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HomeMy WebLinkAbout00-05241 " '" 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: q Id q /1--OhJ / tAta~ Date Melissa Peel Greevy, Esquire Custody Conciliator iliir '" ~l1li iII.i1i1ii1il- ~ C'J N ?= 2:' ,.'-) r-: _'" ",2 ~,=;~ n\~~ ~~ C-. ~25 (.) co",! " ,. '" ,. -'-' '~Ii.iiii-~1L"""":""-'lrt?l"': " """-' ~. , - .."- c " , ',...; "~ - ,~~ ,- ""'"'""., ... ,/ .-- _0 """""'ww,,-i 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. .' . 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 fF _~~,jjj.1I!iw<f;."",,"'il~~I*J~.-M,~'C<iiJliWa&.."'iili.-i;;...1r;it-I.>WMjj:!iI!~:!.N\~~""'''''><~l@illtJiWIl'~ ""., tf~ &1 e ""..i..""'j;."~~~ ~' , '\.I! ~u S;^(l~ ~1tf 071JnJ~~ J..dco -Oojh!J fr::f3Q. -p 'IA~/:rJ'(l Ant; Of- -"'~~J1~ c.u ~/;or:Y - 001 1Y! J VONVO)IO !.-fm or l'3J-rew./..d~ 'f11) - ~/NI<J 'v1NVAlASNN3d AlNnOO 0l'..l'11tB8\^lnO Sf:: :8 ~-ld ~- mw 00 AJ.iV1Q1'{Ot;1,::J:~.~j,..,~~,\:il :JO :1'''~.I, ,-( 1_' .'-. ,:lV\~,_...... . _ ll.~ ~., . bl <"'-~""-",,,-,,~_IMilIF- - .. ". '"y, ,::~~ -' J.lll ! '1 ~bP M 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 H ". ",~ "., ~~- ,~...tiI.~!t!~~~~~I<ir&l;\IllllWi!l'i!ffi~~~___.itc.---WI'-~ ~~. V-""'"1!i;Jj ~I ~- ~= ^ ~I d,~ i~ ~-- ..,--- ,~-~~~~,~, ,-~. ,=-,. ......_~~ '~J," 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. ~'~lj]-l"'il/l!fl', .~.l~~IllLr~Iiffi'i{i!iil'~~!i!N~~~g~..jl1ffilr#~'1If;W',~~~~ 0, ~~-, - <" ^ ,,' " --<, <,~~, ~!l!iii!:ll>>U- '"",.,."'''~~~' ~,,-"" .' =<~~~~ 'j i.' .. ,~.~~ -.. 'j,,-~~, 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: J'; -"~~ik~GSillillil!i;jj-~~..!41r~~~~~~~ll!lli!IlL:ii~W!;j- .,", '~'i!ffilil,."t,ii.~~1iiI ".~-".,~ ,1.- ""' -,~. ~ ~ ...... '~tiIil:,~~Iim,,~-NlR}j"""""I3i' ~, 'C', .--- ~- ~~ ~~ i_I~~!!I~. 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. "~~.~ -~ . .. ~g,\..i 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 '_~"""''''~ltIllIO.. ~ -"""""""",- 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. '1 Date: 7/1- 'f hOb 0 I . -"''''~~ .'_oM,', 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 ~d~ / G. Patrick O'Connor, Esquire Attorney No. 64720 3105 Old Gettysburg Road Camp Hill, PA 17011 (717) 737-7760 Attorney for Petitioner