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Home My WebLink About06-6269 Cara A. Boyanowski, Esquire SERRA TELL! SCHIFFMAN BROWN & CALHOON 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 (telephone) (717) 540-5481 (facsimile) cbovanowski(Q)ssbc-law.com Attorney for Plaintiff vi. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ex. -/'2r.r C?iu~LCy-~ SVETLANA COLVIN, Plaintiff VLADIMIR BORODIANSKI, Defendant CIVIL ACTION - LAW IN CUSTODY COMPLAINT IN CUSTODY AND NOW, comes Plaintiff Svetlana Colvin, by and through her counsel, Cara A. Boyanowski, Esquire, of the law firm of Serratelli Schiffman Brown & Calhoon, and respectfully represents: 1. The Plaintiff is Svetlana Colvin, an adult individual who resides at 223 W. Locust Street, Enola, Cumberland County, Pennsylvania 17025. 2. The Defendant is Vladimir Borodianski, an adult individual who resides at 2249 Brigade Road, Enola, Cumberland County, Pennsylvania, 17025. 3. Plaintiff seeks sole legal custody and primary physical custody of the following child: Present Residence Date of Birth Name Anna 223 W. Locust Street Enola, P A November 22,2002 The child was born out of wedlock. The child is presently in the custody of Plaintiff who resides at 223 W. Locust Street, Enola, Cumberland County, Pennsylvania 17025. 4. During the past five years, the child has resided with the following persons and at the following addresses: A. Plaintiff Svetlana Colvin 223 W. Locust Street Enola, P A 17025 May 25,2006 - Present B. Plaintiff Svetlana Colvin Defendant Vladimir Borodianski 223 W. Locust Street Enola, P A 17025 March 28,2003 - May 25,2006 C. Plaintiff Svetlana Colvin Defendant Vladimir Borodianski 2901 Society Hill Drive, Apt. 103 Camp Hill, P A 17011 Birth - March 28, 2003 5. The mother of the child is Plaintiff Svetlana Colvin who is currently residing at 223 W. Locust Street, Enola, Cumberland County, Pennsylvania 17025. She is single. 6. The father of the child is Defendant Vladimir Borodianski who is currently residing at 2249 Brigade Road, Enola, Cumberland County, Pennsylvania 17025. He is single. 7. The relationship of Plaintiff to the child is that of Mother. The Plaintiff resides with the minor child. 8. The relationship of Defendant to the child is that of Father. The Defendant resides with friends. 9. Plaintiff has not participated as a party in other litigation concerning the custody of this child. Plaintiff has no information of another custody proceeding concerning the child pending in a court of this Commonwealth. 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. 10. The best interest and permanent welfare of the child will be served by granting the relief requested because: A. Plaintiff and the child have a very strong, loving relationship, which should be nurtured. Since the birth of the child, Plaintiff has assumed most all of the day-to-day responsibilities for the child, including but not limited to bathing the child, feeding the child, clothing the child, changing the child, putting her to bed, waking her up in the morning, and transporting her to doctor visits, day care providers, and social events. Furthermore, Plaintiff has financially, emotionally and spiritually supported the child since birth. B. Defendant has had no contact with the child since May 2006. Plaintiff therefore believes that Defendant has no desire to establish a close, meaningful relationship with the child. C. And other reasons which may fully appear at conference. II. Each parent whose parental rights to the child, which 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 this Honorable Court grant her sole legal custody and primary physical custody of the child. Respectfully submitted, SERRA TELL! SCHIFFMAN BROWN & CALHOON Qou&~TlLi Cara A. Boyanowski, Esquire Attorney No. 68736 2080 Linglestown Road Suite 201 Harrisburg, P A 1711 0 (717) 540-9170 Attorney for Plaintiff . . . .. VERIFICATION Upon my personal knowledge, information and belief, I, Svetlana Colvin, do hereby verify that the facts averred and statements made in the foregoing Complaint are true and correct. I understand that false statements or averments therein made will subject me to the criminal penalties of 18 Pa.C.S.A. S4904 relating to unsworn falsification to authorities. By: Svetlana Colvin <j~dt~~~~ Mv2J Date: 10- 3-0lp -;cJ ~ ~ ~ :::::- if- '-J (> t'-.:l s:, r.;'.::") 0 . c:~:-) -n C-';'" -C ~ 0 ::;:l -.. C"'J [-t'l :T ~ ..-I ,. ....... f''' -c-' '" V't -, 1: c-' ,",.; .. ~ ...), ... - f ..\......... 4 -0 '~-~I-~, (;' -.... (~~, f~ 0 1- f') :--\ 1:> :c- :;:; 0) .< Cara A. Boyanowski, Esquire SERRA TELL! SCHIFFMAN BROWN & CALHOON 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 (telephone) (717) 540-5481 (facsimile) cbovanowski@ssbc-Iaw.com Attorney for Plaintiff SVETLANA COLVIN, Plaintiff STIPULATION FOR CUSTODY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA NO. OL.-{,~~'f ~~L~/~~ CIVIL ACTION - LA W' ~ ~ fQ IN CUSTODY N :f~:I1 cn:.",Y ~~~f; ~ ~~~ N '--' :0::..-1 :".6 \..0 -< .... vi. VLADIMIR BORODIANSKI, Defendant WHEREAS, the Plaintiff and Defendant are the parents of one minor child, to wit: Anna V. Borodianski, born on November 22, 2002; v. b, S\ ~ ' WHEREAS, Defendant has indicated to Plaintiff that he does not wish to establish a physical custody schedule for he and Anna B. Borodianski; WHEREAS, the Plaintiff and Defendant, after careful consideration and the opportunity for the advice and assistance of counsel, have reached an agreement to provide for the custody of this child without the need to litigate the matter before this Honorable Court and asks the Court to adopt this agreement as its Order; WHEREAS, it is the belief of the Plaintiff and Defendant that the agreement reached herein provides for the best interest of this child; NOW THEREFORE, intending to be legally bound, the parties agree as follows: 1. Plaintiff, Svetlana Colvin shall exercise sole legal custody over the parties' minor v- b. S;.C, daughter, Anna, born on November 22,2002. The parties agree, V, b. that all major decisions concerning their child, including, but not limited to, the child's health, welfare, education, religious training and upbringing shall be made by Plaintiff, solely, without consultation with Defendant. 2. Plaintiff, Svetlana Colvin shall exercise primary physical custody over the parties' Y. b. S~ minor daughter, Anna, born on November 22,2002, v.b. Sc- 3. The parties shall keep each other informed of their respective current addresses and telephone numbers. 4. Both parties shall encourage the child to love and respect the other and shall not make, nor allow others to make, in the presence of the child, derogatory comments about the other parent. 5. Plaintiff is represented by Cara A. Boyanowski, Esquire. Defendant is not represented by counsel. All parties have been informed of the purpose of this Agreement and its legal effects and consequences. 6. Each of the parties has carefully read and fully considered this Stipulation and all of the statements, terms, conditions, and provisions thereof prior to signing below. IN WITNESS WHEREOF, intending to be legally bound hereby, the parties hereto have set their hands and seals on this ~.k\ ~ day of OC}O b 1 A j ,2006. WITNESS: O(kill,(ll~4W'\Olf'Sli Cara A. Boyanowskl, Esquire Counsel for Plaintiff '~~b &-&~ Svetlana Colvin ~)~~/ 1 ess 11. &,r4iaut1' Vladimir Borodianski (") ~: r, -< r--., = c= (:1' r) n -J 1',) 0" n -71 --\ I"Tl ,nr:--:::.: m I? S.fl -0 :;;: ""1 .-) ;.< -: (....J ~j in ..-{ ')~ <;0 =-< f;? 01 ..~, , " ) d Cara A. Boyanowski, Esquire SERRA TELLI SCHIFFMAN BROWN & CALHOON 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 (telephone) (717) 540-5481 (facsimile) c bovanowski(Q:)ss be-law .com Attorney for Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA NO. ex- -I,~'r (!ICJ~L~~ CIVIL ACTION - LAW IN CUSTODY SVETLANA COLVIN, Plaintiff VLADIMIR BORODIANSKI, Defendant ORDER OF COURT AND NOW, this ~(A day of ~()"c'i\ ~e.( , 2006, upon stipulation of the parties, it is hereby Ordered and Decreed: 1. Plaintiff, Svetlana Colvin shall exercise sole legal custody over the parties' minor daughter, Anna V. Borodianski, born on November 22, 2002. The parties agree that all major decisions concerning their child, including, but not limited to, the child's health, welfare, education, religious training and upbringing shall be made by Plaintiff, solely, without consultation with Defendant. 2. Plaintiff, Svetlana Colvin shall exercise sole physical custody over the parties' minor daughter, Anna V. Borodianski, born on November 22,2002. 3. The parties shall keep each other informed oftheir respective current addresses and telephone numbers. .. 4. Both parties shall encourage the child to love and respect the other and shall not make, nor allow others to make, in the presence of the child, derogatory comments about the other parent. BY THE COURT: \t~\ J. /(~ 3-()c' ~ ~ y.t-s OS :6 HV 8- b,ON gOal ,.J,01 ~'-.... A Cara A. Boyanowski, Esquire SERRA TELL! SCHIFFMAN BROWN & CALHOON 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 (telephone) (717) 540-5481 (facsimile) cbovanowskiriV,ss bc-Iaw .com Attorney for Plaintiff SVETLANA COLVIN, Plaintiff STIPULATION FOR CUSTODY : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA NO. Of.. - {,A.(.. 'f l?t~~L~/~~ CIVIL ACTION - LAW' B ~ pg IN CUSTODY ~ :l~? ~~~f: ~ '~~::2 1;~ ~~rn N ,-' ~:::l :-'.0 \..:l -< vi. VLADIMIR BORODIANSKI, Defendant WHEREAS, the Plaintiff and Defendant are the parents of one minor child, to wit: Anna V. Borodianski, born on November 22, 2002; WHEREAS, Defendant has indicated to Plaintiff that he does not wish to establish a physical custody schedule for he and Anna B. Borodianski; WHEREAS, the Plaintiff and Defendant, after careful consideration and the opportunity for the advice and assistance of counsel, have reached an agreement to provide for the custody of this child without the need to litigate the matter before this Honorable Court and asks the Court to adopt this agreement as its Order; WHEREAS, it is the belief of the Plaintiff and Defendant that the agreement reached herein provides for the best interest of this child; NOW THEREFORE, intending to be legally bound, the parties agree as follows: 1. Plaintiff, Svetlana Colvin shall exercise sole legal custody over the parties' minor \;- b. S;.C, daughter, Anna, born on November 22, 2002. The parties agree, V, b. that all major decisions concerning their child, including, but not limited to, the child's health, welfare, education, religious training and upbringing shall be made by Plaintiff, solely, without consultation with Defendant. 2. Plaintiff, Svetlana Colvin shall exercise primary physical custody over the parties' V, b. 2r~ minor daughter, Anna, born on November 22,2002, v. b. LS<:. 3. The parties shall keep each other informed of their respective current addresses and telephone numbers. 4. Both parties shall encourage the child to love and respect the other and shall not make, nor allow others to make, in the presence of the child, derogatory comments about the other parent. 5. Plaintiff is represented by Cara A. Boyanowski, Esquire. Defendant is not represented by counsel. All parties have been informed of the purpose of this Agreement and its legal effects and consequences. 6. Each of the parties has carefully read and fully considered this Stipulation and all of the statements, terms, conditions, and provisions thereof prior to signing below. . 't . '" ... IN WITNESS WHEREOF, intending to be legally bound hereby, the parties hereto have set their hands and seals on this ~.4 ~ day of Oc1-o h t U ,2006. WITNESS: QouaQl~MQnou:'f,li Cara A. Boyanowskl, Esquire Counsel for Plaintiff .J~~ U.~ Svetlana Colvin ~)~1/ 1 ess 11. &r4'a~ ' Vladimir Borodianski ~ C) c:, 1"-' = c~ <:.::"'" CJ n --l f'.' 0' .;.;'( -a ...'''1]..... ~.. o -n .-l ::C..,., fn~ -i~i - -; j C') ~~3 rn .):,>>< ']J =-< r',) .. 01