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Home My WebLink About05-2192 DANIEL V ANASKIE and KAREN V ANASKIE, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiffs v. NO. 0 S-,- ;:(/'1:A- ALESIA WILLIAMS and JASON WILLIAMS, CIVIL ACTION - LAW IN CUSTODY Defendants COMPLAINT FOR CUSTODY 1. The Plaintiffs are Daniel and Karen Vanaskie, who currently reside at 650 Susquehanna Trail, Liverpool, Perry County, Pennsylvania. 2. The Defendant, Alesia Williams, is an adult individual who currently resid s at 38 Marilyn Drive, Carlisle, Cumberland County, Pennsylvania. 3. The Defendant, Jason Williams, is an adult individual who is presently sta mg at 2435 Lambs Gap Road, Enola, Cumberland County, Pennsylvania. 4. The Plaintiffs seek custody of the following child: Name: Jadalynn Macara Williams Date of Birth: June 20, 2002 Address: 650 Susquehanna Trail, Liverpool, P A 5. The child was born during wedlock. 6. The child is presently in the custody of Daniel and Karen Vanaskie, who re ide at 650 Susquehanna Trail, Liverpool, Perry County, Pennsylvania. 7. During the child's lifetime, she has resided with the following persons and at the following addresses: Name Address Date Daniel and Karen Vanaskie, paternal grandparents 650 Susquehanna Trail 04/16/05 to presen Liverpool, P A 17045 Jason and Alesia natural parents Williams, 38 Marilyn Drive 06/20/02 to 04/16/ 5 Carlisle, PA 17013 8. The paternal grandparents of the child are Daniel and Karen Vanaskie, who reside at 650 Susquehanna Trail, Liverpool, Perry County, Pennsylvania. 9. The mother of the child is Alesia Williams, who resides at 38 Marilyn Dive, Carlisle, Cumberland County, Pennsylvania. 10. Mother of the child, Alesia Williams, is married. 11. The father of the child is Jason Williams, who currently resides at 2435 La bs Gap Road, Enola, Cumberland County, Pennsylvania. 12. Father of the child, Jason Williams, is married. 13. The relationship of Plaintiffs to the child is that of paternal grandparents. 14. The relationship of Defendants to the child is that of father and mother. 15. The Defendants currently resides with the following persons: Mother resides with her brother, Danny D'Ijnazio; Father is presently stayi g with his grandmother, Ruth Strawser 16. Plaintiffs have not participated as a party or witness, or in another capacity, i other litigation concerning the custody of the child in this or any other court. 17. Plaintiffs have no information of a custody proceeding concerning t child pending in a court of this Commonwealth. 18. Plaintiffs do not know of a person not a party to the proceedings wh have physical custody of the child or claims to have custody or visitation rights with espect to the child. 19. The best interest and permanent welfare of the child will be served by gr nting the relief requested for reasons including the following: a. The Paternal Grandparents have been caregivers of the minor chil on a weekly basis since her birth. While in their custody, they have: 1. Planned and prepared meals; 11. Bathed, groomed and dressed the child; lll. Purchased, cleaned and cared for the child's clothing; IV. Arranged medical care, including trips to physicians, as neede v. Arranged alternative daycare, as needed; VI. Put the child to bed nightly, attended the child in the middl of the night, and awakened the child in the morning. b. The child has a psychological bond with the Paternal Grandparents. c. Paternal Grandparents are able to provide a stable environment for t e child. d. On or about April 18, 2005, Mother and Father were involved in a domestic disturbance that resulted in the North Middleton Township Poli being called to their home. The interior of the home and all of their bel ngmgs were destroyed in this incident. e. Detective Timothy Lively, North Middleton Township Police, ade a referral to Cumberland County Children and Youth following this incid t. f. Detective Lively further recommended that the child remain the custody of her paternal grandparents until such a time that this incid nt is investigated by the authorities. g. It is believed and therefore averred that Mother and Father are inv lved in drug use and/or distribution, even when they have custody of the child. h. It is believed and therefore averred that Mother left town for approximately two (2) weeks at the end of March 2005 without notifyin or contacting any member of her family, including her child. The child was Ie III paternal grandparents care at that time. I. It is believed and therefore averred that it is in the best interests of he child to remain in the custody of her paternal grandparents until such a ti e that her parents can become and remain drug free. 20. Each parent whose parental rights to the child have not been terminated s been named as parties to this action. WHEREFORE, Plaintiffs request that This Honorable Court grant primary ysical custody of the child to Plaintiffs/Paternal Grandparents. Respectfully submitted, ABOM & KurULAKlS, L.L.P. DATE DLJ-!Z& /D5 ~l-[D. ( Kara W. Haggerty ill No. 86914 36 South Hanover Street Carlisle, P A 17013 (717) 249-0900 Attorney for PlaintiffS VERIFICATION I, Daniel Vanaskie and Karen Vanaskie, verify that the statements made i this Custody Complaint are true and correct to the best of my knowledge, informatio , and belief. I understand that false statements herein are made subject to the penalties of 18 P .C.S. $ 4904 relating to unsworn falsification to authorities. Date 0/ ;? 7 d 80j L) Daniel Vanaskie Date d-f. JS 05 CERTIFICATE OF SERVICE AND NOW, this 2lL...... fV.aay of ApI! ,( 2005, I, Kara W. Haggeny, Esq ire, of Abom & Kutulakis, L.L.P, hereby cenify that I did serve a true and correct copy f the foregoing Custody Complaint, upon the Defendants by depositing, or causing 0 be deposited, same in the United States Mail, First-class mail, postage prepaid addressed 0 the following: Alesia Williams 38 Marilyn Drive Carlisle, PA 17013 Jason Williams c/o Ruth Strawser 2435 Lambs Gap Road Enola, PA 17025 Respectfully submitted, ABOM & KUTULAKlS, L.L.P. {(J?fLto, (~h Kara W. Haggeny ( ID No. 86914 36 South Hanover Street Carlisle, P A 17013 (717) 249.0900 Attorney for Plaintiffs 1"(\ -- ~ w w "'" " ~ ~ ~--.. ~ () ~~;'~~~\ '--<7 - ~ :>,f' C)< ~' {~~~ */c;" r' 2. ~ ~ -- , -- - o C -:;'Y ,...> ~ <J" !; ~0 ':::. -::"~ - -"'" Q, --' ::;c.-<, f1"'\~~ ~ni""" ~:o C;) ()t~ :::~~S;" ),)"/! ~'7,,-J .>r\\ () -_.,~\ 1D ,"'- ~ v o '-P. (J'\ ....J - ...--- ~ DANIEL V ANASKIE AND KAREN V ANASKIE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY. PENNSYL VANIA v. 05-2192 CIVIL ACTION LAW ALE!SIA WILLIAMS AND JASON WILLIAMS IN CUSTODY DEFENDANT ORDER OF COURT 1ND NOW, Wednesday, May 04, 2005 , upon consideration of the attached Complaint, it is here y directed that parties and their respective counsel appear before Jacqneline M. Verney, Esq. , the conciliator, at 4 h Floor, Cnmberland County Courthouse, Carlisle on Tuesday, May 24, 2lJ!l.?.... _.._. at 8:30 ..AM for a Pre Hearing Custody Conference, At such conference, an effort will be made to resolve the issues in dispute; or if this ca not be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. A I children a,ge five or older may also be present at the conference. Failure to appear at the conference may provide rounds for entry of a temporary or permanent order. T e court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special elief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ facqueline M. Verney, Esq. Custody Conciliator .~ I The Court of Common Pleas of Cumberland County is required by law to comply with the Americans withlDisabilites 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 mus be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled con~ rence or hearing. I YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA ~E AN A TTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FOR~H BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedt()rd Street Carlisle, Pennsylvania 17013 Telephone (717) 249..3166 W c.4n0,r; 1 j?*' -",,,~ XV??r/ 4do:; I * ~ ppPYJ/ to;e14 r~ fp :Z;'r~~.7 Pi?(} j I I., : ,'~ i\._,.1 -, '" [' '")11') S- ;YilSHOZ 'Ie.. .t."'.....: 50 ->.> j(J )/57' -, " ...0-5. j ... DANIEL V ANASKIE and KAREN V ANASKIE, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiffs v. NO. 05-2192 ALESIA WILLIAMS and JASON WILLIAMS, CIVIL ACTION - LAW IN CUSTODY Defendants PRAECIPE TO WITHDRAW CUSTODY COMPLAINT AND NOW, this 9'h day of May 2005, the plaintiffs, Daniel and Karen Vanaskie, by and through their attorney Kara W. Haggerty, Esquire, of Abom & Kutulakis, LLP, hereby files this Praecipe to Withdraw the Custody Complaint in the above-referenced matter. Respectfully submitted, ABOM & KurULAKIS, L.L.P. DATE~ ~JfH~;!~cl;1 ID No. 86914 U 36 South Hanover Street Carlisle, P A 17013 (717) 249..0900 Attorney for Plaintiffi 0" CERTIFICATE OF SERVICE AND NOW, this q +it.-. day of ~ 2005, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Praecipe to Withdraw Custody Complaint, upon the Defendants by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Alesia Williams 38 Marilyn Drive Carlisle, PA 17013 Jason Williams c/o Rutb Strawser 2435 Lambs Gap Road Enola, PA 17025 Respectfully submitted, ASOM & KUTULAKIS, L.L.P. ~({) liGf~ Kara W. Haggerty . ill No. 86914 36 South Hanover Street Carlisle, P A 17013 (717) 249-0900 Attorney for Plaintiffs ~ ,..~.') ~.~ } .::~-"' cr~ r') .::;,., ,-. --c t\-; -': --. , t::) -, --- RECEIVED MAY 11 Za01(' DANIEL V ANASKIE and KAREN: IN THE COURT OF COMMON PLEAS OF V ANASKIE, : CUMBERLAND COUNTY, PENNSYL VANIA Plaintiffs V. : NO. 2005-2192 CIVIL TERM ALESIA WILLIAMS and JASON: CIVIL ACTION - LAW WILLIAMS, Defendants : IN CUSTODY ORDER OF COURT AND NOW, this 11t" day of May, 2005, being advised that the Plaintiffs have filed a Praecipe to Withdraw Custody Complaint, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, acq eline M. Verney, Esquire, C tody Conciliator f"..."1