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Home My WebLink About98-00027 ,l ;~ :; ~~ J , ~ ' { ~ ~ d ,. ~: ,'.\ JAN 0 It 199Rd'::t ' IN TUE COURT OF COMMON I'LE^S OF CUMBERL^ND COUNTY, I'ENNSYLV^NI^ CIVIL ^C'1'I0N - L.^W (I \ Rhonda Sue Radabaugh, I'laintifi' No. q ~. .) 7 Cu.t.R '-r;~ v. Kenneth Lee McCormick, Defendant IN CUSTODY ... ORDER OF COURT AND NOW, this ~ day of -X'\)JJ1"1-:-' 199~upon consideration of the attached Complaint in Custody, it is hereby directed that the parties and their respective counsel appear before Wf\ 'Esq. the conciliator at "2. \..J, the 1CL aay of Ifh(\ n~. 199B.. at Q: 0/:) Q.m. for are-Hearing Custo 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 this conference may provide grounds for entry of a temporary or permanent Order, Hearing to be held at , BY THE COURT, BY: i , ,~- 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Rhonda Sue Radabaugh, PlaintilT N q f. J'1 Cu,i..R--r.;v-.. o. v. Kenneth Lee McCormick. Defendant IN 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 after this Complaint is 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 judgment may be entered against you by the Court without further notice for any money claimed in the Complaint for any other claim or relief requested by the Plaintiff. You may 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. j COURT ADMINISTRATOR FOURTH FLOOR CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE pA 17013 717-240-6200 f. I ; ~ , ( if .. i ~ . !I ,. , i 1, (..., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Rhonda Sue (McCormick) Radabaugh, Plaintiff No. q f.;).1 ~ T......- v. Kenneth Lee McCormick. Defendant IN CUSTODY COMPLAINT FOR CUSTODY I. The Plaintiff, Rhonda Sue (McCormick) Radabaugh, is an adult individual who resides at 131 Salem Church Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant, Kenneth Lee McCormick, is an adult individual who currently resides at 1729 48th Street, Des Moines, Iowa 50310. 3. Plaintiff seeks primary physical and legal custody of the minor child, Jared J.R. McCormick, born July I, 1989, The child was born in wedlock. For the past five years, the child has resided with the following persons and at the following addressed: j , Rhonda (McCormick) Radabaugh Gary Radabaugh 131 Salem Church Road 6/97 - present Mechanicsburg, PA 17055 Rhonda (McCormick) Radabaugh 101 Stoner Drive 3/96 -/97 Mechanicsburg, PA 17055 I' I I Rhonda (McCormick) Radabaugh 3870 92nd Circle Urbandale, IA 4/94 - 3/96 Rhonda (McCormick) Radabaugh Kenneth McCormick 3870 92nd Circle Urbandale, IA 10/92 - 4/94 I 1":( I [, I I , The Mother of the child is Rhonda (McCormick) Radabaugh, is an adult individual who resides at 131 Salem Church Road, Mechanicsburg, Cumberland County. Pennsylvania 17055, ~ She is married. \ The father of the child is Kenneth Lee McCormick, is an adult individual who currently resides at 1729 48th Street, Des Moines, Iowa 50310. He is single. 4. The relationship of the I'laintitl'nnd child is that ofnaturnl parent. The Plaintiff currently resides with the child. 5. The relationship of the Defendant and child is that of natural parent. The Defendant currently resides with his paramour. 6. The Plaintiff has participated as a party in other litigation concerning the custody of the child in the Iowa District Court for Polk County at C.D. No. 50156. The custody action was dismissed by Order of Robert J. Fink, Judge on December 8,1997. A copy of said Order and a copy of the Motion requesting the dismissal are attached hereto and incorporated herein by reference as Exhibits "A" and "B". respectfully. Plaintiff has no information of a custody proceeding concerning the child pending a Court of this Commonwealth. Plaintiff does not know of a person not a party to these proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interests and permanent welfare of the child will be served by granting the relief requested, WHEREFORE, Plaintiff, Rhonda (McCormick) Radabaugh, respectfully requests that the Court grant her primary physical custody and legal custody of the subject minor child. Respectfully submitted, Date: 1'2.{1/ (<f( Keith B. DeArmond, Es , Attorney for Plaintiff DeArmond & DeArmond 2800 Market Street Camp Hill, PA 17011 717-730-9394 Supreme Ct. 1.0. No, 58878 ;.~ 1 ~J '< . . " VERIFICATlOI':1. I, the undersigned, do hereby verify that the statements made in the foregoing document arc correct to the best of my knowledge, information and belief. I understand that statements herein arc made subject to the penalties of 18 Pa. C.S. *4904 relating to unsworn falsification to authorities, Date: ~ ~ - lib -9 1 ~~nia'R:~:;;-~ 1 J "1 " I", I' I I " {,-"r ~ ~ .., ~ " , ~J J . ~ J 0 ~ '5 ~ 'J\. . lti \Ii (.) g. M .. ~ ~ fi; lit ~ c: '... ~ c.J :.3...... ~Q Oi;: n:~ :r: LJ:'i 0- ..;)~ ~r'- ;~{n Fl In . -..,. ~ I tC:z .. fi5LU _. lUlU of ..~ ((Ju... ... ~ ~ co a en '. .. ~~...... '., <:,,;~; &MAR 171998 RHONDA SUE RADABAUGH I : IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. . NO. 98-27 CIVIL TERM . . . KENNETH LEE McCORMICK, . CIVIL ACTION - LAW . Defendant . IN CUSTODY . aIDER OFaxJRT AND tOi, this 12th day of March, 1998, the Conciliator, not having received a request from counsel for either party to reschedule the CUstody Conciliation Conference originally scheduled for February 10, 1998, hereby relinquishes jurisdiction in this case. FOR THE COURT, ~~ CUstody Conciliator r.' "I' "-_ ("" '. .. '~'.' }-" l .'. '.~'" -.!' , 'p" :",' ,.;~' :>I,;,~ 'r.. ",,-.1.'//\1,' c;~ '.A,.", .., I,:" Ie t\': 'Ii I,: n5 (': /' IVj\/"";:'i '.'" ~1'':'' ". ,,',' , .." ," f'r-\" '", '.. '..l ..I i'.;~ Il''';':,\lf. "-f :)/\:'~'/ .., I' it.