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HomeMy WebLinkAbout03-0348JAMES R. TALBOT, Plaintiff vs. AMBRA SUE WILSON, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. - _g y9 : : CIVIL ACTION - LAW : CUSTODY NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days aRer this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff'. You may lose money or property lose money or property or other rights important to you. 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 WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 717/240-6200 NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiem defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demada y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogdo y archivar en la corte en forma escrita sus defen~as so sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la penticion de demanda. Usted puede perder dinero o sus preopiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABAGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO AA LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 717/240-6200 JAMES R. TALBOT, Plaintiff VS. AMBRA SUE WILSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. Oa- ~P/.~ : CIVIL ACTION ~ LAW : CUSTODY COMPLAINT FOR CUSTODY Custodian Ambra Sue Wilson o Plaintiff is James R. Talbot, whose address is P.O. Box 202, Three Springs, Huntingdon County, Pennsylvania 17264. The defendant is Ambra Sue Wilson, residing at 2142 Market Street, Camp Hill, Cumberland County, Pennsylvania 17011. Plaintiff seeks custody of Collin Andrew Talbot, bom March 19, 2002. The child was bom out of wedlock. The child is presently in the custody of defendant, who has had custody of the child since birth. For the past five years, the child has resided with the following persons at the following addresses: Address Dates 2142 Market Street 3/19/02 to Camp Hill, PA 17011 present The mother of the child is Ambra Sue Wilson who currently resides at 2142 Market Street, Camp Hill, Pennsylvania. She is single. The father of the child is James R. Talbot, currently residing at 302 Church Street Three Springs, Pennsylvania. He is single. The plaintiff currently resides alone. The defendant currently resides with her daughter, Jessica, age 10. 10. 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. 11. The plaintiff has no information of a custody proceeding concerning the child pending in a court in this Commonwealth or in any other court. 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 interest and permanent welfare of the child will be served by granting the relief requested because the child will benefit from a relationship with his father. 14. 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 this Court to award him partial physical custody of Collin Andrew Talbot. Timot~ J. O~mnell,~e Turner ahdq~Connell 4415 North Front Street Harrisburg, PA 17110 (717) 232-4551 Verification I verify that 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.A. Section 4904 relating to unsworn falsification to authorities. Date: James~R. Talbot - / JAMES R. TALBOT PLAINTIFF AMBRA SUE WILSON DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-348 CIVIL ACTION LAW IN CUSTODY ORDER OF CO1.JRT AND NOW, Friday, January 24, 2003 ~ upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear befbre Melissa P. Greevy, Es_q. __, the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Tuesday, March 04, 2003 at 11:00 AM for a Pre-Hearing Custody Conference. At such conference, an effbrt will be made to resolve the issues in dispute: or if this cannot be accomplished, to define and nan'o~v 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 grom~ds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE CO URT. By: /s/ Melissa P. Greevy, Esq, Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATI'ORNEy OR CANNOT AFFORD ONE, GO TO OR TELEPHONE ~H-IE OFFICE SET FORTH BELOW TO FI'ND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 JAMES R. TALBOT, : PLAINTIFF : V. : AMBRA SUE WILSON, : DEFENDANT : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-348 CIVIL ACTION - CUSTODY PRAECIPE TO ENTER APPEARANCE AS DEFENDANT'S COUNSEL TO THE PROTHONOTARY: Please enter the appearance of Steven Howell, Esquire on behalf of the Defendant Ambra Sue Wilson. Respectfully submitted, BY:~re ~' 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court I.D. 62063 Attorney for Defendant Certificate of Service I hereby certify that on the date set forth below a true and correct copy of the foregoing document was served upon all counsel of record via postage prepaid, first class United States Mail addressed as follows: Timothy J. O'Connell, Esquire Turner & O'Connell 4415 North Front Street Harrisburg, PA 17110 Date: February 11, 2003 BY: S ~ Howe[~, Esquire JAMES R. TALBOT, Plaintiff AMBRA SUE WILSON, Defendant · HAR 3] Z003~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-348 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this / ~ day of April, 2003, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. .Legal Custody. The parties, James R. Talbot and Ambra Sue Wilson shall have shared legal custody of the minor child, Collin Andrew Talbot, born March 19, 2002. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. Mother shall have primary physical custody. Father shall have visitation and then partial custody in accordance with the following temporary schedule: A. To commence March 26, 2003, and to continue for a period of three (3) months, Father shall have eight (8) three (3) hour visits with the child at the Mother's home. Father will provide Mother with, at minimum, four (4) hours telephonic notice of his requested visitation times. Mother will not unreasonably withhold her consent to Father's requested visits under the provisions of this paragraph. B. In addition to the periods provided for under Sub-paragraph 2A, then to commence June 28, 2003, and to continue each three (3) weeks, Father shall have periods of partial custody to occur on Saturdays from 11:00 a.m. until 5:00 p.m. at Father's home. For Father's periods of partial custody as provided in this paragraph, Mother will provide the transportation by driving the child to Father's residence in Three Springs, Pennsylvania. NO. 03-348 CIVIL TERM 3. The parties have no agreement with regard to transportation beyond the provisions specified within this Order. 4. The Custody Conciliation Conference shall reconvene on October 20, 2003, at 9:00 a.m. at the office of the Custody Conciliator, Melissa Peel Greevy, Esquire, 301 Market Street, Lemoyne, PA 17043. Pursuant to the agreement of the parties in the discussions leading up to the agreement upon which this Order is based, it is expected that on the agenda for the upcoming Custody Conciliation Conference will be the further expansion of Father's periods of partial custody. DJst: BY THE COURT: / Timothy J. O'Connell, Esquire, 4415 North F~ont S~eet, Harrisburg, PA 17110 Steven Howell, Esquire, 619 Bridge Street, New Cumberland, PA 17070 JAMES R. TALBOT, Plaintiff AMBRA SUE WILSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-348 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent litigation is as follows: NAME Collin Andrew Talbot information concerning the child who is the subject of this DATE OF BIRTH March 19, 2002 CURRENTLY IN THE CUSTODY OF Mother 2. A Custody Conciliation Conference was held on March 25, 2003 following a Complaint for Custody filed by the Plaintiff Father on January 23, 2003. Present for the conference were: the Father, James R. Talbot, and his counsel, Timothy J. O'Connell, Esquire; the Mother, Ambra Sue Wilson, and her counsel, Steven Howell, Esquire. 3. The parties reached an agreement in the form of an Order as attached. By mutual agreement of the parties, the purpose of this Order is to provide a structured "adjustment period" for Collin to be reacquainted with his Father. The Custody Conciliation Conference will reconvene on the October date specifie~_jG.~he Order. On the agenda at that time shall be an increase in Father's custodial tir~. } Date Melissa Peel Greevy, Esquire Custody Conciliator :211439 CUMBERLAND COUNTY ADULT PROBATION VS. Kevin Smith 1306 High Street Apt 2 Churchtown, PA 17555 Plaintiff Defendant/Address IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW NO. 02-348 RE: NO. 01-1293 CKIMINAL TERM PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Please mark satisfied the judgment, in favor ofpla:[ntiff Cumberland County Adult Probation and against the above-named defendant, previously emered pursuant to 42 Pa. C.S.A. Section 9728. Also, please prepare a Certificate of Satisfaction. Dennis E. Lebo, Clerk of Court Date: June 13, 2003 Charles R. C~,~row, E§quire Solicitor for the Clerk of Court of Cumberland County, Pennsylvania cc: Defendant Probation Clerk of Court OCT U 9 2003 JAMES R. TALBOT, Plaintiff V. AMBRA SUE WILSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-348 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER TO RELINQUISH JURISDICTION AND NOW, this 29th day of September, 2003, upon the request by counsel for Plaintiff an~ Defendant, the Custody Conciliation scheduled for October 20, 2003 is hereby CANCELED. Tht Conciliator hereby relinquishes jurisdiction of the matter. FOR T/~, RT: Melissa Peel Gre~ire Custody Conciliator Dist: v~_imothy J. O'Connell, Esquire, 4415 North Front Street, Harrisburg, PA 17110 ~,,,~teven Howell, Esquire 619 Bridge Street, New Cumberland, PA 17070 ,¢ . :218938 VlNYA"tAgNN]d zJU ;~, ,