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HomeMy WebLinkAbout97-04211 { - \ , :,-) I .' . . ~..; d ~V ~~ "" \ "t " v:'! ~ .. ~~ '\( ;" - "- ~SJ \J\ \S ~~ ~ ~ .~ ~ \i) 1).. ~! ~ '\\ .- ti"'; ;~ ,. \ . (M" f--' l ~ . \"" , ' [lJ. _M_J ,,-4..::. j' l' U a. '- ?:- t~.... r- ei' --i () ~ ... Z l/l0< 0<> W,.:l ,.:l>- Pol/l zZ oZ >- ~~ .... .oJ Q .... 0 o . ... I::: fo u>- .oJ tII l/l I::: 'tl ,Jl~1 fo I::: 0 lr.Z ... U 00 tII GI foO ... . .... Ill: Po :- GI 0 IlI:U . .Q >- >- lr. OQ W OZ W ,.:l fo ,~~~~ UO< ,.:l Ill: Z Ill: ,.:l ~ ~ ... Will: 0< .\ ~ ~!~ i:W ,.:l Z~ ,.:l Z Po 0 ... X oC III . 0 ...u Po 0 0 U Ill: Z . . . PAUL WORLEY Plaintiff &Ub 0 6 1997 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.: Cl7 ~ J.!.:ll/ ~(.pt CUSTODY v. ROBIN WORLEY, 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 t....\\C \'-.nt" \ I . R()nc), , l'=" q" the conciliator, at \(14 '-" \ R~~\., Can9 \11 \\ on the \ R day of ..s.er~N'\bf. r , 1995, at j:t()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. 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, .1J/1clu:\O 0 sJ.&~ ij'~ (~) 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 WHEtl.E YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR, 4th FLOOR CUMaERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717) 240-6200 ~..,....."" PAUL WORLEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO.: 97. '1.:111 d..:,J T:<<- ROBIN WORLEY, Defendant COMPLAINT FOR CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is PAUL WORLEY, residing at 898 Traver Drive, Lewisberry, York County, Pennsylvania. 2. The defendant is ROBIN WORLEY, residing at 711 Robert Street, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff seeks shared legal and physical custody of the following child: Name Present Residence Age 10 months ASHLEY M. WORLEY D.O.B. 9/3/96 711 Robert Street Mechanicsburg, PA The child was not born out of wedlock. The child is presently in the custody of ROBIN WORLEY who resides at 711 Robert Street, Mechanicsburg, CUmberland County, Pennsylvania. During the child's lifetime, she has resided with the following persons and at the following addresses: Name Address Date Mother and 711 Robert Street July 1 to Mother's family Mechanicsburg, PA Present Mother and 194 Holiday Ave. Jan 97 to Father Mechanic.burg, PA July 97 Mother and 5022 East Trindle Road Sept 96 to Father Mechanic.burg, PA Jan 97 /. -, The mother of the child is ROBIN WORLEY, currently residing at 711 Robert Street Mechanicsburg, Cumberland County Pennsylvania. She is married to the father. The father of the child is PAUL WORLEY, currently residing at 898 Traver Drive, Lewisberry, York County Pennsylvania. He is married to the mother 4. The relationship of plaintiff to the child is that of father. The plaintiff currently is residing 898 Traver Drive, Lewisberry, York County, Pennsylvania. S. The relationship of Defendant to the child is that of Mother. The defendant currently resides with the following persons: Name Relationship Defendant's family 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. 7. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this commonwealth. 8. 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. 9. The best interest and permanent welfare of the child will be served by granting the relief requested because: a. Since the parties' separation on July 1, 1997, the Defendant/Mother has regulated the tillle father ia able to spend with the parties' child;