Loading...
HomeMy WebLinkAbout02-5193YAVETTE D. EDRINGTON Plaintiff VS. JEROME STANFORD Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02- ~{ ~ ~ CIVIL TERM CUSTODY Cumberland County, Pennsylvania. 2. The defendant is Jerome Stanford, residing at 3651 Apartment 101, Harrisburg, Dauphin County, Pennsylvania. COMPLAINT FOR CUSTODY The plaintiff is Yavette D. Edrington, residing 124 R Summer Lane, Enola, Brookridge Terrace, 3. The plaintiffseeks custody of the Name Jaquan Edrington following child: Present Residence 1114 North 2nd Street Harrisburg, PA Permanent Residence 124 R Summer Lane Enola, PA Age 02/15/99 following addresses: Name Janie Edrington Address Date 1114 North 2nd Street Sept. 27, 2002 Harrisburg, PA present The child Jaquan Edrington was bom out of wedlock. The child is temporarily residing with maternal grandmother, who resides at I 114 North 2nd Street, Harrisburg, PA, and the grandmother will not return the child to the mother. urmg the child s hfet~me, he has resided w~th the following persons and at the Yavette Edrington Carlosse Edrington (half-sibling) Yavette Edrington Carlosse Edrington (half-sibling) 124 R Summer Lane Enola, PA 501 Maclay Street Harrisburg, PA June 1, 2001 to Sept. 27, 2002 Feb. 15, 1999 to June 1,2001 The mother of the child is Yavette D. Edrington, currently residing at 124 R Summer Lane, Enola, Cumberland County, PA. She is single. The father of the children is Jerome Standford, currently residing at 3651 Brookridge Terrace, Apartment 101, Harrisburg, Dauphin County, PA. He is single. 4. The relationship of plaintiff to the child is that of mother. The plaintiff currently resides with Carlosse, her son. 5. The relationship of defendant to the child is that of father. The defendant currently resides with his daughter and his daughter's mother. 6. The 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. 7. The plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 8. The child is temporarily residing with maternal grandmother where he has been for three weeks pursuant to a temporary guardianship agreement which was not made an order of court and which was revoked in writing by the mother on October 18, 2002. A copy of the complaint and the custody order will be given to the grandmother. 9. The best interest and permanent welfare of the child will be served by granting the relief requested for reasons including, but not limited to the following: a) The mother has been the primary caregiver since the child's births. The mother has provided for his emotional, physical, educational, and medical needs including establishing a stable home environment for him, and she can continue to provide for him. b) The child has a close relationship with his brother, Caflosse Edrington, his half-sibling, with whom he has resided since his birth. c) In or about September 27, 2002, the mother gave temporary guardianship of the child to the maternal grandmother to facilitate the mother's attendance at school. The mother maintained daily contact with the child at her mother's home including many overnights until October 11, 2002 when the mother decided that she wanted to resume the primary care of her child, and told her mother that she was revoking the temporary guardianship. d) Since on or about October 11, 2002, the mother has been denied contact with her child in spite of numerous requests by phone that the child be returned. The maternal grandmother even denied the mother contact to take the child to his doctor appointment and to keep the child enrolled in his special needs classes. The mother has gone to the grandmother's residence and neither the grandmother nor the child has been there. e) The mother and the father feel that it is in the best interest of the child to be returned to the mother and that a court order be entered granting her custody and the father, who had regular contact with the child during his life, partial custody. 10. The mother requests that the court enter a consent order between the mother and the father to stabilize the situation for the child. WHEREFORE, the plaintiff requests this Court to grant her primary physical and legal custody of the child any other relief that is just and proper. Respectfully submitted, ~ Carey Atlomey~or ~ Mid Penn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 VERIFICATION The above-named PLAINTIFF, Yavette D. Edrington, verifies that the statements made in the above complaint For custody are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.s. §4904, relating to unsworn falsification to authori~es.~ ~.y~v~tte D. Edrin~ Yavette D. Edrington, Plaintiff Jerome Stanford, Defendant : IN THE COURT OF COMMON PLEAS OF : : CUMBERLAND COUNTY, PENNSYLVANIA : NO. o2- 3~/ff~ C~Vm TEP~ : CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Yavette D. Edrington, Plaintiff, to proceed i_n forma pauperis. I, Joan Carey, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 Yavette D. Edrington, Plaintiff Jerome Stanford, VS. Defendant : In the Court of Common Pleas of : Cumberland County, Pennsylvania No. 02--~') 9'3Civil Term : Custody ._C_USTODY OR DE R_ AND NOW, this _?,~ da~02' the following Order is entered by consent of the parties with regard to custody of the parties' child, Jaquan Edrington, DOB: 02/15/99. 1. Plaintiff, hereinafter referred to as the mother, shall have primary physical and legal custody of the child. 2. The father shall have partial custody of the child, on dates and at times mutually agreed upon. 3. Neither party shall do anything which may estrange the ch/ld from the other parent, or injure the opinion of the child as to the other parent or which may hamper the free and natural development of the child's love or respect for the other parent. By the Court, j? _. ~' '~ , J uage This Order is entered pursuant to the consent of Plaintiff and De ~M½dP. enn Legal Ser~icii ........ "k~ pe4,~,v,~( _ 8IrvineR°w~'Carl~'~I'JSA 17013 ( He~ . ~V~,_~ Yavette D. Edrington, Plaintiff VS. Jerome Standford, Defendant AFFIDAVIT OF SERVICE~OR PERSONAL SERVICE : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02- 51qB ,CIVIL TERM : CUSTODY I, 0/:F:,(~'~-~ ][. ~0~<t~ , do hereby swear that l have served Janie Edrington with an Order of Court in the above captioned case pursuant to Rule 1930.4(a)(1) of the Pennsylvania Rules of Civil Procedure by personally handing her a copy at (Street Number and Address) (City) (State) at [ ~ yt{ .m. onthe [0/%~(0--t dayof (Time) (Date) I, ]~ ~t ~r (-TI0- '/0 ~ ~'~ (Month) (Zip) _,2002. verify that the statements made in this (name of person who performed service) Affidavit of Service are true and correct. I understand that fhlse statements herein are made subject to the penalities of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: