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HomeMy WebLinkAbout95-01233 oJ "(.. d Y- <C . ? . - (.. d ~ <! " f ~ I- J I i I ! , rf) rf) (0 - I I I ZIAD B. AKARI, Plaintiff IN THE COURT OF CO~~ON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NUMBER: q5- J :l..3,~ Cu..J' 7er(l) vs. ALECIA D. AKARI, Defendant IN CUSTODY ORDER AND NOW, this I~day of ~, 1995, upon consideration of the within Motion, Complaint, and Stipulation, IT IS HEREBY ORDERED as follows: 1. That primary physical custody of TAMARA LYNN ZIAD-AKARI, born September 14, 1983; and TAREK ZIAD-AKARI, shall be and remain in their mother, ALECIA D. AKARI. 2. That the parties shall share legal custody. 3. That the children's father, ZIAD B. AKARI, shall have liberal rights of temporary physical custody of the minor children as the parties shall from time to time agree. 4. Mother shall have the right to reside with the children in the State of West Virginia if Mother so desires. 5. The children shall be raised in the Moslem faith. 6. Both parties shall strive to maintain a positive relationship between the children and the other parent. 7. Husband shall pay to Wife the sum of Three Hundred Dollars ($300.00) per month as support for the minor children. This amount shall be sUbject to modification from time to time based upon the changing financial circumstances of the parties. It is agreed that the Domestic Relations Office of Cumberland COUllty, Pennsylvania, shall maintain continuing jurisdiction over the matters of child support and health insurance. 8. Father shall pay, in addition to the monthly amount set forth in paragraph 7, or any subsequently-determined amount, any and all reasonable and necessary expenses incurred by Mother for clothing and education for the minor children. 9. Father shall maintain the children as dependents on his , , ! health insurance so long as such health insurance coverage is available at no cost or at reasonable cost to Father through his employer. The parties shall share equally the cost of any for either medical, dental, psychological or orthodontic expense / child that is not covered by health insurance/ " BY THE COURT;' /" J. t\') ZIAD B. AKARI, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NUMBER CUSTODY Plaintiff vs. ALECIA D. AKARI, Defendant COMPLArNT FOR CUSTODY NOW COMES the Plaintiff, ZIAD B. AKARI, by his attorney, Charles E. Petrie, and respectfully represents as follows: 1. Plaintiff is ZIAD B. AKARI, who currently resides at 8 Ash Drive, Mechanicsburg, County of CUmberland, Pennsylvania. 2. Defendant is ALECIA D. AKARI, who currently resides at 131 Staford Court, Mechanicsburg, County of CUmberland, Pennsylvania. 3. Plaintiff seeks to have rights of temporary physical custody with respect to TAMARA LYNN ZIAD-AKARI, born September 14, 1983; and TARER ZIAD-AKARI, born November 20, 1991. The children were not born out of wedlock. The children are presently in the custody of Defendant, ALECIA D.-AKARI. Since 1990, the children have lived with the following persons and at the following addresses: with both parents at 1017 Yverdon Drive, Camp Hill, Pennsylvania until January, 1991; from January, 1991, until March 1, 1995, with both parents at 8 Ash Drive, Mechanicsburg, Pennsylvania; from March 1, 1995, until the present with Defendant only at 131 Staford Court, Mechanicsburg, Pennsylvania. The mother of the child is ALECIA D. AKARI, who currently resides at 131 Staford Court, Mechanicsburg, Pennsylvania. She is married. The father of the child is ZIAD B. AKARI, who currently resides at B Ash Drive, Mechanicsburg, Pennsylvania. He is married. 4. The relationship of the Plaintiff to the children is that of father. The Plaintiff currently resides alone. 5. The relationship of the Defendant to the child is that of mother. She currently resides with the children. 6. The Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or in another court. The Plaintiff has no information of a custody proceeding concerning the custody of the children in this or in another court. Plaintiff does not know of a person not a party to these proceedings who has physical custody of the children or who claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by confirming temporary physical custody in Plaintiff because Plaintiff believes that the children will benefit from maximum contact with Plaintiff. COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I verify that the statements in the foregoing Motion and 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. JJ"/1}'''' ?'fill....i-vu pi- /,/U. Z'l B. I DATE ZIAD B. AKARI, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NUMBER: Plaintiff vs. ALECIA D. AKARI, Defendant IN CUSTODY STIPULATION AGREEMENT, made this day of March, 1995, by and between ZIAO B. AKARI, hereinafter referred to as "Father," and ALECIA D. AKARI, hereinafter referred to as "Mother." WITNESSETH WHEREAS, the parties hereto are husband and wife and are the natural parents of two minor children: TAMARA LYNN ZIAO-AKARI, born September 14, 1983; and TAREK ZIAO-AKARI, born November 20, 1991; and WHEREAS, the parties have reached an agreement concerning the issues of physical custody, legal custody, and temporary physical custody; and WHEREAS, the parties desire that this Stipulation be entered as an Order by the court of Common Pleas of Cumberland County, Pennsylvania; NOW THEREFORE, intending to be legally bound, the parties hereby agree as follows: 1. That primary physical custody of TAMARA LYNN ZIAD-AKARI, born September 14, 1983; and TAREK ZIAD-AKARI, shall be and remain in their mother, ALECIA D. AKARI. 2. That the parties shall share legal custody. 3. That the children's father, ZIAD B. AKARI, shall have liberal rights of temporary physical custody of the minor children as the parties shall from time to time agree. 4. Mother shall have the right to reside with the children in the State of West Virginia if Mother 50 desires. 5. The children shall be raised in the Moslem faith. 6. Both parties shall strive to maintain a positive relationship between the children and the other parent. 7. Husband shall pay to Wife the sum of Three Hundred Dollars ($300.00) per month as support for the minor children. This amount shall be subject to modification from time to time based upon the changing financial circumstances of the parties. It is agreed that the Domestic Relations Office of Cumberland County, Pennsylvania, shall maintain continuing jurisdiction over the matters of child support and health insurance. 8. Father shall pay, in addition to the monthly amount set forth in paragraph 7, or any subsequently-determined amount, any and all reasonable and necessary expenses incurred by Mother for clothing and education for the minor children. 9. Father shall maintain the children as dependents on his health insurance 50 long as such health insurance coverage is available at no cost or at reasonable cost to Father through his employer. The parties shall share equally the cost of any medical, dental, psychological or orthodontic expense for either child that is not covered by health insurance. IN WITNESS WHEREOF, the parties have hereunto set their hands and official seals. ~ r ttP~ WITNESS &i, __R/I If ",L~ .M..-C - --Z B. AKARI ~ E /?7L. WITNESS df?r'IA_1I9' ~ ALECIA D. 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