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Home My WebLink About07-1286 -.. CRYSTALM. PINCKNEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LA W 0'7 -I ).. y(" : NO. CIVIL TERM : IN CUSTODY GARRY A. PINCKNEY, JR., Defendant COMPLAINT FOR CUSTODY 1. Plaintiff is Crystal M. Pinckney, an adult individual currently residing at 28 West Seminary Street, Mercersburg, Franklin County, Pennsylvania. 2. Defendant is Garry A. Pinckney, Jr., an adult individual currently residing at 11 Koser Lane, Shippensburg, Cumberland County, Pennsylvania. 3. The parties are the natural parents of two (2) children, namely, Connor Eugene Pinckney, born October 24,2004, and Ethon Andrew Pinckney, born October 1,2006. The children were not born out of wedlock. 4. For the past five (5) years, or since the children's birth, the children have resided with the following persons at the following addresses for the following periods of time: NAME ADDRESS DATES Crystal L. Pinckney Kimberly Adams (sister) Briana, MeKenna, and Carla Adams (nieces) 28 West Seminary Street Mercersburg, PA 17236 March 4, 2007 to Present Crystal L. Pinckney Garry A. Pinckney, Jr. 11 Koser Lane Shippensburg, P A 17257 July of 2004 to March 4, 2007 - ~ The natural mother of the children IS Crystal M. Pinckney, who resides as aforesaid. She is married. The natural father of the children is Garry A. Pinckney, Jr., who resides as aforesaid. He is married. 5. The relationship of the Plaintiff to the children is that of natural mother. The Plaintiff currently resides with her sister, Kimberly Adams, her nieces, Brianna MeKenna, and Carla Adams, and the children at issue. 6. The relationship of the Defendant to the children is that of natural father. Defendant currently resides alone. 7. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning custody of the children. 8. Plaintiff has no information of any custody proceedings concerning the children pending in any Court of this Commonwealth. 9. It is in the best interest and permanent welfare of the children to grant the relief requested because: a) Plaintiff has been and continues to be the primary care taker of the children from the time they were born to present; b) Plaintiff can provide a stable home life for the children; c) Plaintiff can provide for the day to day needs of the children. 10. Plaintiff does not know any person not a party to these proceedings who claims to have custody or visitation rights with respect to the children. WHEREFORE, Plaintiff requests your Honorable Court to schedule a Custody Conciliation Conference followed by a hearing at which time she should be granted primary physical custody of the children. Respectfully submitted, '\l~~ ~.~~^ - <;:)N\A~dlJ'\. Hannah Herman-Snyder, EsqUl e Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, P A 17013 (717) 243-5551 (800) 347-5552 -,-, - VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: 3/7 / dIJO'7 I I ~~) (y):V:.N~. , CRY L M. PINCKNEY a ......, = 0 .1:4 c:;;. .1 -' R ........ ::IT: =l ~ :l.:;:r,.. rh :!J "- :;.0 r- ~ ~ ~ I n. C::i (X) ~ ~ ~ - .......... -'0 ,,:. l. 0-.. ~ _.>... ;:.-~ ,. ~ ~ ~ rn ~ /,,-.) '" ~ .s:- ~ -C CRYSTAL PINCKNEY PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANJA v, D7-/,l8(p D7 U6S" CIVIL ACTION LAW GARRY A. PINCKNEY, JR. DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, March 19,2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. al____~~l!_!!o~~1_~.!lmberland County Courthouse, Carlisle on Thursday, April 05, 2007 , the conciliator, at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or il'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. 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 hearine. FOR THE COURT. By: /s/ Hubert X Gilro Es 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 infon11ation 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 HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 170 I 3 Telephone (717) 249-3166 "'J . rI'~-tf:~~ - > - ~ 11- I'f:UI kkr; ~-~r1~~V"r9 ) ((J- Oe r- (0, oe.2':- LrJ ~ or" E' VINV^lASl".1N3d AlNneV"\ n~.',".-;' ''"'Ql^'n'" '.)-",c" <,.!i't' /J:::'...Jt'( \J Sf] =21 Wd 02 MYW LOOZ AtN10NOHlOod 3H1:10 301.:HQ-0311=J CRYSTAL PINCKNEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW GARRY A. PINCKNEY, JR., Defendant : NO. 07-1286 : IN CUSTODY CIVIL TERM ACCEPTANCE OF SERVICE I, Lesley J. Beam, Esquire, acknowledge that on or about j/J~ ,2007, I received a true and attested copy of the Order of Court dated March 19,2007, and the Custody \ Complaint filed in the above captioned action and acknowledge that I am authorized to do so on behalf of Defendant, Garry A. Pinckney, Jr. 5/aIi/f21 { Date e "'(,-~ :-tJ ,-.;,,": f"'f' ~{c iflY af~~ '6': ~ ':;.,~ 1--- :::::-:. 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