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HomeMy WebLinkAbout02-3717VS. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION IN CUSTODY NO. NOTICE TO DEFEND TO THE RESPONDENTS NAMED HEREIN: You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Petition and l%tice are served, by entering a written appearance personally or by attomey and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you l~y the Court without further notice for any money claimed in the Petition or for any other claim or relief requested by the Plaintiffs. You may lose money or property or other rights important to you. 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. Cumberland County Bar Association Two Liberty Avenue Carlisle, PA 17013 (717)24%3166 Le han demandado a usted enla corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partie de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objectones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, las corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION IN CUSTODY NO. COMPLAINT IN CUSTODY The plaintiffis"-~:~c\o~ ~[ ~'3~$2¢K, residing at The defendant is~0XOeC3~ S. ~-'~:Xs z¢ lc, residing at Plaintiff seek cs~tody~ (~--~ ~! :. NAME ,..), (.~i~a~.) of tile following child(ren): PRESENT ADDRESS AGE The child(ma) (~)~ bom out of wedlock· The child(~) is presently in the custody of ~a.c\o. ~-. ~-~$~e Kwho resides at During the past five years, the child(ma) has resided with the following persons at the following addresses: LIST OF PERSONS ADDRESSES DATES The mother of the child(.~) is ~'~¢\o, ~. ~),.3Vo~S2-t:? ~ She is (.~l~)(married)(~i~). The father of the child(,,,~) is'X'~¢'"~- · currently residing at. currently residing at He is (ti~l~)(married)(lliltl~). The relationship of the Plaintiffto the child(l~) is: Clho '~q~(- resides with: NAME RELATIONSHIP · The Plaintiff currently The relationship of the Defendant to the child(tl~) is: currently resides with: NAME RELATIONSHIP · The Defendant Plaintiff (~)(has not) participated as a party or witness, or in another capacity, in other litigation concerning the custody of this minor child(e) in this or another court. (if so)The court, term and number, and its relationship to this action is:. Plaintiff (l~)(has no) information of a custody proceeding concerning the child(e) pending in a court of this Commonwealth. (if so)The court, term and number and its relationship to this action is: Plaintiff (l~ml~)(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. The name and address of such a person is:. The best interest and permanent welfare of the child will be served by granting the relief requested ' Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child 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 child will be given notice of the pendency of this action and the right to interv[ne: NAME ADDRESS BASIS OF CLAIM WHEREFORE, Plaintiff requests this court to grant (custody)(t~)(~l~ll~llm,) of the child0~,) to the Plaintiff. Date Respectfully submitted, DARLA F. PTASZEK PLAINTIFF ROBERT S. PTASZEK DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : : 02-3717 CIVIL ACTION LAW : IN CUSTODY : ORDER OF COURT AND NOW, Tuesday, August 06, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before }Iubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, August 22, 2002 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 hearing. FOR THE COURT, By: /s/ Hubert X. Gilrov. Esa. ~ Custody Conciliator ' 0 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 DARLA F. PTASZEK, Plaintiff ROBERT S. PTASZEK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02 - 3717 CIVIL : IN CUSTODY CO~TO~ER AND NOW, this ~/l~' day of ~ ,2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: The Father, Robert S. Ptaszek, and the Mother, Darla F. Ptaszek, shall enjoy shared legal custody of Mitchell R. Ptaszek, born March 3, 1995. 2. The Mother shall enjoy primary physical custody of the minor child. The Father shall enjoy liberal periods of temporary physical custody with the minor child at such times as the parties may agree. In the event either party desires to modify this order, that party may petition the court to have the case again scheduled with a custody conciliator for a conference. BY~ J. CC: /Darla F. Ptaszek 245 Meals Drive Carlisle, PA 17013 Robert S. Ptaszek 111 Adams Road Carlisle, PA 17013 DARLA F. PTASZEK, Plaintiff ROBERT S. PTASZEK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02 - 3717 CIVIL : IN CUSTODY Prior Judge: CONCH.IATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent infm~tiiation pertaining to the child who is the subject of this litigation is as follows: Mitchell R. Ptaszek, born March 3, 1995. A Conciliation Conference was held on August 22, 2002, with the following individuals in attendance: The Father, Robert S. Ptaszek, and the Mother, Darla F. Ptaszek, who both appeared without counsel. 3. The parties agree to the entry of an order in the fol:~i] as attached. DATE  rare