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Home My WebLink About03-0868FRED W. TROUT DARLENE M. TROUT vs. J~LMIE L. CHANDA WILLIAM R. WAUGH Plaintiffs DefendantS : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :NO. O3 -- ~ : CIVIL ACTION - LAW : CUSTODY CUSTODY COMPLAINT 1. The Plaintiffs are Fred W. Trout and Darlene M. Trout who currently reside at 7 Courtland Road, Camp Hill, PA 17011. 2. The Defendants are Jamie L. Chanda and William R. Waugh who currently reside at 300 North Hanover Street, Apt. #5, Elizabethtown, PA 17022-1603 3. Plaintiffs seek primary physical and sole legal custody of Perri E. Chanda born November 16, 1997. Perri E. Chanda resides with Plaintiffs at 7 Courtland Road, Camp Hill, PA 17011. 4. The child was born out of wedlock. 5. Perri E. Chanda has always lived with Fred W. Trout and Darlene M. Trout at 7 Courtland Road, Camp Hill, PA 17011. Since May or June of 1998, Perri has resided only with Fred W. Trout and Darlene M. Trout at this address. From birth until May or June of 1998, Jamie L. Chanda was also living at 7 Courtland Road, Camp Hill, PA 17011. From December 1997 until about April of 1998, William R. Waugh was living at 7 Courtland Road, Camp Hill, PA 17011. 6. The mother of the child is Jamie L. Chanda and she currently is residing at 300 North Hanover Street, Apt. ~5, Elizabethtown, PA 17022-1603. She is not married. The father of the child is William R. Waugh and he is currently residing at 300 North Hanover Street, Apt. #5, Elizabethtown, PA 17022-1603. He is not married. 7. The relationship of Plaintiffs to the child is that of great grandparents. Plaintiffs are the parents of the mother of Jamie L. Chanda. The Plaintiffs currently resides with Perri E. Chanda. 8. The relationship of Defendants to the child is that of mother and father. The Defendants currently resides with each other at 300 North Hanover Street, Apt. #5, Elizabethtown, PA 17022-1603. 9. Plaintiffs have 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. 10. Plaintiffs have no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. 11. Plaintiffs do 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. 12. The best interest and permanent welfare of the child will be served by granting the relief requested because Plaintiffs have been the primary physical and legal custodians of Perri since her birth. 13. 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, Fred W. Trout and Darlene M. Trout request the Court enter an Order granting them primary physical and sole legal custody of Perri E. Chanda. YOFFE & YOFFE, P.C. ~FRE~ N. YO~F~, ESQUIRE Attorney for Plaintiffs 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 VERIFICATION I hereby state that I am an adult individual who is authorized to make this verification and that the facts set forth in the foregoing Complaint are true to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. Dated: D~rle~e Mi' T~out - Dated: Fred W. Trout FRED W. TROUT & DARLENE M. TROUT PLAINTIFF Vo JAMIE L. CHANDA & WILLIAM R. WAUGH DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-868 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, March 06, 2003 _, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear betbre Melissa P. Gree , Esvy~E[~, the conciliator, 301 Market Street, Lemoyne, PA 17043 on Monday, April 07, 2003 at I:00_~PM at 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 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 hearing. FOR THE COURT, By: /si 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 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 FRED W. TROUT DARLENE M. TROUT vs. JAMIE L. CHANDA WILLI~kM R. WAUGH Plaintiffs Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03-868 : CIVIL ACTION - LAW : CUSTODY MOTION FOR ENTRY OF CUSTODY ORDER 1. The undersigned Defendants acknowledge that they have been sezved with a Custody complaint filed in ~his case. 2. The undersigned have read the proposed Order attached hereto as Exhibit "A" and understand its contents. 3. The undersigned want Fred W. Trout and Darlene M. Trout to have primary physical custody and sole legal custody of Perri E. Chanda. WHEREFORE, by placing their signatures hereto, the undersigned request the Court enter the Order attached hereto which essentially grants to Fred W. Trout and Darlene M. Trout primary physical and sole legal custody of Perri E. Chanda. Date:~ 3 ~ ?- o~ Date:~ 3-7 ' 0 YOFFE & YOFFE, P.C. ~E~R~ N. YOCF~, ESQUIRE Attorney for Plaintiffs 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 ' ~J~ L. C-hanS~ ' lliam R. Waugh ~ Date: 3-/7 Date: Fred W. Trout ~arlene M. Trout ' - ..... FRED W. TROUT DARLENE M. TROUT VS. JAMIE L. CHANDA WILLIAM R. WAUGH Plaintiffs Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : : NO. 03-868 : : : CIVIL ACTION - LAW : CUSTODY ACCEPTANCE OF SERVICF. I accept service of the Custody Complaint in the above captioned action. Date: William R. Waugh U 300 North Hanover Street, Apt. Elizabethtown, PA 17022 trout\acceptance FRED W. TROUT DARLENE M. TROUT vs. JAMIE L. CHANDA WILLIAM R. WAUGH Plaintiffs Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-868 CIVIL ACTION .- LAW CUSTODY ORDER ~ AND NOW, this ~ day of __ __, 2003, in consideration of the motion filed by all parties requesting the entry of the same Order, it is hereby Ordered that Fred W. Trout and Darlene M. Trout are hereby awarded primary physical custody and sole legal custody of Perri E. Chanda. Jo FRED W. TROUT DARLENE M. TROUT VS. JAMIE L. CHANDA WILLIAM R. WAUGH Plaintiffs Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03-868 : CIVIL ACTION - LAW : CUSTODY MOTION FOR ENTRY OF CUSTODY ORDER 1. The undersigned Defendants acknowledge that they have been served with a Custody complaint filed in ~his case. 2. The undersigned have read the proposed Order attached hereto as Exhibit "A" and understand its contents. 3. The undersigned want Fred W. Trout and Darlene M. Trout to have primary physical custody and sole legal, custody of Perri E. Chanda. WHEREFORE, by placing their signatures hereto, the undersigned request the Court enter the Order attached hereto which essentially grants to Fred W. Trout and Darlene M. Trout primary physical and sole legal custody of Perri E. Chanda. Date:x %-7 ' 0 3 Date: 3-17- 0 3 Date: YOFFE & YOFFE, P.C. ~E~FR~ N.-YOfF~, ESQUIRE Attorney for Plaintiffs 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 'Jam~- L. C-han~ Fred W. Trout