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Home My WebLink About00-02554 . ~ I ~ ,", ," d- .'~;-- ;.",,- .',-" ,11;,;j , ' . . , , Pam Walker (Custody Complaint) 4.25.00 ~, PAMELA M. WALKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000 - ~554 CIVil TERM IN CUSTODY vs. GREGORY L. BARRICK, Defendant ORDER OF COURT AND now, this 2t. +L. day of 'ILj-A-. '! ' 2000, upon consideration of the attached MoIOn, '" horeby dl""," 100I '" pa"~ 'Pd Ih,l, ~p~~ ..:~I 'l'P'"' 00f0re ILL f. ~ (l t011 -es1, ,Jheconciliator, at i &-, LLU C. Gv.~_ on the....-J 3-\-"" day of .Juhl ,2000, at ~ ;,~D o'clock -.fL. m. for a pre.hearing custody I 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. For the Court, ~), ~ \ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YO d NOT HAVElA LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. By: Office of the Court Administrator Courthouse, 4th Floor Carlisle, Pennsylvania 17013 (717) 240-6200 , r:; !I II I L, _. ,_ .'.. '...,. ,_ ,n '.' . ,~ . 'I I' .'<" - {)O IF:,:? ? 8 . (-. '..' -, l D r'L!1 'I . '-' "I\/L'< , '),~-j i.'" ': '. _.-' (,,-' ", J: .~- , I cf,rI\!",V:1 U--"'''',_,'r}; '..f II -"Jll" ., "'\ ' -.. O'''',!'",'J_ 'I'dll?',?J~. M,~~~ 4 ~ 4Co?S-:Od' '7l~ #'~4 ~ ~ ~o1lf-Cf.? ~ ~ ~ N,~ ~ ': , ~-. "",,~,;,-?'",""'''''_~'fi';'?'''''' _ _ ,~._ j'i~~~m~~:I~~~;~\iU_~R'~~ ",=-.^'~ --'~'~ k ",. .. j-~ ,~:.:~-- ," Pam Walker (Custody Complaint) 4.25.00 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County, Pennsylvania, is required by law to comply with the Americans with Disabilities 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. By the Court, J. .. -- ^. "he" ~ -J 0-, --, --'. ,-" _ . ,- J'. ~ _~__; '---I~ Pam Walker (Custody Complaint) 4-25-00 PAMELA M. WALKER, Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000-:;SSY CIVIL TERM IN CUSTODY GREGORY L. BARRICK, Defendant COMPLAINT IN CUSTODY NOW comes Pamela M. Walker, by and through her counsel FLOWER, FLOWER & LINDSAY and states as follows: 1. The Plaintiff is Pamela M. Walker, residing at 454 Oxford Road, Gardners, Cumberland County, Pennsylvania 17324. 2. The Defendant is Gregory L. Barrick, residing at 1713 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Plaintiff seeks custody of Bryan L. Barrick, nine (9) years of age, presently residing at 1713 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013. 4. The child was _ born out of wedlock. 5. The child is presently in the custody of the Defendant. 6. During the last five years the child has resided with both Plaintiff and Defendant at 1713 Walnut Bottom Road, Carlisle, Pennsylvania 17013. 7. Plaintiff is the child's natural mother. 8. Defendant is the child's natural father. 9. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation concerning the custody of the child in this or another jurisdiction. 10. The Plaintiff has no information of a custody proceeding concerning the child pending in a court of the Commonwealth. ~~ . : ~':.;.I '",) : -,:,'--~-:_:].;,,; . i -"1 _-I'~ Pam Walker (Custody Complaint) 4-25-00 11. The 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. 12. The best interest and permanent welfare of the child will be served by granting the relief requested because: 1) Plaintiff is committed to insuring a continuing relationship with Defendant and his son. 2) Defendant seeks to manipulate his relationship with Plaintiff by using Bryan's custody as a ploy. 3) Defendant refuses to communicate with Plaintiff to arrange shared custody informally. 4) Defendant has a temper, as indicated by his criminal record including assault among other offenses. - 5) Plaintiff is a loving mother, now living with her parents in a good home, along with her other son, James, age thirteen (13). 13. Each parent whose parental rights to the child have not terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, the Plaintiff requests this Court to grant primary physical custody of the child to the Plaintiff. Respectfully submitted, FLOWER, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By:<;J~~ Thomas E. Flower, Esquire ID # 83993 11 East High Street Carlisle, PA 17013 (717) 243-5513 Date: ~~Q ;S; If; fJO ~-'" . -. h,l, ^--' -" ,~-; c_-',"',. ;:-..:.,:,J,,~: '. _ I ,- tl-.! VERIFICATION I, hereby verify that the statements made in the within instrument are true and correct to the best of my knowledge, information 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 to authorities. By yJ~d~ ()~y;JbA/ Pam Walker, Plaintiff Date: I\'("~ \ 1r- ,2000 ,,--"'^. -0-- ,I~-., -'_, ,.~,__,'c_ :'-'''--,___._'''' ,,1 . I~IJ PAMELA M. WALKER, Plaintiff, vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW GREGORY L. BARRICK, Defendant. NO. 2000- IN CUSTODY CIVIL TERM CERTIFICATE OF SERVICE AND NOW, this 25th day of April 2000, I, THOMAS E. FLOWER, Esquire, of the law firm of FLOWER, FLOWER & LINDSAY, Attorneys, hereby certify that I served the within Complaint for Custody this day by depositing same in the United States Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to: Gregory L. Barrick 1713 Walnut Bottom Road Carlisle, PA 17013 FLOWER, FLOWER & LINDSAY Attorneys for Plaintiff BY~~ Thomas E. Flower, Esquire 11 East High Street Carlisle, PA 17013 (717) 243-5513 I.D. # 83993 .1'._I~tujjTfr~Ml~iiIiliiIiIiiliij' ~"~~@iOOiIo~~~l.i.oo- _h'_''!'",..-;,J.,' "_'n 'mll, .'0"""_"_ ",M~'.,_ .. , ,t .,,, "-- -' -~"U." ,,' ~ . " ,_or '._> ,"'" . . .! " il Ii 0 .~.; (~ 0:t~ -'-,'" f " ;{p ~:::- . >:J ..." U1 C:"';.c ,"\J !to 0 f-~L c. ~ it . -'. -0 B >"". .' . 5 {jj ~.~. l_ -C ----'c''-- U1 Q... Z ()\ ""j ::::> " j . u\ :~:J ~~ " -. - -~ . I ",I ~I PAMELA M. WALKER, Plaintiff, vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW GREGORY L. BARRICK, Defendant. NO. 2000 - 2554 CIVIL TERM IN CUSTODY PRAECIPE TO WITHDRAW THE COMPLAINT TO THE PROTHONOTARY: Please withdraw the Complaint in Custody filed by Plaintiff in the above named case. FLOWER, FLOWER & LINDSAY Attorneys for Plaintiff May ~ ,2000 BY~~~~ Thomas E. Flower, Esquire 11 East High Street Carlisle, PA 17013 (717) 243-5513 I.D. # 83993 ;~'L'''''-,~-U~-'' ~-I,,~ ~. ~--~ -~- .. ,,~ ^ ~4,' -.l\Jjj~_~19-- ,~ ~,~, ,.., ~. _~ ^ ""C " ",I =~, "' - - ~- '",,",""'" :! " (") 0 0 C 0 -n =--... ::c :r! -Ow, :po rn ' -< rnpl Z::n I L'Z Z':[ ~~, , ~~; cJ1 ~B "" .~~ >0 :x b 2< 2:0 - 01'1'l - PC .. .~ ~ W G' '< '1 '" .1 h ~._ "11 -,_.~~L~>, , 4;! JUt 1 8 zooaet PAMELA M. WALKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW GREGORY 1. BARRICK, Defendant NO. 2000-2554 CIVIL IN CUSTODY COURT ORDER ~ AND NOW, this (? day of July, 2000, the Conciliator being advised that the parties have reached an agreement in this matter, the Conciliator relinquishes jurisdiction. BY THE COURT, Hubert X. Gilroy, quire Custody Concil. tor ~._~iIIIiIa"~ ""-='4/l!~.!l&~w..~UlIl~~ J~ , , - . d .1 ,-,,, <~ ., ~ '~ ' 0 <::) ~:J ~-= c.::., ,-J -r"Tt"O ,- r1~;-~ r rv- f]d Z::i~~ ;;:: r -.'rfll (1))---' \J) i~O -<~-"~. ~-,:~ (~) ~::i_~. ~:t -----ri 7C~ ~:~1R =(~: )> _.' CS["n C Z => s! :3 ::0 , -< .. ,',~" ".".~ -~'- " ,'~, ~ '<--. ,-",