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Home My WebLink About98-02421 The father of the child is David W, Wnlker, currently residing lit an unknown nddress, He is mnrrled, 4, The relntionship of the Plaintiff to the child is that of Mother, The Plaintiff currently resides with the following persons: Megan R, Walkcr 5, The relationship of the Defendant to the child is that of Father, The Defendant currently resides with the following persons: Unknown 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 cuntody proceedinl\ concerning the child pending in a court of this Commonw~alth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child 01' claims to have custody or visitation rights with respect to the child, 7. The best interest and permanent welfare of the child will be served by granting the relief requested for the following reasons: A, Plaintiff has undertaken and performed the primary parental responsibilites for the child; and B Plaintiff is best able to provide the care and nurture which the child needs for a healthy development: and C, A Comt Order of custody and structured vistitatlon is desired so that the Plaintiff and the child may plan her schedule accordingly; and so that misunderstandings and @MAY 2 6 1998 TAMMY S. WALKER, I IN 'l'HE COURT OF COMMON PLEAS OF plaintiff I CUMBFRLAND COUNTY, PENNSYLVANIA . . vs. NO. 98-2421 CIVIL TERM DAVID W. WALKER, CIVIL ACTION ,. LAW Defendant I IN CUSTODY aIDER OF COORT AND lOll, this 21st day of May, 1998, the Conciliator, being advised by Plaintiff's counsel that the parties are at.tempting to reach an agreement on the custody issues and at the request of plaintiff's counsel that the Conciliation Conference scheduled for June 9, 1998 be canceled, hereby relinquishes jurisdiction in this case. FOl\ ,T~lE COURT, TAMMY S. WALKER Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : CUSTODYIVISITATlON DAVID W. WALKER Defendant : NO. 98-JLfa\ CIVIL TERM COMPLAINT FOR CUSTODY 1. The Plaintiff is Tammy S. Walker, residing at 133 Tower Circle, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is David W. Walker, who previously resided at 133 Tower Circle, Carlisle, Cumberland County, Pennsyvlania 17013. As of the date of the execution of this complaint, his exact residence is unknown. 3. Plaintiff seeks custody of the following child: NAME RESIDENCE DOB AGE Megan R. Walker 133 Tower Circle 10/23/90 7 years The child was not born out of wedlock. The child is presently in the custody of Mother. During her life, the child has resided with the following persons and at the following addresses: NAME ADDRESS DATES Tammy S. Walker and David W. Walker 133 Tower Circle Carlisle, PA 17013 April 1992 April 1998 The mother of the child is Tammy S. Walker, currently residing at 133 Tower Circle, Carlisle, PA 17013. She is married. The father of the child is David W. Walker, currently residing at an unknown address. He is married. 4. The relationship of the Plaintiff to the child is that of Mother. The Plaintiff currently resides with the following persons: Megan R. Walker 5. The relationship of the Defendant to the child is that of Father. The Defendant currently resides with the following persons: Unknown 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. The best interest and permanent welfare of the child will be served by granting the relief requested for the following reasons: A. Plaintiff has undertaken and performed the primary parental responsibilites for the child; and B. Plaintiff is best able to provide the care and nurture which the child needs for a healthy development; and C. A Court Order of custody and structured vistitation is desired so that the Plaintiff and the child may plan her schedule accordingly; and so that misunderstandings and unmet expectations regarding custody and vistitation can be avoided, and also so that the child are not used in a manipulative fashion. D. Plaintiff desires to maintain the family household which has been established, and the continued stability of the household is in the best interest of the child. E. The Defendant has failed to perform his parental duties. F. The Defenadant appears to be unable to tolerate the child's behavior. G. The child has Attention Deficit Disorder and the Defendant refuses to participate in counselling with and for said child. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiff requests the Court to schedule a custody conciliation hearing and further to award custody of the child to Plaintiff. Respectfully submitted, ANDREWS & JOHNSON By: Ronald E. Joh , Esquire Attorney for tlltiff 78 West Po ret Street Carlisle, P A 17013 Telephone: (717) 243-0123 Supreme Court ID No. 16453 ~ " . COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) 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 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. DATEC1,i' J.puLi eN C;~ 1wr~f' \CJ;.LlJ.A-~) . Tammy S. er, Plaintiff --- ~ 1""- I) , \,.; w(:': a' .~ ot. 0#;.,-. tT-, "'~~ \.Lr" q(-. <:1' ot'- W,-.t. N ii~~- (.- '.J i~\_ L_._ t-- ~, ~ en :) tr 0 s; i () ,') L) //j I() ZJ.- "'+- () .~ C if: ~. r:D 7" " 1..~ tC IJ r- :3 )'^\ U) ~ -n -r:; ---' <i.. , (:.J z o rJJ3;CJ Z <1. ~ (<) :t:~iJ)8cD O ......r--. ~ ~~~'-q ~;;;6~~ t.Ll 0 ... rl cJ)zp...,S:::- ~..J..... rJll'" ........ tJ).............. fT' 0 c; --;: 1'-- ~i-:::r-m-' ~C<;>u O<C~ Z ~ -= TAMMY S. WALKER Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Defendant : CIVIL ACTION - LAW : CUSTODYIVISITATION : NO. 98- ;2L/-J I CIVIL TERM v. DAVID W. WALKER ORDER OF COURT AND NOW, SIS , 193'6., upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before l~~\.I\C'h.A . (:::;; <jl. , the conciliator, at 3q \0. MO\''\'\\-'1 ~! "- '..\n ~\(<, \)..5) on the ~ day of '-. 'J,.J(\L. , 199 ~ , at \ 0' clock, ~.m., 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. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: By: ~(J\ \ ~ ~. AuNlrlmA)~ . Custody Conciliator 0 1\:t"J.) The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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 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. Cumberland County Bar Asssociation 2 Liberty A venue Carlisle, PA 17013 Phone: (717) 249-3166 4 r::>', > ,Jr';? -J:. I"r"'" 47 ," .7~' A . v),<5.)> / _ ./>( Y:'1W' ,. _ ~ ~r. 7t< 5c5 ;7Y-- ~p f;P :J'- /r~~-ff' M:;l f0j7 ,M -/.~ ,;'J ',"n"'" ,.,) t. ,:<. '::- I."t't ]') x::. ~!MAY 2 6 1998 \11 TAMMY S. WALKER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 98-2421 CIVIL TERM : DAVID W. WALKER, : CIVIL ACrION - LAW Defendant IN CUSTODY CRDER OF COURT AND NCW, this 21st day of May, 1998, the Conciliator, being advised by Plaintiff's counsel that the parties are attempting to reach an agreement on the custody issues and at the request of Plaintiff's counsel that the Conciliation Conference scheduled for June 9, 1998 be canceled, hereby relinquishes jurisdiction in this case. FOR THE COURT, 0L- S. Sunday, Esquire Custody Conciliator