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Home My WebLink About06-0282 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 0 ~ - :1'6,.1 COLIN TEZIK, v. Defendant CIVIL ACTION - LAW CHILD CUSTODY DANIELLE HAKE, NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property, or other rights important to you, including child custody, or child visitation. 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 MA Y BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 Telephone: (717) 249-3166 A VISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente 0 por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objeccionnes a, las demandas presentadas aqui en contra suya. Se Ie advierte de que si usted falla de tomar accion como de describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda 0 cua1quier otra reclamacion 0 remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. U sted puede perder dinero 0 propiedad u otros derechos importantes para usted. USTED DEBE LLEV AR ESTE DOCUMENTO A SU ABOGADO INMEDIA T AMENTE. SI USTED NO TIENE UN ABOGADO, LLAME 0 V A Y A A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIER UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES PO SIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, P A 17013 Telephone: (717) 249-3166 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA C!l t.> ll. '- I V2....h-1 , COLIN TEZIK, v. : NO. Ol--~~ . ' Defendant CIVIL ACTION - LAW CHILD CUSTODY DANIELLE HAKE, COMPLAINT FOR CHILD CUSTODY AND NOW comes the Plaintiff, Colin Tezik, by and through his attorney, Kristin R. Reinhold, Esquire, and respectfully requests this Honorable Court award him custody of the subject minor child, and in support thereto, avers the following: 1. Plaintiff is Colin Tezik, an adult individual residing at 4 Sunset Circle, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Danielle Hake, an adult individual residing at 107 East Front Street, Lewisberry, York County, Pennsylvania 17339. 3. The subject child is Tara Marie Tezik, born August 28, 1998. 4. The relationship of the Plaintiff to the subject minor child is that of natural father. 5. The relationship of the Defendant to the subject minor child is that of natural mother. 6. The minor child has resided at the following addresses, in the custody ofthe following individuals: a. From August, 1999 to September, 2002 - the subject minor child resided at 30 Terrace Place, New Cumberland, York County, Pennsylvania, in the care and custody of Plaintiff and Defendant, as well as paternal grandparents, Anthony Tezik and Paula Tezik. b. From September, 2002 to February, 2003 - the subject minor child resided on Springers Lane, New Cumberland, York County, Pennsylvania, in the care and custody of Plaintiff and Defendant. c. From February, 2003 to July, 2003 - the subject minor child resided at 30 Terrace Place, New Cumberland, York County, Pennsylvania, in the care and custody of Plaintiff and Defendant, as well as paternal grandparents, Anthony Tezik and Paula Tezik. d. From July, 2003 to November, 2005 - the subject minor child resided at 4 Sunset Circle, Mechanicsburg, Cumberland County, Pennsylvania, in the care and custody of Plaintiff and Defendant. e. From November, 2005 to December 2, 2005 - custody of the subject child was shared by the parties, with Plaintiff residing on Wentworth Drive, Camp Hill, Cumberland County, Pennsylvania, and Defendant residing at 4 Sunset Circle, Mechani(:sburg, Cumberland County, Pennsylvania. f. From December 2, 2005 to present - (:ustody of the subject child is shared by the parties, with Plaintiff residing at 4 Sunset Circle, Mechanicsburg, Cumberland County, Pennsylvania, and Defendant residing at 107 East Front Street, Lewisberry, York County, Pennsylvania, with the child's matemal grandparents, Steve and Gail Bryner, as well as her maternal aunt, Stephanie Bryner. 7. There have been no prior actions for custody of the subject minor child in this or any other jurisdiction. 8. The Plaintiff is not aware of the existence of any other individuals who have any type of claim whatsoever regarding the custody of the subject minor child. 9. Since the parties' physical separation in November of2005, Mother has failed to provide proper supervision of the subject minor child. Specifically, while she has been in her custody, Mother has left the child alone in the I~venings while she went out with other men. On several occasions, the subject minor child awoke frightened and crying and called Father to come over 10. Since Mother moved into her parents' residence on December 2, 2005, Mother has left the child with her maternal grandparents an excessive amount of time while Mother has gone out and spent the night with her boyfriend. 11. The Plaintiff believes and therefore avers that he is much better able to meet the needs of the subject minor child than the Defendant. 12. The Plaintiff believes and therefore avers that it is in the best interest of the subject minor child that she be placed in his legal and physical custody. WHEREFORE, Plaintiff requests this Honorable Court award him custody of the subject minor child. l /. I / /!.,: ! r- ( -, {'- Respectfully submitted, THE LAW O~.FFI. :E. S OF SILLIKER & . fNHOLD '-'y'. """ ~~.r!ei:lj~~i;:--- 5922 ~t~lestown Road Harris6urg, PA 17112 (717) 671-1500 I.D. No. 57911 Attorney for Colin Tezik ._.~-- AFFIDAVIT I, en II II '1(: z i k , hereby certify that the aforegoing is true and COrrect to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. 4909 relating to unsworn falsifications to authorities. Dated: l /3/Dh x 7:.l(:Jl<Q. ~ 1 ~ ...... ;j ~ -2 ....... C> -() () o b..; (j ~ F ~ -z (") :::J ~-;~; '-;l i; r.) CJ ,'...1 COLIN TEZIK PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 06-282 CIVIL ACTION LA W DANIELLE HAKE DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, January 20, 2006 u' upon consideration of the attached Complaint, it is hereby directed that parties and their respcctive counsel appear before Melissa P. Greevy, Esq. at____I':t.JJ.J Manlove's, 1901 State St., Camp Hill, PA 1701\ on Tuesday, February 28, 2006 , the conciliator, at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an cff(Jrt will he made to resolve the issues in dispute; or if this cannot be accomplished, to de line 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 herehy directs the parties to furnish any and all existing Protection from Ahuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearin!!. FOR THE COURT. By: /sl .. Melissa P. Greevy, 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. A II arrangements must be made at least 72 hours prior to any hearing or business be!(lfe 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 Bedt(lfd Street Carlisle, Pennsylvania 17013 Telephone (7 I 7) 249.3 166 ~ f:v 2- ~rfW ~l -10 [Y'.; ;fp .2 'ppjPnif ?~/{, "?(? 2"('./ "7~ P Z. /7~.>fl1,' hk9?'~ '/ (J [,-<; . ( ..--. /'.1 is ~:; :?~ 'i:-; I" "..: ~ \ -, _~ ,..., i..(. L:! _~i~!l .:JO " ~__._____."e''''''_ . . ~ 'Y Plaintiff RECEIVED MAR 0 62CC5 Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-282 CIVIL TERM COLIN TEZIK, v. CIVIL ACTION - LAW DANIELLE HAKE, IN CUSTODY Defendant ORDER OF COURT AND NOW, this '5! j.}. day of March, 2006, upon consideration of the attached Custody Conciliation Su~port, it is hereby ordered and directed as follows: 1. Leoal Custody. The parties, Colin Tezik and Danielle Hake shall have shared legal custody of the minor child, Tara Marie Tezik born August 28, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of 23 Pa. C. S. S5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. The parties shall share physical custody in accordance with the following schedule which shall become effective on March 6, 2006: A. Mother shall have custody on Mondays and Tuesdays. B. Father shall have custody on Wednesdays and Thursdays. C. The parties shall have alternating weekend periods of custody commencing on Friday after school and continuing until Monday morning when the child is returned to school. Mother's first custodial weekend shall commence March 10, 2006. Father's first custodial weekend shall commence March 17,2006. 3. Transportation. The parent relinquishing custody shall be responsible to transport the child to school or to the other parent on non-school days. The custodial exchange time on non-school days shall be 7:30 a.m. Parents receiving custody at the conclusion of the school day are responsible for transportation of the child. -, (. ....J . 06-282 CIVIL TERM 4. Vacation. Each parent shall be entitled to two (2) non-consecutive weeks of vacation upon not less than two (2) weeks notice to the other parent. A vacation week shall commence with and include the vacationing parent's custodial weekend. 5. schedule: Holidays. The attached holiday schedule shall supercede the regular BY THE COURT: w-? J. OiSt:6:0'Alo, Esquire, Mid Penn Legal Services, 401 E. Louther Street, Suite 103, Carlisle, PA 17013 ~tin R. Reinhold, Esquire, 5922 Linglestown Road, Harrisburg, PA 17112 ~J \'\ 0! ~ ,D \? -. 1 COLIN TEZIK, RECEIVED MAR 06 2C25 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 06-282 CIVIL TERM v. CIVIL ACTION - LAW DANIELLE HAKE, IN CUSTODY Defendant CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Tara Marie Tezik August 28, 1998 Mother and Father 2. Father filed a Complaint for Child Custody on January 12, 2006. A Custody Conciliation Conference was scheduled for February 28, 2006. Attending the conference were: the Father, Colin Tezik, and his counsel, Kristin R. Reinhold, Esquire; the Mother, Danielle Hake, and her counsel, Grace D'Alo, Esquire. 3. The parties reached an agreement in the of an Order as attached. ij~JO~ Date ' :270216 v . ... NO. 06-282 CIVIL TERM HOLIDAYS AND TIMES ODD EVEN SPECIAL DAYS YEARS YEARS Easter Dinner From 6pm the evening before the holiday to 6pm the Father Father day of the holiday. Additionally, Mother shall have custody for various Easter egg hunts The parties shall cooperate with each other in working out the specific details of this holidav. Memorial Day From 6pm the evening before the holiday to 6pm the Father Mother day of the holiday Independence Day From 6pm the evening before the holiday to 6pm the Mother Father day of the holiday Labor Day From 6pm the evening before the holiday to 6pm the Father Mother day of the holiday Thanksgiving 1" Half From 4pm the evening before Thanksgiving Day to Mother Mother 4pm on Thanksgiving Day Thanksgiving 2nd Half From 4pm on Thanksgiving Day to 4pm the day after Father Father Thanksgiving Day Christmas 1 s1 Half From 11am on 12/24 to 11am on 12/25 Father Father Christmas 2nd Half From 11pmon 12/25 to 11amon 12/26 Mother Mother Mother's Day From 6pm the evening before the holiday to 6pm the Mother Mother day of the holiday Father's Day From 6pm the evening before the holiday to 6pm the Father Father day of the holiday :270226