HomeMy WebLinkAbout00-05241
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OCT 0 3 200af1P
HARRY B. LAUGHLIN, II,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00-5241
JODIE L. CLINE,
Defendant
CIVIL ACTION - LAW
CUSTODY
AND NOW, this
ORDER OF
:;q~Q
, 2000, the Civil Action
Docketed at 00-5241 is consolidated with the prior action and shall be found under Docket No.
1991-4096 Civil Term in Custody.
FOR THE COURT:
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Melissa Peel Greevy, Esquire
Custody Conciliator
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HARRY B. LAUGHLIN, II
PLAINTIFF
V.
JODIE L.CLINE
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
00-5241 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 3rd day of AU2ust ,2000, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator,
at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on the 31st day of August ,2000, at 9:15 a.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 defme 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.
FOR TIlE COURT,
By: Isl
Melissa P. Greev Es
Custody Conciliator
. The Court.ofCommonPleas 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 disal1ledindividuals having business before the court, please contact our offic.e.. All arrangements
must be made at least 72 hours prior to any hearing or busine~s before the court. You must attend the
scheduled cQnference or hearillg.
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YOU SHOULD TAKE TIllS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE SET
FORTIl BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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HARRY B. LAUGHLIN, II,
Petitioner
vs.
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CML ACTION - LAW
JODIE L. CLINE,
Respondent
NO. 00 - $:1.</1
C~~'C ~~
ORDER OF COURT
AND NOW, this
day of
, 2000, upon consideration of the
attached petition, it is hereby directed that the parties and their respective counsel appear before
, Esquire, the conciliator, at
, Pennsylvania, on
the _day of
,2000,
o'clock .m., for a Pre-Hearing Custody Conference. At such conference,
at
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. Either
party may bring the child who is the subject of this custody action to the conference, but the
child's attendance is not mandatory. Failure to appear at the conference may provide grounds for
entry of a temporary or permanent order.
FOR THE COURT,
By
Custody Conciliator
YOU SHOULD TAKE TillS 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.
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, 4TH FLOOR
CARLISLE, PA 17013
(717) 240-6200
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HARRY B. LAUGHLIN, II,
Petitioner
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNT~PENNSYLVAN~
vs.
Respondent
CIVIL ACTION - LAW
NO. {)-6. $.2'1/ (3;;..( -r ~
JODIE 1. CLINE,
CUSTODY PETITION
AND NOW, Petitioner, Harry B. Laughlin, II, by and through his attorney, G.
Patrick O'Connor, Esquire, files a Petition For Custody of which the following is a
statement:
I. Peititioner is Harry B. Laughlin, II, Father, who currently resides at 812
Yorkview Drive, Grantham, PA, Cumberland County, PA 17027.
2. Respondent is Jodie 1. Cline, who currently resides at 1145 Myerstown
Road, Gardners, Cumberland County, PA 17324.
3. Plaintiff seeks custody of the following child/children:
Name
Present Address
Date of Birth
Kaitlyn E. Laughlin
1145 Myerstown Rd.
Gardners, PA 17324
May 2, 1991
4. The child was not born out of wedlock.
5. The child is presently in the custody of the Mother who currently resides at
1145 Myerstown Rd. Gardners, Cumberland County, Pennsylvania. Mother and Father
are divorced.
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6. During the past five (5) years, the child resided with the following persons
at the following addresses:
Persons Address Date
Jodie L. Cline street unknown 1996 to 1997
Carlisle, PA 17013
Jodie L. Cline 23 Honeysuckle Dr. 1997 to 1998
Aliquippa, PA 15001
Jodie L. Cline 87 Covington Dr. 1998 to July, 1999
William Kokas Shrewsbury, PA 17361
Jodie L. Cline 1145 Myerstown Rd. July 1999 to present
Margie Cline Gardners, PA 17324
Jerry Cline
Debbie Gordon
Peiton Gordon
7. The Mother ofthe child is Jodie L. Cline, whose current address is 1145
Myerstown Rd., Gardners, Cumberland County, PA 17324.
8. The Father of the child is Harry B. Laughlin, who currently resides at 812
Yorkview Dr., Grantham, Cumberland County, PA 17027.
9. The parties are divorced.
10. The relationship of Petitioner to the child is that of Father. Petitioner
currently lives alone.
11. The relationship of Respondent to the child is that of Mother. Respondent
currently resides with the following persons:
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Person
Relationship to Mother
Margie Cline
Jerry Cline
Mother
Father
12. Petitioner and Respondent 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.
13. Petitioner and Respondent have no information of a custody proceeding
concerning the child pending in a court of this Commonwealth.
14. Petitioner and Respondent do not know of a party to the proceedings who
has physical custody of the children or claims to have custody or visitation rights with
respect to the child.
15. Petitioner desires to have joint legal custody and joint or partial physical
custody of the child.
16. The best interests and permanent welfare of the child will be served by
granting the relief requested.
17. Each parent whose parental rights to the child have not been terminated
and the persons who have physical custody ofthe children have been named as parties to
this action.
WHEREFORE, Petitioner respectfully requests that this Honorable Court enter an
Order granting joint legal custody and joint or partial physical custody to Petitioner.
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Respectfully submitted:
By:
G. Pick O'Connor, Esquire
3105 Old Gettysburg Road
Harrisburg, PA 17011
717-737-7760
Attorney l.D. #64720
ATTORNEY FOR PETITIONER
DATE: rj;.t/jt70
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VERIFICATION
I, HARRY B. LAUGHLIN, II, verify that the statements set forth in the foregoing
CUSTODY PETITION are true and correct to the best of my knowledge, information,
and belief. I realize that false statements herein are subject to the penalties for unsworn
falsification to authorities under 18 Pa.C.S. Sec. 4904.
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Date: 7/1- 'f hOb 0
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CERTIFICATE OF SERVICE
I hereby certify that I have, this day, served the herein Custody Petition to the
party indicated below by depositing same in the United States mail, postage prepaid, at
Camp Hill, Pennsylvania:
Jodie 1. Cline
1145 Myerstown Rd.
Gardners, PA 17324
Mary A. Dissinger, Esquire
28 N. 32nd St.
Camp Hill, PA 17011
DATE: 7jz<1oV
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/ G. Patrick O'Connor, Esquire
Attorney No. 64720
3105 Old Gettysburg Road
Camp Hill, PA 17011
(717) 737-7760
Attorney for Petitioner