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HomeMy WebLinkAbout97-02929 ~ '" .~ ~ -.....; <J , / J , , :-- .. .::\ .. '" f)l ,..,.. r')f , ~ ~ . ~ S. The relationship of defendant to the child is that of father. The defendant currently resides with the following persons: ~ Relationship Unknown 6. 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. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 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. 7. The best interest and permanent welfare of the child wll/ be served by granting the relief requested because: a) Plaintiff has been primary caretaker of the child since birth; b) Plaintiff provides the child with a home with adequate moral, emotional and physical surroundings as required to meet the child's needs; c) Plaintiff is wllIing to accept custody of the child; d) Plaintiff continues to exercise parental duties and enjoys the love and affection of 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. All other persons, named below, who are known to have or claim a right to custody or visitation of the child wlll be given notice of the pendency of this action and the right to intervene: ~ Address Basis of Claim NONE Wherefore, plaintiff requests the court to grant custody of the child. L ' -tof-llat- U'.tl ~( mdsay Dare aird, Esquire 37 South Hanover Carlisle, PA 17013 Attorney for Plaintiff I verify that to best of my knowledge and belief, the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.~4904 relating to unsworn falsification to authorities. i -g. ()o >- <'I (j 'r: - n ., '''' r~ 0 ~ ~ .-~ -. ,- lJ..j; ;'.-~ l{) 0.' ~ ,"= \..{l ,--1 .' 0 J_ _', c..: - ;~~; ~ I_~. ~~- ;:<2 1\ 1=1 ~- ...., j ci. -- '~ -J U,:.... I , -.~ --' 0-. _.~,; tI!1 u.:.t? ",n] j~ -.. --; ::!ll.. I, ,.... ,...: 0 _J C'> f.) f!lrs ~ ~~~~ ~ ~I~~~ ~I '" E Sf.a w S ... ~; ... .. iii g" ~ ~ ~ .... ... ~ - - .... ~ :: = ' ~~S~ ... ... I II) 0( '" -"1. Iii, - = DO ... ~ - . C . . . . .;: If' ~ U~ '"" ~I p,I'!I( ! '" = lIllll ~ .... , r ~"d iin ~a: 2l =... ., ~ ; .5.B ~ ] 8 = " = "''Ii ~ i!j lti,'" .. " :c . ~ < g;\lI!!l ~ ~ ~tl ~ :;: - . , -" . .. , . . . . . .. tJAUG 0 Ii 1997 ;. , , ROBIN A. OOLLINS, IN THE COURT OF CCX>IMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. . NO. 97-2929 CIVIL TERM . WAYNE LOSH, CIVIL ACTlOO - LAW Defendant . CUSTODY/VISITATION . AND NeW, this consideration of the attac ed and directed as follows: , 1997, upon n Report, it is ordered 1. The Mother, Robin A. Collins, shall have primary physical custody and sole legal custody of Tyler W. Losh, born December 25, 1994. 2. Any contacts between the Father, Wayne Losh, and the Child shall be arranged by mutual agreement of the parties and shall take place as supervised visitation in the maternal grandmother's (Linda Shearer) residence in Carlisle with the maternal grandmother present. 3. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual agreement. In the absence of mutual agreement, the terms of this Order shall control. J. cc: Lindsay Dare Baird, Esquire - Cou \'/ayne Losh, Pro Se ~' rr...c~~G<L 'it I 1"+/ q'l. ....&,-(3, ROBIN A. COLLINS, . IN THE COURT OF COOMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . VS. . NO. 97-2929 CIVIL TERM . . . WAYNE LOSH, . CIVIL ACTION - LAW . Defendant . CUSTODY/VISITATION . aJS'lOOY CXH:ILIATIOO SlJoIMARY REP<RT IN ACXXlUll\NCE wrm CD!IlERLAND ccumr: RULE OF CIVIL ~ '1<1 ttJRE 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 alRRml'Ly IN aJS'lOOY OF Tyler W. Loah December 25, 1994 Plaintiff/Mother 2. A Conciliation Conference was held on July 30, 1997, with the following individuals in attendance: The Mother, Robin A. Collins, and her counsel, Lindsay Dare Baird, Esquire. The Father, Wayne Losh, participated in the Conference by telephone as he was unable to obtain transportation to the Conciliator's office. The Father is not represented by counsel. 3. The Mother's position on custody is as follows: The Mother sought an Order awarding her primary physical and legal custody. The Mother stated (and the Father acknowledged) that the Father has not seen the Child since Chrisbnas Day 1995, which was the Child's 1st birthday. The Mother stated that until that contact, the Father had shown only periodic interest in the Child. The Mother indicated that the Father has not contacted her or otherwise expressed an interest in seeing the Child. The Mother expressed a concern that if the Father were to begin to see Tyler at this point his interest would soon diminish and the Child would get hurt as a result. 4. The Father's position on custody is as follows: The Father stated that his previous lack of contact was due to stress caused by the circumstances and that the Mother's family did not want him to see the Child. The Father acknowledged that he has not attempted to contact the Mother in 1997. The Father indicated an interest in establishing a relationship with the Child and agreed that any contacts would be supervised in light of the fact that the Child is not familiar with him.