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HomeMy WebLinkAbout96-00320 \ i I I ...;.J; d · -5; , - , eEl i ! . , -;#1 .-.JI ~I :::: 1 E- \ ~ , // / [ ~ J o n ('{) 6/ Z ~ >- N ;. 0- ~ ") r) ,..;: ...::l' t., ,-- -- r ~Cl c.~ :-5".- -, ---0"') )..--. ( )-.'" lEo b:<~) .. -~ ~ o~~ t.~ ,")::c: Ct'.' N ~;~:f~ LUl... N cr:1~' ; ~ :' .c_ :;'~ t:-!tQ ;:::; ..," ~ ['1.i., Lt. -" U '0 ;:; - 'H U .-..... '-... n~ --- - , '- rt"" J M 'f""l ~ ~ ..... '~ ,,",' ~" ~"-+.r--.\\J\ .~ '-..J ~ \.::::J . , - ".,I .. ~ . r , "'" !!,1/ \ip ';)I' ~ . RUTH A, MILCHAK, Plaintiff/Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY. PENNSYLVANIA : NO, it&- ~)o (J I t~~ .J U....:'1r'-. 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 ;.,: -0<-(~-::: r --: .'. I !! .';_.' ~.! I".' ,II '.<1 ,~.:. ~l;j F.; J' f:~: ,. C' ,I ,.~~ .., " ,".' ,-'-,. l,.,}i".. ~,. .' ! 1.....Li\ I j l" l~:\' -:~;'I i:',.',\\',\ ~'e/t.' 96 "ti/tl. fo/}t :nJ/ A> 4 XJd4H~'"x/ ; cJ?,'~ 7:~~c /f,ll~t~ ?l; 1f1 c;Jb f{'/; ~/j' ,naJl./ ;J a~~ .. , .... ~ . 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, -: - Page 2 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, ~~ - Keith B, DeAnnond, Esquire Attorney 1D Number 58878 2800 Market Street Camp Hill, PA 17011 (717) 730-9394 '" DATE: 1/ID/~v I I . .. . 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, K~\\ \' \.~c\ ~V ~ Ruth Milchak Date:~ ~\<',l"-' \ \ \, \94\0 \. I .(Or-. ~ ' " "7, t" , ......... '1 '1 ~ F .- .. - . . 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; :" . ,.- Page 2 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. - - 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; , i ,; j l , 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; - Page 2 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. ~\\ \={. ~u\~\2_ Ruth A. Milchak, PlaintitTlMother V..).M_,.fJ/J11 ii...;- William p, Milchak, DefendantIFather