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Home My WebLink About00-06538 -,- ","""" ]" ~ ~ ~ " -. J' _, '^".""''''''-,~<U,,'' ,.~ ADELE R. DAVIDSON PLAINTIFF V. SCOTT A. PARSON DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA 00-6538 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT , AND NOW, this 29 day orEPTEMBE~, 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, CampHiU, PA 17011 on the 30TH day of OCTOBER ,2000, at 11:00 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 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. FOR THE COURT, By: Isl Melissa P. Greev.y. Esq.tJ 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 TIllS PAPERTO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VB 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 '" . . ." 'e ,__ ~ ,_ _" _ ,,_, ~ ~' ,'_~'_" _, "0 ,~y~ ,,_ _ _ y_ OF ":~ no (V -:I P.I'-I '). r.:: c, ., -". ... I .}" ,..!~ CUM5EFILpi'ilJ COUNlY PENNSYLvW~I,A, , " /Oc2CO M-~~Z; 4~~ It) '01 aY S1/~ _ ~ -z d;t! rr--r-=. j8c)C{;J ~ 1It~ ~ 4 ~ I I I II Ii ~j I' v j-~-~ '. b..l; o _~ ~_ Llflj [I~ " , "~-~- ".". , _ ''i''' ~,' ~;i'i"''''''-'''l@''''wrom'Fi''-m!~'''''''-~~!1i'I~~IW!!1l~~ili!!Ill''!!rrr - r -~ ,-- ~ d "',.- ,,',' ., _ ',' ",-^ ,'-, - .','.. _ < __1,- -, . ~ / ..c, ' ->"-",__:~,,<.-/.- 'w<.--' ;",'c~_)l-_"~~_' . ,,"_'i.' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ADELE R. DAVIDSON, Plaintiff CIVIL ACTION - LAW v. SCOTT A. PARSON, Defendant NO. 2000- ~~ cWJ2 IN CUSTODY ORDER OF COURT AND NOW, this day of , 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and theirrespective counsel shall appear before , the Conciliator, at on the day of , 2000 at .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 define and narrow the issues to be heard by the Court, and to enter into a Temporary Order. All children age five or older shall/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: Custody Conciliator 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 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. ~ .' "' '_"'<0' . '-'.l, - -~.~ '_'" ,Vi. -,"~,;;:_,;:,_."u~ >'.~';';~"",,~ -~,'~-i0; ''=-<'Jij 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 County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 ,'-, .~-: '_ ,-Co . ~" .'. ~ ., .; ,"; "-'''-''''-;' :-->-' - -~-,."",-- -"~'I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ADELE R. DAVIDSON, Plaintiff v. CIVIL ACTION - LAW IN CUSTODY NO. 2000- (,538 c.:;;J. ~ SCOTT A. PARSON, Defendant COMPLAINT FOR CUSTODY AND NOW, comes Plaintiff, ADELE R. DAVIDSON, by and through her attorney, Richard L. Webber, Jr., Esquire, and files the following Complaint for Custody in support thereof avers as follows: 1. The Plaintiff is Adele R. Davidson, an adult individual residing at 1107 Three Square Hollow Road, Newburg, Cumberland County, Pennsylvania. 2. The Defendant is Scott A. Parson, an adult individual residing at 6 Antler Court, Shippensburg, Franklin County, Pennsylvania. 3. The Plaintiff seeks primary custody and visitation of the following child: Name Present Residence Age Shane A. Parson 1107 Three Square Hollow Road Newburg, P A 17240 (Cumberland County) 8 months (DOB 12/25/99) The child was born out of wedlock. The child is presently in the physical custody of the Plaintiff. The child has resided with Plaintiff at his address listed above since birth. ^"-..,->--,, -- "'.~ ~,'--,- , "-'~~ -,'., , .,,' . ,,'~' ~.- , ,'<'"'_",c;:_",, "'.-T.""_' ,,--,-, The mother of the child is the Plaintiff, who resides at 1107 Three Square Hollow Road, Newburg, P A 17240. She resides with the child and her parents, Robert G. Davidson, Jr. and Darlene Davidson. The father of the children is Defendant, who resides at 6 Antler Court, Shippensburg, Franklin County, Pennsylvania. He resides with his parents, Steven Parson and Kim Parson. 4. The relationship ofPlaintiffto the child is that of mother. 5. The relationship of the Defendant to the child is that off ather. 6. Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the child in this or another court. The Plaintiff has no information of a custody proceeding concerning the custody of the child in this or any other court. The Plaintiff does not know of a person not a party to the proceedings who has physical custody ofthe child or claims to have custody or visitation rights with respect to the child. 7. The best interests and permanent welfare ofthe child will be served best by granting the relief requested because: a) The Plaintiff has exercised physical and legal custody ofthe child since the child's birth; and b) Defendant has intentionally caused serious injury to the child. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. There are no other persons who are known to have or claim a right to custody or visitation of the child. ~ -, ,'_L _, - n_.' ~ 0 , - ~"":: _ d-, _--',: ;,;,,:'--.--'~,___: \-;-,,~~_~,__, "",/-,,'j WHEREFORE, Plaintiff respectfully requests Your Honorable Court grant Plaintiff sole physical and sole legal custody of Shane A. Parson. Respectfully submitted, 71/"2_~~ Richard L. Webber, Jr., Esquire Attorney ill No. 49634 19 Brookwood Avenue, Suite 106 Carlisle, P A 17013-9142 (717) 249-5373 Attorney for Plaintiff .,~~".,.....-~~~ ''''''''''^"-- ~. .~ . ~, - . -'" ~ ";:-: . VERIFICATION I verify that the statements made in this Complaint 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. a1;lQ.Qo ~ 1~)"vWUbrt, Adele R. Davidson ''';'-'0' , "-.~~ - -.' -=-.'~ o-^~- ; _ '~__"'_ .; .-. ~ d,,,,;"::;;:;,; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ADELE R. DAVIDSON, Plaintiff v. CIVIL ACTION - LAW IN CUSTODY NO. 2000- t..S 3 P SCOTT A. PARSON, Defendant AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF CUMBERLAND Terry E. Walker, being duly sworn according to law, deposes and says that she mailed the Complaint in Custody in this matter by certified mail, return receipt requested, addressee only, to the Defendant, Scott A. Parson, of6 Antler Court, Shippensburg, PA 17257 on October 7, 2000. The return receipt signed by the Defendant is evidence of service and is attached hereto as Exhibit "A". ~~.(~ Terry . Walker 19 Brookwood Avenue, Suite 106 Carlisle, P A 17013-9142 (717) 249.5373 Sworn to and subscribed before meilisJ~~d~of~tober 2000. ~~~?zf ~ Notarial Seal Denise L. Nye. Notary Public South Middleton Twp., Cumberland County My Commission c. xpirEls Feb. 26, 2001 Member, Pennsy/vanlaAssociationot Notaries F:\User Folder\Firm Docs\Gendocs2000\1836-1aff.serv.l.wpd . ~. '.'" %~i ,- , - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ADELE R. DAVIDSON, Plaintiff v. CNIL ACTION - LAW IN CUSTODY SCOTT A. PARSON, Defendant NO. 2000- rri "" ni CJ Postage ..D ::r nJ ::r Certified Fee ;.40 /. ;l..s- ;;(. ").s- $ Retum Receipt Fee ru (Endorsement Required) C Restricted Delivery Fee g (Endorsement Required) Total Postage & Fees CJ CJ ;;. N8S8se Print C/e8rlr)40.beJl{leted by mailer) SPS .St.---." Ip CA.if---..___..........f.:;,drJ. g: n.=.fa.t~_N?J;~ox;:, ~~ nn.nn.nn_nn_nn.numnmnn s. Ci'r. ZIP+< .. .I...___.... ...___1C.1;.___..___..___.___...___.___....... r- >" "", ___W"_ ,___" . C0l11pIEll~'it"'l11s,1;.2: 'md.S.Aiso. . mple Item 4.1f'R"lltdcled'1iie!ivery is desired. . . - Print your. ~c:iri1e-;1lrid aadress on the reverse. so that we can rteturn the card to you. ' . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: x ~ o Agent Addressee Dyes o No D" Is delivery address different from item 1? If YES, enter delivery address below: <5artt A . Pa.r.stJn &, An./::kr COWl f Sfuppen5iOMi' IJA 11;J..S1 3. Service Type ~rtified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) ~ ..Lf;) I.f{, (?:;L 73 /f3f.p.j t0259&:g9-M-1-7ag .1....'"'.. ~" .,," -", ,,' . .. . ./ ADELE R. DAVIDSON, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-6538 SCOTT A. PARSON, Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this 7- iL day of f.Jo~ , 2000, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Mother, Adele R. Davidson, shall have sole legal and physical custody of the minor Child, Shane A. Parson, born December 25,1999. 2. This Order is temporary in nature. Father may petition for supervised visitation upon the completion of a psychological evaluation and anger management counseling. BY THE COURT, /};L J. Dist: Scott A. Parson, 6 Antler Court, Shippensburg, PA 17 57 Richard L. Webber, Jr., Esquire, 19 Brookwood Avenue, Suite 106, Carlisle, PA 17013-9142 t~~ I J - ~ -00 RK.3 ~ ...... . .. . . ~-' - ~ . ", ".,. .... FfJ:u,"orFICE OF ~: < ,. ':'~'-]\1)Tf\RY 00 NOV - 8 M1 8: I 0 CUM.."'H. ,.,. ('~' 1\l7'y I ,DC ILh\:u ....{)Lh I PENNSYLVAf\.JIA ,. ...,~,..".., fJf~.:~r~l!!Il"","" _~, ',~ _,_~",~ "~,~~l'll!t,,,,_""'"J.~;I/lOlil!!ll\!'~ _ ~. - ~ " ~~ ""_'0" , . ~ 0 "{_, , ,... NOV 62f1~ ,r ADELE R. DAVIDSON, Plaintiff vs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-6538 SCOTT A. PARSON, 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 Shane A. Parson December 25, 1999 Mother 2. A Custody Conciliation Conference was held on October 30, 2000, with the following individuals in attendance: Father, Scott A. Parson, pro se; Mother, Adele R. Davidson, and her counsel, Richard L. Webber, Jr., Esquire. 3. The parties agreed to the entry of an Order in the form as attached. / /- 3~;loLJ 0 Date Melissa Peel Greevy, Es uire Custody Conciliator