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HomeMy WebLinkAbout97-06084 'I )/. " . .. ( "" ~ ., > - , ! F " j., - . :; . ::r- u. () " ..., , t' Ct- . ~ ! ~! " , EDWARD A. THOMAS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v, CIVIL 1997 -~'1 M\:;b,.,. PEGGY ANN McCORMICK, Defendant NO. IN CUSTODY ORDER OF COURT You, Edward A. Thomas and Peggy Ann McCormick, ORDERED to appear in person at are , , Pennsyh'ania, on at o'clock a.m,/p.m. for a Custody Mediation 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, at the request of either attorney or party, be present at the Conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. If you fail to appear as provided by thJ.s Order, an Order for custody may be entered against you or the Court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR ~ANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Court Administrator Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013 (717) 240-6200 . ,,}; FOR THE COURT: Date Custody Conciliator EDWARD A. THOMAS, plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. PEGGY ANN McCORMICK, Defendant NO. IN CUSTODY CIVIL 1997 q7- hO~lf~T~ COMPLAINT FOR CUSTODY 1. The Plaintiff is Edward A. Thomas, residing at 205 Woodley Drive, Harrisburg, Dauphin County, Pennsylvania 17109. 2. The Defendant is Peggy Ann McCormick, residing at 3506 Beverly Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff seeks shared legal and partial physical custody of the following child: Name Present Residence Age Heather Lauren McCormick 3506 Beverly Lane 15, DOB Mechanicsburg, PA 17055 10/5/82 The child was born out of wedlock. The child is presently in the custody of Peggy Ann McCormick, who resides at 3506 Beverly Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. During the past five years, the child has resided with the following persons and at the following addresses: Defendant and Deborah Brandt 3506 Beverly Lane Mechanicsburg, PA 17055 1992 to Present The mother of the child is Peggy Ann McCormick. who currently resides at 3506 Beverly Lane, Mechanicsburg, PA 17055. She is single. The father of the child is currently residing at 205 Woodley Drive, County, Pennsylvania 17109. He is single. Edward A. Harrisburg. Thomas, Dauphin 4. The relationship of Plaintiff to the child is that of father. The Plaintiff currently resides with his mother, Margaret L. Thomas. 5, The relationship of Defendant to the child is that of mother. Defendant currently resides with Deborah Brandt. 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. It is in the best interest and permanent welfare of the child to be in the primary physical custody of her mother, shared legal custody in both parents and partial physical custody in her father at times mutually agreed upon, per the parties' Stipulation which is being filed simultaneously with this Complaint for Custody. 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. WHEREFORE, Plaintiff requests the court to grant the parties' wishes as stated in their Stipulation, i.e" shared legal custody, primary physical custody of the child in Defendant and part.ial physical custody in Plaintiff at times mutually agreed upon by the parties. HEPFORD, SWARTZ & MORGAN BY:,~dJ~~ ,- Sandra L. Milton P.O. Box 889 Harrisburg, PA 17108 (717) 234-4121 Attorneys for Plaintiff VERIFICATION I, Edward A. Thomas. acknowledge that the facts stated in the within document are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, ~tf~ t<-~~ Edward A. Thomas DATED: lo/~1 /'11 ;I{ ~~ ~ - l ~ . '1 , i ." , , z .. < ~ 5 !- .... -... J:Ji=~~ I::! L ~.- "J:j=~ . 01( :a . Z ~ j~!~~~ . z '" ~ Q - . 101 a: - . I- 0- iI ... . ... . ... . :c = ,', . , NOV 0 5 1991 FlI.ED-OfACE OF TIJ~ r;':0'F(,'i:,;TNlY 97NOV-G PM 1::10 CU" :;; 'L ,",,1'. ('!~: "'''Y h,l;~"" r, ,IJ ,v.... '\ I PEl' """ -, '\'. N ' ',.'\IJIl- ,~j J'\ EDWARD A. THOMAS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. CIVIL 1997 PEGGY ANN McCORMICK, Defendant IN CUSTODY STIPULATION AND NOW, this 3\ st day of Oc{dhel< , 1997, Plaintiff (hereinafter referred to "Father"), together with his counsel, Sandra L. Meilton, Esquire, and Defendant (hereinafter referred to as "Mother), hereby inform your Honorable Court that they have amicably resolved to their mutual satisfaction the issues of custody and visitation regarding their minor child, Heather Lauren McCormick, born October 5, 1982, and do hereby stipulate that the following is the substance of their agreement respectfully requesting that your Honorable Court issue an appropriate Order of custody and visitation in accordance with their agreement and stipulation. The parties stipulate as follows: 1. The parents shall share legal custody of Heather and each parent shall consult with the other concerning all major decisions affecting Heather, including but not limited to, health, education and religion.