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HomeMy WebLinkAbout06-5420 .: SANDRA L. BUCKLEY-RUSNOV, PLAINTIFF v. IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA No.30131-S-JQq<6 CORNELIUS J. RUSNOV, DEFENDANT CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before the Custody Conference Officer, J tJ d i-C~ C A \ ~ 1l'\J , Esquire, on the ;u. day of ~ p..:p+ 19 q~, at ~ fL.M., at a Pre-Hearing Custody Conference at DA\JrL(~~ C~1 to lJ~! , L{ 1:..U..f J ur, Pennsylvania. 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 shall also be present at the Conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. For the Court, Date of Order: f? I} ,I ~ ~ By: \\ LL.t(b ~l la tistOdy Conciliator ~ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Dauphin County Lawyer Referral Service 213-A North Front Street Harrisburg, PA 17101 (717) 232-0581 .i. SANDRA L. BUCKLEY-RUSNOV, PLAINTIFF IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA v. NO. 3~3l-S-Jqq?t CORNELIUS J. RUSNOV, DEFENDANT CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT You, Cornelius J. Rusnov, Defendant, have been sued in Court to obtain custody, partial custody or visitation of the child: Niles A. Rusnov. You are ordered to appear in person at the Dauphin County Court House, Front and Market Streets, Harrisburg, Pennsylvania, on the day of 1998 at o'clock .m. If you fail to appear as provided by this Order, an Order for custody, partial custody or visitation may be entered against you or the Court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Dauphin County Lawyer Referral Service 213 North Front Street Harrisburg, Pennsylvania 17101 Phone: (717) 232-7536 BY THE COURT: J. SANDRA L. BUCKLEY-RUSNOV, PLAINTIFF IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA v. NO. 3&3l-S-lqq~ CORNELIUS J. RUSNOV, DEFENDANT CIVIL ACTION - LAW IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Sandra L. Buckley-Rusnov, social security no. 175-54- 0570, residing at 1839 Rudy Road, Harrisburg, Dauphin County, Pennsylvania 17104. 2. The Defendant is Cornelius J. Rusnov, social security no. 179-44-9218, residing at 1839 Rudy Road, Harrisburg, Dauphin County, Pennsylvania 17104. 3. Plaintiff seeks primary custody of the following child: NAME PRESENT RESIDENCE D.O.B. Niles A. Rusnov 1839 Rudy Road November 6, 1992 Harrisburg, Pennsylvania The child was not born out of wedlock. The child is presently in the custody of Sandra L. Buckley-Rusnov, who resides at 1839 Rudy Road, Harrisburg, Pennsylvania. During the past five years, the child has resided with the following persons and at the following addresses: NAME RESIDENCE DATE Sandra L. Buckley-Rusnov and Cornelius J. Rusnov 1839 Rudy Road 11/06/92 - Present Harrisburg, Pennsylvania .' The mother of the child is Sandra L. Buckley-Rusnov, currently residing at 1839 Rudy Road, Harrisburg, Pennsylvania. She is married. The father of the child is Cornelius J. Rusnov, currently residing at 1839 Rudy Road, Harrisburg, Pennsylvania. He is married. 4. The relationship of Plaintiff to the child is that of mother. The Plaintiff currently resides with the following person/persons: NAME Niles A. Rusnov RELA TIONSHIP Son Cornelius J. Rusnov (separated within the residence) Husband 5. The relationship of Defendant to the child is that of father. The Defendant currently resides with the following person/persons: NAME Niles A. Rusnov RELATIONSHIP Son Sandra L. Buckley-Rusnov (separated within the residence) Wife 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 does not know of a person not a party to the proceedings who has physical custody of the child or 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. 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, the Plaintiff, Sandra L. Buckley-Rusnov, requests the court to grant primary custody of the minor child, Niles A. Rusnov, to her. JAMES, SMITH, DURKIN & CONNELLY Date: IJ-JLf-98 By: J 1 H . b 17108 (717) 238-4776 PA 1.0. No. 15615 VERI FICA TION I verify that the statements made in this Pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 P~C.S. section 4904 relating to unsworn falsification to authorities. .,~~ '\ Dat~ 1J-/tf-9g -", Litl/~{/fN Sandra L. Buckley-Rusnov, Plaintiff .J:; . c::: ." .,,;:::- m- ;e:l': :.:co 110.40 c::: Z -..,. -< ~ . it " IIr ~ ;: 00 A:) -f""'rJm :Z:."'t'to Com :at_ 0""'< -lorn ......,0 ~ -<-~ ~. ~ VI:. :t ~-"._~ SANDRA L. BUCKLEY-RUSNOV, Plaintiff Judith A. Calkin, ~b~~__ Date Submitted: 1.2/1.5/98 \ /i C l;;l \ IlP I") 6 IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA . , vs. No. 3231. S. 1.998 CORNELIUS J. RUSNOV, Defendant IN CUSTODY - 0::> INSTRUCTIONS x Case settled-see attached Order Case continued Case not settled Motion to Dismiss No Interim Order See attached Interim Order Assign to Judge Reassign to Judge L_ ~ SANDRA L. BOCKLEY-ROSNOV, Plaintiff IN THE COURT OP COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA vs. NO. 3231 S. 1998 CORNELIOS J. ROSNOV, Defendant CHILD CtrSTODY TEMPORARY ORDBR OP COURT AND NOW, to wit this~day of ~J&~n1l7C~, 199B, the parties and their respective counsel, having appeared for a custody conference on December 10, 1998, before Judith A. Calkin, Bsquire, and having reached a temporary agreement with regards to the best interest and welfare of their minor child, it is hereby ORDBRED AND b. Mother will have the balance of the time with DBCREBD aa follows: 1. It is the intention of the parties and the parties agree that they will share joint legal custody of Niles A. Rusnov, born November 6, 1992. 2. Mother, Sandra L. Buckley-Rusnov, and father, Cornelius J. Rusnov, will share physical custody on the following schedule: a. Father will have the child on alternating weekends from Friday after school until Sunday at 5:00 p.m. and on Tuesday and Thursday every week from after school until the next morning. the child. 3. Both parents will have the right of first refusal to care for the child should the custodial parent be unavailable for a ~riod of 2 1/2 hours or more. _.. , 4. In 1998 Father will have the child from December 22, 1998, after school until December 24, 1998 at 11:30 a.m. Mother will have the child from December 24, 1998 at 11:30 a.m. until December 26, 1998 at noon. S. During any period of custody or visitation the parties to this order shall not possess or use any controlled substance, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this prohibition. 6. Each parent shall be entitled to reasonable telephone contact with the child when he is in the custody of the other parent. 7. Both parents shall refrain from making derogatory conunents about the other parent in the presence of the child and to the extent possible shall prevent third parties from making such conunents in the presence of the child. 8. The parents agree to cooperate in a custody evaluation to be perfonned by Reigler Shienvold & Associates. Each will pay 1/2 of the cost of the evaluation. 9. If any party feels the need for another conference a full hearing after the evaluation on this matter, that party shall be responsible for requesting same. All such requests shall be made with this Honorable Court by filing the appropriate motion with the Office of the (- (::J :1;', ~, c;.."? ,.....""\ (""I - if .. . , \J '0 :;:S"~('\ C,' ~ -r"\ C' -'^ .....r:...,..,-t"i' -b. C1 -:; _.:~~ rn ."." c.? ~ :P' ~ --:: - cP 7J: --------- IfviAGED IN TliE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLV ANIA SANDRA L. BUCKLEY -RUSNOV Plaintiff : No. 3231 S. 1998 ~ = c,~:::;J .~'T"-\ -~ '"j ::.. CORNELIUS J. RUSNOV Defendant : CUSTODY : Action-Law !'.-- ,:,,; c..> (....:' vs. -~:." ~'? N O'l PETITION FOR EMERGENCY SPECIAL RELIEF - CHANGE OF VENUE AND NOW, comes the Defendant / Petitioner, Cornelious J. Rusnov, and files this Emergency Petition for Special Relief - Change of Venue and in support thereof avers the following: 1. The Petitioner is Cornelius J. Rusnov, who is the Father of Niles A. Rusnov. age 13 and born November 6, 1992 and Theo C. Rusnov, age 7 and born June 12. 1999, hereinafter "Children," and currently resides at 1110 Apple Drive, #1 Mechanicsburg, Pennsylvania 17055. 2. The Respondent is Sandra L. Buckley-Rusnov, who is the Mother of the Children, and is believed to currently reside at 4105 Hollow Road Phoenixville, Pennsylvania. 19460. 3. Petitioner is seeking cmergency temporary lcgal and physical custody of the Children, in Cumberland County, however, a Custody Action was commenced in 1998 in Dauphin County. (See attached Cumberland County Petition and Complaint, and Dauphin County Temporary Order). 4. For at least the past five years the parties have resided together in Cumberland County. 5. Another Child was born to the parties in 1999 in Cumberland County, for which Dauphin County has no jurisdiction over. WHEREFORE. the Petitioner. by and through his counsel, respectfully requests that this Honorable Court grant Petitioner a change in venue from Dauphin County to Cumberland County. Respectfully Submitted by ,..- to ey for Derek #83284 319 South Front Street Harrisburg, P A 17104 (717) 9] 9-4002 .1 :2 SANDRA L. BUCKLEY-RUSNOV, Plaintiff IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA VB. NO. 3231 S. 1998 CORNELIUS J. RUSNOV, Defendant CHILD CUSTODY TEMPORARY ORDER OF COURT l'T'pm t~ , AND NOW; to wit t:.his,/~}--" day of L'lJOrPta!Jtr--, 1998; the parties and their respective counsel, having appeared for a custody conference on December 10, 1998, before Judith A. Calkin, Esquire, and having reached a temporary agreement with regards to the best interest and welfare of their minor child, it is hereby ORDERED AND DECREED aa follows: 1. It is the intention of the parties and the parties agree that they will share joint legal custody of Niles A. Rusnov, born November 6, 1992. L. Mother, Sandl:-a Buckley-Rusnov, and father, Cornelius J. Rusnov, will share physical custody on the following schedule: a. Father will have the child on alternating weekends from Friday after school until Sunday at 5:00 p.m. and on Tuesday and Thursday every week from after school until the next morning. b. Mother will have the balance of the time with the child. 3. Both parents will have the right of first refusal to care for the child should the custodial parent be unavailable for a .period of 2 1/2 hours or more. 4. In 1998 Father will have the child from December 22, 1998, after school until Decen~)er 24, 1998 at 11:30 a.m. Mother will have the child from December 24, 1998 at 11:30 a.m. until December 26, 1998 at noon. 5. During any period of custody or visitation the parties to this order shall not possess or use any controlled substance, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this prohibition. 6. Each parent shall be entitled to reasonable telephone contact with the child when he is in the custody of the other parent. 7. Both parents shall refrain from making derogatory comments about the other parent in the presence of the child and to the extent possible shall prevent third parties from making such comments in the presence of the child. 8. The parents agree to cooperate in a custody evaluation to be performed by Reigler Shienvold & Associates. Each will pay 1/2 of the cost of the evaluation. 9. If any party feels the need for another conference a full hearing after the evaluation on t,his matter, that party shall be responsible for requesting same. All such requests shall be made with this Honorable Court by filing the appropriate motion with the Office of the /.:i~,;',.~ ,~',~"".' ;t"" . ,~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV ANIA CORNELIUS 1. RUSNOV Plaintiffs :No. VS. SANDRA L. BUCKLEY-RUSNOV Defendant : CUSTODY : Action-Law ORDER OF COURT AND NOW, this _ day of . 2006. upon consideration of the attached Plaintiff's Complaint for Custody and Plaintiff's Petition for Emergency Temporary Custody_ it is hereby ordered and decreed that the Children, Niles A. Rusnov, age 13 and born November 6. 1992 and Theo C. RUSIlOV, age 7 and born June 12, 1999, shall be returned to their residence at 1110 Apple Drive #1. Mechanicsburg, Pennsylvania and be placed in the sole legal and physical custody ol'the Plaintiff pending a hearing and/or conciliation conference on the matter. By the Court: ,Judge 3 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV ANIA CORNELIUS J. RUSNOV Plaintiff :No. vs. SANDRA L. BUCKLEY -RUSNOV Defendant : CUSTODY : Action-Law NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in cOUli. If you wish to defend against the claims set forth in the following pages. you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the comi. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff You may lose money or property or other rights important to you. including custody or visitation of your children. When the grounds for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Cumberland County Prothonotary. IF YOU DO NOT FILE A CLAIM fOR ALIMONY, DIVISION OF PROPERTY, LA WYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR ('ANNen- AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY AVENUE CARLISLE. PENNSYLVANIA 17013 ] (800) 990-9] 08 (717) 249-3166 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CORNELIUS J. RUSNOV Plaintiff : No. vs. SANDRA L. BUCKLEY-RUSNOV Defendant : CUSTODY : Action-Law PETITION FOR EMERGENCY TEMPORARY CUSTODY AND NOW. comes the Plaintiff: Cornelious J. Rusnov, and files this Emergency Petition for Custody and in support thereof avers the following: I. The Plaintitfis Cornelius J. Rusnov, who is the Father of Niles A. Rusnov, age 13 and born November 6. 1992 and Theo C. Rusnov. age 7 and born June 12, 1999, hereinafter "Children." and currently resides at 1110 Apple Drive, # 1 Mechanicsburg, Pennsylvania 17055. hereinafter "Plaintiff." 2. The Defendant is Sandra L. Buckley-Rusnov. who is the Mother of the Children, hereinafter "Defendant" and is believed to currently reside at 4105 Hollow Road Phoenixville, Pennsylvania, 19460. 3. PlaintifT seeks emergency temporary legal and physical custody of the Children. 4. On August 25th, 2006. the Defendant. with one of the parties' Children went to pick up the parties' other Child at her sister's home at 4105 Hollow Road Phoenixville. Pennsylvania, 19460. 5. On August 25th. 2006. the Defendant. without any notice, telephoned the Plaintiff and said she would not be returning with the Children and she would be enrolling the Children in school at her location. 6. There aTe no allegations of abuse or neg1ccL 0 f tne Children or between the parties in this case. However, the Defendant ha~ a history of (.{cprcssion, has been on mm1crous antidepressants over the yea;-s and b(.:'cn for "aid depression. 7, The Ch1]drcn were to have start..::d scl '>01 i;1~he !\1echanicsburg school district on August 28. 2006. 8. Plaint) ff fears for the errlOtional and physical wc\lbeing ofthe Children and is seeking the Children's return to the parties' residence. 'will allovv' rhem to \1cgin school in a tinlcly 111.<3.(',nc,". rl EREFORE. the Plaintiff rCSDcct r requests that this Honorable Court grant sc)]e legal and pl1ysical. cu::'ludy ()rder Children's ,'durn to pending Courl Jf in the alternative Order a Custody Conciliation on an Emergency basis. I verify that the statements made in the foregoing Petition for Ernergcncy Custody are true and co,rrcct. 11.Jnderst~nld tbat false ~~tatcrnents . are rnad(: ~:ubject to the per'IC.:dties e>f relating to unsworn i'alsillcation to authorities. /) C~ F'''t \~,./ -'" , , ' ' J " /' . _.".,,:: ,~ ~ {\ \. ' : \___/, " _<~_r==-,-:.:,-ii:::::-'-~ , ,'\L\'/V~LUJ.;~~~~~,~\_h"/!':=k "\'~~ (S /,L Curneli us .i. l~ usnov ' )'lk i </ ~'\\ //. / 1'1:.-" / f i !..,- ./ / &j, /1 //'," , ,,,,' y\,' , . /, \ !?,espccH uily Suhmltted bY,)(kf..A.c-.'!j---' p~., V~~__. Attorney fg': Plaintiff n 1 {' ../,. ,- . Uerel<. \,.!}vQ!CL t:squlre. #83284 3] 9 South Front Street Harrisburg. P A 17! 04 (717) 919-4002 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA CORNELIUS J. RUSNOV A Plaintiff :No. vs. SANDRA L. BUCKLEY -RUSNOV Defendant : CUSTODY : Action-Law 0RPE~R_QF COURT AND NOW. ________, upon consideration of the attached Complaint. it is hereby directed that the pmiics and their respective counsel appear before. , the conciliator. at on at for a Pre-Hearing Custody Conference. At such conference. and 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. AU children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent order. The court hereby directs that parties to furnish any and all Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to the scheduled hearing. FOR THE COURT By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans 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. IF YOU DO NOT HA VE A LAWYER 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 2 LIBERTY A VENUE CARLISLE, PFNNSYLV ANIA 17013 1 (800) 990-9108 or (717) 249-3166 IN THE COURT OF COMMON PLE1\.S CUMBERLAND COUNTY, PENNSYLV ANIA CORNELiUS .1. R.USNOV ?laintl iT , r\~: c)~ "IS. SANDRA L. BL'CKLEY -RUSNOV Detendant l'ODY " I\,ction- !' j'\,'I"Cf.' T..Q fnl:-'C,--.!\.lI.... A 'i',Tj' r'" 'II' ,1TRIGT f're< "'\j C;, t ,.,::", ; n ).'-1 t.: " ..Y }'\ J" "J 'l.../ ~"I... V t, !' Hi 1 ,') Yau have been in court. I f you \\ish ;0 ;lgainst ,he claim.s set in the follO\ving pages, you must take prornpl ;;ctior:. ule warned that if l~lil to do so. the case mav Droceed \'vithoul vou a decree of divorce or annulment may be entered .) I.." .., against you the court. A judgmcn; nm; alSO be entered against you l(X any other claim or relief requested in these papers by the plainrilT "y'ou may lose money or property or other Tights important to you, including custoc:y or visitation of your children. When the grounds rUT (E'/met' is indigr:itics ,l)" ,nctr;ev,-~bk breakdown of the marri2ge. you may rcque~;t counseling A list or ;;ni'ri cmnlse10rs is available in tbe Office of the (~un1bcrlalld P'rothOH('tlarv" If YOU DO NOT FILE A CLAIM FOR }\UtviONY, DIVISION or PROPERTY, LA\V'y'ER FEES OR EXPENSES BF RL~ A DIVORCE OR ANNULMENT IS GR/i,N YOU ]\;1A Y (II TO CLAIiVl ANY THEM. YOU Sl TAKE TlilS PAPLR. NOT H/\V ~ A LAWYER OR \11\1 THE ICE SET FORTH BELO\V F1ND \N ' Af ONC-:. iF VUU DO IO OR] HONE \/VIIERE YOU C/\ GET LEGAL .LP CUMBERLAND TNTY B/\R ASSOCIA TION 2 UBITTY 1\ CARUSU P, 17013 l{gOO; !)<)()-9 );,; (717) :'>:19-3166 " IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV ANIA CORNELIUS J. RUSNOV Plaintiff : No. vs. SANDRA L. BUCKLEY -RUSNOV Defendant : CUSTODY : ,,1.ction- Law COMPLAINT FOR CUSTODY 1. The Plaintiff is Cornelius J. Rusnov, who currently resides at 1110 Apple Drive, #1 Mechanicsburg, Pennsylvania 17055, hereinafter "Plaintiff." 2. The Defendant is Sandra 1. Buckley-Rusnov, hereinafter "Defendant" and is believed to currently reside at 4105 Hollow Road PhoenixvilIe. Pennsylvania, 19460. 3. Plaintiffs seek shared legal and primary physical custody of the following Children: Niles A. Rusnov. age] 3 and born November 6. 1992 Theo C. Rusnov, age 7 and born June 12, 1999 The Children were born during wedlock. 4. During the past five years. the Children have resided with the following persons and at the following addresses: From the year 2000. with both parents at 1110 Apple Drive, Mechanicsburg, Pennsylvania 17055. to August 25th, 2006. With Mother from August 25th. 2006. to the present. The Father currently resides alone at the Children's home. 5. The relationship of the Plaintiff to the Children is that of Father to Sons. 6. The relationship of Defendant to the Children is that of Mother to Sons. 7. Plaintiff has participated as a party in litigation concerning the custody of the Children . . in this or another court. (SEE THE A TT ACHED ORDER from Dauphin County). The Parties reconciled after the date of the Temporary Order and had their second Child. a) Plaintiff has no information of a custody proceeding concerning the Children pending in a cOUli of this Commonwealth or any other state. b) Plaintiff does not know of a person not a party to the proceedings who has physical custody of the Children or claims to have custody or visitation rights with respect to the Children. 8. The best interest and permanent welfare of the Children will be served by granting the relief requested because: It is in the best interest of the Children in that their financial, physical. and emotional well being shall be served by Children's Father to have sole legal and primary physical custody of the Children with Mother to have partial physical custody/visitation with the Children. 9. Each parent whose parental rights to the Children have not been terminated and the person who has physical custody of the Children have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the Children will be given notice of the pendency of this action and the right to intervene: There are no other persons having a claim of right to custody. WHEREFORE, Plaintiff requests this Honorable Court to grant the Father sole legal custody and primary physical custody of the Children with Mother to have partial physical custody/visitation with the Cr,ildren. . .. 1 ve,') that statements In ;)' Cmnpbin1 C'ustJdy arc true and correct 1 understand that nllsc stater':nts h'~rcin T'C :TIace subject tc,; 'the penalties of relating to ijrlSV,Crn fa: ,;: rica', ion to authorities. /~ . , t 1 \ , n ~\ \ \ I ! (,., \ \, / 8/" '. I. I \ ' \" ~"-"'-~~/ " ---, ~^' ~/Q-:t~~'lQ.~c.l.1.~,~-A):Y/Y~/'.~._._6' '-:l-.t;/ (,b {"}!'l)C1j', IS' I PiIS'rl('V ,)"t"," ' \..,' " ,. ,,,,.' .'-... . J ~ '" '" '. ~t (---- .' .- \, /' , " /~ ' :i;1 '" /!' ., ~ I 1,/, /'i,; 1....'1 ;.1 /1.,,, ' v ~ (, L...: l'\ ;~...---v I, ... _.....,/:____._.. _. __,___' l_____",_______ A'itorncy t~)r j~laintiff Derek Ccrdi-eL Esquire. mn284 :. 9 South Front Street tlarrisburg. 17104 (717) 9 9--!-002 R_cspcc-tl~ lv, , " . . ~ IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA SANDRA L. BUCKLEY -RUSNOV Plaintiil : No. 3231 S. 1998 YS. CORNELIUS J. RUSNOV Defendant : CUSTODY : Action- Law QRDhR Or: COURT AND NOW, this day of . 2006. upon consideration of the attached Petition for Emergency Special Relief - Change of Venue, it is hereby ordered and decreed that venlJe in the above captioned matter is changed from Dauphin County to Cumbcriand County. By the Court: ,Judge 3 - . t!J .-. [} Copies Distributed . n<tt,. CJ) /Oy_ tnl~"'" il/llS IN THE COURT OF COM~A'fflPI-mtCtjm~TY, PENNSYLVANIA CORNELIUS J. RUSNOV Defendant : CUSTODY : Action-Law o ~ c. ..,., -0 :1:. rn-' :;r. -x. ::::0 :P' c:> ,.- .....- -.... ..t~~ -~ ~ .,.. ~ '"'0 , vs. -0 ~ -0 ::Do';O ~-r\f""\ :,t:-r\C"') O-rn ::;t:n- or"'.c::: -{om :;p."",O :;x:l -< SANDRA L. BUCKLEY-RUSNOV Plaintiff : No. 3231 S. 1998 - --"'i... Ci/ s:- #" ORDER OF COURT AND NOW, this L day of~, 2006, upon consideration of the attached Petition for Emergency Special Relief - Change of Venue, it is hereby ordered and decreed that venue in the above captioned matter is changed from Dauphin County to Cumberland County. By the Court: .~ A~l 1 , Judge --2 J ~ ct> \ ~ - ~ \he tor~ \6 a \ hir~Y cQrtif)' \b~nnv *' ....' \rUiI ~ corrtc\ """1"' _ tiel. I :Jf.1J.!!rV e.. prot~funotary d:J ~ 1M \CI ",: ~\L CLJ~ ~\)){\ n I Dlt ' ~O~ U(,~ 1 t~ \+\ 1\ 1'\)1\3 ~Ulr~, 5\Cl. ~ ~ ----i-r-~Sly~ ~S9\J1Y"~, dL.\ oJ ~ S+y-~ \, 0 \ \ ~ (:) ~ ....... t ....... k) (1 r--<' . 0 0 -n ....... ( ,'\ ....., -.. 0 -r ~ ...0 fll )oJ V - c ~ C> ~ - ; .. - - ' J; .. ..,- L:,) .-' :n ~ , C~. .< Dauphin County ROA Report Case: 1998-CV-3231-CU Current Judge: Scott A. Evans Sandra L Buckley Rusnov vs. Cornelius J Rusnov Date: 9/14/2006 Time: 01 :13 PM Page 1 of 1 Date 7/24/1998 8/30/2006 8/31/2006 9/1/2006 ot. -51.J~ CioiL User: LGARCIA I J"...."..--' '" -:::::- ~'I' L'-'-D-, ':.1. _~ 1 V .c...,' SEP 1 5 2006 IBY:~( CustodyNisitation Judge New Civil Case Filed This Date. No Judge See Docket Book for prior entries. No Judge Petition for Emergency Special Relief - Change of Venue, filed No Judge Judge assigned to case. Scott A. Evans Upon consideration of the attached Petition for Emergency Special Relief- Scott A. Evans Change of Venue, it is hereby ordered and decreed that venue in the above captioned matter is changed from Dauphin County to Cumberland County. See ORDER filed. Copies distributed 9/1/2006 The above action transferred to the Court of Common Pleas of Cumberland No Judge County. ****NO MORE ENTRIES CASE TRANSFERRED**** No Judge TO THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY SEP 1 4 moB I fMlreby cirtify Ul&t the foreQOiog is a taw aA4 corrlCt copy rPf the oritttlal fIei. f) ~f]2l '<! (!,. /f ~ 1~,:.wJ _ PrOf!' --,'1-,;~"f1.' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA CORNELIUS J. RUSNOV Plaintiff : No. vs. SANDRA L. BUCKLEY-RUSNOV Defendant : CUSTODY : Action-Law COMPLAINT FOR CUSTODY 1. The Plaintiff is Cornelius J. Rusnov, who currently resides at 1110 Apple Drive, #1 Mechanicsburg, Pennsylvania 17055, hereinafter "Plaintiff." 2. The Defendant is Sandra L. Buckley-Rusnov, hereinafter "Defendant" and is believed to currently reside at 4105 Hollow Road Phoenixville, Pennsylvania, 19460. 3. Plaintiffs seek shared legal and primary physical custody of the following Children: Niles A. Rusnov, age 13 and born November 6, 1992 Theo C. Rusnov, age 7 and born June 12, 1999 The Children were born during wedlock. 4. During the past five years, the Children have resided with the following persons and at the following addresses: From the year 2000, with both parents at 1110 Apple Drive, Mechanicsburg, Pennsylvania 17055, to August 25th, 2006. With Mother from August 25th, 2006, to the present. The Father currently resides alone at the Children's home. 5. The relationship of the Plaintiff to the Children is that of Father to Sons. 6. The relationship of Defendant to the Children is that of Mother to Sons. 7. Plaintiff has participated as a party in litigation concerning the custody of the Children in this or another court. (SEE THE A TT ACHED ORDER from Dauphin County). The Parties reconciled after the date ofthe Temporary Order and had their second Child. a) Plaintiff has no information of a custody proceeding concerning the Children pending in a court of this Commonwealth or any other state. b) Plaintiff does not know of a person not a party to the proceedings who has physical custody of the Children or claims to have custody or visitation rights with respect to the Children. 8. The best interest and permanent welfare of the Children will be served by granting the relief requested because: It is in the best interest of the Children in that their financial, physical, and emotional well being shall be served by Children's Father to have sole legal and primary physical custody ofthe Children with Mother to have partial physical custody/visitation with the Children. 9. Each parent whose parental rights to the Children have not been terminated and the person who has physical custody of the Children have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the Children will be given notice of the pendency of this action and the right to intervene: There are no other persons having a claim of right to custody. WHEREFORE, Plaintiff requests this Honorable Court to grant the Father sole legal custody and primary physical custody of the Children with Mother to have partial physical custody/visitation with the Children. I verify that the statements made in the foregoing Complaint for Custody 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. ~cj.Q~8/~JD6 Cornelius J. Rusnov Date Respectfully Submitted by Attorney or P aintiff Derek Cor' , Esquire. #83284 319 South Front Street Harrisburg, PAl 71 04 (717) 91 9-4002 I ' I SANDRA L. Bt7CICLBY-Rt7SHOV, Plaintiff IN THE C01JR.T OF COMMON PLEAS DAUPHIN COUNTY, PBNNSYLVANIA VB. : NO. 3231 S. 1998 CORNELIt7S J. Rt7SNOV, Defendant CHILD CUSTODY TEMPORARY ORDER OF C01JR.T AND NOW, to wit this~day of ,J.J6>t?rtJ.6t:r, 1998, the parties and their respective counsel, having appeared for a custody conference on December 10, 1998, before Judith A. Calkin, Esquire, and having reached a temporary agreement with regards to the best interest and welfare of their minor child, it is hereby ORDBRBD AND DECREED as follows: 1. It is the intention of the parties and the parties agree that they will share joint legal custody of Niles A. Rusnov, born November 6, 1992. 2. Mother, Sandra L. Buckley-Rusnov, and father, a. Father will have the child on alternating weekends from Friday after school until Sunday at 5:00 p.m. and on Tuesday and Thursday every week from after school until the next morning. b. Mother will have the balance of the time with the child. 3. Both parents will have the right of first refusal to care for the child should the custodial parent be unavailable for a ~riod of 2 1/2 hours or more. I . ~ 4. In 1998 Father will have the child from December 22, 1998, after school until December 24, 1998 at 11:30 a.m. Mother will have the child from December 24, 1998 at 11:30 a.m. until December 26, 1998 at noon. 5. During any period of custody or visitation the parties to this order shall not possess or use any controlled substance, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this prohibition. 6. Each parent shall be entitled to reasonable telephone contact with the child when he is in the custody of the other parent. 7. Both parents shall refrain from making derogatory conunents about the other parent in the presence of the child and to the extent possible shall prevent third parties from making such conunents in the presence of the child. 8. The parents agree to cooperate in a custody evaluation to be performed by Reigler Shienvold & Associates. Each will pay 1/2 of the cost of the evaluation. 9. If any party feels the need for another conference a full hearing after the evaluation on this matter, that party shall be responsible for requesting same. All such requests shall be made with this Honorable Court by filing the appropriate motion with the Office of the Prothonotary. i' ': f, C 'i. 9 "lnnO I f'\ 1,) U {,., LUUU ~ J hace.";y ClJltfy tl;~t t.'1e f()(egoing is a ::. aAIl coo.. ~z Woo ......... ~ ~. -~~- p., notary ") 4-"l .-\ -r: ..... r-l-~ r~~~.. ..-c.. C":1 - -- ,) ........' ~:i I I . .. #0 ~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :No. Ol--SC/:J.O (!t~t.'L~~ CORNELIUS J. RUSNOV Plaintiff vs. SANDRA L. BUCKLEY -RUSNOV Defendant : CUSTODY : Action-Law PETITION FOR EMERGENCY TEMPORARY CUSTODY AND NOW, comes the Plaintiff, Cornelious J. Rusnov, and files this Emergency Petition for Custody and in support thereof avers the following: 1. The Plaintiff is Cornelius J. Rusnov, who is the Father of Niles A. Rusnov, age 13 and born November 6, 1992 and Theo C. Rusnov, age 7 and born June 12, 1999, hereinafter "Children," and currently resides at 1110 Apple Drive, #1 Mechanicsburg, Pennsylvania 17055, hereinafter "Plaintiff." 2. The Defendant is Sandra L. Buckley-Rusnov, who is the Mother of the Children, hereinafter "Defendant" and is believed to currently reside at 4105 Hollow Road Phoenixville, Pennsylvania, 19460. 3. Plaintiff seeks emergency temporary legal and physical custody of the Children. 4. On August 25th, 2006, the Defendant, with one ofthe parties' Children went to pick up the parties' other Child at her sister's home at 4105 Hollow Road Phoenixville, Pennsylvania, 19460. 5. On August 25th, 2006, the Defendant, without any notice, telephoned the Plaintiff and said she would not be returning with the Children and she would be enrolling the Children in school at her location. J """ -.. .. ;. 6. There are no allegations of abuse or neglect of the Children or between the parties in this case. However, the Defendant has a history of depression, has been on numerous antidepressants over the years and has been hospitalized for said depression. 7. The Children were to have started school in the Mechanicsburg school district on August 28, 2006. 8. Plaintiff fears for the emotional and physical wellbeing of the Children and is seeking the Children's return to the parties' residence, which will allow them to begin school in a timely manner. WHEREFORE, the Plaintiff respectfully requests that this Honorable Court grant Father sole legal and physical custody of the Children and Order the Children's return to there home, pending further Order of Court or in the alternative Order a Custody Conciliation on an Emergency basis. I verify that the statements made in the foregoing Petition for Emergency Custody 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. Q~j.Q~J2-~cb Respectfully Submitted by Atto Dere Q ier, Esquire. #83284 319 South Front Street Harrisburg, PAl 71 04 (717) 919-4002 ( 2 - ~ ~ () C/ ~0 F -J- o C' ~ ~2;::. .(.r', ';-:1\ - (..f\ ~- -~"... G.J \..D ?..., ".2 . .--- CORNELIUS J. RUSNOV, Plaintiff v. SANDRA L. BUCKLEY- RUSNOV, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW NO. 06-5420 CIVIL TERM ORDER OF COURT AND NOW, this 15th day of September, 2006, upon consideration of Plaintiffs Petition for Emergency Temporary Custody, a hearing is scheduled for Thursday, September 21, 2006, at 1 :30 p.m., in Courtroom No.1, Cumberland County Courthouse, Carlisle, Pennsylvania. ~ek Cordier, Esq. 319 South Front Street Harrisburg, P A 17104 Attorney for Plaintiff A'dra L. Buckley-Rusnov 4105 Hollow Road Phoenixville, P A 19460 ~ Defendant, pro Se :rc BY THE COURT, lP\f 1\ ~ o .. -, S' i .') .------- Pamela L. Purdy, Esquire Attorney 10 No. 85783 115 Pine Street, Suite 100 Harrisburg, PA 17101 (717) 221-8303 tel (717) 221-8403 fax plpurdy@verizon.net Counsel for Defendant CORNELIUS J. RUSNOV, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5420 CIVIL TERM SANDRA L. BUCKLEY-RUSNOV, Defendant CIVIL ACTION - LAW IN CUSTODY MOTION FOR CONTINUANCE AND NOW comes Defendant Sandra L. Buckley-Rusnov, by and through her attorney, Pamela L. Purdy, Esquire, and files this Motion for Continuance, and in support thereof, avers as follows: 1. Plaintiff is Cornelius J. Rusnov ("Father"), an adult individual who currently resides at 1110 Apple Drive #1, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Sandra L. Buckley-Rusnov ("Mother"), an adult individual who currently resides at 4105 Hollow Road, Phoenixville, Chester County, Pennsylvania. 3. Mother and Father are the parents of Niles A. Rusnov, born November 6, 1992, and Theo C. Rusnov, born June 12, 1999. 4. On August 30, 2006, Father filed a Petition for Emergency Special Relief - Change of Venue in Dauphin County to the custody matter that existed between the parties before that Court. 5. Father's Petition for Emergency Special Relief requested that Dauphin County transfer the custody action to Cumberland County, where Father currently resides. 6. On September 6,2006, Mother was admitted to Phoenixville Hospital due to a blood clot in her leg. 7. On September S, 2006, Mother and her counsel spoke for the first time over the telephone regarding the parties' custody situation. S. On September 9, 2006, Mother was released from the hospital. 9. On September 11,2006, Mother was still having a great deal of pain and went to her doctor to be re-examined, which resulted in her doctor re-admitting her to the Intensive Care Unit of the Phoenixville Hospital. 10. On September 14, 2006, Dauphin County Court granted Father's Petition and transferred the case to Cumberland County. 11. On September 15, 2006, this Court received the custody file from Dauphin County and docketed Father's Complaint for Custody and Petition for Emergency Temporary Custody to the above caption. 12. On September 15, 2006, this Court entered an Order scheduling a hearing on Father's Petition for Thursday, September 21,2006 at 1 :30 P.M. '" 13. Mother is still admitted to Phoenixville Hospital and her doctor has not given her a release date yet, although he has informed her that it will not be before September 21,2006. A true and correct copy of Dr. Jaqueline DiBiasio's prescription dated September 20,2006 confirming Sandra Rusnov's status as a patient at Phoenixville Hospital and that Mrs. Rusnov's release date is pending is attached hereto as Exhibit "A" and incorporated herein as if fully set forth. 14. Mother's doctor also has not told her whether or not she will be cleared to travel upon her release from the hospital. 15. Mother's doctor has also told her that she is not in a condition to testify via telephone or otherwise. 16. Mother and her attorney have not met yet or have been able to have a substantive conversation over the telephone about the parties' custody matters due to the effects of Mother's medication, including Percocet, and lack of privacy in her hospital room. 17. Mother's counsel has not been able to prepare Mother for testimony or determine what witnesses would be appropriate to testify at the upcoming hearing. 18. In order to alleviate the urgent nature of this matter, Mother has offered on at least two occasions to enter into a non-prejudicial, temporary custody agreement with Father that would allow him custodial time with the children pending a custody conciliation, hearing, or trial, but Father has refused. 19. Father does not concur in this Motion. . . ,... WHEREFORE, Mother respectfully requests that this Court enter an Order continuing the hearing scheduled for September 21, 2006 until after Mother is released from Phoenixville Hospital and cleared to travel. Respectfu lIy su bm itted, pf~uf' ft? ~" Counsel for Plaintiff Dated: September 20,2006 j . ,... CERTIFICATE OF SERVICE The undersigned certifies that on the 20th day of September, 2006 a true and correct copy of the foregoing Motion for Continuance was served by facsimile upon the following: Derek J. Cordier, Esquire Cordier & Brownewell Law Offices 319 South Front Street Harrisburg, PA 17104 ~rfE~~ Of Counsel for Defendant s C.p. 20, 2006 7: 28AM 5th Floor Nursing No. 4776 ~~ .. 4 r/~'~).IY'lOl I:r PM.A Medical SpeciaHst8 . NEl. MD 0 RAYMOND 1. KOVAIJXL MD 0 1m'I!kY T. LUMI.EY. , 76fi MOOlOl318 00Xl9I7SL o PAtll II. R(lGEII.S. M;ll 0 ~ Eo MN.lNE8S. MO 0 SOMIlRAA. AU. MD MDOI3O'I LE MDm737lE MIl42lI!U lJ MArnDlW B. NAI!GLE, MD [:J MARK S-1lROWN'.l.fD [J JOHN w. FOtl.WA.CB. DO MDOI/lXIOt . MD03D3SIi fBl104I3iL o JOHN f. FllBI!IIAJ'ER, MD 0 SIIAllDN 1 DAVIDIlIlISER. MIl C ~ A. 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D~' TJ' N ~SIBLf , ORDER FORA BRAND NAME PRODUCT TO BE DISPENSED, PR!SClUBlm MUSl' HANPWRm "aRAND NttBSSARr BaOW. ADDRESS 1 DEFENDAJCT'S ~ - ~EXHI8IT ! A SEP-20-2006 08:29 From: 6109831701 ID:PURDY LAW OFFICE Page:002 R=100% p, 2 ... I I (") ~ fi? s <:;;;> iRS- ~ UJ fq fK::n ~ r!l ~f-~>;; ""'ti F:: (Jj ,;t'- I'\.) .150 -< ."' C :;:; f) 0(,1'1 ~~- :boo -::;:If -',:.;;-{. ? "--d ~'c-' ::Jt: 0--, -'>(') C - C5f71 -';" C ~ ::-t -< - :1) I\.) "'< SANDRA L. BUCKLEY-RUSNOV,: IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW CORNELIUS J. RUSNOV, Defendant NO. 06-5420 CIVIL TERM ORDER OF COURT AND NOW, this 20th day of September, 2006, upon consideration of Plaintiffs Motion for Continuance and following a telephone conference on September 20, 2006, in which Pamela Purdy, Esq., represented the Plaintiff, and Derek J. Cordier, Esq., represented the Defendant, the request is denied. Plaintiff shall be permitted to testify by telephone at the hearing scheduled for September 21, 2006. BY THE COURT, ~mela L. Purdy, Esq. 115 Pine Street Suite 100 Harrisburg, P A 1710 1 Attorney for Plaintiff ~ek Cordier, Esq. 319 South Front Street Harrisburg, P A 17104 Attorney for Defendant , V!/C-.-,. esley Oler, :rc 'VlNVA1ASNN3d AJNn08 O~,"';1}j38WnO 6 0 :2 Wd OZ d3S 900Z AtNIONOHlOCld 3Hl :10 3OH:l{Xl31l:J ; "-. ~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SANDRA L. BUCKLEY-RUSNOV Plaintiff : No. 06-5420 vs. CORNELIUS J. RUSNOV Defendant : CUSTODY : Action-Law DEFENDANT'S PETITION FOR EMERGENCY SPECIAL RELIEF - EXCLUSIVE POSSESSION AND NOW, comes the Petitioner, Cornelius 1. Rusnov, by and through his counsel, Derek J. Cordier, Esquire and files this Petition for Emergency Special Relief - Exclusive Possession of the marital residence. AND NOW, comes the Petitioner, Cornelius J. Rusnov, and files this Emergency Petition for Custody and in support thereof avers the following: 1. The Defendant is Cornelius J. Rusnov, who is the Father of Niles A. Rusnov age 13 and born November 6,1992, and Theo C. Rusnov, age 7 and born June 12, 1999, hereinafter "Children," and currently resides at 1110 Apple Drive, #1 Mechanicsburg, Pennsylvania 17055, hereinafter "Petitioner. " 2. The Plaintiff is Sandra L. Buckley-Rusnov, who is the Mother of the Children, hereinafter "Respondent" and currently resides at 4105 Hollow Road Phoenixville, Pennsylvania, 19460. 3. The Respondent has a history of mental health issues. 4. On August 24th 2006, Respondent absconded with the Children to Phoenixville Pennsylvania and enrolled them in school. 5. By Order of the Honorable Judge J. Wesley Oler, Jr., dated September 21st, 2006, Petitioner was granted shared legal custody and primary physical custody of the parties' Children, with Respondent to have partial physical custody on three weekends per month. t . __ . 6. Today, September 22nd 2006, it was learned by and through the Respondent's attorney Pamela Purdy, Esquire that the Respondent plans to move home with the Children this weekend. 7. Clearly it is not in the best interest of the Children to have the parties reside in the same household at this time. 8. Respondent testified under oath that she was in fear of Petitioner, which Petitioner adamantly denies and Petitioner also believes that the Children will acknowledge the lack of fear on the part of Respondent and on the part of themselves. 9. Due to the animosity of Respondent against the Petitioner it is clearly not in the best interest of the Children for the parties to reside in the same household at this time. 10. The best interest of the Children would be served by granting Petitioner's request for the exclusive right to reside in the marital residence with said children. WHEREFORE, the Petitioner, Cornelius J. Rusnov respectfully requests that the court allow the Petitioner exclusive possession of the marital home to the exclusion of the Respondent. I verify that the statements made in this petition 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 ~a,ISifiC n.tio: ~ to \ut~:,_..,..- ~~ KUaY~v\ Oflupb Cornelius 1. Rusnov Date Respectfully submitted by: 2- ~ s' 4:.,'0-' ...... ~ Ch. \Ji fl. \ r~ '" ~ 2 "\:_J.: ~ ~. OJ /. <::::> -'" t'" <:::> 12',- "(, }:; c ' ~ ~C YC:: ~~ '<. -~ c:.Q.'> ~<t.. " c;;- o (""'0, ~ ~ ~ "\ ~ c::;;:> d"" (/) Cd rV rV -0 ~ N .. o 0) ~ ;~ d,t, ;~~1" ..-\- :!) ';~o 15fo ~ :e; a . . SANDRA L. BUCKLEY-RUSNOV,: Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW CORNELIUS J. RUSNOV, Defendant 06-5420 CIVIL TERM IN RE: PETITION FOR EMERGENCY SPECIAL RELIEF ORDER OF COURT AND NOW, this 21st day of September, 2006, upon consideration of Defendant's Petition for Emergency Special Relief, and following a hearing held on September 21, 2006, which has not yet been completed with respect to the parties' children, Niles A. Rusnov (date of birth, November 6, 1992) and Theo C. Rusnov (date of birth, June 12, 1999), it is ordered and directed as follows pending a custody conciliation conference and further Order of Court: 1. Legal custody of the children shall be shared by the parties. 2. Physical custody of the children shall be as follows: a. The mother shall have physical custody of the children on three consecutive weekends out of every four from 6:00 p.m. on Friday until 6:00 p.m. on Sunday. b. At all other times the father shall >- ~ b w-. r-.L. :::::0 ~l: :c qts 6g: ~ o:~ ~ 0"\ N ?-= 3~ -) :1 :3 ,i:/) ..-'" ,:: :::3: 'JW 5JCL -..-... ,. ::s u <5 """q- ;0: N N 0- W en ...0 = c::::l ~ a - have physical custody of the children, who shall attend school in the Mechanicsburg Area School District. 3. Transportation for exchanges of custody shall be the responsibility of the party receiving custody. 4. Neither party shall inflict corporal punishment upon either of the children. 5. Nothing herein is intended to preclude the parties from deviating from the terms of this order by mutual agreement. 6. The Court Administrator is directed to refer this matter to a custody conciliation conference for purposes of a more permanent custodial order. 7. A continuation of the hearing in this case shall take place on Thursday, January 4, 2007. It lS noted that at the time of adjournment on today's date Defendant had completed his case-in-chief and Plaintiff was still in the process of presenting her case-in-chief, and was being subjected to direct examination by her counsel. No exhibits have been identified or admitted. 8. Neither counsel has requested the transcript of the proceeding held on today's date. By the Court, - l Pamela L. Purdy, Esquire 115 Pine Street Suite 100 Harrisburg, PA 17101 For Plaintiff Derek Cordier, Esquire 319 South Front Street Harrisburg, PA 17104 For Defendant :mae v ... SANDRA L. BUCKEY-RUSNOV IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V' CORNELIUS J. RUSNOV : NO. 2006 - 5420 CIVIL TERM ORDER OF COURT AND NOW, this 22ND day of SEPTEMBER, 2006, a Rule is issued upon Plaintiff To Show Cause Why Defendant's Petition for Emergency Special Relief - Exclusive Possession should not be granted. Rule returnable thirty (30) days after service. In the meantime, nothing herein intended to preclude Plaintiff from returning to the marital residence with the children. By the Court, Pamela L. Purdy, Esquire 115 Pine Street Suite 100 Harrisburg, Pa. 17101 :sld t:M 'i/~;' - 0 (, ttl \w~~lY ~ ~ ~ -.&Q~ Vlt Derek Cordier, Esquire 319 South Front Street Harrisburg, Pa. 17104 '.hI' jU'"1! t"" 'f\l....d V!l\ '1/\ 1/\;)1\ ,j . l'I<'n"""-' -, ~, '''''~'~Inf'\ I\JJ~! ,!~.),> .! -<,; i-"J~'~tfV'~l V frO :~ Wd 22 d3S 90Ul Al:Nl0NOH.L08d 3Hl :10 301:l:l0-{l31t:l .-.. " IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA SANDRA L. BUCKLEY-RUSNOV : No. 06-5420 Plaintiff o ~ vs. CORNELIUS J. RUSNOV Defendant : CUSTODY : Action-Law PRAECIPE TO DISCONTINUE PETITION FOR EMERGENCY TEMPORARY CUSTODY AND NOW, comes Defendant / Petitioner, Cornelius 1. Rusnov, by and through his counsel, Derek J. Cordier, Esquire and files this Praecipe to Discontinue the above captioned action without prejudice. 1. The Defendant, Cornelius 1. Rusnov, the Plaintiff, Sandra L. Buckley-Rusnov, and the parties' Children all currently reside at the same residence. 2. Therefore this Court no longer has jurisdiction over any custody proceedings concerning the Children of the parties' marriage. WHEREFORE, the Petitioner, Cornelius 1. Rusnov respectfully discontinues the above captioned action without prejudice. Respectfully submitted by: o ,......1 = ~5~ a c) --; 0'1 o 01 "-1'; ....... . " Cordier & Brownewell Law Offices 319 South Front Street Harrisburg, PA 17104-1621 Derek]. Cordier, Esquire Phone: (717) 919-4002 Email: derek@{krckjconlier.com Fax: (717) 213-4984 October 12, 2006 Prothonotary of Cumberland County One Courthouse Square Carlisle, PA 17013 RE: Rusnov v. Rusnov 06-5420 Praecipes to Discontinue Dear Prothonotary: Please find the enclosed Praecipes to Discontinue and stamped envelopes for both parties' attorneys. Please also forward timed stamped copies to the Honorable Judge, J. Wesley Oler, Jr. so he may alter his schedule. Thank you very much for your attention to this matter. If you have any questions or need anything further, please contact my office at the above telephone number or address. r-" ~J ~~=~ o -[1 --t \:-n r11~ o C-), (J\ -c" -'.... _>ilo (Jl c;\ J}i ~ '. o IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA SANDRA L. BUCKLEY-RUSNOV : No. 06-5420 Plaintiff vs. CORNELIUS J. RUSNOV Defendant : CUSTODY : Action-Law PRAECIPE TO DISCONTINUE DEFENDANT'S PETITION FOR EMERGENCY SPECIAL RELIEF - EXCLUSIVE POSSESSION AND NOW, comes Defendant / Petitioner, Cornelius 1. Rusnov, by and through his counsel, Derek J. Cordier, Esquire and files this Praecipe to Discontinue the above captioned action without prejudice. 1. The Defendant, Cornelius J. Rusnov, the Plaintiff, Sandra L. Buckley-Rusnov, and the Parties' Children all currently reside at the same residence. 2. Therefore this Court no longer has jurisdiction over any custody proceedings concerning the Children of the parties' marriage. WHEREFORE, the Petitioner, Cornelius J. Rusnov respectfully discontinues the above captioned action without prejudice. Respectfully submitted by: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA SANDRA L. BUCKLEY-RUSNOV : No. 06-5420 Plaintiff YS. CORNELIUS J. RUSNOV Defendant : CUSTODY : Action-Law PRAECIPE TO DISCONTINUE DEFENDANT'S PETITION FOR EMERGENCY SPECIAL RELIEF - EXCLUSIVE POSSESSION AND NOW, comes Defendant / Petitioner, Cornelius 1. Rusnov, by and through his counsel, Derek J. Cordier, Esquire and files this Praecipe to Discontinue the above captioned action without prejudice. I. The Defendant, Cornelius J. Rusnov, the Plaintiff, Sandra L. Buckley-Rusnov, and the Parties' Children all currently reside at the same residence. 2. Therefore this Court no longer has jurisdiction over any custody proceedings concerning the Children of the parties' marriage. WHEREFORE, the Petitioner, Cornelius J. Rusnov respectfully discontinues the above captioned action without prejudice. ., Respectfully submitted by: -<vi' De~ Cordier Esq. #83284 319 Sollth nt Street Harrisburg, P A 17104-1621 (717) 919-4002 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SANDRA L. BUCKLEY-RUSNOV : No. 06-5420 Plaintiff VS. CORNELIUS J. RUSNOV Defendant : CUSTODY : Action-Law PRAECIPE TO DISCONTINUE DEFENDANT'S PETITION FOR EMERGENCY SPECIAL RELIEF - EXCLUSIVE POSSESSION AND NOW, comes Defendant / Petitioner, Cornelius J. Rusnov, by and through his counsel, Derek J. Cordier, Esquire and files this Praecipe to Discontinue the above captioned action without prejudice. I. The Defendant, Cornelius 1. Rusnov, the Plaintiff, Sandra L. Buckley-Rusnov, and the Parties' Children all currently reside at the same residence. 2. Therefore this Court no longer has jurisdiction over any custody proceedings concerning the Children of the parties' marriage. WHEREFORE, the Petitioner, Cornelius J. Rusnov respectfully discontinues the above captioned action without prejudice. Respectfully submitted by: De~k Cordier Esq. #83284 319 Sotrtll nt Street Harrisburg, P A 17104-1621 (717) 919-4002 , ' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA SANDRA L. BUCKLEY-RUSNOV : No. 06-5420 Plaintiff VS. CORNELIUS J. RUSNOV Defendant : CUSTODY : Action-Law PRAECIPE TO DISCONTINUE DEFENDANT'S PETITION FOR EMERGENCY SPECIAL RELIEF - EXCLUSIVE POSSESSION AND NOW, comes Defendant / Petitioner, Cornelius 1. Rusnov, by and through his counsel, Derek J. Cordier, Esquire and files this Praecipe to Discontinue the above captioned action without prejudice. I. The Defendant, Cornelius 1. Rusnov, the Plaintiff, Sandra L. Buckley-Rusnov, and the Parties' Children all currently reside at the same residence. 2. Therefore this Court no longer has jurisdiction over any custody proceedings concerning the Children of the parties' marriage. WHEREFORE, the Petitioner, Cornelius 1. Rusnov respectfully discontinues the above captioned action without prejudice. Respectfully submitted by: ., De~k Cordier Esq. #83284 319 Sotrth nt Street Harrisburg, PAl 71 04-1621 (717) 919-4002 (') c 1',) (:'""'..,,;, (..::":' CT' o ,'J --I (]'", --. -, , -~,.. ~'.,,,,, _.~ ...::" en ..: " ::0 .<