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HomeMy WebLinkAbout05-3197 KATHRYN M. GETZ- V ARDZIK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. {J5~ 3,Q., Civil Term DANIEL HAFER, : CUSTODY Defendant CUSTODY COMPLAINT I. Plaintiff is Kathryn M. Getz-Vardzik who currently resides at 1024 W. Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant is Daniel A. Hafer, who currently is believed to reside with his mother, Nora Hummel, Big Spring Terrace, Lot 153, Newville, Cumberland County, Pennsylvania, 1724 I. 3. Plaintiff is the mother of the following child and seeks custody of the following child: NAME DOB/AGE ADDRESS Kody Elijah Getz 7/11100 (4) 1024 W. Trindle Rd, Mechanicsburg, Pa. 17055. Mother currently has primary physical custody of the child. During the past five years, the children have resided with the following persons and at the following addresses: NAME ADDRESSES DATES Kathryn Getz- V ardzik George Vardzik (spouse) Kaylin Vardzik Austin Vardzik 1024 W. Trindle Rd. 2004 - present Mechanicsburg, Pa. 17055 Kathryn Getz George Vardzik Austin Vardzik 26 Steven Drive 2002 - 2004 Camp Hill, Pa. 17011 Kathryn Getz George Vardzik 6280 Carlisle Pike, Lot 309 11echanicsburg,Pa.17055 2000 - 2002 The mother of the children is: Kathryn 11. Getz- V ardzik and she currently resides at: 1024 W. Trindle Road, 11echanicsburg, Pa. 17055. She is married to: George Vardzik. The father the children is: Daniel Hafer and he currently resides in Newville, Pennsylvania. He is not married. 4. The relationship of plaintiff to the children is that of 11other. Plaintiff currently resides with George Vardzik, the child, and the couple's two other children. 5. The relationship of defendant to the children is that of Father. The defendant currently resides with his mother. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a party to the proceedings who has physical custody of the child or anyone who 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: 110ther has had orimary custody of the child since birth and has been the orimary caretaker. Father has had limited contact with the child especiallv over the past two years. during which Father was incarcerated. 110ther does not oQ.pose some oeriods of partial custodv with the child for father: however. she is requesting a court order indicating that she has primary custodv and soecifving father's oeriods of custodv. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiff requests the court to grant custody of the child. Respectfully submitted, DM< 0/ ?,q/oS- e Adams, Esquire J.D. No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF 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. 94904 relating to unsworn falsification to authorities. Date: C I ~) . O.s~ ~ 1?l.)j~- ~ . Kathryn M, G -Vardzik, PIa' ~ ~ ~ ""- (;'- <1"1 '1 \D 6' (~ l\ * ~ - - -... ~ ~~ ~ ~ "" & 0 t-' CJ = ~.. c::> -., c.n ,- --I f.~ "TI C:..: 1-.' ,.. N CJ N (::) 0:-' \-~~} ~~,~ .~, _.. , J\l ~:-~ -.... U1 'T1 {,,:> :< KATHRYN M. GETZ-VARDZIK PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COmiTY, PENNSYLVANIA V. 05-3197 CIVIL ACTION LAW DANIEL HAFER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, Jnne 29, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hnbert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cnmberland Connty Conrthonse, Carlisle on ThnrsdllY, Jnly 21, 2005 at 9:30 ~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 pllrties 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: Isl Hubert X. Gilrov. Esq. Custody Conciliator .y The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990, For intonnation about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our offiee, 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 HA VE 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 17013 Telephone (717) 249-3166 , rf~fr ~~ 4r6; f(/.~e-~ ~? ~ ~lt, YOQe.'7 ~ ~ ~ ~":: ~.~ Jr?jC'>? I VlN\f^1~SNN3d A.iNnOO !} Nl"38Wn:J ZO :f; Wd 6Z Nor SOOl AW1ONOH10Cld 3H1:10 3:)l::l::lO-<B'1I:l -.. -..~. 0/ KATHRYN M. GETZ-V ARDZIK, Plaintiff RECEIVED AUG 22 Z005 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW DANIEL HAFER, Defendant NO. 05-3197 IN CUSTODY COURT ORDER AND NOW, this 2~(lday of August, 2005, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. The mother, Kathryn M. Getz-Vardzik, shall enjoy legal and physical custody of Kody Elijah Getz, born July 11, 2000. 2. The father, Daniel Hafer, shall enjoy visitation with the minor child at such times and under such circumstances as agreed to by the mother. 3. In the event the father is dissatisfied with periods of custody provided to him by mother, father may petition the Court to have this case again scheduled with the Custody Conciliator for a Conference. 4. Legal counsel for the mother shall mail a copy of this Order and the attached Report to the father at the father's last known address. cc:./ane Adams, Esquire ~ wo1-b.- J 'jYW oct' >. a.' ..i: >c:; we, o:c --C) }t:+:,: i'.,Jb 6(Y we: dlu ~:r: 1-- u.. o !.{') .. ...:r ~r:'~ 1::1: LO N C9 :.::.J < or> = = "" KATHRYN M. GETZ-V ARDZIK, Plaintiff IN THE COl1RT OF COMMON PLEAS OF Cl1MBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW DANIEL HAFER, Defendant NO. 05-3197 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Kody Elijah Getz, born July 11, 2000. 2. A Conciliation Conference was held on Augnst 12, 2005, with the following individuals in attendance: The mother, Kathryn M. Getz-Vardzik, with her counsel, Jane Adams, Esquire, and the father did not attend. 3. The mother related that the father was released from prison after a two-year jail stint in June of this year. He has seen the child once since that time. Father was notified of the Conciliation Conference and did not attend. 4. The Conciliator recommends an Order in the form as attached. Cl!/(.t[ oj DATE ClJ-rJ Hubert X. Gilroy, Es Custody Conciliator /