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HomeMy WebLinkAbout96-02661 JAMES H. BEST, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ,?(. .II, t, I 1.1,.<l 7-"", CIVIL ACTION. LAW vs, .JANE H. BEST, Defendant IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, Plaintiff, James H, Best, by and through his attorney, Edward J. Weintraub, Esquire, files a Complaint For Custody against Defendant Jane H. Best, and in support thereof, aven; the fallowing: 1. Plaintiff is James H. Best, Father, who currently resides at 2731 Walnut Street, Camp Hili, Pennsylvania, 17011. 2. Defendant Is Jane H. Best, Mother, who currently resides at 911 Country Club Road, Camp Hili, Pennsylvania, 17011. 3. Plaintiff seeks partial physical custody of the following child: NAME Present Address AGE Michael W. Best 911 Country Club Road 13 Camp Hili, PA 17011 Charles A. Best 911 Country Club Road 17 Camp Hili, PA 17011 4, The children were not born out of wedlock. 6. Both children are presently in the primary physical custody of Mother, Jane H. Best, who currently resides at 911 County Club Road, Camp HIli, Pennsylvania, 17011. Person Relationship NONE 12. Plaintiff and Defendant have not participated as a party or witness, or in another capacity, In other litigation concerning the custody of the children In this or another court. 13. Plaintiff and Defendant have no Information of a custody proceeding concerning the children pending in a court of this Commonwealth. 14. Plaintiff and Defendant do 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. 15. The best interests and permanent welfare of the children, Michael W. Best and Charles A. Best, will be served by granting the relief requested, Inmr alia, because the Plaintiff/Father has been one of the children's primary caretakers. 16. Each parent whose parental rights to the children have not been terminated and the persons who have physical custody of the children have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action and the right to intervene, Name Address Basis of Claim VERIFICATION I, James H. Best, hereby swear and affirm that the facts contained in the foregoing Complaint For Custody are true and correct and are made subject to the penalties of 1 B Pa.C.S.A. Section 4909 relating to unsworn falsification to authorities. Date:~ (' '- i " JAMES H. BEST, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 96.2661 CIVIL TERM JANE H. BEST, Dafendant IN CUSTODY ~ AND NOW, this ~ day of the Conciliator's Report, It appearing that the partl , 1996, upon receipt of ave agreed to the terms and provisions of this Order which was dictated In the presence of their counsel, and authorized and approved by them, It Is hereby ordered and directed as follows: 1. The minor children, Charles A, Best, d.o.b, 19 February 1979, and Michael W. Best, d.o,b, 1 July 1982, will attend a minimum of six (61 sessions with their Father to attempt to work out a visitation schedule and Mother will cooperate In ensuring that the children attend those sessions. Three of the sessions will be with Betty Weinberger, and the other three sessions will be with Ann Smith Associates, either with Ann Smith, Jeb Bird, or Richard Kelly. The parties will attempt to schedule those sessions 50 that they occur on a weekly basis if at all possible, commencing the week of 9 July 1996. 2, In the event that the parties are unable to work out an appropriate schedule and either party leels the need to have a mora 6. The Defendant's position on custody Is as follows: Sea attached Order. 7. Need for separate counsel to represent children: None requested. 8. Need for Independent psychologlcel evaluation or counseling: See attached Order. Date: 10 July 1996 I~ I ( ( I \. I, i , ,( '..' Mlc ael L. Bangs Custody Conciliator I , , 2