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HomeMy WebLinkAbout06-1867 ERIC WENGRZYN, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. OC.~jf[.7 CIVIL TERM KELLI PETERSON, : CIVIL TERM - CUSTODY Defendant CUSTODY COMPLAINT 1. Plaintiff is Eric Wengrzyn, who currently resides at 3685 Winkler Ave., Apt 923, Fort Myers, Florida, 33916. 2. Defendant is Kelli Peterson, who currently resides at 2903 Society Hill Drive, Apt 302, Camp Hill, Cumberland County, Pennsylvania, 17011. 3. Plaintiff is the father of the following child and seeks a custody order regarding of the following child which provides him with periods of partial custody: NAME DOB/AGE ADDRESS Maya Peterson 4/5/00 (5) 2903 Society Hill Dr. Apt 302 Camp Hill, Pa. 170 II Mother and Father were neyer married. 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 Kelli Peterson 2903 Society Hill Dr., Apt 302 Camp Hill, Pa. 17011 birth to present The mother ofthe child is Kelli Peterson. She resides at 2903 Society Hill Driye, Apt 302, Camp Hill, Pa. 17011. She is not married. The father the child is Eric Wengrzyn. He resides at 3685 Winkler Ave., Apt 923, Fort Myers, Florida, 33916. He is not married. 4. The relationship of plaintiff to the children is that of Father. Father currently resides alone. 5. The relationship of defendant to the child is that of Mother. Mother currently resides with 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: There is currently no custodv Order in place reg:arding the child. Father is seeking an Order which would provide for re&!ular periods ofllartial custody with the child. It would be in the best interest of the child for her to have regular contact and periods of custodv with her father. 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, Date: 3' 30 . & 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. ~4904 relating to unsworn falsification to authorities. Date: 3,~), 10 ~~ Eric Wengrzyn, Plaintiff ~~ , ~ -- IA ...J t;J ~ ~ ';J - ........ "- 9..J ~ ~ 'b -:.... ~ ~ '- \) ~~" ~J ~ K '- ~ ';, ':.... ~ ~~ ~ ~ ~.~ ,~:? " - ,~'''I "4-1 ~-:. -~~] f11i::';-, :;,.i,) (." C' ,..~ '-, r,", " L~" (I' ---- PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV ANIA ERIC WENGRZYN v. 06-1867 CIVIL ACTION LAW KELLl PETERSON DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, April 04, 2006 ,_, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. at MDJ Manl~v~}2!l1~~ate St., Camp Hill, ~~!7011. on u_.l'ri~~r,..l\1"LI9, 20~L_.___, , the conciliator, 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 cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children agc five or older may also be present at the conference. Failurc to appcar at the conference may provide grounds for entry of a temporary or permanent ordcr. 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 scheduled hearing. FOR THE COURT. By:. Is; . Melissa P..Greevv. Es.<j.. Custody Conciliator --r-- The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilitcs Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals haying business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business bef(lfe the court. You must attend the scheduled con ference 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 170 I 3 Telephone (717) 249-3166 4?i~~ p:'7.J. 1fJ'-rN/ 41119 L t rp1 ~7I'l;. !!~P:-.u~ -f/[ -4, 1~PJ1ll #p J. ;f/~' ~ ,r9 ~, ..., .C' ~,-!\ \'"" .';..; .;.'" ;1 ;J.h ,tf J,,}. /? ,/1 Wh l/ v ....... 1- RECEIVED MAY 25 ?11(l(l Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-1867 CIVIL TERM ERIC WENGRZVN, v, KELLI PETERSON, CIVIL ACTION - LAW IN CUSTODY Defendant ORDER OF COURT AND NOW, this ~ day of lM.7 '"'\ ,2006, upon consideration of the attached Custody Conciliation Summary Repdrt, it is hereby ordered and directed as follows: 1. Leaal Custody. The parties, Eric Wengrzyn and Kelli Peterson, shall have shared legal custody of the minor child, Maya Peterson, born April 5, 2002. 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. ~5309, 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. Phvsical Custody. Mother shall have temporary primary physical custody subject to Father's rights of temporary partial custody which shall be arranged as follows: A. On the weekend of Mav 19. 2006 through Mav 22. 2006 (1) May 19, 2006 from 6:00 p.m, until 8:30 p.m. for dinner with Mother. The parties shall meet at the child's day care center. (2) May 20, 2006 from 8:30 a.m. until noon and a four hour period from approximately 3:00 p.m. until 7:00 p.m. The times for the 3:00 p.m. until 7:00 p.m. may be varied as necessary to adjust for the child's nap time and the end of a movie which Father and the child may be viewing. With regard to the morning, period of custody on May 20, 2006, the parties shall meet at the Lower Allen Park if it is not raining, or McDonald's if it is raining. Father shall return the child to Mother at noon. With regard to the .. ~ +J 8 : II ~~V 08 j,VW 900l ^' U'r'lr'!I:":; ',r' -: II,':,,;,.}' ::JHl ::10 QV. v ."..... .~'T.._' '...~.. -11. 3~)\::HO'{EflL:I -1 '" . NO. 06-1867 CIVIL TERM afternoon period of custody on May 20, 2006, Mother shall contact Father by cell phone to let him know when the child is awakened from her afternoon nap. (3) May 21, 2006 from 8:00 a.m. until noon. Father will provide transportation incident to these custodial exchanges. (4) May 22, 2006 from 6:30 a.m. until noon. Father will provide transportation incident to these custodial exchanges, and will provide the child lunch on this date. B. Summer 2006. Father will be returning to Pennsylvania for the period from August 25, 2006 through August 29, 2006. During this period, Father's partial custody shall be arranged as follows: (1) August 25, 2006 from 6:00 p.m. until 8:30 p.m. (2) August 26, 2006 from 8:30 a.m. until August 27, 2006 at 5:00 p.m. (3) August 28, 2006 and August 29, 2006 during Mother's work hours. C. SDrina and Christmas. Father shall have custodial periods to be exercised in Pennsylvania during Spring and Christmas upon a similar schedule as to the arrangement for August of 2006. Father will provide Mother with thirty days' notice via e-mail or U.S. Mail with regard to the Spring and Christmas custodial periods. Mother's custodial period for Christmas shall occur in December but for 2006, shall not occur during the period from December 22, 2006 through December 25,2006. 3. Father shall arrange for Mother to meet with Father's uncle, Ed Hall, and to visit Uncle's residence where the child is expected to be during period of time that she is in Father's custody. 4. Father shall be entitled to reasonable telephone access with the child in between visits. Additionally, Father shall be entitled to alternate weekend electronic access through the web cam which he has provided to Mother, once it becomes installed on her computer. 5. The parties have exchanged telephone numbers. Any changes to these contact numbers shall be provided to the other parent within seventy-two hours. 'II" -- NO. 06-1867 CIVIL TERM 6. The parties' diligent work in establishing the schedule is acknowledged by the Court. This Order is a result of an agreement of parties and may be modified upon their mutual consent. In the absence of their agreement, the terms of this Order shall control pending agreement or further Order of Court. BY THE COURT: J. Dist: Theresa Barrett Male, Esquire, 513 N, Second Street, Harrisburg, PA 17101 Jane Adams, Esquire, 64 S. Pitt Street, Carlisle, PA 17013 --".J1~.t.. ~ .!/, 36"11., . -, ~- COURT OF COMMON PLEAS OF CUMBERLAND OUNTY, PENNSYLVANIA ERIC WENGRZVN Plaintiff v, NO. 010- I!?Cotj u--ull lerM KELLI PETTERSSON Defendant CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, August t J? ~ ,2006, upon consent the parties, Order of Court dated May 26, 2006 is MODIFIED as follows: Defendant Kelli Pettersson shall have sole legal and physical custody of Maya Pettersson (dob: 04/05/02). BY THE COURT: ~' Distribution: ~e Adams, Esq., 64 S. Pitt St., Carlisle, PA 17013 ~eresa Barrett Male, Esq., 513 N. Second St., Harrisburg, PA 17101-1058 fu,O'& O~ l'SJ i , ifINW:1ASio.JN3d AlNnCO "",',r::a'ln::) I ( 98 :01 WV 9 I 8nv 900l AtJ\tlONOH10'dd 3Hl :10 38wo.o::rll:J . ERIC WENGRZYN, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 06 - 1867 CIVIL TERM KELL! PETERSON, : CIVIL TERM - CUSTODY Defendant JOINT MOTION FOR ENTRY OF STIPULATED ORDER REGARDING CUSTODY ~ AND NOW, this 1 b day of fiv~2006, upon the joint motion of Plaintiff and Defendant, and to implement an agreement of the Parties, the parties hereby request entry of a custody order providing that Mother, Kelli Pettersson, shall have sole legal and physical custody of Maya Pettersson, date of birth, April 5, 2002. LJ3~/L Theresa Barrett Male, Esquire 513 N. Second St. Harrisburg, Pa. 17101 (717) 233-3220 Attorney for Mother Dated: ~/~ M~ Adams, Esquire . Pitt St. C lisle, Pa. 17013 (717) 245-8508 Attorney for Father Dated: 1)\ \lo '00