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HomeMy WebLinkAbout05-3979 AZEMA SEJMENOVIC, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. No. DS- .3 q-"fer Civil Term ENVER SEJMENOVIC, Defendant : CUSTODY CUSTODY COMPLAINT I. Plaintiff is Azema Sejmenovic, who currently resides at: 152 C. St., Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Enver Sejmenovic, who currently resides at: 308 N. West St., Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff is the mother of the following child and seeks periods of custody with the following child: NAME DOB/AGE ADDRESS Emina Sejmenovic 12/25/2002 (2) 308 N. West St. Carlisle, Pa. 17013 Mother and Father married in April, 2002. Father currently has primary physical custody of the child. During the past five years, the child has resided with the following persons and at the following addresses: NAME ADDRESSES DATES Enver Sejmenovic Azema Sejmenovic Hava Sejmenovic (maternal grandmother) 308 N. West St. Carlisle, Pa. 17013 12/25/2002 - 12/25/2003 Enver Sejmenovic 308 N. West St. Hava Sejmenovic Carlisle, Pa. 17013 (maternal grandmother) 12/25/2003 - present. The mother of the child is: Azema Sejmenovic and she currently resides at: 152 C. St., Carlisle, Pa. 17013. She is married to: Enver Sejmenovic. The father the child is: Enver Sejmenovic, and he currently resides at: 308 N. West St. Carlisle, Pa. 17013. He is married to : Azema Sejmenovic 4. The relationship of plaintiff to the child is that of mother. The persons that the Plaintiff currently resides with are: her parents, Cima and Ramo Mehmedovic, and her brother, Zaim Mehmedovic. 5. The relationship of defendant to the child is that of Father. The defendant currently resides with his mother, Hava Sejmenovic, and the child. 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: Since the date of seoaration. Mother has had limited visitation with the child and has not been permitted to visit with the child outside of the Father's home. Mother is requesting liberal periods ofoartial custody with the child to occur outside of the Father's home. 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, <C? -~ Date: (). '::)- s rr----- e Adams, Esquire . No. 79465 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: <(;'. ~ . S- l>.fZc/77~ Jct,V;1'<!/-7,-;7.vC Azema Sejmenovic, Petitioner I pre..-iaed translated the information contained in the attached complaint and provided language assistance to Azema Sejmenovic. 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: 'l5 . ") . j AJ ~ ~ It- l ::::: :--..; "1 -- C> 6"- R.J ~ ~ ~ G"- ~ :f2 ~ (0) C) -1'1 .-4 : ';~~ ,.,[ "-".'" , ~ c:) Gl AZEMA SEJMENOVlC PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 05-3979 CIVIL ACTION LAW ENVER SEJMENOVIC DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, August 08, 2005 , upon consideration ofthe attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, September 15, 2005 , the conciliator, at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children aj!;e 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 scbeduled hearing. FOR THE COURT, By: Isl Hubert X Gilroy, Esq. Custody Conciliator <~ The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR A TTORNEY 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 . ~ ~tf6 ~ ~?p7 ~ J';?-,jJ '~p ~~~~~.S ~,Pt? f;!P :2- ~ 4 -/'P .5t?'6.g VlNVmASNN3d AiNnoo ON\f1I:E18V'Jro I I :Z Wd 6- snv SOOl Ai:N10NOH10Cld 3Hl :10 30l.i-!o-o31l:l AZEMA SEJMENOVIC, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 05 - 3979 Civil Term ENVER SEJMENOVIC, Defendant : CUSTODY AFFIDAVIT OF SERVICE AND NOW, this August 18, 2005 I, Jane Adams, Esquire, hereby certify that on August 5,2005, a certified true copy of the NOTICE TO DEFEND AND CUSTODY COMPLAINT was served, via certified mail, return receipt requl:sted, addressed to: Enver Sejmenovic 308 N. West St. Carlisle, Pa. 17013 DEFENDANT . Complete ~ems 1, 2. and 3. Also complete ~em 4 if Restricted Delivery is desired. . Print your name and address on the rev8r'Sl9 so thet we can relIJrn the card to you. . Attach this card to the beck of the mallplece, or on the front if space pennits. 8-8-~) 1. Article Addressed to: ~~ER SE']}\ENOVIIQ '3o~ N. ~ES\ S~ CJ\~~\S\..E PA , /10B c. of DeI!>'<<Y rl ~ '11"0/ D. Is delivery address from liom 11 0 Yes If YES, enter delivery address below: ~o 3. Service Type XCenlfled Moll 0 Express Msli CI Registered ~etum Receipt ~ r L.~I._,~I~ e_Mail 0 C.O.D. 4. nwt......... ~ (&Ita Fee) C Yes 2. Article Number ~from_-> i PS Form 3811, February 2004 7005 0390 0003 2635 3815 Domestic Return Receipt 102586-02-M-1i14O Respectfully Submitted: :l ~i?L- Adams, Esquire . No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF Q ~.i: 1.:': (~7:..'~~ ~L\...- ~k\:;:'_ 7~/ '2 d Q. ~ .-,l ~ ~~ c:;. -0\3 ~ '~\b - q,-!:, cP .~.~ --0 ~~ -:S :6 :;A ~ - .' - - - ~ RECE'V'::':: S'::O 232005 \..\ AZEMA SEJMENOVIC, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW 05'- 3n~ NO. J90J In IN CUSTODY ENVER SEJMENOVIC, Defendant COURT ORDER AND NOW, this z..-~- day of September, 2005, upon consideration of the attached Custody Conciliation Report, ordered and directed as follows: 1. The Father, Enver Sejmenovic, and the Mother, Azema Sejmenovic, shall enjoy shared legal custody of Emina Sejmenovic, born December 25, 2002. 2. Physical custody shall be handled as follows: a. Mother shall have custody on every weekend Friday at noon until Monday 9:00 a.m. b. Father shall have custody of the minor child from Monday at 9:00 a.m. until Friday at noon. 3. For holidays, the following holiday schedule shall control: a. Eid AI Fitr: This holiday shall be divided into two Blocks. Block A shall run from 12:00 noon on the first day of the holiday to 12:00 noon on the second day of the holiday. Block B shall run from 12:00 noon on day two of the holiday to 12:00 noon on the third day of the holiday. 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 numbercd ycars. b. Eid AI Adha: This holiday shall be divided into two Blocks. Block A shall run from 8:00 a.m. on day one of the holiday to 8:00 p.m. on the second day of the holiday. Block B shall run from 8:00 p.m. on day two of the holiday to 8:00 p.m. on day four of the holiday. Mother shall have Block A in even numbercd years and Block B in odd numbered years. Father shall have Block A in odd numbered years and Block B in even numbered years. SS : I ~ld 8Z d3S ~OOl AtNlOi~\:;:"LO~1d 3Hl :f0 38i:!;J,Q-O:!ltJ 4. The parties may modify this Order as they agree. Absent an agreement, the Order as set forth shall control. 5. In the event either party desires to modify this Order, that party may petition the Court to have the case again scheduled with the Custody Conciliator for a conference. 6. For exchange of custody, the non-custodial parent shall pick up the child with Mother picking the child up on Fridays, and Father picking the child up on Mondays. BY THE COURT, - Judge Cc: 4e Adams, Esquire ~r. Enver Sejmenovic (308 N. West Street, Carlisle, PA 17013) AZEMA SEJMENOVIC, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v CIVIL ACTION - LAW ENVER SEJMENOVIC, Defendant NO. 2003-3979 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: I. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Emina Sejmenovic, born December 25, 2002. 2. A Conciliation Conference was held on September 17, 2005, with the following individuals in attendance: Mother, Azema Sejmenovic, with her counsel, Jane Adams, Esquire Father, Enver Sejmenovic, who appeared without counsel. 3. The parties agreed to the entry of an Order in the form as attached. Date: tf--2;) - () S' ~.