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HomeMy WebLinkAbout00-07528 ""I >< 'I .",;j j -'~,- ~"'~ " '1r " RONALD L. ALLANDER PLAINTIFF V, BRENDA K. ALLANDER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA 00-7528 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 27TH day of OCTOBER, 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 28TIllayof NOVEMBER, 2000, at ~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 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. Greevy. Esq.ftJ 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 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 l~ i&l li~J;jj~lil~.;i!iji&:iih<!!ih~"'@'-_il'..!l<l~~~"'k"'.!<ll1.hMm~_WJW;""",;;o.,";".'''lrh1i','1ifW-,,:,~~rillll\i~""~"'~~-- '"""-'ifrniil...ulilll!lillll!lt.j ~?~~~ ~jfr~~~ ~~~~~-n ViN\f^lASNN3d ,lJ.NnOO (IN'{I\:E181f1n8 9S:S ~<\d OOJO 00 "",':-'[ ;,;";:..:,,1 "~';,':,l ~O I LM' U"'U, CJ.'",,"-"" ^rJ'J..t.. j ~ .;..... (""\-t,), :Jfj!J-i\,,}'- ...!:'" ,:... -iV' " ~ ~_e_ ",'M~ . -'lMlIti! -~ (/'0 - ap 171 c/c?- c;?f-' i? / a:;;- r:r 11/ a.lM.i ~~=~ ff RONALD L. ALLANDER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. IN CUSTODY/VISITATION BRENDA K ALLANDER, Defendant NO. CO - 75;J-ti ~ ORDER OF COURT AND NOW, this day of , 2000, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel 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 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 hOl1rs prior to any hearing or business before the court. You must attend the scheduled conference or hearing. .- ~ ," ^.' ,'~ _",I, -':<~ I, '. , ":"~--""~ ""' ..1",,>>,., - - ,,-,.=~,--t-<,:,k,- .,,", ': ~;,-';'~:A.'/""';d>~"';:\ ,i ""'i I I i YOU SHOULD TAKE THIS PAPER TO YOUR LA WYERAT ONCE. IF YOU DO NOT HA VB 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, PA 17013 (717) 249-3166 """,,,_,, .,1,;,"" ~,,' "c' _ - "~',',,J..^ ,J,~",j.,~ '~'wl:- 'j ,.,,,,'__ ""':'11 ,,', .'J.:',; ,:,,'TI,'~J',-:::-,:, -~', > -,,',',. '''"~",.,,, :,-""",,:," '.~ . . <<':)-"'+'1 RONALD L. ALLANDER, PlaintitT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLV ANIA CIVIL ACTION - LAW v. IN CUSTODY/VISITATION BRENDA K. ALLANDER, Defendant NO. fm- 76 ;1,~ ~ J.u-.- COMPLAINT FOR CUSTODY 1. The Plaintiff is Ronald L. Allander, an adult individual who resides at 143 Lee Ann Court, Enola, Cumberland County, Pennsylvania 17025. 2, The Defendant is Brenda K Allander, an adult individual who resides at 12 Windsor Way, Camp Hill, Cumberland County, Pennsylvania 17011. 3, The Plaintiff seeks shared legal custody and partial physical custody of the following children: Name Present Residence Date of Birth Taryn L. Allander 12 Windsor Way Camp Hill, Pennsylvania August 30, 1993 Trevor L. Allander 12 Windsor Way Camp Hill, Pennsylvania August 25, 1994 Kiersten L. Allander 12 Windsor Way Camp Hill, Pennsylvania July 21, 1997 The children were not born out of wedlock ".~ ;", I." -"...." ",',~ , ~-- ;, " --~, ",;~; i., \,,,:--I",~, ,~ '~- ,. ". """'';'~~''..,';;i ,:,~,:2>k.:~~":;>, ' ". ' ,,,', The children are presently in the custody of Brenda K Allander who resides at 12 Windsor Way, Camp Hill, Cumberland County, Pennsylvania 17011, 4. During the past five years, the children have resided with the following persons and at the following addresses: A. Defendant Brenda K Allander 12 Windsor Way Camp Hill, Pennsylvania September 26, 2000 - Present B, Plaintiff Ronald L. Allander and Defendant Brenda K. Allander 12 Windsor Way Camp Hill, Pennsylvania Birth - September 26, 2000 5, The mother of the children is Brenda K Allander, currently residing at 12 Windsor Way, Camp Hill, Cumberland County, Pennsylvania 17011. She is married to Plaintiff, however, a divorce action is presenting pending at docket number 2000-6845 Civil Term. 6. The father of the children is Ronald L. Allander, currently residing at 143 Lee Ann Court, Enola, Cumberland County, Pennsylvania 17025, He is married to Defendant, however, a divorce action is presently pending at docket number 2000-6845 Civil Term, 7, The relationship of Plaintiff to the children is that ofFather. The Plaintiff currently resides with no one. 8, The relationship of Defendant to the children is that of Mother, The Defendant currently resides with the children, Taryn L. Allander, Trevor L. Allander, and Kiersten L. Allander. "f ~ 'C,,," "10",""", '..',", "~". .;1 "L-", '."''-'-,0"'',,,''', """',-,\,k,C>'c,:' ,,~,~;:i;~,'t 9, Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in tbis or another court, Plaintiff has no information of a custody proceeding concerning the cbildren pending in a court of tbis Commonwealth, Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the cbildren, 10. The best interest and permanent welfare of the cbildren will be served by granting the relief requested because: A. The emotional, physical and/or spiritual development of the cbildren would be enhanced by granting periods of partial physical custody of the cbildren to the Plaintiff. B, The Defendant continuously makes custody arrangements with the Plaintiff, only to withdraw the agreement at the last minute. On one occasion, after agreeing to a specific schedule of custody with Father, Mother followed Father and the children to bis place of residence, waited for Father to park the car, then went to the car and removed the children from Father's car in order to probibit Father from visiting with bis cbildren, On another occasion, Mother would not allow Father to visit with the children, since he was unable to pick up the children at noon, the time she designated, , , , " ,,~~; " '~", , ''" , '~<'- , ',-,k ~'- " ,,', ""'0'" ,'""t.,. Ii >-'""'.,.,,.., "" J, """,:,",----',"',.:',--:'",., . ". '.'<"',,"",' _ 'C', ,,,:--,,';-,lC--,'=~'--i.~~k..~~,,,,,,;=,,d,"""'" <-'i,j/ C. The Defendant unilaterally decided to place the children with a babysitter during the periods which she works. The Defendant will not provide the Plaintiff with any information regarding who is watching the children, D. And other reasons which may fully appear at conference. 11. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children 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 shared legal custody and periods of partial physical custody ofthe children to the Plaintiff, Ronald L. Allander. Respectfully submitted, DALEY LAW OFFICES ara A Boyanowski, E Attorney No. 68736 1029 Scenery Drive Harrisburg, P A 171 09 (717) 657-4795 Attorney for Plaintiff ;;;;,""., r_~ ,~," " , 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. ~4904 relating to unsworn falsification to authorities. Date: 10 -i7-o0 By:1:?~/ ~ Ronald L. Allander, Plaintiff ,., , ,. I "I .~ J1li NQV 2 2 200~ RONALD L. ALLANDER, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA v. No. 00-7528 Civil Action - Law BRENDA K. ALLANDER, Defendant. In Custody ORDER OF COURT AND NOW, this 17TH day of November, 2000, the Conciliator, being advised by Plaintiff s counsel that the parties are attempting reconciliation, hereby relinquishes jurisdiction in this case. ~,.-~,-> Melissa Peel Greevy, Esquire Custody Conciliator '"