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Home My WebLink About96-05663 " '> 1 I I I I Katherine Morrow. Plaintiff v. l .,d:i' : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA : CIVIL ACTION - LAW : IN CUSTODY Darren Green, Defendant : NO. 96. CIVIL TERM Q(..-6(.(,J ORDER OF COURT AND NOW, this 11..1~day of 7),). '~~n ,1996. upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before, HeA ",(1 'I ",,' 11': the conciliator, at l J I h f I(J> . Cumberland County Courthouse, on the " 'ilay of llr( r"',It., , 1996, at lr' .~" m., for a Pre-Hearing Custody Conference. At such conference, an effon will be made to resolve the issues in dispute; or if this C8Mot be accomplished, to deftne and narrow the issues to be heard by the coun. and to enter into a temporary order. Either party may bring the child who is the ~'Ubject of this custody action to the conference, but the child's attendance is not mandatory. Failure to appear at the conference may provide: grounds for entry of a temporary or permanent order. FOR THE COURT: By: . . ,:..,,/~ C!L, ",- .7(G,/4 YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 00 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. omCE OF THE COURT ADMINISTRATOR COURTHOUSE. 4th Floor CARUSLE, PA 17013 717/240-6200 AMERICANS WITH DISABILITIES ACT OF 1990 The Coun of Common P\eas of CumberlmJ County is required by law to comply with the Americans with Disabtlities Act of 1990, For infonnation about accessible facilities and reasonable .xommodatiom .1V1ilabk: to disabled individuals havina business before the coun. pIeast COllIlct our olTlCe. All manacmcnts must be made at least 72 boun prior to any hcarina or business before the coon. You must attmt the kbeduled conference or hearina. FIl.EO-OFFICE ~ TI-r: Pn01H'JlOTMY 96 OCT 18 AH 11130 CUeER:.N~D COUNlY PENNSYLvJM.\ //).j(9~ &,J. o/f ~~~~ /b./f-?J ~ ~~.~ t4tI . /P'/ff~ o/t~ ~ tI ~fiz .. ._'-...-- Katherine Morrow. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 96- CIVlL TERM : CUSTODY v. Darren Green, Defendant NonCE TO DEFEND AND CLAIM RIGHTS You bave been sued in court. If you wish to defend against the claims set fo11h in the following pages, you must take prompt action, You are warned that if you fail to do so, the case may proceed without you and I judgment may be entered against you for any other claim or relief requested in these papers by the plaintiff, You may lose money or propeny or other rights important to you, including custody or visitation of your children. 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. Coun Administrator, Fourth FJoor Cumberland County Cou11house Carlisle, Pennsylvania 17013 (717)240-6200 AMERICANS wrm DISABILITIES ACf OF 1990 The Coon of Common PJeas of Cumberland County is required by law to c:omp1)' with the Americans with Disabilities Act of 1990. For infonnation about ecmsible facilities and rusoaabIc acco...nodatIons available to disabled individuals havilll !lusu,- before the court, p1ease CXMUtt our off'ICe, All amr~1IIs must be made at Jeast 72 boIlrs prior to any beari1I& or ~asm- before the cowt. You must attm1 the ICbcduIed COIIferm:c or beari1I&, 7. The mother of the child is Katherine Morrow, currently residing at 119 1/2 W. Chapel Avenue, Carlisle, Cumberland County, Pennsylvania 17013. She is single. 8. The father of the child is Darren Green, who is currently incarcerated in the Cumberland County Prison, Carlisle, PA 17013. He is single. 9. The relationship of the defendant to the child is that of father. 10. The relationship of plaintiff to the child is that of mother. The plaintiff currently resides with the following persons: rBmt Anton Morrow R..llItlondtlp Child II. 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. 12. Plaintiff has no information of a custody proceeding concerning the child pending in a coun of this Commonwealth. 13. Plaintiff does not know of a person not a party to the proceedings woo has physical custody of the child or claims to have custody or visitation rights with respett to the child. 14. The best interest and permanenI welfare of the child will be served by grantina the relief requested t--t1~. a) Plaintiff has been primary c:aretakcr of the child since birth; b) Plaintiffprovidcs the child with a home with ~Ia~ moral, cmotiodaI and pbysical surroundinp as required to meet the child's ncah; t) Plaintiff is williDI to IICtcpl custody of the child; d) PIaintifY cmi1lln to ucrcbe parental dutiet and etVoys the love and affection of the child; IS. Each parent whose parental rights to the children have not been terminated and the ~"l- THOMAS M. PLACE ROBERT E. RAINS KATHERINE C, PEARSON Supervising Attorney GAIL R. SHEARER StaffAttomey FAMILY LAW CUNIC 4S Nol1h Pitt Street Carlisle, PA 17013 7171243.2968 person who has physical custody of the children have been named as patties to this action. WHEREFORE, plaintiff requests the court to grant to her custody of the children. Date \C)~~ ~ '-\ '-\ ~,k. S T. Tighe '1)- Certified Legal Intern VERIFICATION I verify that the statements made in this Custody Complaint are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification authorities. Date 10 J {~ ~JW.in.t(',:,jNon.rl::~~V Katherine Morrow . .....-.--""-'----.<""....,....:-.-..~ .... ". t ~ l\/ (' p,: c, (.)~ J f, - L:." f.: ('-: :.",: .. , $ " 1 . t , ~- '.( ........ '.'" "l ". (,;.;.', . ~""_~'._T'W_<" ._,""""",,,"-- Katherine Morrow, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA : CML ACTION - LAW IN : CUSTODY : NO. 96- CIVIL TERM v. Darren Green, Defendant AFFIDAVIT SUPPORTING PETITION FOR I.F.A VIr. TO PROCEED IN FORMA PAUPERIS 1. I am the Plaintiff in the above matter and because of my rmancial condition am unable to pay the fees and costs of prosecuting or defending the action or proceeding. 2. I am unable to obtain funds from anyone, io;luding my family and usoc:iates, to pay the costs of litigation. 3, I represent that the information below rellting to my Ibility to pay the fees and costs is true and correct. <I) Name: Katherine Morrow Address:119 1/2 W. Chapel Averme, Carlisle, PA 17013 Social Security No.: 184-64-8901 (b) Fmployment If you are presently employed, state Fmployer: nil Address: nil Sa1aIy or WIJCS per momh: nil Type of work: nil If you are preseDtly Uul:lDp1oyed, state Date of last empIoymellt: 12.95 Sa1aIy or WIJCS per momh: $800.00 Type of work: Diewy Aide (e) Other income within the pili tvfclvc modhs Buslnm or profasloll: nil Other self-cmploymcDt: nil I....at: 0 D1vtdcftds: 0 Pmsion and amWes:O SocialleCWity bcneftb: 0 Suppan payments: 0 Disability payments:O Unemployment compensation and supplemental benefits: 0 Workman's compensation: 0 Public Assistance: S316,OO/per month Other: Food Stamps S220.00/per month (d) Other contributions to household suppan (Wife)(Husband) Name: nla If your (wife)(husband) is employed. state Employer: nla Salary or wages per month: nla Type of work: nla Contributions from children:nla Contributions from parents: nla Other contributions: nla (e) Property owned Cash: 0 ~lri." account:nla Savinp aa:ount: nla CertiflClleS of deposit: nla RcaI estate (including home): nla Motor mucic: Make , Year nla Cost , Amount Owed S Stocks: bonds: nla Other: nla (f) Debts and obligations Mortpge: nla Rent: nla (HUD) Loans: nla Other: Utilities: Electric: $73.OOImth au : W.OOImth Cable : $13.OOImth Phone : $2O.OOImth CIodling: $IOO.OOImth Diapet. : $ 4O.OOImth Items IlOt c:o\'Cred by Food Stamps: $30.00 <J> re...... dcpendtnt upon you for support (Wirc)(Husband) Name: nla CblIdren. if any: Name: Ale: Antoft Morrow 14 mths Other pet1OM:nla Name: nla Rdatiomhip:llla . . 'f,r t-r--; ( L. L.. 'j, c' ., .. L, " ( .. , .. > '. L , SHERIFr's RETURN - REGULAR CAHK NUl l~9~-0~663 P ClJIIIIONW~:M.T" In' PENNSYI,VANIA I crJIJNTY m" CUII,n:RLAND IIlJRRIJW _uKA.T.lI!';~ [~f. Vli. qRP:N PARR~:r~. ~Jr-!lAF.I. JtARB,lC!L__ __,_ __.,_ CUIIBERl.AND County, P.nnsylvania, who to law, say., th. within COIIPI.AINT - upon _~RJiF.1t, .DAliREN___,..u___ ___" d.f.ndant, at 935100 HOURS, on th. 1 '322 at __C1!ltQf.RLAND COUNTY PR t SON CARt.t~J.F..,_,f..~ l7'-13 , liheriff or Deputy Sh.riff of b.ing duly .worn according CUSTODY was s.rv.d th. ~ day of Nov..b.r . .CIJIIBERLAND . County, Pennsylv.ni., by h.nding a true and att..t.d copy of the together with 9R~ER Of_QQVRT and at th. .... ti.e dir.cting ~ att.ntion to th. cont.nts th.r.of. to DARR~:N COIIPLAINT GREEN - CUSTODY . . Hhl:.'riff'. CostB' Dock.ting S.rvic. Affidavit Surch.rg. l8.00 3.1. .00 2.00 S7~A!~ H. ThO... a~ln.. ~n.rlXX 5~~.lU "'N':"" :~ .. r ~? h ~5" ' Sworn and BubBr.rib.d to before .. th18 /'1 J:.. day of 1u...- C- 1':1 9(._ ..0, \..~.. c, It..ti._~'-'P.c.,' T'i protl'iano("ary ..- " KATHERINE MORROW, PLAINTIFF v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY DARREN GREEN, DEFENDANT NO. 96-5663 PRAZCIPB TO DISCONTIHUB CUSTODY ACTION To the Prothonotary: Kindly allow Katherine Morrow, by and through her attorneys, The Family Law Clinic, to discontinue the above-captioned CUstody action, Date: 11S/Q1 r' Ii!-. Intern 1t4io-ll? ,(JJ. - - . ~' 1HOMAS HI PLACE ROBERT E. RAINS KATHERINE C. PEARSON Supervising Attorney GAIL R. SHEARER Staff Attorney THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968