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HomeMy WebLinkAbout14-7309 V Centre County Prothonotary Room 102 Courthouse \� Bellefonte, PA 16823 ` (814) 355-6796 Page Number: 'j, GENERAL Filed. . . . . . . . . 07-12-2011 Case Number..:, 11-297 :' DIVORCES 01 : 39 I t:::. "''�`� Sat/Dis/Gntd. . 02-27-2012 -------------------------------------------------------------------------------- -------------------------------------------------------------------------------- Litigants -------------------------------------------------------------------------------- Plaintiff (s) Lawyer (s) for the Plaintiff (s) ------------ ------------------------------ DMITRIYEV, DENIS ROBBINS, LAURA, ESQ. 103 GWENEDD COURT 315 S . ALLEN STREET, STE 217 PLEASANT GAP PA 16823 STATE COLLEGE PA 16801 814-234-1550 NO LONGER WITH MIDPENN; HAS A BOX Defendant (s) Lawyer (s) for the Defendant (s) ------------ ------------------------------ DMITRIYEV, VIKTORIYE CERTIFIED from the records as entered 500 GENEVA DRIVE Oand file In thi office �/ APT. C5 of D 20%MECHANICSBURG, PA 17055-_--ADDRESS UPDATED: 8/20/2014 ta and Cier f theCourt _------------------------------------------- -�--------_r ------- Proceedings -------------------------------------------------------------------------------- 07-07-2011 DIVORCE* -COMPLAINT WITH NOTICE TO DEFEND (CONSENT) 3301 (C) (PLTF SERVING/GAVE CERTIFIED COPIES) 07-12-2011 COMPLAINT FOR CUSTODY, FILED. (GAVE COPY AND CERT COPY TO ATTY FOR SERVICE) (SENT TO CRT ADMIN 7-13-11) 07-25-2011 ORDER OF COURT, FILED. (CONCILIATION/MEDIATION CONFERENCE 8-31-11 AT 11 : 00 AM IN JUDGE LUNSFORD ' S CHAMBERS, COURTHOUSE ANNEX) (GAVE COPY TO MID PENN LEGAL, MAILED COPY TO DEFENDANT 7-27-11) 07-29-2011 COMPLAINT FOR (CUSTODY) (PARTIAL CUSTODY) (VISITATION) , FILED. (COPY GIVEN TO PLTF/CERT. COPY GIVEN FOR SERVING) (SENT TO JUDGE 7/28/11) 08-03-2011 BY PAPER FILED, JUSTINE F. ANDRONICI, ESQ. , ENTERS HER APPEARANCE ON BEHALF OF VIKTORIYE DIMITRIYEV. (GAVE COPY TO ATTY. ANDRONICI 8/3/2011) (SENT COPY TO JUDGE 8/4/2011) 08-12-2011 ORDER, FILED. (DOCKET 11-2974 AND 11-2898 ARE HEREBY CONSOLI- DATES; ANY FILING UNDER 11-2898 WILL BE APPLIED TO 11-2974) (GAVE COPY TO ATTY ANDRONICI VIA PROTHON MAILBOX, MAILED COPY TO PLNTFF, DEF AND ATTY ROBBINS 8-15-11) 08-12-2011 ORDER OF COURT, FILED. (CONFERENCE 8/31/11 @ 11 : 00 AM IN JUDGE LUNSFORD' S CHAMBERS, COURTHOUSE ANNEX) (GAVE COPY TO ATTY ANDRONICI VIA PROTH. MAILBOX 8/15/11; MAILED COPY TO PLTF, DEF AND ATTY ROBBINS 8/15/11) 09-09-2011 ORDER, FILED. (REGARDING CUSTODY) (COPY MAILED TO ATTY ROBBINS 9/13/11, COPY GIVEN TO ATTY ANDRONICI 9/12/11) 10-18-2011 BY PAPER FILED, THE COMPLAINT IN THE ABOVE CAPTIONED MATTER IS REINSTATED. (GAVE TWO COPIES OF REINSTATED COMPLAINT TO PLTF 10/18/11) 10-24-2011 ACCEPTANCE OF SERVICE, FILED. (ACCEPTED 10/22/11) O1-12-2012 EDUCATION CERTIFICATE, FILED. (VIKTORIYA DMITRIYEV) 01-12-2012 EDUCATION CERTIFICATE, FILED. (DENIS DMITRIYEV) 02-22-2012 AFFIDAVIT OF CONSENT, WITH WAIVER, FILED. (PLTF) 02-22-2012 AFFIDAVIT OF CONSENT, WITH WAIVER, FILED. (DEF) 02-22-2012 PRAECIPE TO TRANSMIT RECORD, FILED. (SENT TO JUDGE 2/24/12) QtW4 ifiais.s6i)a 110.6 11- W WZ)4% . . n f1!•1r_1 Centre County Prothonotary Room 102 Courthouse Bellefonte, PA 16823 (814) 355-6796 Page Number: 2 GENERAL Filed. . . . . . . . . 07-12-2011 Case Number: 11-2974 DIVORCES 01 : 39 Sat/Dis/Gntd. . 02-27-2012 -------------------------------------------------------------------------------- 02-28-2012 FINAL DECREE IN DIVORCE, FILED. (DECREE SIGNED 2/27/12) (COPIES OF THE DECREE WERE GIVEN TO ATTY' S L. ROBBINS & J. ANDRONICI 2/29/12) 03-29-2012 BY PAPER FILED, JUSTINE F. ANDRONICI, ESQUIRE WITHDRAWS HER APPEARANCE ON BEHALF OF THE DEF WITH CONSENT. (COPY SENT TO COURT ADMIN 4/2/12) 06-18-2012 PRAECIPE TO PROCEED IN FORMA PAUPERIS, FILED. (REGARDING NOTICE OF ELECTION TO RESUME PRIOR NAME) (COPY GIVEN TO ATTY BARNEY 6/18/12) 06-18-2012 ORDER, FILED. (PETITON OF DEFENDANT TO PROCEED IN FORMA PAUPERIS OF NOTICE OF ELECTION TO RESUME PRIOR NAME) (COPY GIVEN TO ATTY BARNEY 6/18/12) 06-18-2012 NOTICE OF ELECTION TO RESUME PRIOR NAME, FILED. (KRAPOVA) (5 CERTIFIED COPIES GIVEN TO ATTY BARNEY 6/18/12 FOR SERVICE) 06-18-2012 BY PAPER FILED, SHARON BARNEY, ESQUIRE OF CENTRE COUNTY WOMEN' S RESOURCE CENTER CIVIL LEGAL REPRESENTATION WITHDRAWS HER APPEARANCE ON BEHALF OF THE DEF. (COPY GIVEN TO ATTY BARNEY 6/18/12) 07-23-2012 PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF CUSTODY, PARTIAL CUSTODY, VISITATION ORDER, FILED. (GAVE COPY AND CERTIFIED COPY FOR SERVICE TO PLAINTIFF 7/23/2012) (SENT TO JUDGE 7/24/2012) 08-15-2012 NOTICE AND ORDER TO APPEAR, FILED. (HEARING 8-31-12 AT 3 : 00 PM IN COURTROOM ANNEX) (MAILED COPY TO PLNTFF & DEF 8-16-12) 08-27-2012 BY PAPER FILED, SHARON BARNEY, ESQ. , ENTERS HER APPEARANCE ON BEHALF OF VIKTORIYA KRAPOVA WITH CERTIFICATE OF SERVICE. (SENT COPY TO JUDGE 8/29/2012) 08-29-2012 CONTINUANCE REQUEST AND ORDER, FILED. (HEARING ON 9/18/2012 AT 9 : 30AM IN ANNEX) (GAVE COPY TO ATTY. ROBBINS AND ATTY. BARNEY VIA COURTHOUSE MAILBOX 8/30/2012) 09-25-2012 TEMPORARY ORDER, FILED. (CUSTODY AGREEMENT) (GAVE COPY TO ATTYS ROBBINS AND BARNEY VIA MAILBOXES 9-25-12) 02-13-2013 ORDER, FILED. (STATUS CONFERENCE WED 3-27-13 AT 1 : 30 PM IN CRTROOM 1) (GAVE COPY TO ATTYS ROBBINS AND BARNEY VIA MAILBOXES 2-14-13) 03-15-2013 PETITION TO WITHDRAW APPEARANCE WITH CERTIFICATE OF SERVICE, FILED. (GAVE COPY TO ATTY. WILSON 3/15/2013) (WALKED THRU TO JUDGE 3/15/2013) If 03-18-2013 ORDER ALLOWING WITHDRAWAL, FILED. (YVETTE WILLSON, SHARON BAR- NEY, & JUSTINE ANDRONICCI, ESQUIRES AND THE CENTRE COUNTY WOMANS ' S RESOURCE CENTER CIVIL LEGAL REPRESENTATION IS PER- MITTED TO WITHDRAW AS DEPS COUNSEL) (COPY GIVEN TO ATTY' S ROBBINS & WOMEN' S RESOURCE CENTER 3/19/13) 08-20-2014 PETITION TRANSFER JURISDICTION, FILED. (MAILED COPY AND CERTIFIED COPY FOR SERVICE TO DEFENDANT 8/21/2014) (SENT TO JUDGE 8/21/2014) 09-02-2014 ORDER FILED. (HEARING ON SEPTEMBER 30, 2014 AT 9 : 30AM IN ANNEX) (MAILED COPIES TO PLTF. & DEF. - 09/03/14) 09-29-2014 PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF CUSTODY, PARTIAL CUSTODY, VISITATION ORDER, FILED. (GAVE COPY AND CERTIFIED COPY TO PLAINTIFF 9/29/2014) (SENT TO JUDGE 9/30/2014) 10-06-2014 ORDER, FILED. (DEPS PETITION TO TRANSFER JURISDICTION IS HEREBY GRANTE, PROTH' S OFFICE IS HEREBY DIRECTED TO TRANSFER THIS CASE TO THE COURT OF COMMON PLEAS OF CUBERLAND COUNTY, PA) (COPY GIVEN TO ATTY ROBBINS VIA PROTH MAILBOX 10/6/14, COPY MAILED TO DEF 10/7/14 , COPY GIVEN TO PROTH 10/6/14) i • Centre County Prothonotary Room 102 Courthouse Bellefonte, PA 16823 (814) 355-6796 Page Number: 3 GENERAL Filed. . . . . . . . . 07-12-2011 Case Number: 11-2974 DIVORCES 01 : 39 Sat/Dis/Gntd. . 02-27-2012 -------------------------------------------------------------------------------- 10-09-2014 AMENDED ORDER, FILED. (PETITION TO TRANSFER GRANTED, CENTRE COUNTY PROTHONOTARY' S OFFICE IS HEREBY DIRECTED TO TRANSFER THIS CASE TO THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANAI . ALL COSTS ASSOCIATED WITH THE TRANSFER OF THIS MATTER SHALL BE PAID BY THE DEFENDANT. ) (GAVE COPY TO ATTY ROBBINS; MAILED COPY TO VIKTORIYA DMITRIYEV WITH INVOICE FOR TRANSFER FEE - 10/10/14) 12-04-2014 CASE TRANSFERRED TO COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA, 1 COURTHOUSE SQUARE, CARLISLE, PA 17013 ON DECEMBER 4 , 2014 , BY CERTIFIED MAIL #7005 1820 0001 9588 8671 . -------------------------------------------------------------------------------- Fees -------------------------------------------------------------------------------- CUSTODY - SEPARATE ACTION 128 . 00pd 07-12-2011 CUSTODY - CONTEMPT PETITION 75 . 00pd 09-29-2014 TRANSFER CASE TO ANOTHER CO. 50 . 00pd 12-03-20114 253 . 00 End of case print-out IIIIIIII IIIIIIII IN THECOURT OF COMMON PLEAS OF CENTRE COUNTY, PEA IIIIIIIIII IIIIIIII!IIIIIIfII I IIfIIIIIII I II0011QB6W CCGPRO 201404 CIVIL ACTION - LAW DENIS DMITRIYEV NO. 2011-2974 VS . VIKTORIYA DMITRIYEV , A M E N D E D O R D E R AND NOW, September 30, 2014, Defendant' s on to Transfer Jurisdiction is hereby GRANTED. The Centre County Prothonotary' s 0 ice is here y directed to transfer this case to the Court of Co on Pleas of C mberland County, Pennsylvania. All costs associated with the ransfer of thi matter shall be paid by the defendant . BY THE COURT Bradley P. Lunsford, Judge. rs CD C-1) o e7 ct� GJ ':- 0C1, � IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION - LAW II III IIIIIIIII _ IIIIIIIIIIIIII III I IIIlilllllllll DENIS DMI IIIIIIIII TRIYEV NO. 2011 2974 IIIIOOQ95C CC GPft02(1/409 Vs. . VIKTORIYA DMITRIYEV O R D E R AND NOW, September 30, 20 e is Petition to Transfer Jurisdiction is hereby GRANTED. The Centre County Prothon tary' s Office is he by directed to transfer this case to the Cour of Common Pleas of umberland County, Pennsylvania. BY Bradley P. Luis o d, Judge Ot ter- rJ a i n" L N • • IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PEN IIIIIIIIIII IIIIIIIIIII I _ IIIIIIIIIIIIIII IIIlilllll 1111111 CIVIL ACTION--LAW OOOOQ61Q CCGPR0201 Q4 1 )EIS iS 1 JNl I TiLi y U PLAINTIFF / NO: 9-011 - Q- An L1 DEFENDANT PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF (CUSTODY) (PARTIAL CUSTODY) (VISITATION) ORDER' 1. Petitioner's name:_ i=N iS L�iml yLu Address: Ill CrPLEAS �AD YPA 1GE111 2. Respondent's name: i Kroai Ya KA I i n Address: SOU GeNr-VA a. APT� S C � MAQAA i��S,:PA i1Ciss, 3. That onSF-P, ` 'l )0 11 Judge LLANi-,nizt, entered an Order4warding„, the(Petitioner)(Respondent), custody (partial custody)(visitation)of the minor child -_ A true and correct copy of the Order is attached to this petition. -,Z 4. Respondent has willfully failed to abide by the Order in that SHE ( ViK10(14TY�.4 i2oVR Lt LtL.1✓T (�EhsI 6 VNAU E W WFISSAo TNS L.�ECKE►JllS T'MAT Ay_e M rtv�. �t-1F WOO& its ALSO kJO-r TZssi>t)tjt�t' TO E• U Pi- Oor CALLS.1mNT Ir PXIN6, Ru0,r,. CLASTM\v 0 QTS, A Amb F�c� WHEREFORE, Petitioner requests that Respondent be held in contempt of court. (Petitioner)or(Attorney for Petitioner) $ly —9 czLI --71S.% (Phone#) 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.P.4904 relating to unsworn falsification to authorities. G-29�1N Date (Petitioner) or(Attorney for Petitioner) I:\Forms\contcustody. rm IMM MeAP CC p0 A1Zoe IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION—LAW DENNIS DMITRIYEV, Plaintiff CIVIL ACTION-LAW VS. No. 2011-2974 VIKTORYIA KRAPOVA (formerly Dmitriyev), Defendant TEMPORARY ORDER AND NOW,this ?S day of S' � 20 1'2,-after Parties reached an agreement with respect to custody and visitation, it is hereby ordered and decreed as follows: 1. Plaintiff(hereafter"Father"), or the Father's Parents, shall be responsible for the transportation of the minor child,Vanessa Dmitriyev(hereafter"Child"), for four(4) months during the Defendant's(hereafter"Mother")current pregnancy. 2. The Court shall schedule a Status Conference four(4)months from this Order. 3. During said four(4)month period of time, Mother shall take necessary measures to establish a means of transportation to transport ChiPsh 4. All other terms of the September 7, 2011in effect. c � RT: CD U W=> � a Xaz --a rx u-) x C Q z Presiding Judge W I.,J - - V 2 I:_ ' III IIII IIII III IIII III IIII IIII III IIII IIII IIII III IIII IIII OOIIOQiVH CCGPRG 201 a09 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION -LAW Plaintiff(s), ) m C/) r. V. ) No. c rT1 Defendant(s). ) - r -�> „ .z, r, co SCHEDULING REQUEST Kindly schedule the attached Petition/Motion for Hearing/Argument/Coriference before the Court. It is anticipated that the matter will require approximately minutes/hours/days for resolution. ❑ The undersigned certifies that good faith efforts were made to resolve this matter without the necessity of Court involvement. ❑ Opposing counsel/party does not oppose the relief sought, and the attached proposed Order may be signed 'without appearance. o Date Name hone E-Mail Address ORDEJR. AND NOW, this. Zcj day of A U v S upon consideration of the Petition/ tion, it is the ORDER of this Court that the hearing/argume.nt/c�,eqfe4eme is scheduled for the 3(� day of � �b�.f _ 2-0 1 L4 at 9 ; G .in ., in the Annex Courtroo Courtroom No. I -re County Courthouse AnnexlCentre County Courthouse, Bellefonte, Pennsyl ania. Judge f � �{ IIIIIIII IIIIIII IIIIIII IIIIIII IIIIIII (IIIIIIII 111111 (III • • nnGnQI PH CCGPRO 201404 IN THE COURT OP COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION - LAW } V) ��1 ) PLAINTIFF ) .c 55 vs ) NO. 7 IDE FENDANT ) PETITION \YWS- CE� 1. The Plaintiff is D1\S 1 )�Y11 \�2�� and \03 C� c�e 0UVat - Etc s(�vi n1e11 Dbga �r 2. The Defendant is l who resides at Son er12UQDrwe- , } (_' s \�C�1C� 3. On or about ��(' �l OL 4r 1 • • 1 j 5. 12\ Date ` (PIaintiff)�efe� nd (Phone#) COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CENTRE ) VERIFICATION duly swear that the facts set forth in this Petition are true and correct to the best of my knowledge. Sworn to and subscribed before me this — —day of.-4 u�_ 20 !S/. EvKM -awn w2 SPNO 1W. mail v *, g,4. I:1rORMSIPLTIT'10N.FRM III IIII (IIII II Ililllil illll 111111 IIIII 1111111 111111 000ON6D6 CCGPRO201 I IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DENIS DMITRIYEV, Civil Action-Law Plaintiff V. No: 2011-2974 VIKTORIYA KRAPOVA, (formerly DMITRIYEV) Defendant IN DIVORCE/CUSTODY ORDER ALLyOWING WITHDRAWAL AND NOW, this �1 day of �ha�Uln , 2013, after petition by Yvette L. Willson, Esquire, to withdraw as counsel for Plaintiff, Viktoriya Krapova, it is hereby ORDERED that Yvette Willson, Sharon Barney, and Justine Andronicci, Esquires, and the Centre County Women's Resource Center Civil Legal Representation Project are permitted to withdraw as Defendant's counsel in the above captioned matter. BY THE OURT: 4 Bradley P. Lunsford, Judge cr) C> r� U .� LU - Q CC CL F— =J C O C] zt C) CD ti W � � W " '4 Zr ..d E:: v • • 111111111111111111 III111111111111 IIIIIIIIIIIIII 1111111 r 8808N8Q$ CCGPROMIWI h ~�f IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DENIS DMITRIYEV, Civil Action-Law Plaintiff �7 V. No: 2011-2974 m rrt . Co � v VIKTORIYA KRAPOVA, rrno cn C".) (formerly DMITRIYEV) Defendant IN DIVORCE/CUSTODY c. -+ m4 rn rn to -< r cn PETITION TO WITHDRAW APPEARANCE AND NOW comes the Plaintiff's attorney,Yvette L. Willson, Esq., and the Centre County Women's Resource Center Civil Legal Representation Project,and respectfully files this Petition to Withdraw, averring as follow: 1. Attorney Justine Andronici, Esq., entered the appearance of the Centre County Women'.s Resource Center Civil Legal Representation Project in the above-captioned custody matter on August 3, 2011. 2. Attorney Sharon Barney most recently represented Plaintiff in a custody conference in September 2012. 3. Since that time, the Defendant has informed Attorney Barney on January 29, 2013 and February 13, 2013, that she no longer wishes for our office to represent her. 4. Since those two dates,two copies of a Consent to Withdraw was mailed to the Defendant for her signature and return. 5. Defendant has failed to sign and return either copy, despite being advised to do so. 6. In a letter dated February 19,2013,Defendant was advised of the above and informed that if she did not return the Consent to Withdraw that we would petition the Court to Withdraw as her attorney. 7. A custody conference is currently scheduled for March 27, 2013 at 1:30 and the Defendant has been notified of this by telephone and by mail by sending the Scheduling Order along with a letter to Plaintiff on February 19, 2013. 8. Attorney Willson attempted to contact Defendant by telephone yesterday at both of her numbers; however, there was no answer at either and no way to leave a message. 9. Opposing counsel does not object to the relief sought. 10. Good cause for withdrawal exists under Rule 1.6 of the Pennsylvania Rules of Professional Conduct. Attorney Willson is unable to provide adequate representation to the Defendant because the Defendant is no longer cooperating with her as counsel. WHEREFORE,Attorney Willson and the Centre County Women's Resource Center Civil Legal Representation Project respectfully request this honorable court issue an order granting her permission to withdraw as Defendant's Viktoriya Krapova's counsel in the above-captioned matter. Centre County Women's Resource Center Civil Legal Representation Project Respectfully submitted, Date: 6 l?:> "vetteL. n, Esq. ndant Centre County Women's Resource Center Civil Legal Representation Project 116 S. Allegheny St. 3rd Floor Bellefonte, PA 16823 PA Id.No. 202691 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DENIS DMITRIYEV, Civil Action-Law Plaintiff V. No: 2011-2974 VIKTORIYA KRAPOVA, (formerly DMITRIYEV) Defendant IN DIVORCE/CUSTODY CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the Petition to Withdraw Appearance filed in the above-captioned matter was properly served by sending through the U.S. Postal Service'via'' C') -a a 3 r rn :vrn My first class mail or via Courthouse mailbox, addressed as follows: ca a M -n Viktoriya Krapova, Defendant z - (address kept confidential) C_ < � co Dan Palchik, Esquire r� c) MidPenn Legal Services Ln 3500 E. College Ave., #1295 State College, PA 16801 (814) 238-4958 Centre County Women's Resource Center Civil Legal Representation Project Date: BY: Pomevy Willson, Esquire for Defendant 116 S. Allegheny St. 3`d Floor Bellefonte, PA 16823 (814) 355-0301 PA I.D. 202691 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DENIS DMITRIYEV, Civil Action-Law Plaintiff V. No: 2011-2974 VIKTORIYA KRAPOVA, (formerly DMITRIYEV) : Defendant IN DIVORCE/CUSTODY RULE TO SHOW CAUSE-PETITION TO WITHDRAW APPEARANCE AND NOW, this day of , 2013, upon consideration of the attached Petition to Withdraw Appearance, the Court grants a rule to show cause why the appearance of Yvette Willson, Sharon Barney,and Justine Andronicci, Esquires, and the Centre County Women's Resource Center Civil Legal Representation Project on behalf of Defendant, Viktoriya Krapova, should not be allowed to be withdrawn. Rule returnable on , 2013 at—_.m. in Judge Lunsford's Chambers/Courtroom Annex , Centre County Courthouse, Bellefonte, PA. Bradley P. Lunsford, Judge _0000N]VS CCGPRO 201301 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DENNIS DMITRIYEV ) Plaintiff, ) vs. ) No. 201.1-2974 rR9 VIKTORYA KRAPOVA (formerly Dmitriyev) ) ` �C:) - Defendant, ) =©, rn a C) �C) 4b: rn ORDER <70tr � AND NOW, this 13th day of February, 2013 , as per the Temporary Order dated September 25, 2012, a Status Conference is hereby scheduled for Custody Court on Wednesday, March 27,2013 beginning at 1:30 p.m. in COURTROOM NO. 1, Centre County Courthouse, Bellefonte, Pennsylvania. fTH T: Judge Bradley P. Lunsford Laura Robbins, Esquire Sharon Barney, Esquire s �Illil IIIIIIiII IIIIIIiIII IIIIIIIlI illiiliil! 1111111 0000MEAP CCGPRO 20209 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION—LAW DENNIS DMITRIYEV, Plaintiff CIVIL ACTION.-LAW vs. No. 2011-2974 VIKTORYIA KRAPOVA (formerly Dmitriyev), Defendant TEMPORARY ORDER AND NOW,this o�5 day of .Se t 20 after Parties reached an agreement with respect to custody and visitation, it is hereby ordered and decreed as follows: 1. Plaintiff(hereafter"Father"), or the Father's Parents, shall be responsible for the transportation of the minor child,Vanessa Dmitriyev(hereafter"Child"), for four(4)months during the Defendant's(hereafter"Mother")current pregnancy. 2. The Court shall schedule a Status Conference four(4)months from this Order. 3. During said four(4)month period of time,Mother shall take necessary measures to establish a means of transportation to transport Chil 4. All other terms of the September 7, 2011 raremaeffect. cv <t © w U �tr y= �f�--x OLn UOv 0 0- ct � Presiding Judge W co') M=�— �4 x N � • � 111111 III IIII III I III II III IIII (IIII II IIII III III IIII II 0000MBZN CCGPR02012p) IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION—LAW DENIS DMITRIYEV, ) Plaintiff, ) No. 2011-2974 VS. ) z 0 m � qc, v C=o C3 c, VIKTORYIA KRAPOVA, ) IN DIVORCE%M 01� (formerly DMITRIYEV), ) oil -° Defendant. ) CD3 -0 :< r3n o CONTINUANCE REQUEST D a C cn. X I, Sharon Barney, Esquire of the Centre County Women's Resource Center Civil Legal Representation Project, represent the Defendant in the above-referenced action. A civil contempt hearing is scheduled for the 31s' day of August, 2012 at 3:00 p.m.in which we are requesting a CONTINUANCE for the following reason: Plaintiff served the Petition for Civil Contempt on Defendant at the wrong address. Therefore, Defendant did not receive notice of the hearing until August 23, 2012. Defendant notified Attorney Barney, who was no longer attorney of record, on August 24, 2012. Attorney Barney requests more time to gather information and prepare for the civil contempt hearing. _ Opposing party does not object to the above request. X Please do not schedule the above conference for the following dates as opposing counsel or myself are unavailable: 9/4/12 afternoon, 9/7/12, 9/11/12 morning, 9/13/12 afternoon, 9/1.7/12 morning. g�27�iZ Date Sharon Barney, Eiqttire 814 355-0301 _sbarney(@ccwrc.org Telephone E-Mail Address ORDER AND NOW, this ZI day of20) he above eferenced matter is being RESCHEDULED to , 206Z, !,30 . ./gm. i Annex at Centre County Courthouse Annex, Bellefonte, Pennsylvania. THE OURT: IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION–LAW DENIS DMITRIYEV, ) Plaintiff, ) No. 2011-2974 VS. ) VIKTORYIA KRAPOVA, ) (formerly DMITRIYEV), ) IN DIVORCE/CUSTODY Defendant. ) CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the Continuance Request filed in the above- captioned matter was properly served by sending through the U.S. Postal Service via first class mail, addressed as follows: Denis Dmitriyev 103 Gwenedd Ct. Pleasant Gap, PA 16823 Centre County Women's Resource Center Civil Legal Representation Project Date: 7 '2 BY: Sharon—Barney' Esire Attorney for Defen 116 S. Allegheny St. 3rd Floor Bellefonte, PA 16823 (814) 355-0301 sbarney@ccwrc.org P.A I.D. 311883 n o _U , , F Co SSD IV CSD CD C') "0 ,C C "C5�<r— t� �1 !� � IIIIII (IIIIIIIIII IIIIIIIIII IIIIIIIIII _IIIIIIIIII IIIIIIII OOOUM9TA 'OOGPRO IOIZ07 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION—LAW DENIS DMITRIYEV, ) Plaintiff, ) No. 2011-2974 VS. ) I ) VIKTORIYA KRAPOVA , ) (formerly DMITRIYEV), ) Type of Case: Defendant. ) DIVORCE/CUSTODY Type of Pleading: Praecipe for Entry of Appearance Filed on Behalf of: Viktoriya Krapova Counsel of Record: Sharon Barney, Esq. 116 S. Allegheny St. 3`d Floor Bellefonte, PA 16823 (814) 355-0301 sbarney@ccwrc.org PA I.D. 311883 CD r--- M i"T1 Go rn� �s D C CD =o.- o CD tv i ' i • IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION—LAW DENIS DMITRIYEV, ) Plaintiff, No. 2011-2974 VS. ) VIKTORIYA KRAPOVA, ) (formerly DMITRIYEV), ) IN DIVORCE/CUSTODY Defendant. ) CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the Praecipe for Entry of Appearance filed in the above-captioned matter was mailed by U.S. Postal Service via first-class mail, addressed as follows: Denis Dmitriyev 103 Gwenedd Ct. M Pleasant Gap, PA 16823 no. M r, C3 Z i -^J � C=C.?_ --+v T7 rh :< On rs Centre County Women's Resource n ter ca Civil Legal Representation Project Date: Z-7 2 BY: Sharon Barney, Esq re Attorney for Defendan 116 S. Allegheny St. 3`d Floor Bellefonte, PA 16823 (814)355-0301 sbarney@ccwrc.org PA I.D. 311883 4 IN THE COURT#OMMON PLEAS OF CENTRE COUN*PEr v CIVIL ACTION--LAW IIIIII II kill 11111 IIIII IIII IIII IIII III py)T4 V 1 / J 0000M7M6 CCGPRO 201207 M�i-21'y,Ey PLAINTIFF VaTola NO: Y _ D/ A4'T7-p--rvc- y DEFENDANT NOTICE AND ORDER TO APPEAR LEGAL PROCEEDINGS HAVE BEEN BROUGHT AGAINST YOU ALLEGING YOU HAVE WILLFULLY DISOBEYED AN ORDER OF COURT FOR(CUSTODY)(PARTIAL CUSTODY) (VISITATION). IF YOU WISH TO DEFEND AGAINST THE CLAIM SET FORTH IN THE FOLLOWING PAGES, YOU MAY BUT ARE NOT REQUIRED TO FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS. WHETHER OR NOT YOU FILE IN WRITING WITH THE COURT YOU6 DEFENSES OR OBJECTIONS, YOU MUST APPEAR IN PERSO IN COURT ONZ-61 Z, AT '. _IN COURTROOM IF YOU DO NOT APPEAR IN PERSON, THE COURT MAY ISSUE A WARRANT FOR YOUR ARREST. IF THE COURT FINDS THAT YOU HAVE WILFULLY FAILED TO COMPLY WITH ITS ORDER FOR(CUSTODY)(PARTIAL CUSTODY)(VISITATION), YOU MAY BE FOUND TO BE IN CONTEMPT OF COURT AND COMMITTED TO JAIL, FINED OR BOTH. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. :i -Ti -+ rr1 � � O COURT ADMINIST TOR ,-,o CENTRE COUNTY CO THOUS 102 SOUTH ALLEGHE STREErri BELLEFONTE, PA 16823 rn h (814)355-67 Dir- C) r d Date Judge INT • ' HE COURT OF COMMON PLEAS OF CENTRE COUNTY PEP I 1111111 111111 111111 CN 111111 ILA __ IIIIII� ACTION 1111111 N 11111 LA 61111 W 11111 ;� 1,r 000UM41C CCGPRO I0f2p5 PLAINTIFF NO: 9011 Ll Vrkro r ve Nd r7-ZX YE L/ DEFENDANT o ti +-= PETITION FOR CIVIL CONTEMPT FOR DISOBEDW&CE o OF(CUSTODY) (PARTIAL CUSTODY) (VISITATI456"DW � 0 1. Petitioner's name: rn Address: F �LF-ASR �,� �A 2. Respondent's name: 'D Address: JAN J E (. 4PE �'A�� SLS ?4 3. That on 11-20 r1 Judge the(Petitioner)(Res ondent the an Order Awarding P ), (custody)(partial custody)(visitation)of the minor child (ren). K Z Y DMr-1JxyrV XS M Or r1u T(JC THE CM TL U4 1 L MD rL4JONT I mss�INrr-2 yV/ 7�-1E EC A true and correct copy of the Order is attached to this petition. 4. Respondent has willfully failed to abide b the Order in that V.r K.tO k-r Wrt� TNS oR1�i=Z. rcrr� %s oY- Co/MPlT1=u� CTTaN F S�GTLO Alt 6 ��, 1 S Gt`TmL) 11 0. WHEREFORE, Petitioner requests that Respondent be held in contempt of court. etiti ner)or(Attorney for Petitioner) L ��' (Phone#) 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.P.4904 relating to unsworn falsification to authorities. Date (Petitio'9.' or(Attorney for Petitioner) IAForms\contcustody,frm J< �w ^Omlloe IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION—LAW DENIS DIMITRIYEV, Plaintiff * CIVIL ACTION LAW VS. * NO. 2011-2974 VIKTORIYE DIMITRIYEV, Defendant .J ORDER 'T� 1 AND NOW, this day of e,/-- ,2011, after conference with the parties, it is hereby ordered and decreed as follows: 1. Plaintiff(hereafter"Father") and Defendant(hereafter"Mother") shall share legal custody of their minor child, Vanessa Dmitriyev, born June 21, 2009. 2. Mother shall have primary physical custody of the minor child, subject to Father's partial physical custody rights, as set forth below: A. During the time Mother resides in Centre County, Pennsylvania, Father shall have every other weekend from Friday 6:00 P.M. until Sunday 6:00 P.M. Father shall also have partial physical custody of the child each Tuesday and Thursday from 5:00 P.M. until 8:00 P.M.,while Mother resides in Centre County, B. Mother and Father agree that Mother is permitted to move with the minor child to the Harrisburg, Pennsylvania area. C. When Mother begins resid;..g in the Harrisburg, Pennsylvania area, Father shall be entitled to the following regular periods of partial physical custody: 4 I. Father shall be entitled to the second, fourth and fifth(when there are five weekends in one month) weekend of each month with the minor child, from Friday 6:00 P.M. until Sunday 6:00 P.M. II. Father shall also be entitled to a four-hour period of partial physical custody with the minor child one day each week, sometime between Monday and Friday, provided Father gives Mother 48 hours' advance notice of when he wishes to exercise this period of partial physical custody. III. Mother and Father agree that all exchanges shall occur at a halfway point between State College and Harrisburg, once Mother moves to the Harrisburg, Pennsylvania area, except that for weekday visits outlined in 2.A.II. above, Father shall be responsible for all transportation. D. Mother and Father shall alternate the Thanksgiving holiday. For all odd- numbered years, Father shall be entitled to have the minor child from 6:00 P.M. the Wednesday immediately before Thanksgiving Day until the following Sunday at 6:00 P.M. Mother shall be entitled to physical custody of the minor child according to this schedule on all even-numbered years. E. Mother and Father shall alternate the Christmas holiday. For purposes of this Order, Christmas holiday is defined as from December 23`d until January 2"d of each year. For all odd-numbered years, Mother shall be entitled to have the minor child from 6:00 P.M. December 23`d until 12:00 P.M. December 26` . Father shall be entitled to have the remainder of the Christmas holiday until January 2nd during all odd-numbered years. In all even-numbered years, this schedule shall be switched between Mother and Father. F. Father shall be entitled to have the minor child for three additional one-week periods of physical custody of the minor child each year. One of these weeks shall occur in the spring season, one shall occur in the month of July, and one shall occur in August. For the spring of 2012,Mother and Father agree that Father can take this one-week vacation sometime in late April or early May, to facilitate Father's vacation to Florida. G. On the minor child's birthday,the parent out of custody shall be entitled to five (5)hours of physical custody, which the non-custodial parent providing all transportation to facilitate this period of physical custody. H. For the Easter holiday, Mother shall, in even-numbered years, be entitled to have the minor child from Saturday at 6:00 P.M. the night before Easter until Easter Monday at 6:00 P.M. Father shall be entitled to this period of physical custody in all odd-numbered years. 4. Mother and Father agree that Father may have further custodial periods with the minor child as is mutually agreeable between the parties. 5. Mother and Father agree that all periods of physical custody during holidays and special occasions shall supersede Mother's and Father's regular periods of physical custody. 6. Access to Records: Both parents shall have full access to all relevant medical, dental, psychological, educational, or religious records. Each parent may obtain such records directly from the provider without the other parent's consent. Parents shall provide each other with any records not easily obtainable by the other parent. Any school district which the Child attends shall provide both parents identical information. 7. Decision-Makin-: Both parents shall use their best efforts to engage in joint decision- making with respect to the Child. Parents shall consults with each other concerning major health decisions, transfer of schools, changes in school curriculum,participation in extra-curricular school activities, participation in non-school lessons or structured non-school activities or organizations,participation in summer camps,and similar activities. If the parents are unable to reach an agreement,they shall exchange written proposals, including explanations of their positions, after which they shall meet and discuss their positions in person. If they still cannot resolve their differences, the Court will, upon written request, schedule a hearing. 8. Maior Events: Both parents shall be notified of and invited to major events in the child's life, including, but not limited to, graduations, awards presentations,performances by the child, and similar extra-curricular activities. The custodial parent has a special obligation to assure such notice. 9. Illness,Accidents, and other Emergencies: Each parent shall promptly notify the other of any serious accident or illness or any legal or educational emergency involving the child. If the child is hospitalized,both parents and step-parents and/or any grandparents may visit with the child regardless of any custody schedule. If the child is taking medication,that medication or a prescription for the medication shall be made available to each parent. The non-custodial parent shall be provided copies of medical assistance and insurance documents. 10. Telephone Contact: The parent out of custody shall be entitled to reasonable telephone contact with the child. Such telephone contact shall not be monitored by or interrupted by the custodial parent. In the event of long distance calls,the parents shall agree on specific times when the child will be available to receive calls, and the custodial parent shall be responsible for assuring the child's presence at the telephone. 11. No conflict zone: A. The parents shall establish a no-conflict zone for their child and refrain from making derogatory comments about the other parent in the presence of their child and to the extent possible, shall not permit third parties from making such comments in the presence of their child while in their physical custody, whether they are sleeping, awake, or in another room. B. The parents shall not alienate the affections of their child from the other parent and the other parent's extended family and shall make a special conscious effort not to do so and to the extent that is possible prevent third parties from alienating the child's affections from the other parent as well as the other parent's extended family. C. Each parent shall speak respectfully of the other whether it is believed the other reciprocates or not. Each parental figure shall refer to the other by the appropriate role name such as Mom, Dad, Grandma, etc. D. Each parent shall refrain from encouraging their child to provide reports about the other parent. Communication should always tak lace directly between parents,never using the children as an intermediary. TH COURT: J. II IIIII III Ii 111 l 111111 l II I IIIII Ili II IIIII II IIII OOOOMOLM CCGPRO 201205 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DENIS DMITRIYEV, Civil Action-Law , C Plaintiff t V. No: 2011-2974 ` �� •7) do VIKTORIYA DMITRIYEV, Defendant IN DIVORCE o-�r - " c cv CONSENT TO WITHDRAW I, Viktoriya Dmitriyev, hereby consent to Sharon Barney,Esq. of Centre County Women's Resource Center Civil Legal Representation Project, withdrawing as my attorney of record in the above-captioned matter. Date: o r\v a �b� Q Viktoriya Dmitriyev PRAECIPE TO WITHDRAW Please withdraw the appearance of Sharon Barney,Esq.as counsel for Defendant,Viktoriya Dmitriyev, in the above-captioned action. Respectfully submitted, Date:(D6 VI-KAM3du a K tKW x- Sharon Barney, Esq. Centre County Women's Resource Center Civil Legal Representation Project 116 S. Allegheny St. 3rd Floor Bellefonte, PA 16823 PA Id. No. 311883 • illlllillllllll Ilililllllllllll II IIIIIIIIIiIiI IIIIIIIII OOOOMOLF OOGPRO 201205 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL DIVISION DENIS DMITRIYEV, Plaintiff NO. 2011-2974 C:)co c VS. «- " c o 00 VIKTORIYA DMITRIYEV, IN DIVORCE z� c� M Defendant : ,�� xC i' W_ C_j NOTICE OF ELECTION TO RESUME PRIOR NAME 4; TO THE PROTHONOTARY: Pursuant to 54 Pa.C.S.A. §704, I, Viktoriya Dmitriyev, Defendant in the above-titled case in which a Decree in Divorce was entered on February 27, 2012, do hereby elect to resume my prior name of Viktoriya Krapova. Date:-%I ! Viktoriya Dmitriyev, Defendant COMMONWEALTH OF PENNSYLVANIA COUNTY OFC olberla.nd AND NOW, this 12 day of 4./u- ne , 2012, before me, a Notary Public in and for said County and State, personally appeared the above-named Viktoriya Dmitriyev and acknowledged the foregoing written notice of intention to resume her prior name of Viktoriya Krapova to be her act and deed, to the end that it may be recorded as such. Notary Public hca'n Aviv W*113 mtt�o 41 AtRf1 3 ONVlu go"0 Al lqMWMX A"313A '1119s 1riuV1�1 T - _ IIII VIII (IIIIII IIIIIIIIIII IIIIIIIIIII IIIIIIII I OOOOLVAZ CCGPRO 201203 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DENIS DMITRIYEV, Plaintiff, No. 2011-2974 VS. VIKTORIYA DMITRIYEV, ; IN DIVORCE Defendant. ORDER AND NOW, this / day of , 2012, upon consideration of the Petition of Defendant to Proceed In Forma auperis, it is hereby ORDERED and DECREED that Viktoriya Dmitriyev, Petitioner, may file the Notice of Election to Resume Prior Name in forma pauperis and proceed without payment of filing fees or o ts., Prothonotary CD cv b C) Uj �z bf c:)=, c7 C3 CD _' M C) c �( IIIIII VIII IIII VIII IIII VIII Ilill IIII II II IIII II III III IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA 3 CIVIL ACTION - LAW DENIS DMITRIYEV, Plaintiff, No. 2011-2974 VS. VIKTORIYA DMITRIYEV, IN DIVORCE Defendant. PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Petitioner, Viktoriya Dmitriyev, to proceed in forma pauperis on her Notice of Election to Resume Prior Name. I, Sharon Barney, Esq., attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal service to the party. Respectfully submitted, Centre County Women's Resource Center Civil Legal Representation Project N C) LQ� =>: BY: <j Sharon Barney, Esquire _C Attorney for Defendant a c-=, 116 S. Allegheny St. m= � rd Floor Cl- Bellefonte, PA 16823 H ' (814) 355-0301 sbarney@ccwrc.org PA ID: 311883 II II III III III III II III II III II III III III III II III IIII II II II 0 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CCGPRO 7p17pp CIVIL ACTION-LAW DENIS DMITRIYEV, Civil Action-Law Plaintiff V. No: 2011-2974 VIKTORIYA DMITRIYEV, Defendant IN DIVORCE CONSENT TO WITHDRAW I, Viktoriya Dmitriyev, hereby consent to Justine F. Andronici, Esq. of Centre County Women's Resource Center Civil Legal Representation Project,withdrawing as my attorney of record in the above-captioned matter. Date: ©' / Vikt iya m5riyew__-7n rn Q Co :3-1 rri CD PRAECIPE TO WITHDRAW =o -° F � Please withdraw the appearance of Justine F. Andronici, Esq. As o nse tcfc)b r Dendant, Viktoriya Dmitriyev, in the above-captioned action. Respectfully submitted, Date: Ji" tine F. Andronici, Esq. Centre County Women's Resource Center Civil Legal Representation Project 116 S. Allegheny St. 3rd Floor Bellefonte, PA 16823 PA Id. No. 304841 Ill�lllll�ll � � W001-GG2 CCGPRq 201101 DENIS DIMITRIYEV IN THE COURT OF COMMON PLEAS Plaintiff OF CENTRE COUNTY vs 2011-2974 F VIKTORIYE DIMITRIYEV o Defendant N O C-) co ::V -Q— DECREE IN DIVORCE --4 n � 0M � o C:) ;;0 cr- AND NOW, this�1 day of FeA ry 2012, it appears to the Court as follows: 1. Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 7/7/11 alleging that the marriage between the;parties hereto is irretrievably broken; 2. Ninety days have elapsed from the date of service of said Complaint, and 3. Each party has filed an affidavit evidencing that they both consent to a divorce. Therefore, it is hereby ORDERED, ADJUDGED AND DECREED that a divorce from the bonds of matrimony is granted to: DENIS DIMITRIYEV FROM VIKTORIYE DIMITRIYEV The attached agreement between the parties dated, September 7, 2011, is entered and incorporated as a part of the Decree in Div'`-oorce. y the ourt, J Attest: PROTHONOTARY IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL DIVISION IIIIifI IIIIIII IIIIIIII IIIIIIII! IIIIIIII I DENIS MITRIY D IIIIIII IIli! EV IIII OOOOLDTP CCGGRRO21201 Plaintiff, NO. 2011-2974 VS. VIKTORIYA DMITRIYEV, IN DIVORCE Defendant. PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: A Complaint in Divorce was mailed to Defendant on July 7, 2011 by first-class mail with the United States Postal Service. Defendant accepted service on October 22, 2011. 3. Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by Plaintiff February 3, 2012; by Defendant February 14, 2012. 4. Related claims pending: none. 5. Date Plaintiff's Waiver of Notice in §3301(c)Divorce was filed with the Prothonotary: February 22, 2012. 6. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: February 22, 2012. Cn r- �Q rn 0 n Iv �t CD— � o cow � f V • • Centre County Women's Resource Center Civil Legal Representation Project DATE: V22- t2-- BY: Sharon Barney, Esquir Attorney for Plaintiff 116 S. Allegheny St. 3d Floor Bellefonte, PA 16823 (814) 355-0301 sbarney@ccwrc.org PA I.D. 311883 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL DIVISION DENIS DMITRIYEV, IIIIIIIIIIIIIIIIIIIIII IIII IIIIIIIIII�IIII I IIIIII�I�II I I Plaintiff, : NO. 2011-2974 0000LDT5 CCGPR0201201 VS. VIKTORIYA DMITRIYEV, IN DIVORCE Defendant. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on July 7, 2011. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and serving the Complaint. 3. I consent to the entry of a final decree of divorce after service of Notice of Intention to Request Entry of the Decree. I verify that the statements made in this affidavit 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. Date:-Q 1'01 Vikt a Dmit yev a,ra M CD c -n N p CD C-) N 7:0 mUJ w 7 co IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL DIVISION DENIS DMITRIYEV, Plaintiff, NO. 2011-2974 VS. VIKTORIYA DMITRIYEV, IN DIVORCE Defendant. , WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filled with the Prothonotary. I verify that the statements made in this affidavit 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. Date: D �/ -70 /- Vikto ' Dmi r v C7 c� _ N) C7 M E'rl Grt-Tl W CD UJ co IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL DIVISION DENIS DMITRIYEV, III IIII II IIII IIII III III III III III III IIII III W SII W III LDT III 1 III Plaintiff, NO. 2011-2974 -GPR020"' VS. VIKTORIYA DMITRIYEV, IN DIVORCE Defendant. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on July 7, 2011. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and serving the Complaint. 3. 1 consent to the entry of a final decree of divorce after service of Notice of Intention to Request Entry of the Decree. I verify that the statements made in this affidavit 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. Date: _3 Denis itriyev .- C� �:QEri (T O O .`li. C-)p N p CzC?. M ` 1 lJ! a IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL DIVISION DENIS DMITRIYEV, Plaintiff, NO. 2011-2974 VS. VIKTORIYA DMITRIYEV, IN DIVORCE Defendant. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filled with the Prothonotary. I verify that the statements made in this affidavit 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. Date: 02-3-oZoia- D�e 's Dmitriyev crzl r� M C:)w rn C7 > m CSO N O v n N 70 � y 7 70 UJ co m 1' NNSTATE N outreach � N N r - N 6 � COntinuingEducatioll4141 co Cn Penn State Justice and Safety Institute w under contract with The Commonwealth of Penns lv y anis, °° Centre County Court of Common Pleas this certifies that Denis Dmitri ev case# 2011.-2898 -moi has completed EDUCATION PROGRAM FOR -1-0 �o1l-a�7y m FOR SEPARATES PARENT - p S consisting of a D Four-Hour Mandated Seminar on January 11, 2012ME University Park,Pennsylvania -= �e o=_ Vice Presides for Outreach — �I D 51metor,lenni fer A.Mastrofski,ph_), M CD Ln I �'rNNSTAT N m Outreach N N N Ln N Continuing Educatio 42,OD Penn State Justice and SafetyW o • W Institute, co `'' under contract with The Commonwealth of PennsylvaniaCm C CC Centre County Court of Common Pleas L� - C U_ L, this certifies thatC Viktori a Dwitri ev // C Case # -4 EDUCATION PROGRAM completed -"5F1'g. -n 4011-;41tf m PROGRAM FOR SEPARATED PARENTS e consisting of a • D Four-Hour Mandated Seminar m 'n�� on January 11, 2012 r University Park Pen�ylvania _=—�- -- 0 o=— Vice President for Outreach �r ttucWr,Jennifer A.Maa�rafaki,phi m . m m � I I ILII IIIIII� ` IIII IIIIIiI II VIII IIIIII IIIIII VIII I 01109KT40 CCGPft0207109 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff ) DIVORCE ) VS > �S� � a-06�•a-4'7�i Def— a nt ) ,v a SCD- �v� � — ACCEPTANCE OF SERVICE <T `" I hereby accept service of a copy of the Complaint in Divorce filed in the above captioned matter. Defendant z(�:T (� Date RETURN TO:. Centre County Prothonotary Centre County Courthouse Bellefonte,PA 16823 (WP/I:Accsry-c) �► � l������i�Id III�I I��iI I�I�i�l�li��11�llll����Il llll li�l -000II IiTN'U CCGPRO M1109 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff ) VS ) NO. ) L/r k-1�vi2Tk//y DO-4 T 7-a-TYZ' ) Defendant ) PRAECIPE TO REINSTATE Please reinstate the above captioned matter. Plaintif Date RETURN TO: CZ) `''' �'-' >= Centre County Prothonotary n 1¢, Centre County Courthouse co U m c-, Bellefonte,PA 16823 C o C-.) Gl C-a rnO LIJ W t cam-i (WP/hprae-rei) � • IIIIIIIIIIIIIIIIIIIIIIIIIIIII IIIIVIIIVIIIiIII 0000KLLH CCCPRO M106 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION—LAW DENIS DIMITRIYEV, Plaintiff * CIVIL ACTION - LAW * vs. * NO. 2011-2974 VIKTORIYE DIMITRIYEV, Defendant CD ORDER f9 AND NOW, this day of � �� �' , 2011, after conference with the parties, it is hereby ordered and decreed as follows: 1. Plaintiff(hereafter"Father") and Defendant(hereafter"Mother") shall share legal custody of their minor child, Vanessa Dmitriyev, born June 21, 2009. 2. Mother shall have primary physical custody of the minor child, subject to Father's partial physical custody rights, as set forth below: A. During the time Mother resides in Centre County, Pennsylvania, Father shall have every other weekend from Friday 6:00 P.M. until Sunday 6:00 P.M. Father shall also have partial physical custody of the child each Tuesday and Thursday from 5:00 P.M. until 8:00 P.M., while Mother resides in Centre County. B. Mother and Father agree that Mother is permitted to move with the minor child to the Harrisburg, Pennsylvania area. C. When Mother begins resid;:Lg in the Harrisburg, Pennsylvania area, Father shall be entitled to the following regular periods of partial physical custody: I. Father shall be entitled to the second, fourth and fifth (when there are five weekends in one month) weekend of each month with the minor child, from Friday 6:00 P.M. until Sunday 6:00 P.M. II. Father shall also be entitled to a four-hour period of partial physical custody with the minor child one day each week, sometime between Monday and Friday, provided Father gives Mother 48 hours' advance notice of when he wishes to exercise this period of partial physical custody. III. Mother and Father agree that all exchanges shall occur at a halfway point between State College and Harrisburg, once Mother moves to the Harrisburg, Pennsylvania area, except that for weekday visits outlined in 2.A.II. above, Father shall be responsible for all transportation. D. Mother and Father shall alternate the Thanksgiving holiday. For all odd- numbered years, Father shall be entitled to have the minor child from 6:00 P.M. the Wednesday immediately before Thanksgiving Day until the following Sunday at 6:00 P.M. Mother shall be entitled to physical custody of the minor child according to this schedule on all even-numbered years. E. Mother and Father shall alternate the Christmas holiday. For purposes of this Order, Christmas holiday is defined as from December 23rd until January 2nd of each year. For all odd-numbered years, Mother shall be entitled to have the minor child from 6:00 P.M. December 23rd until 12:00 P.M. December 26`h. Father shall be entitled to have the remainder of the Christmas holiday until January 2nd during all odd-numbered years. In all even-numbered years, this schedule shall be switched between Mother and Father. F. Father shall be entitled to have the minor child for three additional one-week periods of physical custody of the minor child each year. One of these weeks shall occur in the spring season, one shall occur in the month of July, and one shall occur in August. For the spring of 2012, Mother and Father agree that Father can take this one-week vacation sometime in late April or early May, to facilitate Father's vacation to Florida. G. On the minor child's birthday, the parent out of custody shall be entitled to five (5)hours of physical custody, which the non-custodial parent providing all transportation to facilitate this period of physical custody. H. For the Easter holiday, Mother shall, in even-numbered years, be entitled to have the minor child from Saturday at 6:00 P.M. the night before Easter until Easter Monday at 6:00 P.M. Father shall be entitled to this period of physical custody in all odd-numbered years. 4. Mother and Father agree that Father may have further custodial periods with the minor child as is mutually agreeable between the parties. 5. Mother and Father agree that all periods of physical custody during holidays and special occasions shall supersede Mother's and Father's regular periods of physical custody. 6. Access to Records: Both parents shall have full access to all relevant medical, dental, psychological, educational, or religious records. Each parent may obtain such records directly from the provider without the other parent's consent. Parents shall provide each other with any records not easily obtainable by the other parent. Any school district which the Child attends shall provide both parents identical information. 7. Decision-Makin : Both parents shall use their best efforts to engage in joint decision- making with respect to the Child. Parents shall consults with each other concerning major health decisions, transfer of schools, changes in school curriculum,participation in extra-curricular school activities,participation in non-school lessons or structured non-school activities or organizations, participation in summer camps, and similar activities. If the parents are unable to reach an agreement, they shall exchange written proposals, including explanations of their positions, after which they shall meet and discuss their positions in person. If they still cannot resolve their differences, the Court will, upon written request, schedule a hearing. 8. Major Events: Both parents shall be notified of and invited to major events in the child's life, including, but not limited to, graduations, awards presentations, performances by the child, and similar extra-curricular activities. The custodial parent has a special obligation to assure such notice. 9. Illness Accidents and other Emergencies: Each parent shall promptly notify the other of any serious accident or illness or any legal or educational emergency involving the child. If the child is hospitalized, both parents and step-parents and/or any grandparents may visit with the child regardless of any custody schedule. If the child is taking medication, that medication or a prescription for the medication shall be made available to each parent. The non-custodial parent shall be provided copies of medical assistance and insurance documents. 10. Telephone Contact: The parent out of custody shall be entitled to reasonable telephone contact with the child. Such telephone contact shall not be monitored by or interrupted by the custodial parent. In the event of long distance calls, the parents shall agree on specific s times when the child will be available to receive calls, and the custodial parent shall be responsible for assuring the child's presence at the telephone. 11. No conflict zone: A. The parents shall establish a no-conflict zone for their child and refrain from making derogatory comments about the other parent in the presence of their child and to the extent possible, shall not permit third parties from making such comments in the presence of their child while in their physical custody, whether they are sleeping, awake, or in another room. B. The parents shall not alienate the affections of their child from the other parent and the other parent's extended family and shall make a special conscious effort not to do so and to the extent that is possible prevent third parties from alienating the child's affections from the other parent as well as the other parent's extended family. C. Each parent shall speak respectfully of the other whether it is believed the other reciprocates or not. Each parental figure shall refer to the other by the appropriate role name such as Mom, Dad, Grandma, etc. D. Each parent shall refrain from encouraging their child to provide reports about the other parent. Communication should always tak lace directly between parents, never using the children as an intermediary. Y TH COURT: J. III I II II II II II it II I I I II I I I ,If OOOOKHB6 CCGPRO 20f 106 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION-LAW PLAINTIFF J011 VS s . ;011-Aggq N T, D! +FENDANT o D CD C)CD n ro :;0 OZ• - ORDER OF COURT z v 0 -� .r-' o You, t C tU ��y�t-�(�, ,t� , have been sued in Court to obtain (C4�tddy)(Pai:tial Custody) (Visitation)of �,�u kN You are ordered to appear in person at ) (Judge �V h S (C S Chambers) in rn��C the Centre County Courthous ABe lefonte,Pennsylvania, on the.31 day of G , 20J, at 11 .06 n.n -o'clock for a (hearing) (conference). If you fail to appear as provided by this Court Order,an Order for Custody may be entered against you or the Court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. ) IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. COURT ADMINISTRATOR CENTRE COUNTY COURTHO E 102 SOUTH ALLEGHENY ST EE BELLEFONTE,PA 168 (814)355-6727 G � _ Date J. CG , Der,iS \I 0br� Cj Om'' fr'' e�'n 1 _ J• I_ Ll 1 � / iIIIIIIIII I IIIIIillll IIIIIIII I I II II IIIIIIIIII 1NIODKH87 GCGPR0201108 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DENIS DIMITRIYEV ) Plaintiff ) V. ) No. 2011-2974 VIKTORIYE DIMITRIYEV ) DIVORCE/CUSTODY Defendant -3 rnv CD DENIS DMITRIYEV ) A o Plaintiff V. ) No. 2011-2898 '' 'y VIKTORIYA DMITRIYEV ) CUSTODY Defendant ) ORDER AND NOW, this Bch day of August, 2011 ,the above referenced cases, Docket Number 2011-2974 and Docket Number 2011-2898 are hereby CONSOLIDATED. Any filings under Docket Number 2011-2898 will be applied to Docket Number 2011-2974. BY T E COURT: Bradley P. Lunsford, Judge Laura Robbins, Esquire Denis Dmitriyev (Plaintiff filed Complaint for Custody Pre-Se) Justine Andronici, Esquire Viktoriya Dmitriyev • • II II III II III II IIII II II II II II II II I II III II II I II I II III II II cccvRo 201 10a IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DENIS DIMITRIYEV Plaintiff, NO. 2011-2974 VS. VIKTORIYE DIMITRIYEV, IN CUSTODY Defendant. PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY OF SAID COURT: Please enter my appearance on behalf of Viktoriye Dimitriyev, Defendant, in the above- captioned matter. Respectfully submitted: Centre County Women's Resource Center Civil Legal Representation Project BY: us ine F. Andronici, Esquire Attorney for Plaintiff 116 S. Allegheny St. 3`d Floor Bellefonte, PA 16823 (814) 355-0301 jandronici@ccwrc.org DATE: PA I.D. 304841 � 3'� M — F M c=; =A _T1i a comp w �7 =C:)— >o_.,. D � w co IIIIVIIIIIII II IIIIIIIIIIIIIiI IIIIIIII I IIIIIIIIIIIIIiI 1� OOOOKBSF CCGPRO 201W6 i IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY,PENNSYLVANIA CIVIL ACTION-LAW �1 )��►� ,)1M int'�V-�dC o � PLAINTIFF NO. OII vs jrM'� rC IL T) II n CD M CD DkFENDANT CD 7-1 =C) 70 -� c5 o COMPLAINT FOR(CUSTODY)(PARTIAL CUSTODY)(VISITAT:IbN) .ZD TO THE HONORABLE JUDGES OF SAID COURT: AND NOW,comes (Plaintiff)(Defendant) �'\ , V ,who files this Complaint for(Custody)(Partial Custody)(Visitation) and avers as follows: 1. Plaintiff is91ZS �`(Y� j�ttl� 1/ y�, residing at �LZ lkloAa 2. Defendant is �f W\Anr�N 0 nniresiding at aon &in�-�, ��ic-Ale Zrive Vt*�A �'I atI� ��gp , ? I �,g2.3 3. Plaintiff and Defendant are the parents of � �h QgQ �, \ )t{�r�� ��`• t/ 4. The reasons (Pl``aintiff)(Defendant)seeks an Order for(Custody) (Partial Custody) (Visitation) are as follows: �1 uja11' a ,gcQ(C_ c�pCClyVls��(1 `t�1 W r 01 j3Pea m Q J21 %4,-, C}.�S Z�-, CSV z � ck-2w V 5. (Plaintiff)(Defendant) has no information of another Custody proceeding concerning the child(ren) in this Commonwealth or any other jurisdiction. �6. (Plaintiff)(Defendant) does not know of a person not a party to the proceedings who has physical custody of the child(ren) or claims or have custody or visitation rights with respect to said child(ren). 7. The best interests and permanent welfare of the child(ren)will be served by granting the relief requested. WHEREFORE, (Plaintiff)(Defendant) requests the Court to grant(custody) (partial custody) (visitation)of said child(ren) to him/her. Respectfully Submitted, �I�k�lZ9Cl`;�cct (Plaintiff)(Defendant) Phone# Date: I -z'o VERIFICATION I hereby verify that the statements appearing in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that the statements made herein are subject to penalties of 18 PA.C.S.A. Section 4904, relating to unsworn falsification to authorities. (Plaintiff)(Defendant) Date L T (:\forms\custodycompl nt.wpd � 1111111 IIIII 1111111 111 1111111 III 111111 IIIII II 0000KCV5 CCGPRO 201106 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY,PENNSYLVANIA CIVIL DIVISION DENIS DIMITRIYEV, Plaintiff * No. 24>1J- 2,97Y VS. * VIKTORIYE DIMITRIYEV, Defendant ORDER OF COURT You,Viktoriye Dimitriyev, Defendant,have been sued in Court to obtain custody, partial custody or visitation of the child: Vanessa Denise Dimitriyev. NI ex You are Ordered to appear in person at the Centre County Courthouellefonte, Pennsylvania,JL4�e S Ck r,+L- , on Aunusf ?> , 2011, at A.M. fa- conciliation or mediation conference. - 1 a pretrial conference. a hearing before the Court. `1 If you fail to appear as provided by this order,an order for custody, partial custody or visitation may be entered against you or the Court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Centre County Court Administrator's Office Centre County Courthouse Bellefonte, PA 16823 355-6727 HE CO T: J. III III • III III • IIII II III III IIII III III III II II III II IIII III K6n I C CCGPR020f i05 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY,PENNSYLVANIA CIVIL DIVISION DENIS DIMITRIYEV, Plaintiff * No. * VS. * Type of Case: Custody * VIKTORIYE DIMITRIYEV, * Type of Pleading: Custody Complaint Defendant * Filed on Behalf of. Denis Dimitriyev * * BY: Laura Robbins,Esq. Laura Robbins Law, LLC 315 S. Allen St. Suite 217 State College, PA 16801 (814) 234-1550 FAX: (814)234-1551 Child: Vanessa Denise Dimitriyev(DOB 06/21/2009) C., o 0 c w o CJC) N 70 CDS. C O CD3 � n <xrn o D W � IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY,PENNSYLVANIA CIVIL DIVISION DENIS DIMITRIYEV, Plaintiff * No. Zvll �� vs. * VIKTORIYE DIMITRIYEV, Defendant COMPLAINT FOR CUSTODY 1. The Plaintiff is Denis Dimitriyev, an adult individual currently residing at 103 Gwenodd Court, Pleasant Gap,Pennsylvania, 16823. 2. The Defendant is Viktoriye Dimitriyev, an adult individual currently residing at 200 N. Danielle Drive,Apt. 221, Pleasant Gap, Pennsylvania, 16823. 3. Plaintiff seeks shared legal and primary physical custody of the following child: Name Present Residence Age Vanessa Denise Dimitriyev 200 N.Danielle Drive 2 Apt. 221 Pleasant Gap, PA 16823 The child was not born out of wedlock. The child is presently in the custody of Viktoriye Dimitriyev,residing at 200 N. Danielle Drive,Apt. 221, Pleasant Gap, Pennsylvania, 16823. n O Tj 1I'M t_ f CD 0J C QD rT;+1:Z �- CD CD CD;Z:n N -a Cp� -v-<r 77 O D w --�7 Since birth,the child has resided with the following persons and at the following addresses: Persons Addresses Dates Yan Dimitriyev,Anton 103 Gwenodd Court birth—May 2010 Dimitriyev, Zhanna Pleasant Gap, PA 16823 Dimitriyev, Svetlana Dimitriyev,Vitaliy Dimitriyev, Vera Dimitriyev,Denis Dimitriyev, and Viktoriye Dimitriyev Denis Dimitriyev and 200 N. Danielle Drive May 2010 - Viktoriye Dimitriyev Apt. 221 July 7,2011 Pleasant Gap, PA 16823 Viktoriye Dimitriyev 200 N. Danielle Drive July 7, 2011 — Apt. 221 present Pleasant Gap,PA 16823 The mother of the child is Viktoriye Dimitriyev, currently residing at 200 N. Danielle Drive,Apt. 221,Pleasant Gap, Pennsylvania, 16823. She is married. The father of the child is Denis Dimitriyev, currently residing at 103 Gwenodd Court, Pleasant Gap, Pennsylvania, 16823. He is married. 4. The relationship of Plaintiff to child is that of father. The Plaintiff currently resides with the following persons: Name Relationship Vera Dimitriyev Plaintiff's mother Vitaliy Dimitriyev Plaintiff's father Zhanna Dimitriyev Plaintiff's sister Svetlana Dimitriyev Plaintiff's sister Anton Dimitriyev Plaintiff's brother Yan Dimitriyev Plaintiff's brother 5. The relationship of Defendant to child is that of mother. Plaintiff does not reside with anyone else. 6. Plaintiff has not participated as a parry or witness, or in another capacity,in other litigation concerning the custody of this child in this or another court. 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: A. Father can provide a physically and emotionally stable environment for the child. B. It is in the child's best interest and permanent welfare to reside with father. WHEREFORE, Plaintiff requests the Court to grant shared legal and primary physical custody of the minor child,Vanessa Denise Dimitriyev,to the Plaintiff. Respectively Submitted, Lk6ra Robbins, Esq. Attorney for Plaintiff Laura Robbins Law,LLC 315 S. Allen St. Suite 217 State College, PA 16801 (814)234-1550 PA Supreme Court ID: 90459 r ^• 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 10 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. Denis Dimitriyev Plaintiff AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Centre County is required by law to comply with the Americans with Disabilities 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. IIIIIII #1 (IIIIIIIFORM iI ((IIIIIII III IIIIIII IIIIIII IIIIIII 0II0OK9AW GCGPR0201106 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA rn c_ F= ")4xaS ►J� l rf � rn rn PLAINTIFF f --i a Q 'w © C NO. / ���1111 T7zT� tI CD _ws h � o=cam -j � A11-2a7y =xc, V�Ir7D�2�Yi9 �H2TJLt yFV CIVIL ACTION-LAW-IN DIV Cgs o DEFENDANT NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. IF YOU T TAKE PROMPTSH ACTIODEFEND N.ACTION YOUTNST THE ARE WARNED(TIHAT IF YS SET OOU FAIL RTH IN THE FOLLOWING PAGES,YOU MUS TO DO SO,THE CASE MAY PROCEED WITHOUT YOU AND A DECREE OF DIVORCE OR ANNULMENT MAY BE ENTERED AGAINST YOU BY THE COURT. A JUDGMENT MAY ALSO BE ENTERED AGAINST YOU FOR ANY OTHER CLAIM OR RELIEF REQUESTED IN THESE PAPERS BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU,INCLUDING CUSTODY OR VISITATION OF YOUR CHILDREN. WHEN THE GROUND FOR THE DIVORCE IS INDIGNITIES OR IRRETRIEVABLE F MARRIAGE COUNSELORS ORS IS MARRIAGE, YOU MAY REQUEST MARRIAGE COUNSELING. A LIST O AVAILABLE IN THE OFFICE OF THE PROTHONOTARY AT ROOM 102,CENTRE COUNTY COURTHOUSE, BELLEFONTE, PA 16823. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DI NIU MENT S GRANTEDON OF PROPERTY, LAWYER'S FEES OR EXPENSESA DIVORCE YOU MAY LOSETHE RIGHT TO CLAM ANYOOF THEM. LAWYER AT ONCE. IF YOU DO YOU SHOULD TAKE THIS PAPER TO YOUR OFFICE SET FORTH BELOW.OTHIS HAVE A LAWYER , GO TO OR TELEPHONE T OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE ALAWYER, THIS AGENCIESFFICE MAY BE ABLE TO THAT MAY OFFER LEGAL PROVIDE YOU WITH INFORMATION ABOUT SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. BYPAPERF THE WITHIN XTION IS COURT ADMINISTRATOR REINST THIS QAYOF .20 NTRE COUNTY COURTHOUSE, RM 208 102 SOUTH ALLEGHENY STREET BELLEFONTE, PA 16823 PROTHONOTARY 814-355-6727 CHILDREN UNDER 18: YES NO ' IN THE COURT O OMMON PLEAS OF CENTRE COUN , PENNSYLVANIA V PLAINTIFF NO. -r; � CIVIL ACTION -LAW-IN DIVORCE DEFENDANT O ,L7 COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODI d /173 >rU��� C1• ?IFEA14AIT `u��? � who currently resioq�p 1. The PLAINTIFF is (include PO Box#) -De r,3 S 1 mai tlL�c/F to �n 2. The DEFENDANT isMXA i J1/CEC�F �),Tr"Krm-6,4p,>VT� who currently resides at (include PO Box#) 1- 2 Z-MT F- 3. Plaintiff and/or Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six(6) months immediately previous to the filing of this Complaint. 4. The parties were married on. g- D®g at(town,state) cR'K Lis L TA Jyi9�lEss�F �Nr sS�G 5. There are / #) children born of this marriage, namely V Wks sozU 81v JWJ �-I -'ZOO? No prior determination concerning primary custody has been made. NO'-,< Plaintiff requests the Court to award primary custody to him/her with appropriate provisions for visitation and any other related items deemed appropriate. 6. The marriage between the parties is irretrievably broken. 7. State whether there has been any prior action for divorce or annulment of marriage, between the parties. NO'2�_YES Case# Disposition 8. The Plaintiff has been advised of the availability of counseling and that he/she may have the right to request that the Court require both Plaintiff and Defendant to participate in counseling in accordance with the provisions of rule 1920.45. 9. NO).YES The Plaintiff requests the Court to equitable divide,distribute or assign the marital property of the parties. 10. NO-_YES The Plaintiff lacks sufficient assets to provide for his/her reasonable needs and is unable to Support himself/herself through appropriate employment. Plaintiff requests the Court to determine the nature, amount duration and manner of payment of alimony pursuant to section 501 of the Divorce Code of 1980. 11. NO ✓� YES The Plaintiff lacks funds to support and maintain himself/herself and to meet The costs and expenses of this litigation during the pendency of the same. Plaintiff requests the Court to issue an Order awarding alimony pendente lite and directing defendant to pay Plaintiff's counsel fees and costs. 12. Plaintiff requests the court to enter a decree of divorce. 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.4904, relating to unsworn falsification to authorities. / Date: �,S'= `2 1/1 P AINTIFF PHONE#