. 14. Plaintiff does not know of a person not a party to the who has physical custody of the children or claims SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA to have custody or visitation rights with respect to the children. The name and address of such person is: Not applicable. 15. The best interest and permanent welfare of the children will be served by granting the relief requested because the children have lived with Plaintiff all of their natural lives, with the exception of the past few weeks, which has been arbitrarily controlled by the Defendant. The Plaintiff has been their primary caregiver throughout their lives and has a stable home in the same school district along with Defendant. 16. Each parent whose parental rights to the child have been terminated and the person who has physical custody of child have been named as parties to this action. All other named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: None. WHEREFORE, Plaintiff requests the court to grant Plaintiff, Kathleen A. Karrasch, custody of the children, or in the alternative, to enter a shared legal and custody situation with the children. Respectfully submitted, SAIDIS, SHUF/~ ~ER & LINDSAY Attorney I.~D. #53147 26 West High Street Carlisle, PA 17013 Attorney for Plaintiff not the persons, SAIDIS SHUFF, FLOWER & LINDSAY 26W. High Slreet Carlisle, PA VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated: ~. ~rrasch KATHLEEN A. KARRASCH PLAINTIFF V. CHRISTOPHER J. KARRASCH DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-4869 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, August 29, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, September 26, 2001 at.8:30 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. 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/ Jacqueline M. Verney. Esq._~p 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 SEP 6 KATHLEEN A. KARRASCH, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001-4869 CIVIL TERM CHRISTOPHER J. KARRASCH,: CIVIL ACTION - LAW Defendant : : IN CUSTODY ORDER OF COURT AND NOW, this 2-7' da of .Y~o~'t,...4~.r ,2001, upon consideration of the attached Custod~ Concd~ati(m Report, ~t is ordered and directed as follows: 1. The Mother, Kathleen A. Karrasch, and the Father, Christopher J. Karrasch, shall have shared legal custody of Daniel J. Karrasch, bom March 25, 1991 and Scott M. Karrasch, bom March 23, 1995. 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 her health, education and religion. 2. Father shall have primary physical custody of the children. 3. Mother shall have periods of partial physical custody of the children on the following schedule: A. Beginning October 13, 2001, altemating weekends from Saturday at 9:00 a.m. to Monday morning when Mother will put the children on the school bus. B. Every Sunday after church to Monday morning when Mother will put the children on the school bus. C. Every Wednesday after work to Thursday morning when Mother will put the children on the school bus. parties. The parties shall share the Thanksgiving holiday at times agreed by the 5. The parties shall alternate the Christmas holiday. Block A shall be from 12:00 Noon Christmas Eve to 12:00 Noon Christmas Day and Block B shall be from 12:00 Noon Christmas Day to 12:00 Noon December 26. Father shall have Block A in odd numbered years and Block B in even numbered years. Mother shall have Block A in even numbered years and Block B in odd numbered years. 6. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. 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: Johnna J. Kopecky, Esquire, for Mother Thomas S. Diehl, Esquire, for Father KATHLEEN A. KARRASCH, Plaintiff SEP 2 6 001 : IN THE COURT OF COMMON PLEAS OF i CUMBERLAND COUNTY, PENNSYLVANIA V. : 2001-4869 CIVIL TERM : CHRISTOPHER j. KARRASCH,: CIVIL ACTION. LAW Defendant : : IN CUSTODY PRIOR JUDGE: None 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 is the subject of this litigation is as follows: NAME Daniel J. Karrasch Scott M. Karrasch DATE OF BIRTH March 25, 1991 March 23, 1995 CURRENTLY 1N CUSTODY OF Father Father 2. A Conciliation Conference was held in this matter on September 26, 2001, with the following individuals in attendance: Mother. Kathleen A Karrasch with her counsel, Johnna J. Kopeckv, Esnuiro e-*~. ~ .... ' , was present ~ ,~ ~. -,~u~, ~rtrlstopher J. Karrasch, was present with his counsel, Thomas S. DieM, Esquire. 3. The parties agreed to an Order in the form as attached. Date Y ciliator