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HomeMy WebLinkAbout95-04844 , tN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA () , (' j . "f~ _' '- lL.1/....... SAMUEL KACYON, Jr., PlaintitT 96 - l,S /,4 v. No. 1995 PATRICIA KACYON, Defendant CIVIL ACTION. CUSTODY ORDER OF COtJRT AND NOW, this 14U, day of bC"'Or,.mP.-'--, 1995, upon consideration ofthe attached complaint, it is hereby directed that the parties and their respective counsel appear before O".A..rl 5 , S..."cl'^-;I r~f ,theconciliator,at '69 W M""n ,Sf. Mt( ~\<\h;,~l:Mri; on the ~ th day of (J ( +-'" b r( , 1995, at Of ;j)c) A. m., 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 the narroW Issues to be heard by the court, and to enter Into 8 temporary order. All children age five or older Wtl 'Iso be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. By: YOU SHOULD TAKE THIS PAI'ER TO A 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. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4th FLOOR CARLISLE, PA 17013 (717) 240.6200 q_ / ~ r( I Jh' II t . (1,/ ~ Jr If I (, ,-, . $ - !i I.:,.. ~ .... rl Sl 0:> - In V' " '.' v. No. 1995 IN THE COURT OF COMMON I'LEAS OF CUMBERLAND COUNTY. I'ENNSYL VANIA SAMUEL KACYON, Jr.. I'laintiO' PATRTCIA KACYON, Defendant CIVIL ACTION - CUSTODY COMPLAINT FOR PARTIAL CUSTODY AND VISITATION t. The Plaintiff Is Samuel Kacyon. Jr.. residing at601 Keller Street, Mechanicsburg. Cumberland County, PA 17055. 2. The Defendant is Patricia Kacyon, residing at35 Millers Gap Road. Enola. Cumberland County, PA 17025. 3. Plalntift'seeks partial custody and visitation ofthe following children: Samuel Robert Kacyon, age 8 and Christopher Kacyon, age 5. both residing at 35 Millers Gap Road, Enola. Cumberland County, PA 17025. The children were not bom out of wedlock. The children are presently in custody of Defendant at the above address and have resided at that address for the pastl1ve years with both Plalntill'and Defendant. Plalntllfisthe lather of the children. Defendant Is the mother of the children. Plaintiff and Defendant are married. 4. The plaintiff currently resides with Rhonda Billinger. 5. Defendant currently resides with the children whose custody is allssue In this case. 6. Plalntlll'has not participated as a party or witness. or in another capacity, In oth~r litigation concerning the custody of the children in this or another court Plalntll1'has no Information ofa custody proceeding concerning the children pending In a court of this Commonwealth. I'lalnlll1' docs 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. 7. The best Interest and permanent welfare of the children will be best served by granting the relief requested because It is Important for the children to have the love and nurturing of both of their parents 8. Both parents, one of whon; has physical custody of the children, are parties to this action. No other persons are known to have or claim a right to custody or visitation of the child. WHEREFORE, PlaintilT requests the court to grant partial custody and visitation of the children. I verilY that the statements made in this Amended Complaint and allached income and expense statement are true and correct. 1 understand that false statements herein are made subject to the penalties of t8 Pa. C.S. 4904, relating to unsworn falsification to authorities. Date: ~,.~-\:- 9 / ) ('I'i s- f Samuel Kacyon. Jr. PlalntilT ~ tf). ./? Aaron D, Parnes, Esquire Allorney I.D. No. 58793 KINO & PARNES, Allorneys at Law t 7 South Market Square, Suite 310 Harrisburg, PA 17101 SAMUEL KACYOO, Jr., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 95-4844 CIVIL TERM PATRICIA KACYON, Defendant CIVIL ACTION - LAW CUSTODY auJm OP CDM1' NIl tUf, this upon consideration of the is ordered and directed as Ij -...... ~ V\. day of \ attached Custody concil~at on Suntnary follows: , 1995, Report, it 1. The Mother, Patricia Kacyon, shall have legal custody and primary physical custody of samuel Robert Kacyon, born Decenber 21, 1986 and Christopher Joseph Kacyon, born October 7, 1989. 2. The Father, Samuel Kacyon, Jr., shall have partial physical custody of the Children every Wednesday, alternating Saturdays and alternating Mondays following weekends during which the Father did not have a period of partial custody. The times for exchange of custody under the foregoing schedule shall be arranged by mutual agreement of the parties on an ongoing basis. 3. The parties shall share custody of the Children on holidays as arranged by mutual agreement of the parties. 4. The parties may modify the terms of this Order by mutual agreement. In the absence of mutual agreement, the provisions of t~ Order shall control. ./ .-' , BY THE CQlJRT, CCI Patricia Kacyon Aaron D. Parnes, Esquire ~~.. ~.. ~J.. 1~I.,Lr;J- :.d. t. J. . J , '... N ~~ ..:z- .. '" :c ;t n.. 8~ ~ 5tn I {f~ '-' g:: dE l::5 In ~ u, SAMUEL KACYOO, Jr., Plaintiff IN THE COURT OF ca-1MON PLEAS OF CUMBERLAND COONTY, PENNSYLVANIA va. NO. 95-4844 CIVIL TERM PATRICIA KACYON, Defendant CIVIL ACTION - LAW CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN AOCXIIDl\NCB Wl'l1I aJlIIBRLAND aumr RlJLB (Xl' CIVIL l'R)o.....U 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Children who are the subjects of this litigation is as follows: NAME BIRTHDATE CURRENTLY IN CUSTODY OF Samuel Robert Racyon Christopher Joseph Kacyon December 21, 1986 October 7, 1989 Mother/Defendant Mother/Defendant 2. A Conciliation Conference was held on November 30, 1995, with the following individuals in attendance: The Father, Samuel Racyon, Jr., with his counsel, Aaron D. Parnes, Esquire. The Mother did not attend the Conference but contacted the conciliator's Office to advise thst she agreed to the partial custody arrangements outlined in a written Agreement prepared and signed by the parties. The Mother is not represented by counsel in this matter. 3. The Father provided the Conciliator with the written Agreement at the Conference and further background and details concerning the parties' agreed arrangements were obtained by the Conciliator. 4. The parties agreed to the attached. entry of an Order in the t}(1~~ Dawn S. Sunday, Esqu r Custody Conciliator form as ~ :5 0, 1'1'1,) illite