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Home My WebLink About96-03245 , Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PIA T, WRIGHT, v CIVIL DIVISION - LAW NO, 96.? 7.--'f!:' CIVIL TERM MICHAEL L, WRIGHT, Respondent CUSTODY PRAECIPE TO UlSCONTINUE TO ,THE PROTHONOTARY: Please mark the above captioned case DISCONTINUED, " June 10, 1996 .. B OUlDS, J('OUSTON PC John' ,Broujos, Esquire Att\ y I.D, No, 06268 4 North Hanover Street Carlisle, Pennsylvania 17013 717/243-4574717/766-1690 FAX 717/243-8227 j' - r:: I.r.l ~ en ~~) r:)~ ~ :r.: '-l~ .... 91 FI - S- i; - ~ ,9j rfj G!~ ~... & to "j O. 0 . . . ,:;~':, . n . \< ~;..- I;,' ~1~f:" -, 'TO .,-~,:;~you MI M..'IY NOf.'" TO .\.IAD TO :'<,,,. ,-aNGLO.aD ,s.&ADtH. WlTttl" )"'1;',,*,"" ... DAY' 0' ""'ilC1 HllUbp . ""', .-."AUIo' AlDGMCHT MAY .. unP~ Aeo\IH'T YOU. P,O, . , .'"...... re' BROUJ08, GILROY III HOUSTON, ~.. ATTO"NaV. AT LAW .. NUftTH HANOV." wr".1IT CARLI.UI:. ,.a:NNBVL-VANlA '''Ol~ 17171 ....04.".. 7,.""0 JUN 07 1996 }r-' , . , J ~t " I"" . 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V,' CIVIL TERM Respondent CUSTODY ORDER OF COURT AND NOW, this _ day of June, 1996, it is hereby directed that the parties and their respective counsel appear before a.wn Sunday , on the.!L day of SuJy , Conciliator, at :tJ I.JJ, /Y)(.,~ 01' (Y]elhtfliCShI.J:j 1:00 . 1996, at f' ,m" for a Prehearing 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, Either party may bring the child who is 1he subject of this custody action to the conference, but the child's attendence is not mandatory, Failure to appear at 1he conference may provide grounds for entry of a temporary or permanent order, 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, PENNSYLVANIA 17013 TELEPHONE: 717. 240.6200 )10 dg~~ dtd-ulfu,-y Q\lLI )..a..J "e4?fM (iWr."~ FOR THE C;OURT: ~ By: dfIc~ '/1dt:~ Ism i! Custody Co\'clliator ' . ._---._,--.__...--.....~..--. the following addresses: Person Address Dates Pia T, Wright Michael L. Wright 100 E, Willow Street Carlisle, PA 17013 October 1995 to present Pia T, Wright Michael L, Wright 102 W, Willow Street Carlisle, PA 17013 April 1995 to October 1995 Pia T, Wright Michael L, Wright 6747A E, Saratoga Tucsan, AZ 85711 1992 to April 1995 . The mo1her of the children is Pia T, Wright, currently residing at 100 E, Willow Street, Carlisle, Cumberland County, Pennsylvania 17013, . She is married to Defendant, . The father of the children is Michael L. Wright, currently residing at 100 E, Willow Street, Carlisle, Cumberland County, Pennsylvania 17013, . He is married to Plaintiff. 4. The relationship of Plaintiff 10 the children is that of mother. . The Plaintiff currently resides wi1h the following persons: ~ Relationship Michael L. Wright Jason Michael Wright Christian Phillip Wright Husband Son Son 5. The relationship of Defendan1 to the children is that of fa1her, . The Defendant currently resides with 1he following persons: ~ Relationship Pia T. Wright Jason Michael Wright Christian Phillip Wright Wife Son Son 6. The Plain1iff has not participated as a party or witness, or in another capacity, in other litigation concerning the cus10dy of the children in this or another Court, 7, Plaintiff has no infonnation of a cus10dy proceeding concerning 1he children pending in a Court of this Commonwealth, 8, Plain1iff does not know of a person not a party to thc proceedings who has physical custody of the childrcn or claims to have custody of visitation rights with respect to the children, 9, The best interest and pennanent welfare of the children will be served by granting the relief reques1ed because: the childrcn have bcen in the custody of the Plaintiff conlinuously since the children's births; Fa1her works full lime during the day and is unable to supervise children during daytime; Father is pennanently moving to Arizona on or about July I, 1996; and the Plaintiff is capable of caring for the children, In addition, the following conditions exist: . Father and M01her are currently separating as of June 7, 1996, . Father has taken Mother's foreign passport, Mother is a citizen of Great Britain and has resident alien status as spouse of a citizen, . Fa1her Is leaving pennanently for Arizona on July I, 1996, Mother has reason to believe that Father will toke the childrcn without a court detennlnation, . Father has car; recently sold a truck to obtain ready cash; took the family checkbook to a joint account; and has taken olher actions Indicating Intent to move from the area, . Mother is not currently working; has been at home with youngest child, . Mother wants 10 keep Jason Michael in Carlisle for the remainder of school tenn, which ends on June 12, 1996, and wants custody of the child Chris11an Phillip, 10. Each parent who has parental rights to the children which have not been tenninated and the person who has physical custody of the children are parties to the action, 11. Plaintiff seeks an immedia1e court order directing that she be given physical custody of the children pending a custody conciliation hearing or a hearing before the Court, WHEREFORE, Plaintiff requests this Court to grant an immediate order granting physical custody of the children to Plaintiff and to direct conciliation, June 7, 1996 R , ,\- , Broujos, Esquir y for Plaintiff BROUJOS, GiLROY & HOUSTON, P,C, 4 North Hanover Street Carlisle, Pennsylvania 17013 7171243-4574 7171766-1690 FAX# 717/243-8227 I verify that the statements in the foregoing pleading are Il1le Wld correct, I understWld that false sta1ements herein are made subject to the penalties of 1 [l PaeS 4904 relating to unsworn falsification to authorities. 11. cJ ;'~>fed! Pia T, Wright J ! ~' 'i \ !t -~ t i t f5 w ;:: R ] -a.. ~i a :i .,1- ,;J.s ~ 8 e- I" ." 8 D 'ili -- ~l:l ~ ,'- r;)~ , 10 .i.: r- g ui U1 'F, 1t ... "tI- t '. !.!l ::t rew ~ j-,J,(-, 'J '::>": ~ I~.J~ .!!J fi () l; ~'..J Ul '3 en G