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RUTH A, MILCHAK,
Plaintiff/Petitioner
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY. PENNSYLVANIA
: NO, it&-
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V.
: CIVIL ACTION. LAW
IN CUSTODY
WILLIAM p, MILCHAK,
Defendant/Respondent
ORDER OF COURT
AND NOW, this :2!Ji lQay of J n nL-<'" 'I , 1996 on consideration of the attached
petition, it is hereby directed that the parties and their respective counsel appear before
_OO''-VfI <:;, Sv-rc\t.'l Esquire. the conciliator, at ~"1 Lv. f\'l c.;.... Sl rVkcll''''''~ \k~
on the ~day of f-e J, I v-c, I y . 1996, at q~()) It,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 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 this conference may provide grounds for entry of a temporary or permanent
order, Hearing to be held'l .--..
BY THE COURT,
BY: O~I1.d.d.~LV~ i- o,er
Custody Conciliator 't-?'g j/(
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.
Court Administrator
Cumberland County Courthouse
Carlisle. PA 17013
(717) 240-6200
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RUTH A. MILCHAK.
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO,
CIVIL ACTION - LAW
WILLIAM P MILCHAK,
Defendant
IN CUSTODY
COMPLAINT FOR CUSTODY
I, Plaintiff, Ruth A, Milchak is an adult individual residing at 1459 Hillcrest Ct.,
CountryWalk Apt 505, Camp Hill, Cumberland County. Pennsylvania. 17011.
2, Defendant, William p, Milchak is an adult individual residing at 13 Hunter Lane, Camp
Hill, Cumberland County, Pennsylvania. 170 II,
3, Plaintiff seeks custody of the parties' minor child, Brent Paul Milchak, born May 24,
1984, residing at 1459 Hillcrest Ct., Country Walk Apt. 505, Camp Hill, Cumberland County,
Pennsylvania, 170 II,
4, In the past five years, the parties' child has resided with the following persons, at the
addresses and for the periods of time indicated below:
Plaintiff
1459 Hillcrest Ct" Country Walk Apt. 505,
Camp Hill, PA 8/95 - present
Plaintiff & Defendant
80 Stricker Drive, York Haven, PA 6/94 - 8/95
Plaintiff, Defendant &
AI Kennedy
4125 The Burns Road. Mechanicsburg, PAl 0/89 - 6/94
The child was not born out of wedlock,
The child is presently in the custody of Ruth A. Milchak who resides at 1459 Hillcrest Ct"
Country Walk Apt. 505, Camp Hill, Cumberland County. Pennsylvania, 170 II,
The Mother of the child is Ruth A. Milchak who resides at 1459 Hillcrest Ct., Country
Walk Apt, 505, Camp Hill, Cumberland County, Pennsylvania, 17011.
She is married,
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The Father of the child is William p, Milchak, currently residing at 13 Hunter Lane, Camp
Hill, Cumberland County, Pennsylvania 170 II.
He is married,
5, The relationship of Plain tilT to the child is that of Mother,
The PlaintilT currently resides with the child,
6, The relationship of the Defendant to the child is that of Father,
The Defendant resides with Naomi Frey,
7, PlaintilT has participated as a party in other litigation concerning the custody of the
child at NO, 95-SU-03284-02D, York County, Pennsylvania, however, that custody action has
been dismissed,
PlaintilT has no other information of a custody proceeding concerning the child pending in
a court of this Commonwealth,
The PlaintilT does not know of a person nor 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,
8, The best interests and permanent welfare of the child requires that primary physical
custody and legal custody of the child be with the PlaintilTlMother, Ruth A. Milchak because she
is the primary physical caretaker of the child,
Wherefore, PlaintilT, Ruth A. Milchak, respectfully requests that she be awarded primary
physical custody and primary legal custody of the subject minor child as provided herein,
~~
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Keith B, DeAnnond, Esquire
Attorney 1D Number 58878
2800 Market Street
Camp Hill, PA 17011
(717) 730-9394
'"
DATE: 1/ID/~v
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VERIFICATION
I. Ruth Milchak, the undersigned. do hereby verifY that the statements made in
the foregoing instrument are true and correct to the best of my knowledge. information and belief.
1 understand that statements herein are made subject to the penalties of J 8 Pa, C, S, Section 4904,
relating to unsworn falsification to authorities,
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Ruth Milchak
Date:~ ~\<',l"-' \ \ \, \94\0
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RUTH A, MILCHAK,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO, 96-320 Civil Term
CIVIL ACTION - LAW
WILLIAM P MILCHAK,
Defendant
IN CUSTODY
f., ,. r~R
AND NOW, thJ ~ day of ~1996, upon presentation of the foregoing
Agreement, it is hereby ordered that Ruth A. Milchak shall have primary physical custody of
Brent Paul Milchak born May 24. 1984: It is further ordered that:
I, The Mother and Father shall have joint legal custody,
2, The Mother shall have primary physical custody of the minor child, Brent Paul
Milchak,
3, The Father shall have visitation andlor partial physical custody rights as follows:
a, On alternating weekends commencing at 6:00 o'clock on Friday until
6:00 o'clock on Sunday;
b, Every other Thursday from 5:00 o'clock P,M. until 9:00 o'clock P,M, on
the weeks there are no weekend visitation;
c, During the Christmas holiday Father shall have physical custody from
9:00 o'clock A.M, on December 26 until 9:00 o'clock P,M, on December
28, It is specifically understood that Mother shall always have physical
custody of the minor child every year on Christmas eve and Christmas Day
and December 29 through January I.
d, The parties shall alternate physical custody of the minor childduring the
following holidays: Easter. Memorial Day. Fourth of JulY, Labo~ Day, and
Thanksgiving; :" .
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e. Father shall be entitled to three weeks of visitation during the summer, It
is understood that two of the weeks of Father's summer visitation may be
taken consecutively,
By the Court,
1.
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Rum A, MILCHAK,
PLAINTIFF
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,I'ENNSYLVANIA
VS,
: NO,
: CIVIL TERM
: CIVIL ACTION - LAW
WILLIAM p, MILCHAK,
DEFENDANT
: IN CUSTODY
CUSTODY AGREEMENT
AGREEMENT made this (~'I ~ day of 11 N4 1995, between Ruth A,
Milchak, hereinafter referred to as MOlher and William p, Milchak, hereinafter referred to as
Father.
WHEREAS, the above named Mother and Father had born to them Brent Paul Milchak
on May 24, 1984,
WHEREAS, the above named Mother and Father desire to enter into an agreement as to
the custody of the above said child and to the visitation rights of the non custodian parent:
NOW, THEREFORE, in order to effectuate the above purpose, the above named Mother
and Father hereby agree that:
I, The Mother and Father shall have joint legal custody,
2, The Mother shall have primary physical custody of the minor child, Brent Paul
Milchak.
3, The Father shall have visitation and/or partial physical custody rights as follows:
a, On altcrnating wcekends commencing at 6:00 o'clock on Friday until
6:00 o'clock on Sunday;
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b, Every other Thursday from 5:00 o'clock P,M, until 9:00 o'clock P,M, on
the weeks there are no weekend visitation;
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c, During the Christmas holiday Father shall have physical custody from
9:00 o'clock A.M, on December 26 until 9:00 o'clock P,M, on December
28. It is specilically understood that Mother shall alwllYs have physical
custody of the minor child every year on Christmas eve and Christmas Day
and December 29 through January (,
d, The parties shall alternate physical custody of the minor child during the
following holidays: Easter, Memorial Day, Fourth of July, Labor Day, and
Thanksgiving;
e, Father shall be entitled to three weeks of visitation during the summer, It
is understood that two of the weeks of Father's summer visitation may be
taken consecutively,
4, This Agreement may become an Order of Court,
5, This Agreement may be modilied or terminated in whole or in part upon written
consent of both parties, Ifit becomes an Order of Court. modilication of the Court Order is also
required, The parties agree that they shall refrain from making derogatory remarks in the presence
of the child about the other parent,
6, The parties hereto intend to be legally bound by the terms of this Agreement.
IN WITNESS THEREOF, the parties here unto set their hands and seals the day and year
mentioned above.
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Ruth A. Milchak, PlaintitTlMother
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William p, Milchak, DefendantIFather