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HomeMy WebLinkAbout00-00627 i MORGAN L. JOHNSTON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. NUMBER : ;ZC?oo -(e,2'7 CIVIL TERM WILLIAM FARLING, Defendant CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Motion, it is hereby directed that the_parties and their respective counsel appear before C1 e the conciliator, at 39 i,J on the o day of , 2000, at ;; (M or afor of Pre-Hearing Cust y 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 age 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. BY THE COURT: c> 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, 4th Floor CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717) 240-6200 n. ?( 7). r-- 14 i ego 11:1-17 IZ MORGAN L. JOHNSTON, Plaintiff VS. WILLIAM FARLING, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NUMBER al9fib • (1-'-) 7 a'-a -Z ' CUSTODY COMPLAINT FOR CUSTODY NOW COMES the Plaintiff, MORGAN L. JOHNSTON, by her attorney, Charles E. Petrie, and respectfully represents as follows: 1. Plaintiff is MORGAN L. JOHNSTON, who currently resides at 330 South Washington Street, Apartment 7, Mechanicsburg, County of Cumberland, Pennsylvania. 2. Defendant is WILLIAM FARLING, who currently resides at 216 Bridge Street, Apartment 4, New Cumberland, County of Cumberland, Pennsylvania. 3. Plaintiff seeks to have rights of primary physical custody with respect to WILLIAM TRAVIS FARLING, born July 4, 1994. The child was born out of wedlock. The child is presently in the custody of Plaintiff, MORGAN L. JOHNSTON. Since birth the child has resided with the following persons and at the following addresses: From birth, until November 11, 1996, with both parents at 384 Lewisberry Road, New Cumberland, Pennsylvania; from November 11, 1996, until February, 1997, with mother at 2459 Rudy Road, Harrisburg, Pennsylvania; from February, 1997, until May, 1998, with mother on Boas Street, Penbrook, Pennsylvania; from May, 1998, until July, 1999, with mother at 2966 Wilson Parkway, Harrisburg, Pennsylvania; from July, 1999, until the present with mother at 330 South Washington Street, Apartment 7, Mechanicsburg, Pennsylvania. The mother of the child is MORGAN L. JOHNSTON, who currently resides at 330 South Washington Street, Apartment 7, Mechanicsburg, Pennsylvania. She is not married. The father of the child is WILLIAM FARLING, who currently resides at 216 Bridge Street, Apartment 4, New Cumberland, Pennsylvania. He is not married. 4. The relationship of the Plaintiff to the child is that of mother. The Plaintiff currently resides with the child. 5. The relationship of the Defendant to the child is that of father. He currently resides alone. 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 in another court. The Plaintiff has no information of a custody proceeding concerning the custody of the child in this or in another court. The Complaint for Custody filed on November 14, 1996, in the Court of Common Pleas of York County, Pennsylvania, docketed to number 96-SU-5254-03 was withdrawn December 13, 1996. Plaintiff does not know of a person not a party to these proceedings who has physical custody of the child or who claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by confirming custody in Plaintiff because Plaintiff can better care for the child and Plaintiff has been the primary caregiver for the child. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff requests the Court enter an Order confirming custody in Plaintiff. Respectfully submitted, CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I verify that the statements in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ?L. JO NS ON D &E MO-7tA T ?. a ?f, c;?a ? !=7 -7 MORGAN L. JOHNSTON IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. WILLIAM FARLING DEFENDANT 00-627 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, this 17th day of November , 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on the 12thday of December , 2000, at 9:30 a.m. for a Pre-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 age 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. FOR THE COURT, By. /s/ Dawn S. Sunda, Esc. 6!!5 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ^UI ,Y pcN" SYLWVlIA i MORGAN L. JOHNSTON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. NUMBER : 2000-627 CIVIL TERM WILLIAM FARLING, Defendant CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at , , on the day of , 2000, at _.M., for a Pre-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 age 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. BY THE COURT: 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, 4th Floor CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717) 240-6200 r MORGAN L. JOHNSTON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION -LAW WILLIAM FARLING, : NO.: 2000-627 CIVIL TERM Defendant : CUSTODY/VISITATION PETITION TO MODIFY CUSTODY ORDER NOW COMES the Plaintiff, MORGAN L. JOHNSTON, by and through his attorney, Charles E. Petrie, and respectfully represents as follows: 1. That Plaintiff is MORGAN L. JOHNSTON, who currently resides at 330 South Washington #7, Mechanicsburg, County of Cumberland, Pennsylvania. 2. That Defendant is WILLIAM FARLING, who currently resides at 1075 Kunkles Mill Road, Lewisberry, County of York, Pennsylvania. 3. That the parties are the natural parents of a minor child, WILLIAM TRAVIS FARLING, born July 4, 1994. 4. That on April 4, 2000, the Honorable Kevin A. Hess entered an Order of Custody granting primary physical custody to Plaintiff and granting rights of temporary physical custody to Defendant. A copy of said Order is attached hereto. 5. Defendant has concerns regarding the welfare of the child while he is in the custody of Defendant and Plaintiff feels that it would be in the best interests of the child for Defendant to resume a schedule of every other weekend with said child. r Specifically, said minor child is left with a babysitter every weekend and spends very little time with the Defendant. Said minor child is forbidden to attend any of Plaintiff's family functions. WHEREFORE, Plaintiff requests that Your Honorable Court vacate the attached Order and grants primary physical custody of the minor child to Plaintiff. Respectfully submitted, CHARLES E. PETRIE 3528 Brisban Street Harrisburg, Pennsylvania 17111 (717) 561-1939 Attorney for Plaintiff I COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I verify that the statements in the foregoing Motion are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. V] /1 0 DAT C? ?' O C L-i -n -a c"• ? _? ' . z ?- _ `* ? ,?-, . ; - w , ? ra _ ? ._t ; fi = C•J °?r?r; t .. T? ° ?rs ? -- -< MORGAN L. JOHNSTON, Plaintiff vs. WILLIAM FARLING, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NUMBER: 00-627 CIVIL TERM IN CUSTODY PRAECIPE TO WITHDRAW Please withdraw the above referenced Petition to Modify filed on November 13, 2000. December 18, 2000 DATE s?.vo CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiff a -o cc rn -_- rnM e? i ?7i ? rn - ??. :rte C 'c5 ? cn DEC 2 Q 200 MCRGAN L. JOHNSTON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 00-627 CIVIL TERM CIVIL ACTION - LAW WILLIAM FARLING, Defendant IN CUSTODY ORDER OF COURT AND NCW, this 13th day of December, 2000, the Conciliator, being advised by the Plaintiff's counsel that Plaintiff is withdrawing her Petition to Modify Custody, hereby relinquishes jurisdiction in this case. The Custody Conciliation Conference scheduled for December 13, 2000, is canceled. FOR THE COURT, L-- Dawn S. Sunday, Esquire Custody Conciliator FL D-C? - ROE ?" r>- ti i i ,%11ARY 00 Dr~ 2N F1;1 3' S PENNSYLVANIA Morgan L. Johnston, miff In The Court Of Common Pleas Of Cumberland County, Pennsylvania Civil Action Law Vs. William Farling, Defendant Number 2000-627 Civil Term Custody Petition for Modification of Custody Now comes the Plaintiff, Morgan L. Johnston, respectfully represents as follows: 1. Plaintiff is Morgan L. Johnston, who currently resides at 967 West Trindle Rd # 13, Mechanicsburg, PA County of Cumberland. 2. Defendant is William H. Farling, who currently resides at 212 Third St, Apt 1, New Cumberland, PA County of Cumberland. However, spending most of his time with including weekend visitation with another family in New Cumberland, PA. 3. Plaintiff has primary physical custody of William Travis Farling, born July 4`t', 1994, currently 14 years of age. The child was born out of wedlock. 4. The relationship of the Plaintiff to the child is that of mother. The child currently resides with the Plaintiff, and has for 13 years. 5. The relationship of the Defendant to the child is that of father.. 6. Plaintiff is concerned for the welfare and morals of her minor child during weekend visits. 7. After a returning from a scheduled weekend visit with the Defendant on December 14, 2008, the Plaintiff suspected suspicious activity. The Plaintiff performed a home drug test on her minor child, which produced a positive result for marijuana. (See exhibit A) • The child admitted he used marijuana in the company of the Defendant and presence of other adults and minors that live-in the home whore most weekend visitations occur. i' 8. Plaihtiff is requesting visitation be limited to 2.5 hours per week with adult supervision required for 2.5 hour visits at Plaintiff's discretion and convenience until a routine is established. Plaintiff requests 24-hour notice prior to all visits. 9. Plaintiff requests all Holiday and Birthday visits be 4 hours at a family members home with adult supervision present. 10. If supervised visits are not possible for the Defendant, or the adult provided is unsatisfactory, Defendant may visit child in Plaintiff's home, or agreed upon location for undisclosed time frame, at agreed convenience, provided 24 hours notice, with no harassing activity from either parry. 11. It is not the intent of the Plaintiff to dissolve the relationship, it is however, the desire for the father-child relationship to have that of the4 best interest and welfare of the child at heart in a healthy and safe environment. Respectfully Submitted 1 ?8 or . Johnston 967 W. Trindle Road # 13 Mechanicsburg, PA 17055 Plaintiff ,t r f Control Exhibit A FifttChecl( Home Testing Kits H Preliminary Positive kakusugm -CoNw urine specimen. 1 ?} ?? - r'? ?;°? (? , \? ::? \,r n ? ?°-- ?a ^"°?-., ?"` ?" ? ,--? c:'? ? t"? , ?? ._,t . ?; MORGAN L. JOHNSTON IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2000-627 CIVIL ACTION LAW WILLIAM FARLING IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Monday, December 22, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, January 14, 2009 at 1:,30 PM for a Pre-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. 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: lsl Dawn S. Sunda 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 ? 1?? ?? -- i u t ? t?"q; r? b ?; ??; :` ?? ?? JTM?J ??3? ??? ?? JAN ' 6 Z009? MORGAN L. JOHNSTON IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2000-627 CIVIL ACTION LAW WILLIAM FARLING : Defendant IN CUSTODY ORDER AND NOW, this 14th day of January, 2009, the conciliator, being advised by the Plaintiff that all custody issues have been resolved by agreement between the parties, hereby relinquishes jurisdiction. The custody conciliation conference scheduled for today, January 14, 2009, is cancelled. FOR THE COURT, Dawn S. Sunday, Esquire Custody Conciliator s _ ' i n f c .a _a