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Home My WebLink About06-4219 . -~ BLAIN D.IDLEMAN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NICOLETTE B. RAJK CIVIL ACTION - LAW ~ NO. ~-4:U9 (!,u~L't~ : IN CUSTODY ( Defendant COMPLAINT FOR CUSTODY AND NOW, this ~ day of July, 2006, comes Plaintiff, Blain D. Hileman, by and through his attorney, The Law Office of Darrell C. Dethlefs in support of his custody complaint avers the following: 1. The Plaintiff, Blain D. Hileman, is an adult individual with a residence located at 2249 Orchard Road, Camp Hill, Pennsylvania 170 II. 2. Defendant, Nicolette B. Rajk, is an adult individual with a residence located at 4 West Avenue, Enola, Pennsylvania, 17025. 3. Plaintiff and Defendant are the natural parents of Alyssa M. Hileman, born July 17,2000 hereinafter referred to as "Child." 4. Since birth, the Child here resided with Plaintiff and Defendant until October 2005 and then with Defendant at 4 West Avenue, Enola, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions ofthe Soldier's and Sailor's Civil Relief Act of 1940 or any amendments thereto. 6. Plaintiff and Defendant are citizens of the United States of America. 7. The best interest in the permanent welfare of the children will be served by granting primary custody to the Plaintiff, Blain D. Hileman. - ~ . WHEREFORE, Plaintiffs request that the Court grant primary physical custody of the children to Plaintiff, Blain D. Hileman. ~~ Attorney ID # 58851 Law Office of Darrell C. Dethlefs 2132 Market Street CampHiIl,PA 17011 (717) 975-9446 ATTORNEY FOR THE PLAINTIFF - BLAIN D. HILEMAN, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. CIVIL ACTION - LAW NICOLETIE B. RAJK, Defendant NO. IN CUSTODY VERIFICATION I hereby verify that the statements off act made in the foregoing Complaint for Custody, are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the criminal penalties contained in 18 Pa C. S. Section 4904, relating to unsworn falsification to authorities. Date: ;; ~ 01, - 0 tft 8I~Dd~ Blain D. Hileman .---" C) c. ~ - I( f') ~ rn. .l.l . D ~ Lv () \)< r- ~ ~ ~ "3 J .-. "\~ -~ C..~ . ,~t .' .-.- ...c_ c- ~'~ J (..,:: ........1 ~"~- ., . . BLAIN D. HILEMAN PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 06-4219 CIVIL ACTION LAW NICOLETTE B. RAJK DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, August 17, 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, September 08, 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. 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 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 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 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 ~ ~ -P /?f}';pW ~ ?~. N,!. .~ -? ;,~,_;tV ~~ 7Cl-:!/:f, /~~~r~~ <?~,~/.~ VIN'iAlASNN3d AlNnn'"" ",' '~'-'^In"'" I". .,' "',-,-::':i~jr V 60 :21 Wd B I gOV 900l Ai:lV10NOHJ.Ci:!cl 31-tl :10 38H,Q-(J3ll:l Plaintiff I J~E:{;EIV }4~U I SEP 1 8 2006 IBY: fiJi IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-4219 CIVIL TERM ./" CIVIL ACTION - LAW BLAIN D. HILEMAN, v. NICOLETTE B. RAJK, Defendant IN CUSTODY No. 06 -LRL,q ~ C ivi (( e;'m ORDER OF COURT AND NOW, this ~ day of September, 2006, the Court takes judicial notice of the prior action filed in this matter at 05-6698 in which Mother is the Plaintiff and Father is the Defendant. Accordingly, the Complaint for Custody filed at No. 06-4219 Civil Term shall be treated as a Petition for Modification of the prior Order of February 2, 2006, at No. 05-6698 Civil Term. Further pleadings in this matter should be filed to No. 05-6698 Civil Term. The Complaint at No. 06-4219 Civil Term is consolidated therein. BY THE COURT: Dist: \j \"I~.r;i/\l"S.\lN 3d I ! ~ Jr,,"'''--' (1'" .I;, j-'o'^'nt"\ l\LI~ "_:' . ...., ':'::klf'l. V 9 2 :01 WV ZZ d3S 900l },WIONOHLOl::id 3Hl :10 30l:3J(.t-(J311:J COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BLAIN D. HILEMAN Plaintiff : File No. 06-4219 v. NICOLETTE B. RAJK Defendant CERTIFICATE OF SERVICE I, Patrick M. Duggan, Jr., hereby certify that on November 13,2006, a true and correct copy of the foregoing Subpoena was served via hand delivery on the following: Christine Frenchek, Principal East Pennsboro Elementary School 840 Panther Parkway Enola, P A 17025-2065 Date: I/J/3~ I I Custodian of Records East Pennsboro Elementary School 840 Panther Parkway Enola, P A 17025-2065 By:f{Jj~~ Patrie M. Duggan, Jr., urier Law Office of Darrell C. Dethlefs 2132 Market Street Camp Hill, PA 17011 (717) 975-9446 r--.:> <.:;:::;) C:::l =, ....",. ('5 ~ w co . '") Bryan W. Shook, Esquire ID # 203250 The Law Office ofDarrel C. Dethlefs 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone - (717) 975-9446 Fax - (717) 975-2309 BShook@dcdlaw.net Attorney for Plaintiff BLAIN D. HilEMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. No: 06-4219 - CIVIL TERM NICOLETTE B. RAJK, Defendant CIVil ACTION - LAW IN CUSTODY PRAECIPE FOR ENTRY OF APPEARANCE To the Prothonotary: Please enter my appearance on behalf of Plaintiff, Blain D. Hileman, in the above captioned matter. All papers may be served on the undersigned at the address set forth above for purposes of this action. B~::iJll - Dated: //-/7- ~ 006 It ~. v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No: 06-4219 - CIVIL TERM BLAIN D. HILEMAN, Plaintiff NICOLETTE B. RAJK, Defendant CIVIL ACTION - LAW IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Praecipe for Entry of Appearance, was hereby served by depositing the same within the custody of the United States Postal Service, First Class, postage prepaid, addressed as follows: Nicolette B. Rajk 29 Cheyenne Court Windsor, PA 17366 Respectfully Submitted, Dated: 11-/7- 0, THE LAW OFFICE OF DARRELL C. DETHLEFS By: ~~~ cv.ftL-- ~~~;~O;,ESqU~e I.D.# 203250 2132 Market Street Camp Hill, PA 17011 (717) 975-9446 Attorney for Plaintiff r-' c::-) ,:.:.:>- ~..:;.j""" :;.'-0: o ...,.;;:;. -..l ~=t (,\)