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HomeMy WebLinkAbout00-05394 ELAINE SARGEANT PLAINTIFF V. GLEN SARGEANT DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-5394 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 7th day of August ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear beforeMelissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on the ~ day of September, 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 THE COURT, By: Isl Melissa P. Greevy. Esq~ Custody Conciliato~ 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 )l1,. ,. ~ - - ~^,- ". "-,- -~.Ift~i"!\IlOl~j,;\~Iiil""'~I!,",l:I<l;l"~JlUHl~~'_i'>:i!i1i"""~J~<W,""lil.'''''~!:i&''-l''i~R%';;-jJ~~itj;~~:;iil'~.,~IW'"~- ~ '"- ",j"'..'-,,,jj,lIiil~~IEilliIl-" ~ ~=~~ I ,i~' -~ ~'" ,,-llil!(!i1i:i!!lIIl1iM ~.. MI& ~I.I r-n.nccICc l;_,.~.., '-.Ii, '1_ OF TiiE [~-!'')-n~Cf\:OT..;,RY 00 AllG -9 Prl I: 52 CUMBERLAND COUNlY PENNSYLVANIA <?f4J w- ~ ~ $ cdf ~ ~-1.&O~~ ~a4~ g;-oo /1~ ~ ~ d4~ r;,:;-,:'^)}~-JJ.J,,~~:~:~.-~~~Jlfm"~,J~L,- _<j-" 7"rjo',',,'>' ,__-~ J ~'_",_ Il!ii v, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. ckQ) - 53<fl.f C-1~t1 ELAINE SARGEANT, Plaintiff GLEN SARGEANT, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , the Conciliator, on the day of , 2000 at o'clock .m., at , Cumberland County, Pennsylvania, for a Custody Conciliation. 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 the entry " . of a temporary or permanent Order. BY THE COURT: Date of Order: By: Custody Conciliator 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 COUNT BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ~~ . . '" . .~ , ""'n, ELAINE SARGEANT, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. GLEN SARGEANT, Defendant : CIVIL ACTION - LAW : IN CUSTODY NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are serve, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. 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 mE OFFICE SET FORm BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNT BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 m.", .-, A VISO USTED HA SIDO DEMANDADO/A EN CORTE. Se usted desea defenderse de las demandas que se prsentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proxirnos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente 0 par medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se Ie advierte de que si usted fa11a de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fall por cualquier suma de dinero reclamada en la demanda 0 cualquier otra reclamacion 0 remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Used puede perder dinero 0 propiedad u otros derechos irnportantes para usted. USTED DEBE LLEV AR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO 0 NO PUEDE PAGARLE A UNO, LLAME 0 VAYA A LA SIGUIENTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. CUMBERLAND COUNT BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 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 assessable facilities and reasonable accommodations available to disable 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. , i :,1 I CUMBERLAND COUNT BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 .~ ~~, - On _"__ , . ~~< v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. IJ1J - 53 q '7 Ci,;.; I..e-.--- ElAINE SARGEANT, Plaintiff GLEN SARGEANT, Defendant : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Elaine Sargeant, an adult individual who resides at 115 Rolo Court, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The Defendant is Glen Sargeant, an adult individual who resides at 607 East Winding Hill Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. The Plaintiff seeks custody of the following child: Name Date of Birth Af;:e Jacob Sargeant 12/3/83 16 The child is presently in the physical custody of his mother, who resides at the address above. The child was born in wedlock. 4. During the past five years the child has lived with the following persons at the following addresses: a. With Mother 115 Rolo Court Mechanicsburg, P A ~, "~ 5. The Mother of the child is Elaine Sargeant, currently residing at 115 Rolo Court, Mechanicsburg, Cumberland County, Pennsylvania. Her marital status is separated. 6. The Father of the child is Glen Sargeant, currently residing at 607 East Winding Hill Road, Mechanicsburg, Cumberland County, Pennsylvania. His marital status is separated. 7. The relationship of the Plaintiff to the child is that of Mother. Plaintiff :1 U currently resides with her son, Jacob Sargeant. 8. The relationship of the Defendant to the children is that of Father. Defendant currently resides with the following persons: Name Relationship Tom (do not know last name) Room Mate 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 the custody proceedings of 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 the child. -c_ 9. The best interest and permanent welfare of the child will be served by granting the relief requested because: a. Plaintiff has shared in the care giving of the child and has provided the child with consistent and loving care. b. Plaintiff is willing and able to continue to provide proper care and supervision of the child. c. Plaintiff can provide a stable and loving environment to the child 10. Each parent whose parental rights of the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. There are no other persons who are known to have a claim or right to custody or visitation in this matter. WHEREFORE, Plaintiff requests the Court to grant primary physical and legal custody of the child to the Plaintiff with liberal partial physical custody to Defendant. Respectfully Submitted, /~o t.I~~~ Marianne E. Rudebusch, Esquire 845 Sir Thomas Court, Suite 11B Harrisburg, PA 17109 (717) 657-0632 Id. No. 63522 Dated: ~ '--,''''''*l. _~ ELAINE SARGEANT, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. GLEN SARGEANT, Defendant : CIVIL ACTION - LAW : IN CUSTODY VERIFICATION I verify that the statements made in the foregoing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. By. E ame Sargeant ~\ Date: ~<~:~ " --c,*,", ~'" ~" " ElAINE SARGEANT, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY,PENNSYLVANIA v. : NO. GLEN SARGEANT, Defendant : CIVIL ACTION - LAW : IN CUSTODY CERTIFICATE OF SERVICE AND NOW, this /s!' day of II/v~ ,2000, I, Katherine A. Frey, Secretary to Marianne E. Rudebusch, Esquire, Attorney for the Plaintiff, hereby certify that a copy of the within document has been served, by depositing a copy of the same in the United States mail, first class, postage prepaid, at Harrisburg, Pennsylvania, to the following addressee: Mark T. Silliker, Esquire 5922 Linglestown Road Harrisburg, PA 17112 ~~I '.\' ~ .<. _. r _. .,-.' I', " ~, . ... .,; SEP 1 4 20~\ vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5394 ELAINE SARGEANT, Plaintiff GLEN SARGEANT, Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this IS It day of S ~ ~t, '1 ~(' f , 2000, upon consideration of the attached Custody Conciliation Summary Repo and the agreement of the parties, it is ordered and directed as follows: 1. Legal Custody. The Mother, Elaine Sargeant, and the Father, Glen Sargeant, shall have shared legal custody of the minor Child, Jacob Sargeant, born December 3, 1983. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education, and religion. Pursuant to the terms of this paragraph, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. Mother shall have primary physical custody subject to periods of liberal partial custody in Father which shall occur on weekends and as otherwise agreed by the parties. In the event that the Child would like to modify the custodial arrangement the parties agree to honor his wishes within reason. The Child shall not reside with his Sister. BY THE COURT, c& J. Dis!: Marianne Rudebusch, Esquire, 845 Sl. Thomas urt, Suite 11A, Harrisburg, PA 17109, Counsel for Plaintiff "'. ,. ",,,,,,. '~oi.."", ,_ ""', ".._, '^ H"', CoOM" .;:\~ L ~,\~~~~ ,,~ '.",~", ,.'<'C r, ' - "-' '., r .. jj>!@!!M~~l\MI<!~nl:&f~~f:~lM~__~oa&~W~W~~iij('fN'P"">'&~'_l!ltiliiillIi1iiitM q, l:T ~"-'~E r n... 1.J-f .Jrft1..l OF T' ,- I"""'" '''''OTMY -,r!.; rr~c)l)",,;Ui~: tj 00 SEP 15 PM 3: 16 CUMP~~fN~UN1Y ~ ~ I , ~ c~." --------.'''1 " ,--~ .~ \. SFP 1 4, 2a~ vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5394 ELAINE SARGEANT, Plaintiff GLEN SARGEANT, Defendant CIVIL ACTION - LAW CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915,3-8, the undersigned Custody Conciliator submits the following report: 1, The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Jacob Sargeant December 3,1983 Mother 2, A Conciliation Conference was held on September 7,2000 with the following individuals in attendance: The Mother, Elaine Sargeant, and her counsel, Marianne E. Rudebusch, Esquire; the Father, Glen Sargeant, and his counsel, Mark T. Silliker, Esquire, 9/ Jt / L.t)lrO , 3. The parties reached an agreement as reflected in the Order as attached. l iaC6 r ~elis a Peel Greevy, Esquire Custody Conciliator Date -""'~~ ~-----. 'C. ~ -;'- ~; ,~" , ^. -~ ;po COMMONWEALTH OF PA., DEPT. OF TRNASPORTATION, BUREAU OF DRIVER LICENSING, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 00-5599 CIVIL CIVIL ACTION - LAW vs. HAROLD PROWELL, Defendant LICENSE SUSPENSION APPEAL ORDER AND NOW, this I<;~ day of September, 2000, it appearing that a supersedeas of license recall was ordered in this case without hearing and therefore entered in error, that portion of our order of August 16, 2000, staying proceedings pending hearing is VACATED. This order is entered without prejudice to the appellant to obtain a hearing on the matter of supersedeas by filing a motion and proposed order for hearing. BY THE COURT, George Kabusk, Esquire For PennDOT /lJ-. 1\. Hess, 1. j1 . -fI~ L. ~'/~'oO ~\Z~ Philip L. Zulli, Esquire F or the Appellant :r1m '.:.1 ^ - _.._-~.- c",,'''' >>,,-,.. -"-.- ---'-,-, "~' ~_. '" ."-"--' .'. ~'~M;1~~~~~..rj]~liII1IlJl:l~ "'Ild!!ilW \i';' HlEl}.OFFlCE CF' "', ;.' r',"r," '~"'\'''''MY ,i ~ni': 1'~;'-:',.rli~...WfVII 00 SEP I 5 PI; 2: 141 CUMjkEfJiJ>ND CQ\.JNlY NN$YLVAN"IA ,. ~~ , .<, - <, ' . ~,~, ,'~ . - .--~, "~---- ~.',- ~- . "'""" . =~ C~ ~ ,= .n. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR AND INDUSTRY to the use of the UNEMPLOYMENT COMPENSATION FUND DOCKET NUMBER 00 5640 CIV vs. CARS BY GETTEL BODY SHOP INC 1143 HARRISBURG PIKE CARLISLE ?A 17013 AUTHORITY TO REMOVE LIEN TO THE PROTHONOTARY OF SAID COURT: NOW, to wit, AUGUST 30, 2000 , the Commonwealth of Pennsylvania, Department of Labor and Industry, to the use of the Unemployment Compensation Fund, Plaintiff in above action, through its Chief Counsel. by its Assistant Counsel, desires that the above captioned lien be removed from record. AND you, the Prothonotary of said Court, are hereby authorized and empowered, in the name and stead of the Plaintiff, to remove said lien from the record as fully and effectually, to all intents and purposes, as we could were we present in person to do so: and for so doing, this shall be your sufficient warrant of authority. IN TESTIMONY WHEREOF, there is hereunto affixed the Seal of the Department of Labor and Industry, Commonwealth of Pennsylvania, this 30 TH day of AUGUST , 2000. ACCOUNT NO. 21-17723 AD NO. 285978 0, ,.', ~,I"..-(;).. ~ ..::r- GA-e~ -SEAN F. 'CREEGAr'- Deputy Chief Counsel For Employment Security "'^""''''''''I!<." . ., --, /,,,! i ;'~ I'. .~, ~ ~ ~ - ~ ru 0 (- 0 ~ '!l: V) .l ~ 1"'1 -0 h:;l::l::! Z":"f , --- .c;;-. ~ Zs.; (Jl iS9 ~:i: c --- ~ r~d -,9 ~ "'"' ,,~ " "-1'~ .., 2;:8 ::Ii: r5-::J -.. .." ~C) tv ..? - c5m 01 ~"'2 " -OJ c-..\ ~ ::1> Y =<! 0 lJ N ::< tI FI """"",~.~~~_~_i!jI'l'''I'',.i1jl'M''''''~'.'!1l~~IOOil'':m~~,W@ii'~~'~~~~:r '!"" ~~."