HomeMy WebLinkAbout95-01922
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BRANDON A. FABIANKOVITZ, . IN THE COURT OF COMMON PLEAS
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. CUMBERLAND COUNTY, PENNSYLVANIA
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Plaintiff .
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V. . NO.
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CINDY J. SCHEIDEGGER, CIVIL ACTION - LAW
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Defendant CUSTODY
COMPLAINT FOR CUSTODY
AND NOW COMES plaintiff, Bradon A. Fabiankovitz, in the
above captioned action, by his attorney Lori K. serratelli and
the law firm of SERRATELLI, SCHIFFMAN' BROWN who petitions this
Honorable Court to grant him shared legal and partial physical
custody of the parties' child based on the following:
1. Plaintiff and Defendant are the parents of one minor
child, namely: Joseph A. Fabiankovitz, born January 5, 1992.
2. The Plaintiff currently resides at 421 Belle Vista Drive,
Summerdale, Cumberland County, Pennsylvania, 17093. He resides
with his mother, Susan Fabiankovitz and his sister, Alexis
Fabiankovitz.
3. The Defendant currently resides at 254 Redwood Lane,
County Manor Trailer Park, Carlisle, CUmberland county,
Pennsylvania 17013. She resides with the child and her
grandmother, Josephine Scheidegger.
4. During the past five years the child has resided with the
fOllowing persons and at the following addresses:
Persons
Address
Chester Road
Enola, PA
Dates
cindy J. Scheidegger
Josephine Scheidegger
(Grandmother)
1-5-92 - 12-92
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3. Plaintiff and Defendant agree to submit to a home study of
each of their r.espective homes, Plaintiff - 421 Belle Vista Drive,
Summerdale, Pennsylvania, and Defendant - R.D. #2 - Box 2136,
Mahoney Valley Road, Duncannon, Pennsylvania, to be conducted as
soon as possible, the cost of which will be shared by the parties.
Pending the home studies, Plaintiff agrees he will exercise his
partial custody rights at his grandparents' home.
4. The parties shall alternate Thanksgiving and Easter
beginning with Thanksgiving for Plaintiff for 1995. A holiday
shall constitute the day beginning at 10:00 a.m. until 8:00 p.m.
5. The Christmas holiday shall be divided into two segments:
a. Beginning Christmas Eve at 12: 00 noon until Christmas
Day at 12:00 noon.
b. Christmas Day at 12:00 noon until December 26 at
12:00 noon.
Beginning December 1995 Defendant shall have segment "a" and
thereafter the segments shall be alternated between the parties.
6. Plaintiff shall be entitled to receive medical records,
school records, religious records, and any other important vital
statistical records concerning Joseph A. Fabiankovitz directly from
any medical provider, psychologist, school, governmental agency,
religious institution or any entity acting as custodian of records
relative to the child.
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3. Plaintiff and Defendant agree to submit to a home study of
each of their respective homes, Plaintiff - 421 Belle Vista Drive,
Summerdale, Pennsylvania, and Defendant - R.D.l1 - Box 2136,
Mahoney valley Road, Duncannon, pennsylvania, to be conducted as
soon as possible, the cost of which will be shared by the parties.
Pending the home studies, Plaintiff agrees he will exercise his
partial custody rights at his grandparents' home.
4. The parties shall alternate Thanksgiving and Easter
beginning with Thanksgiving for Plaintiff for 1995. A holiday
shall constitute the day beginning at 10:00 a.m. until 8:00 p.m.
5. The Christmas holiday shall be divided into two segments:
a. Beginning Christmas Eve at 12: 00 noon until Christmas
Day at 12:00 noon.
b. Christmas Day at 12: 00 noon until December 26 at
12:00 noon.
Beginning December 1995 Defendant shall have segment "a" and
thereafter the segments shall be alternated between the parties.
6. Plaintiff shall be entitled to receive medical records,
school records, religious records, and any other important vital
statistical records concerning Joseph A. Fabiankovitz directly from
any medical provider, psychologist, school, governmental agency,
religious institution or any entity acting as custodian of records
relative to the child.