The URL can be used to link to this page

Home My WebLink About00-02034 '.-" j \\i'lTSB\f!Mnily i..aw\ClibtDirectory\Reed-S\Pleadings\ComPlaint for Cuslody.wpd Marcli23,2000 , REAGER, ADLER & COGNETTI, PC MARIA P. COGNETTI, ESQUIRE Attorney LD. No. 27914 2331 Market Street Camp Hill, PA 17011-4642 Telephone No. (717) 763-1383 Attornevs for Plaintiff SAMUEL L. REED, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. ,1O.;;J D3~ 4:J : CIVIL ACTION.. LAW : IN CUSTODY JACKIE S. PLITT, Defendant ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before '}:::AvJ.v <): ~N" rIl'(--:;:;-, Esquire, Conciliator, at the :~c; IAJ. fV/.'/. r.J S"'t-, IMRl k.csLJ fjIf ,Pennsylvania, on the ;/3y-;:J day of may ,2000, at .~: CD P.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. Either party may bring the children who are the subject of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT DATED: BY: Custody Conciliator t;J yOU SHOULD TAKE TillS 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. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLIS~E, P A 17013 (717) 240-6200 '" ~ (. " ' , " _ . ~. n ,_ - 0;[' /'71 c. T n Ii', ....t.:/)_.(.,;~,. t, .... ':' '/~;"?J~~/1Q? UnO I., lAir.,"^< n,.,'P "Vld!'y II"..... jut 1 ..... I C . p'! 414/', r 12: I .., I('f,....~.), , ,( A4.,/,f"',,,"_ I 'flVf.J',iViJ ' V.S'YlI.;4 ~\' 1S'U;if!1' " ,~'I r I L,I'"}.Ot1 &~.~~~~ 4'-?-Oc; ~. ~ ~ ~ Lf-)-otJ ~ ~-E 0/ ". . -~ ',,-'7' _ =~ ~ ~!IIlli~I~'7""'~"-.'__'" _e ,_, - ~,~.,,,,.,,, ._ x!,F!~ "c ,-' '\"0 'H_-- , Jh__"_ ~.~"""'" \\f{tsb\fllnHl-y law\ClientDirectory\Reed_S\Pleadings\Complaint for Custody.wpd Marcb22,2000 , REAGER, ADLER & COGNETTI, PC MARIA P. COGNETTI, ESQUIRE Attorney J.D. No. 27914 2331 Market Street Can1p Hill, PA 17011-4642 Telephone No. (717) 763-1383 Attornevs for Plaintiff SAMUEL L. REED, JR., Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. /)() - -2IJ3<{ ~ /~ JACKIE S. PLITT, Defendant : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY I. Plaintiff is Samuel L. Reed, Jr., who resides at 1625 Airport Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Jackie S. Plitt, who resides at 1601 Summit Avenue, Camp Hill, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following child: Name Present Address Age Joshua S. Reed 1601 Summit Avenue Camp Hill, P A 14 4. The child was not born out of wedlock. The child is presently in the custody of Defendant who resides at 1601 Summit Avenue, Camp Hill, Cumberland County, Pennsylvania. ;, , j - ~ ~:' \\Ntsb\family law\Client Directory\Reed-S\Pleadings\Complaint for Custody.wpd Marc~22,2000 5. During the past five (5) years, the child have resided with the following persons at the following addressees): Name Address Dates Jackie Plitt 133 West Locust Street Apt. CI8 Mechanicsburg, P A 1990 to October 1997 Jackie Plitt 1625 Airport Drive 11echanicsburg,P}\ October 1997 to Present 6. The mother of the child is currently residing at 1601 Summit Avenue, Camp Hill, Cumberland County, Pennsylvania. She is married. 7. The father ofthe child is currently residing at 1625 Airport Drive, Mechanicsburg, Cumberland County, Pennsylvania. He is single. 8. The relationship ofPlaintiffto the child is that off ather. Plaintiff currently resides with the following persons: Name Relationship Stephanie Murray John Murray Sara Murray Cora Murray Tara Reed Friend Friend's son Friend's daughter Friend's daughter Daughter 9. The relationship of Defendant to the child is that of mother. Defendant currently resides with the following persons: Name Relationship Victor Plitt Victor Plitt, Jr. Joshua Reed Husband Stepson Son ; ,-....~-= ~,,'o--_ \'lNtsb\family llifl1(\Client Directory\Reed-S\Pleadings\Complaint for Custody.wpd Marc.b.22,2000 . 10. Plaintiff has not participated as a party or a witness, or in any other capacity in other litigation concerning the custody of the child in this or any other Court. 11. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 12. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 13. The best interest and permanent welfare of the child will be served by granting the relief requested. 14. 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 to grant him shared legal and physical custody of the child. Respectfully Submitted: REAGER, ADLER & COGNETTI, PC Date: March 22, 2000 By: 2331 Market Street Camp Hill, PA 17011-4642 Te1ephoneNo. (717)763-1383 Attorney for Plaintiff . - ,-j .'." "".~, .1 ,,,'.- ,,,_ VERIFICATION I, SAMUEL L. REED, JR., hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 94904 relating to unswom verification to authorities. .J\n~ ~Q oo~, ~ SAMUEL L. REED, JR. DATE: 3--a"d.-cx) :< . ~ ,_. - I~ - '~o-~i SAMUEL L. REED, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. . NO. 00-2034 CIVIL TERM . . . JACKIE S. PLITT, : CIVIL ACTION - LAW Defendant : IN CUSTODY aIDER OF <XXlRT AND lQq, this I j ~ day of ~ eo. consideration of the attached Custody Co iliation and directed as follows: , 2000, upon Report, it is ordered 1. The Father, Samuel L. Reed, Jr., and the Mother, Jackie S. Plitt, shall have shared legal custody of Joshua S. Reed, born August 21, 1985. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. During the summer school break, the parties shall alternate having physical custody of the Child on a weekly basis with the exchange of custody to take place every Moncjay at 10:00 a.m. The alternating weekly schedule shall begin with the Father having custody of the Child on Monday, June 12, 2000. 3. The parties shall make arrangements for custody of the Child on holidays by mutual agreement. 4. The non-custodial parent shall be entitled to have liberal and reasonable telephone contact with the Child. 5. The party receiving custody of the Child shall be responsible to provide transportation for the exchange of custody. 6. Neither party shall consume alcohol during his or her periods of custody. 7. The parties and their counsel shall attend a second CUstody Conciliation Conference in the office of the Conciliator, Dawn S. Sunday, Esquire, on August 29,2000, at 1:00, p.m. for the purpose of reviewing the custody schedule and establishing ongoing custody arrangements for the school year, if the parties have not been able to do so by agreement. 8. This Order is entered pursuant to an agreement of the parties at a CUstody Conciliation Conference. The parties may IIlOdify the provisions of I 'I!IIIl~_ c ""'.,.- . i1-I.IZ C{ ,() P\O\\-..OM\-Q'\"t O\.t;c.t 1D-1V-CX) .,'8 ~~~l!lII;II'jI ~~.:;"""""',. l~J'Io~~~mW~~f'r"",'!in"!l!Wl'~Jl!.II!!1~IIFJ'W-'~~~lIi'll!!~___4 _1~~I~l .. " I ~ ,L- o _'_l^ ',,-- ~ ._ ~~ "~'i:; this Order by IIIUtual consent. In the absence of IIIUtual consent, the terms of this Order shall control. BY THE COURT, cc: Maria P. Cognetti, Esquire - Counsel for Father Robert O'Brien, Esquire - Counsel for Mother J.>>- f\~I~1\ rr &_I~~OO ~~ - -= " -~ .---; . . SAMUEL L. REED, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. : NO. 00-2034 CIVIL TERM : JACKIE S. PUTT, . CIVIL ACTION - LAW . Defendant . IN CUSTODY . CUSTODY ~IATI<l\I SUMMARY REPCRT IN AC<XIIDANCE WITH CUMBERLAND OOUNTY ROLE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Joshua S. Reed August 21, 1985 Mother 2. A custody conciliation Conference was held on June 7, 2000, with the following individuals in attendance: The Father, Samuel L. Reed, Jr., with his counsel, Maria P. Cognetti, Esquire, and the Mother, Jackie S. Plitt, with her counsel, Robert O'Brien, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Jv.J- 0~ Date YdJ'1 Custody Conciliator ~, '''~I, .ld ~__ . ~ ~ SEP 11 , SAMUEL L. REED, JR., Plaintiff : IN THE CXlORT OF CXlMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : CIVIL ACTION - LAW : NO. 00-2034 . . JACKIE S. PLITT, Defendant : : IN CUSTODY aIDER OF <XXIRT AND NOW, this 29th day of August, 2000, the Conciliator, at the request of counsel for the parties, hereby relinquishes jurisdiction in this case. The Custody Conciliation Conference scheduled for August 29, 2000 is canceled. FOR THE CXlORT, 12,,~, Dawn S. Sunday, Esquire Custody Conciliator Ili_~iIl..llilIlIlM~j!liiil~~;;i;'~1lI1Ii'-:J.A4.~f~ll~j~~ilit.fi "' ""' ,- -'-'- ~'/iV'/r7 h, " ) I~!r),~,\" "01\1\1],., . '- ':1.1,),": ,"-" :"--:j.vn:) '5" ,~ :z i I,] ,,'. . I. n, , i ,- r_', {".", '"..J>J'.;" ~i$ 1:1I '"