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HomeMy WebLinkAbout07-0430Dennis R. Mulholland, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. No. 07 - ~3© CIVIL TERM Cowin E. Ward, Defendant : IN CUSTODY COMPLAINT FOR CUSTODY 1. 2. 3. The plaintiff is Dennis R. Mulholland, residing at 26280 Coleman Lane, Onancock, Virgina 23417. The defendant is Corrin E. Ward, residing at 828 Nesbit Drive, Cazlisle, Cumberland County, Pennsylvania. Plaintiff seeks custody of the following child: Name Present Residence DOB Age Mason Wazd 828 Nesbit Drive 10/11/03 3 yeazs Carlisle, PA 17013 The child was born out of wedlock The child is presently in the custody of Corrin E. Ward who resides at 828 Nesbit Drive, Carlisle, Cumberland County, Pennsylvania. During the past five years, the child has resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Dennis R. Mulholland 45 South East Street Cowin E. Wazd Cazlisle, PA 17013 2003-2004 Cowin E. Ward 828 Nesbit Drive Cazlisle, PA 17013 2004-Present 4. The mother of the child is Corrin E. Wazd residing at 828 Nesbit Drive, Carlisle, Cumberland County, Pennsylvania . She is not married. The father of the child is Dennis R. Mulholland, currently residing at 26280 Coleman Lane, Onancock, VA 23417 He is not married. 5. 6 The relationship of plaintiff to the child is that of Father. The plaintiff currently resides with the following persons. Name Jennifer Rillo Relationship Girlfriend The relationship of defendant to the child is that of Mother. The defendant currently resides with the following persons. Name Rick Ward Relationship. Father 7. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. The best interest and permanent welfare of the child will be served by granting the relief request because: Plaintiff has been unable to schedule visitation with the child since separating from the Mother. Plaintiff has been unable to visit with the child in Mother's home because of the discriminatory and demoralizing comments from Mother. A Court Order of custody and structured visitation is desired so that the Plaintiff and the child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion. A Court Ordered determination of custody is required to avoid continuing conflict between the parties regarding responsibility for custody and support. WHEREFORE, Plaintiff requests this Court grant Plaintiff partial physical custody with scheduled visitation and joint legal custody. Date: ~~ Zs~D~"r Respectfully submitted, .-- Michael O. Palermo, Jr. squire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 93334 Attorney for Plaintiff a J VERIFICATION I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unsworn falsification to authorities. Dennis R. lholland, Plaintiff ~ d (~ ~ ~' ~ _ _T f"' .~,a ' i. ~) ~~ S ~ - ~ ] ~! ~ ~ j J _ rn ~ ~ .... . W ~ W, ~ . ~ ~v W -~C ~~ 4 M DENNIS R. MULHOLLAND IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. CORRIN E. WARD DEFENDANT • 07-430 CIVIL ACTION LAW 1N CUSTODY ORDER OF COURT AND NOW, Wednesday, January 24, 2007 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, February 16, 2007 at 1:00 PM for aPre-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 ale five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR. THE COURT, By: /s/ ohn .Man an r. Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must. be made at least 72 hours prior to any hearing or business before the court. You. must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~tY~f' o ~~ ~% ~ {~ i ; t, ranr~ ~:: 1, «! __~;_ .~ f '. a-' Dennis R. Mulholland, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. No. 07 - 430 CIVIL ACTION LAW Comn E. Ward, IN CUSTODY Defendant ORDER OF COURT AND NOW this ~' day of ,tea., , 2007, upon consideration of the attached Custody Conciliation Report, it is Ordered and Dir ce ted as follows: 1. The Mother, Cowin. Wazd, and the Father, Dennis Mulholland, shall have shared legal custody of Kason Ward, bom 1011312003. Each parent shall have equal right, to be exercised jointly with the other parent, to make all non-emergency decisions effecting the child's general wellbeing including, but not limited to, all decisions regarding his health, education and religion. 2. The Mother, Corrin E. Wazd, shall have primary physical custody of the minor child, Kason Ward. 3. It is not contested that Father currently has a bench warrant for his arrest and does not currently reside in the Commonwealth Pennsylvania. It is contradictory that Father is seeking the Commonwealth's authority to assist in asserting his legal rights to his child in the Commonwealth of Pennsylvania when he refuses to acknowledge the Commonwealth's authority over him in the pending criminal matter. 4. In light of this, should Father address his bench warrant issues with the Commonwealth of Pennsylvania, Father, or his counsel, has the right to file a Petition to Modify the Instant Custody Order. 5. This Order is .entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions' of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. By the Court, Dis bution: ichael O. Palermo, Esquire ,col J. Lindsay, Esquire John J. Mangan, Esquire '! , ~~ MAY 0 2 20011 ~ ~ Dennis R. Mulholland, Plaintiff v. Corrin E. Ward, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 07 - 430 CIVIL ACTION LAW 1N CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVII.. PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH Kason Wazd 10-13-2003 Currently in the custody of Mother, Corrin E. Wazd. 2. A Conciliation Conference was held with regazd to this matter on Mazch 23, 2007 with the following individuals in attendance: The Mother, Corrin E. Wazd, with her counsel, Cazol J. Lindsay, Esquire. The Father, Dennis Mulholland, was not in attendance but was represented by his counsel, Michael O. Palermo, Esquire. 3. -The undersigned Conciliator submits the entry of an Order in the form as attached. L ~~ ~ Date ~~ John gan, Esq ' e Custody Conciliator ~i_~:i.S` ~..~~ 1 til_ 2~~~ F~F~~~ "8 f'i't 1 9 .. .... I•~`~y~f tm f~`-~H.