Loading...
HomeMy WebLinkAbout03-0802JOHN A. MURRAY, III, Plaintiff V. JANICE E. MURRAY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03- IN CUSTODY CIVIL TERM COMPLAINT FOR CUSTODY Plaintiff is John A. Murray, III, an adult individual currently residing at 21 Comell Drive, Camp Hill, Cumberland County, Pennsylvania. Defendant is Janice E. Murray, an adult individual currently residing at 104 Juniper Drive, Mechanicsburg, Cumberland County, Pennsylvania. The parties are the natural parents of two (2) children, namely, Lauren Michelle Murray, bom April 8, 1990, and John Alexander Murray, IV, bom August 21, 1997. The children were not born out of wedlock. 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 Janice M. Murray John A. Murray, III Janice M. Murray ADDRESS 104 Juniper Drive Mechanicsburg, PA 17043 104 Juniper Drive Mechanicsburg, PA 17043 DATES December 24, 2002 to Present 1997 to December 24, 2002 The natural mother of the children is Janice E. Murray who resides as aforesaid. She is married. The natural father of the children is John A. Murray, III, who resides as aforesaid. He is married. o The relationship of the Plaintiff to the children is that of natural father. The Plaintiff currently resides with his mother, Dolores H. Murray. The relationship of the Defendant to the children is that of natural mother. Defendant currently resides with the children at issue. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning custody of the children. Plaintiff has no information of any custody proceedings concerning the children pending in any Court of this Commonwealth. 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 equally capable of being the custodian for the parties' children from the time of their birth through present; b) Plaintiff has the ability to provide for the financial physical and emotional needs of the children; 10. c) Plaintiff has a strong and emotional attachment with the children; Plaintiff believes that the children's best interest would be served if the parties negotiated an arrangement where the parties each had liberal access to 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 Custody Conciliation Conference followed by a hearing at which time he should be granted shared legal physical custody of the children. Respectfully submitted, Marylo~fg.~, Esquir~ Attorney for~Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 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 unswom falsifications to authorities. DATE :~~~.~O~ J~N A. MURRAY; m7 Plaiq~-~ JOHN A. MURRAY, III PLAINTIFF JANICE E. MURRAY DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-802 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, February 27, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, March 18, 2003 at 3:30 PM 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. All children a~e 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 hearing. FOR THE CO'URT, By: /s/ Jacqueline M. Verney, 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 c.r business before the court. You must at'tend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE 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 17013 Telephone (717) 249-3166 JOHN A. MURRAY, III Plaintiff JANICE E. MURRAY, Defendant : IN THE COURT OF COMMON Pi : CUMBERLAND COUNTY, PENN : : NO. 2003-802 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT. AND NOW, this 8th day of April, 2003, being advised that the parti, reached a stipulated agreement, the Conciliator hereby relinquishes jurisdic matter. FOR THE COURT, /acq~mey, Esquire, Cusl LEAS OF SYLVANIA ~s have ion in this ~y Conciliator