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HomeMy WebLinkAbout06-2266 EUGENE M. CHABAK Plaintiff, :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA v. :No. ~ b - J, :L II & Civil Term WENDY L. CHABAK, Defendant :CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, this day of , 2006, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at on the day of , 2006, at .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. FOR THE COURT, By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the American with Disabilities 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 LA WYER AT ONCE, IFYOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUR WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166 .-' EUGENE M. CHABAK Plaintiff, :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA v. . :No. OitJ - ;;L.;l." ~ Civil Term WENDY L. CHABAK, Defendant :CIVIL ACTION - CUSTODY COMPLAINT FOR CUSTODY I. Plaintiff is Eugene M. Chabak, an adult individual who resides at 608 E, Winding Hill Road, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Wendy 1. Chabak, an adult individual who resides at IS E. Glenwood Drive, Camp Hill, Cumberland County, Pennsylvania. 3, Plaintiff seeks custody of his children Kyle M. Chabak, born May 2,1997, and Haylee R, Chabak, born June 1,2004, 4. The children presently reside with Defendant at IS E. Glenwood Drive, Camp Hill, Pennsylvania. 5. Since the children's birth, they have resided with the following persons over the past five years: Name Address Date Eugene Chabak & Wendy Chabak 68 W. Winding Hill Road 05/97 to 3/29/06 Mechanicsburg, PA 17055 Wendy Chabak Walter Leibig & Helen Leibig 15 E. Glenwood Drive 3/29/06 to present Camp Hill, PA /701/ 6. The natural mother of the child is Wendy Chabak, currently residing at the above stated address. 7. The natural father ofthe child is Eugene Chabak, currently residing at the above stated address. 8. The relationship of the Plaintiff to the child is that of natural father. 9. The relationship of the Defendant to the child is that of natural mother. 10. The Plaintiff has not participated as a party or in any other capacity, in other litigation concerning the custody ofthe children in this or any other court. 11, Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 12, The best interests and permanent welfare of the child will be served by granting the relief requested because the Plaintiff is natural father of the child and can best care for the children. 13. Plaintiff is being denied custody as well as communication with the children. 14. Defendant continually disparages Plaintiff in front of the children. 15. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the children have been named as parties to this action. No other persons are known to have or claim to have any right to custody or visitation of the child other than the parties to this action. WHEREFORE, Plaintiff requests your Honorable Court to enter a custody order which grants Plaintiff full physical and legal custody, in the alternative, to grant Plaintiff equally shared custody. Respectfully submitted, ~J.4 Iou Dat I - L-/~ul7~ ;1A,.~ZA,.j&(I[.{ Kirstin M. Sweigard, Esquire P.O. Box 1168 Camp Hill, PA 17001 (717) 554-5008 Attorney for Plaintiff .' EUGENE M. CHABAK Plaintiff, :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYL VANIA v. :No. Civil Term WENDY L. CHABAK, Defendant :CIVIL ACTION - CUSTODY VERIFICATION I verifY that the statements made in the foregoing Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S. Section 4904, relating to unsworn falsification to authorities. 'I Z'I-06 Date fb/')1 ~t ugene M. abak ""'~ ;;.; ~ ~ ;N c- 0 ~ "S. ',' ! " ,.J, "" - 1--' <:::0 D "\- ~ <+ , , EUGENE M, CHABAK PLA]NT]FF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V, 06-2266 CIVIL ACTION LAW WENDY L. CHABAK DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, May 03, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy. Esq. , the conciliator, at MDJ Manlove, 1901 State St., Camp Hill. PA 17011 on Friday, June 02, 2006 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 age five or older may also be present at the conference, Fai]ure 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 scheduled hearin!!. FOR THE COURT. By: Isl Melissa P. Gree Es Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of ] 990, 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 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 ] 7013 Telephone (7] 7) 249-3 ]66 . ~p $- ~ ~ "Jr?-C$' .~ 2' ~tJ 't-.V~~U; '1t?- ['-9 ~fz:? 2. ~'P~~-;r:p "l17'E:"? ~ ,\L\I["1'" . \:i ';:~]/\jnJ "0 ? I'd (' 1"'./ DWl7 (, :J ,';" t,,- )\'~'l' .Hi:"'", "I<. (, "'. ......" ::ILli ...Jr"1 At!';iJJ,)I''i\....:' ....' .... -IV , -','," , ,"- ~'-'-Jl',J :i ,_;; ~~ :-.!./ ;, )~- I:J EUGENE M, CHABAK PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, 06-2266 CIVIL ACTION LAW WENDY L. CHABAK DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, May 05, 2006 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy. Esq. , the conciliator, at MDJ Manlove, 1901 State St., Camp Hill, PA 17011 on Friday. June 02, 2006 at 2:30 PM 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 parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to schedllled hearin!!. FOR THE COURT. By: /s/ 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, 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 HAVE 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 ~cI . J P' cI iYrfJ{ ~~-/ .}o (. . ~ p~'- . of' ~ ~~. ~. ) (;U j) (Y7 d''!P () !' ()' I; 'tJt ()11 U/c . e, i ~ '" J: *:0 ~~.. ~ ~~ ~c '"0 12.,0 ~ c :x 5~ :>2 -:: ~ ~ ~ -.: EUGENE M. CHABAK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2266 CIVIL TERM v. CIVIL ACTION - LAW WENDY L. CHABAK, IN CUSTODY Defendant ORDER AND NOW; this ')....1 day of July, 2006, pursuant to Cumberland County Local Rule 1915.5.1, the Conciliator hereby continues generally the Custody Conciliation Conference presently scheduled for Friday, July 28, 2006 at 10:30 a.m. upon concurrence of counsel. The matter may be reschedule for conciliation upon petition. ::R T:;r!~Lv-~ Melissa Peel Greevy, Esquire Custody Conciliator Dist.: John W. Purcell, Esquire, 1719 N. Front Street, Harrisburg, PA 17102 Kirstin M. Sweigard, Esquire, P. O. Box 1168, Camp Hill, PA 17011-1168 Taryn Dixon, Court Administrator, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 :280120 >- ~,'- ~ I,.U~ t..);: U\...~) ,,-:c 151--- 6?? ::1 a: w:::lU FE lL. o r- C') N x: 0- N C"J Ck::: cd: x: l"- e::> = C'--l r.: z ::::>-r- n~ :--')Z :~ .~ ,:...J ,_/" ~~~ ;!.JU] .JJr :::?- ,.... ~ (.)