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Home My WebLink About96-00923 \ " 1% i".:5 ! . -7 8 If) d "'::L 1), ~ j r() C6 C} J ~ cr 1./ o -z IN THE COURT Olt' COMMON PLEAS OF CUMBERI.AND COUNTY, PENNSYL VANIA SUSAN LYNNE KASSAY Plaintiff, No. v. Civil Action - Custody JAY MICHAEL WAY Defendant COMPLAINT roR CUSTODY 1. The plaintiff is Susan Lynne Kassay, an adult individual, sui juris, who resides at 749 Old Silver Spring Road, City of Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania, 17055. 2. The defendant is Jay Michael Way, an adult individual, sui juris, who resides at 65 S. 35th St., City of Camp Hill, County of Cumberland, Commonwealth of Pennsylvania, 17111. 3. Plaintiff seeks custody of the following child: Name Present Residence Age Alexandra Kassay 749 Old SUver Spring Road Mechanlcsburg, PA 170!! 6 years 4. The child was born out of wedlock. 5. The child is presently in the custody of Plaintiff. 6. During the past five years, the child has resided with the following persons and at the following addresses: Person Address Dates Susan Kassay 749 Old Sliver Spring Rd. Mechanlcsburg, PA 17055 )2.94 to present Susan Kassay Jeanne & Edward Fox 63 Fairway Dr. Camp Hili, Pa 17111 1-92 to 12-94 Susan Kassay & Jay Way Hummel Ave Lemoyne, PA 1991 7. The mother of the child is Susan Kassay. who currently resides at 749 Old Silver spring Road, Mechanicsburg, PA 17055. 8. She is single. 9. The father of the child is Jay Way, who currently resides at 65 S. 35th Street, Camp Hill, PA 17111. 10. He is married. II. The relationship of plaintiff to the child is ,hat of biological mother. VERIFICATION I verify that upon personal knowledge or information and belief that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject 10 the penalties of 18 Pa.C.S. 0 4904, relating to unsworn falsification to authorities. Isl Susan Kassay Plaintiff Dale: / " 7 i ~~ ~~~ ~~E~ ~~u~ f:i~ 8 ~8~~ S~~ ~~~ .... .... .... .., c ..... ~~ ~ ..., ~ 1 .... .21 ~ ~ ~ ~ ,., hi 8~ ;~ ~"~.g ..~ ~j~ ~~ ,jJ,J ~' ~ ~ .... ,-. jlI,I i I ... ~ 'I! . :::! . a ~. 5' 1i "a ~ ~ j ::'~ .,..... :.Ti- ia. M.: t.. t"l ~ ... . III > 'i SUSAN LYNNE KASSAY, Plaintiff IN THE COURT OF CCWICtl PLEAS OF CUMBERLAND COUNT'l, PENNSYLVANIA va. NO. 96-923 CIVIL TERM JAY MICHAEL WAY, Defendant IN CUSTODY 0I9'l'00r CDlCItIATIC>>I 5lM'l\RY REPCRl' IN AaXRDAIICB wrm <nmIIRLAND cx:unY RULE CR CXVIt PIlO ",..e 1915.3-8, thA undersigned Custody Conciliator submits the following report: 1. The relevant information pertaining to the Child who is the subject of this litigation is as follows: NAME BIRTHDATE CURRENrLY IN CUSTODY OF Alexandra Kassay August 16, 1989 Plaintiff/Mother 2. A Conciliation Conference was held on April 16, 1996, with the following individuals in attendance: The Mother, Susan Lynne Kassay.. with her counsel, Lee E. Oesterling, Esquire, and the Father, Jay Michael Way, with his counsel, Andrew C. Sheely, Esquire. 3. The parties agree to entry of an Order in the form as attached. Date f.Jr.l'~ ~lh._ ,L.li~~ Dawn S. Sunday, ire Custody Conciliator I 7 I '9CJ~ . ~ ; I ~ ~ I , i -.l ~ ; II c. . ~ ;.,.... .... I ~ ~~ ~t II ::.f ," ~ ZlS ~J ... B , .a,g t~ c. -.l :1 = - - ';d H 1. !l ,';;.., . ~.... > UJ ' I. oJ! ';l c" ~ ~~ . U~ H [<; > U ~ ~ [<; ;.I ',; if . "Ii . :;! = H a . r - 'd ~ -.l :&: ~ ~ ~ = ~- ~ ~ :>< ~ I ~ it ::: :: ~ <C ~ ;:: P ICf: ~ "0 .., -.l ;51. \i"'l~ H ~ > . H ~ U ; z ~ H SUSAN LYNNE KASSAY, Plaintiff : IN THE COURT OF C01MON PLEAS OF : CUMBERLAND CClUNTY, PENNSYLVANIA . . v. : NO. 96 - 923 CIVIL TERM . . JAY MICHAEL WAY, Defendant . . : IN CUSTODY PRIOR JUOOE: GEORGE E. HOFFER QJS'l'OOY' CXK:ILIATlOO SlMIARY RflP(Rr IN ACCORDANCE WITH CUMBERLAND COUN'l'Y RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The relevant information pertaining to the Child who is the subject of this litigation is as follows: NAME BIRTHDATE CURRENTLY IN CUSTODY OF Alexandra Kassay August 16, 1989 Plaintiff/Mother 2. The initial conciliation Conferencfl was held in this matter on April 17, 1996. The parties were able to agree on a two-month visitation schedule to reintroduce the Father into the Child's life gradually as the Father had not had contact with the Child for several years. As a result of the Conference, this Court entered an order on April 27, 1996, granting the Mother legal and primary physical custody and outlining a visitation schedule for the Father with a second Conciliation Conference to be held in a two-month period. 3. The second Conciliation Conference was held on June 26, 1996, with the fOllowing individuals in attendance: the Mother, Susan Lynne Kassay, with her counsel, Greg Hazlett, Esquire: and the Father, Jay Michael Way, with his counsel, Andrew C. Sheely, Esquire. 4. The pa.rties were not able to agree on long term partial custody arrangements for the Father and therefore the parties requested that a hearing be scheduled in this matter. An expanded visitation schedule was established for the Father pending hearing and it is the Conciliator's belief that as the Father/Daughter relationship naturally develops over the course of the temporary schedule, the parties are likely to be able to further expand the Father's contact with the Child to partial custody by agreement. 5. The Mother's position on custody is as follows: prior to initiation of this action, the Father had not seen the Child since December, 1992. The Mother believes that, while the two-month viDitation schedule previously ordered by agreement of the parties went well, the contact was not sufficient to begin partial custody at this time. The Mother strongly believes that the Child should not be rushed into partial custody arrangements for which she may not be ready. The Mother also bV IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSAN LYNNE KASSAY Plaintiff, No, 96-923 v. Civil Action - Custody JA Y MICHAEL WAY Defendant ORDER AND NOW, this day of , 1996, based upon the within Petition for Mental Examination of Parties and Child, it is hereby ORDERED that the parties and their child, SlJ.lJan Lynne Kassay (Motber), Jay Michael Way (Fatber) and Alexandra Kassay (Child), m~e themselves available to appear before ,(Appointee), for examination and evaluation concerning the cu,tody of Alexandra Kassay. The cost for said examination and report shall be equally apportioned between the parties. , (Appointee), shallprovide a copy of his report to counsel no later than ten (10) days prior to the date of a hearing on the merits of this case. BY THE COURT, J. ii IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA SUSAN LYNNE KASSAY Plaintiff, No. 96-923 v. Civil Action - Custody JAY MICHAEL WAY Defendant ~LE TO SHOW C SE AND NOW, this I day of , 1996, upon consideration of Plaintiffs Petition for Mental E)[aminat n f ties and Child, Defendant is hereby Ordered to show cause, if any, why the requested relief s ould not be granted. Rule Returnable: I~~~ , r~e.(,.. ., , " J. <- .) ,., '1 , J f, , . :J , , ! ) , '1 1 .,! t_,) ~; , . . WHEREFORE, Petitioner respectfully requests this Honorable Court to: a. Order the parties and child to appear before a psychiatrist and or psychologist of the Court's choosing. b, Order the parties to equally bear the COSls of said examination and report. c. Such other relief as is necessary. Respectfully Submitted, HAZLETI & OESTERLING Q' ,l.; ';;d~ / Lee E. oesterling, .D. # 7132t1' Attorney for Plaintiff 1002 South Market Street Mechanicsburg, PA 17055 (717)790-0490 1 " ~ 'I . .. I~ . ~ ..,~ 1 " " , ' , " , .1 \"-' :1 " C', L j -. \ " \",' ,J i' 0(_1 !_. 't- ,,:,; f f') IN THE COURT OF COMMON PLEAS 01<' CUMBERLANI> COUNTY, IJENNSYL VANIA SUSAN LYNNE KASSAY Plaintiff, No. 96-923 v. Civil Action - Custody JAY MICHAEL WAY Defendant ~ ORDER OF COURT AND NOW, 'hi'~ d" of * . ~,po" pre,,"";," and consideration of the attached stipulation and agreemcnt and upon agrccmcnt of thc partics, BY THE COURT, it is hcrcby ordcrcd and dccrccd that the attachcd agreemcnt is made an Order of Court. J. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL DIVISION - LAW SUSAN LYNNE KASSA Y Plaintiff No. 96.923 V. CUSTODY JAY MICHAEL WAY Defendalll STIPULATION FOR ENTRY OF AN AGREED ORDER OF CUSTODY AND NOW, the parties by and through their allorneys, stipulate and agree that it is in the best illlerest of their minor child, Ale~andra Kassay, age 7, (hereinafter "Child"). to elller into the following custody arrangement which shall be elllered as an Order of Court. I. LEGAL CUSTODY shall be with Mothcr. Susan Lynne Kassay, which will include decision making with regards to importalll matlers such as education, medical care, religious training, etc.. 2. PRIMARY PHYSICAL CUSTODY shall be with Susun Lynne Kassay, (hereinafter "Mother"), 3, PARTIAL CUSTODY shall be with Juy Michucl Way, (hereinufter "Fmher"), subject to the following schedule: a. INITIAL CUSTODY PERIOD: Father shall have partial custody of the child on Septcmber 11 st & 12nd 1996. for u period of four (4) hours each day after which the child shall be relUrned to Mother. b. THE THIRD WEEKEND OF CUSTODY AND EVERY OHlER WEEKEND TIlEREAFTER: Beginning on Friday Octobcr 4, 1996 Fathcr shall have partial custody of the child every other weekend from Friday at 6 p.m. until Sunday at 4 p.m. c. IIOUDA YS: The Holidays shall be split between the parties with one half day being spent with Mother and the other half with Father as per the parties mutual agreemelll. The parties shall agrce to share Christmas Eve 1996 with Mother having custody from 11 a.m. December 14 ulllil 4 p.m December 24 and Fmhcr huving partial custody from 4 p.m. Dcccmber 14 ulllil 9 p.m December 14. '.. [; lr) i '.-- ~ . l)" (~~ '.- , , l!' L ", (..; r, l I "'; ]~ , L.l ,) " ,