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HomeMy WebLinkAbout97-05919 ~ , I , i {! ~ v - - ~ ~ ~ !! <.t. - Q .3 ~ / ! ! , I il ;-... .. .':) ... \:J " ~ ....... <t' . , '<) // I t--. ~ F!' ~ , \; . -. ( , .. : . , , , , , , (!- ( c:.. " ,- \ , Ci' . ~ \r, I' I~~ ~ j ~'< ' 1'-.J ~ j"~ ~ ~ ".l U ''*fIllD. ..1"......U....m,,~.,tl"l..'lY HIllo"ltI'40 nt-1l'I.o....,., "."lWMlUl'MIl.....,u L..., '-S '-.::;t. ~ rn~ (Y\ '<;;) .... i::::; ''() .'\ ~~~ . L.. Omcu & CAUiOON, P.c. S Iff MAN, BROWN i']) SERRATELLl. ell 'u~:"Il<"" (.$QCT 2 9 loAo IJNt.lIrA 17110.9445 IlAullaUau, ., ", . <.l .. ~ a :.~ ~ ~ ~ .... ! ~"=:. J - J 5 ' .; , !JIll'ij ~~~~ ~ ~... ...~ ~ J ~ DAVII A. WOLI', IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. (/'1- -11/{ (i C-U-Lt, CIVIL ACTION - LAW CUSTODY Plaintirt vs. JO AIlH KOBLLBR, Detendant ORDBR OF COURT ~ \ day of Oc -\O\::::e r ,1997, upon attached Petition, it is hereby directed their respective counsel appear before , , the conciliator, at '\ I, " r on the ., ~ day of r''{--( f> N\t:)l' r , 199::z., at for a Pre-Hearing custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Either party may bring the child who is the subject of this custody action to the conference, but the child's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. AND NOW, this consideration of the that the arties and .m. , FOR THE COURT, Date of Order: -1D.1 ~\ \ Cr1 By: ~J\.~I~ custody Conciliator (~. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE 1 COURTHOUSE SQUARE FOURTH FLOOR CARLISLE, PA 17013 (717) 240-6200 . , ,'" '-'I , " "", ~. ',- , 1.-. " 110'.9) a-I /~ /JdtiJ/ '$ 4 ~. 113 . 9") '7b-~ /llUcW ~ 1Jf'. 113'?)~~~4 ~~ '~ ,~. . t. _co, q DAVE A. WOLF, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. lj 7- 5'}1'1 di.J T~,.... CIVIL ACTION - LAW CUSTODY Plaintiff VS. JO ANN MUELLER, Defendant CUSTODY COMPLAINT TO THE HONORABLE, THE JUDGES OF SAID COURT: 1. The Plaintiff is Dave A. Wolf, who currently resides at P.O. Box 329, Campbelltown, Lebanon County, Pennsylvania 17010. 2. The Defendant is Jo Ann Mueller, who currently resides at 12490 Unit No. 211 Quivira, Overland Park, Kansas city, MO 66213. 3. Plaintiff seeks primary physical custody and shared legal custody of the parties' one (1) minor child, Autumn Wolf, born December 15, 19B2. 4. The child was not born out of wedlock. 5. The child is currently in the custody of the Defendant, who resides at 12490 Unit No. 211, Quivira, Overland Park, Kansas City, MO 66213. 6. During the past five years the child has resided with the following persons and at the following addresses I Persons Address Dates Jo Ann Mueller Kurt Mueller (step Father) Kurt Mueller (step brother) 12490 unit #211 Quivira, Overland Park Kansas City, MO september 1997 to Present Jo Ann Mueller 61 South pin Oak Dr. Boiling springs, PA 1992 to September 1997 7. The father of the child is Dave A. Wolf, who currently resides at P.O. Box 329, Campbelltown, Lebanon County, Pennsylvania. B. The relationship of Plaintiff, Dave A. Wolf, to the child is that of father. The Plaintiff currently resides with Betty Wolf, Plaintiff's mother. 9. The relationship of Defendant to the child is that of mother. The Defendant currently resides with the child and the persons listed in Paragraph 6 above. 10. Plaintiff has not participated as a party, witness, or otherwise in litigation concerning the custody of the said child. 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 interests and permanent welfare of the child will be served by granting the relief requested because Defendant unilaterally removed the child from Pennsylvania in total disregard of Plaintiff's relationship with the child. Plaintiff is more likely than Defendant to ensure the child has contact with both parents. 14. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiff respectfully prays that Your Honorable Court award primary physical custody and shared legal custody of the child to the Plaintiff. Respectfully submitted, re 17110 Attorney for Plaintiff VBRIFICATION I verify that the statements made in the foregoing complaint are true and correct. I understand that false statements herein are made subject to the penalties of 1B Pa. C.S. section 4904, relating to unsworn falsification to Date: /~6~7 ,J MAR 1 7 1998 tJ DAVE A. WOLF, . IN THE COURT OF WIMOO PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. . NO. 97-5919 CIVIL TERM . . . JO ANN MUELLER, . CIVIL ACTIOO - LAW . Defendant . IN CUS'roDY . auJI!R OE' axRl' AND tOf, this 9th clay of March, 1998, the Conciliator, hereby relinquishes jurisdiction in this case as neither the parties nor counsel appeared for the schedule(] Conciliation Conference on February 26, 1998. FOR THE COURT, Dai2~ CUstody Conciliator .