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Home My WebLink About00-08645 " DENNIS WILSON, Petitioner v. RUTH HENSLEY, Respondent , ~ ~ ~ ~ ~ ~ ~ ~ ..' - "'~ "~ '*~,,, .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW CUSTODYNISITATION NO, (nJ - f(" <fr) ~ T:.e.- ORDER OF COURT AND NOW, this ~ day of ~ , 200~, upon consideration of the attached Petition for Special Relief, Petitioner, Dennis Wilson, is hereby temporarily granted sole physical and legal custody of the children, Dennis Z. Wilson and Robert T. Wilson, until further Order of Court _.----~" ,~-, .,/ /' J;W"THE C9, J. / tapJDO -fY).aJJ J ~-J<j.OO "RXS ;t ,. -~ ~~~- ""'- ,~'" <' ,", _ ~ _ " '" ~' 'or'" ,_ ~.-/. ~. ,,< ~ ~ "'<"%-1~~-"- .-.'- ~, T. . ,'--"'>'-1\")' , .)ii~>I~l' ('t..., I' v" ,r-t'\ U Jt,L fA V F'\' i; I:;H ',~ ..J C"/i,!:" ", UJI'I,-<;f'."'" ., "'. i)E~JIV~yiJLi.(! COUNTY V ,ANIA ... ,~IlII~ll!Il'lf~-iOO'i~~~.i~~-f""N'l~~'lf!"-~~~~ ,1!Jl."",o.,.,~~~_"!! ~,~" I~,'P"':-'_ "'w.', DENNIS WILSON, Plaintiff v. RUTH HENSLEY, Defendant ~ ~ ~ ~ ~ ~ ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION -LAW CUSTODYNISITATION NO, ()1) - 1?G. 'f /( ~ -r J->- PETITION FOR SPECIAL RELIEF AND NOW, comes the Plaintiff, Dennis Wilson, by his attorney, Roger R. Laguna, Jr., and represents as follows: 1. Plaintiff, Dennis Wilson, resides at 413 Lebanon Street, Steelton, Dauphin County, Pennsylvania 17113. 2. Defendant. Ruth Hensley. currently lives at an undisclosed location. As of September 30. 2000. she had lived at 708 Hummel Avenue. Lemoyne. Cumberland County. Pennsylvania. 17043. 3. The parties are the natural parents of two (2) minor children which are the subject of this complaint: Dennis Z. Wilson, born January 16th, 1995, and Robert T. Wilson, born November 6th, 1996. 4. Plaintiff avers that Defendant telephoned him on or about September 27th. 2000 to say that she had taken the c/1ildren to an undisclosed location (possibly in Florida) because she learned that Plaintiff intended to pursue custody proceedings. Plaintiff avers that Defendant --_._=~ .~ " , ~' J. _ ~'"'<; stated to him that she intended to "chanl!e the color of [hg] hair" and continue to move from one location to another in order to prevent the children from bein~ located by him or authorities. 5. Plaintiff visited the last known residence of the Defendant and it appears vacant. 6. Plaintiff avers that Defendant had no apparent financial resources or other ability to properly care for the children while she is on the run. so to speak. 7. The children have been removed from schooL 8. The emotional and physical safety and welfare of the children is apparentlv at risk so . long as they are being moved about surreptitiouslv by Defendant. 9. Since birth, the children have resided with the following persons at the following addresses: Name Address Date With both parties 48 E. Main St. 1-16-95 to 4-1-95 Mechanicsburg, P A With Defendant unknown - York County 4-1-95 to 6-1-95 With Defendant Enola, PA 6-1-95 to Est'd 6-1-97 With Defendant Enola, PA 6-1-97 to Est'd 2-1-99 With Defendant Mechanicsburg, P A 2-1-99 to Est'd 10-1-99 With Defendant Lemoyne, PA 10-1-99 to 9-23-2000 Unknown Unknown 9-23-2000 to present '~ " p-', ,1 ~ ,. " - -. , . . ,,- ,---~ - ';.;..;., - .- > '-'; '-,,, :~ 10. The Plaintiff currently lives alone. 1 L Plaintiff has no idea with whom the Defendant may currently reside. 12. The best interest and permanent welfare of the children will be served by granting the relief requested. The quality of the children's physical, intellectual, moral, and spiritual environment would be improved by Plaintiffs proposed custody and supervision. WHEREFORE, Plaintiff requests sole physical and legal custody of the children, temporarily, so that he may attempt to locate the children, ensure their safety and well-being, get them back into their school, etc., and return them to this Court's jurisdiction so that it will be possible to conduct a custody hearing in order to determine the children's best interests. A fully sUbmitt11, Date: \ ~'15 -00 " . ~ \;f --------.- B: ,/\1 Roge~ R. Laguna, i~\, Esquire Supreme Court LD. ~o.: 75900 Attorney for Plaintiff LAGUNA REYES MALONEY, LLP 15 North Front Street, Suite 203 Steelton, PA 17113 (717) 939-4429 .>.l e_'_'. .', do'. ---" - ,,- .~ '~.. -:JI DENNIS WILSON, Plaintiff v. ~ ~ ~ ~ ~ ~ ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW CUSTODYNISITATlON RUTH HENSLEY, Defendant NO. CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I served a certified copy of the Petition for Special Relief filed in the above-captioned matter upon the Defendant, by regular and certified mail, return receipt requested, on December 15, 2000, addressed to: Ruth Hensley 708 Hummel Avenue Lemoyne, P A 17043 December 15,2000 ./ \ \ ltOger R. L'a&\ma, Jr" Esquire "'''' - . ~" " , ,< -<<--, ^ '-'; VERIFICATION I verify that the statements made in the foregoing pleading are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein may subject me to the penalties of 18 Pa.eS. Section 4904 relating to unsworn falsification to authorities. Jth1: () tJ~ Dennis Wilson ?; /'" ~' ". "-..l ~" ,:>.., 0- i':S~ f',"--l "" 4') ''V ,:.... ~' ,"5 .D~ \..)~ ') (~:) .$" " ,iJf :-::::,,14":(1 d 6:: }:'J " (~:' .r;:;) t..') -.< . -~~ ~~ ~ o ~ .',_~ ~_!!I__.,~, ~,_ ~, "".~." JI~~,~'!'~~~~$'l~jWtil;(l;t;;I~~~~..., . _,]I!iI ,_j .~~$I~~1i1'!!:Wl~: IT ,-~~ . -"...."_l_~_~,., , , " DENNIS WILSON' PLAINTIFF V, RUlli HENSLEY DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA 00-8645 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 19th day of December, 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 22nd day oUanuary, 2001 , 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 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 TIIE COURT, By: /s/ Melissa P. Greevy. Esq, tP 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 iit1 - '<' -",' ^-- ~ ' ,~"' N~, ""' 0"", _'"', -, -',"^, ';'" " ';',. "", , .,,' 'C.''',' ~. >--.~~" r.~ , , e[1 " ~ : "! '.\1'''''''',\1-'1'11' ,..:.JJhnI "'0' 0"''' ~'U- u' ,"j / '_,'-I !C., Pt',) :} Ii? . {.,: U~ CUM~~Fr~i :.11',I:-.} (\l':IU"ITV --. '...., 'I ~l.,.; ......1...) 1\ . P8\INSYLVANiA ' /d-cXJ.aJ M. ~'Y/ ~ ~ df ~ /';/-,;)0 110 ~ ~ ;j ~ /;),-.)L)-CJtfJ t?7# ~ W 4~ , . ;'~~ ~. ,.__!'lll~_, ~",~__~ ,~~,~ Wlliilr~~~. _"~ ~" ~,1l!j!~~""""lG'''-iJ'ff!11tw''_':JW''''f1if"W,j;~mI1o~~l~lJill!~*ii''~Ji~,,,,,_" ~ ""';~_1"', H~liJ~ > ' . ~-- ~io;~,' DENNIS WILSON, Plaintiff v. ~ ~ ~ ~ ~ ~ ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW CUSTODYNISITATION RUTH HENSLEY, Defendant NO. ov- h'l!S'~ I.e...-. ORDER OF COURT You, Ruth Hensley, Defendant, have been sued in court to modify custody of the children: Dennis Z. Wilson and Robert T. Wilson. AND NOW, this day of , 200_, 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 ,200_, at .m., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or ifthis 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: Custody Conciliator ,~~ ~ 1"~ ". ,'. L lIOl'I>?b";'",_"j,.",Co The Court of Common Pleas of Cumberland County is required by law to comply with the American with Disabilities Act of 1990. For information about accessible facilities and reasonable accomodations 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. 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, PA 17013 (717) 249-3166 ~-- ,I " . ,~ ----"" - "~ DENNIS WILSON, Plaintiff v. ~ ~ ~ ~ ~ ~ ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION -LAW CUSTODYNISITATION RUTH HENSLEY, Defendant NO. 0-0. rVI~ ~ I.Q.<- COMPLAINT AND NOW, comes the Plaintiff, Dennis Wilson, by his attorney, Roger R. Laguna, Jr., and represents as follows: L Plaintiff, Dennis Wilson, resides at 413 Lebanon Street, Steelton, Dauphin County, Pennsylvania 17113. 2. Defendant, Ruth Hensley, currently lives at an undisclosed location. As of September 30, 2000, she had lived at 708 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania, 17043. 3. The parties are the natural parents of two (2) minor children which are the subject of this complaint: Dennis Z. Wilson, born January 16'h, 1995, and Robert T, Wilson, born November 6th, 1996. 4. Plaintiff avers that Defendant telephoned him on or about September 27th, 2000 to say that she had taken the children to an undisclosed location (possibly in Florida) because she learned that Plaintiff intended to pursue custody proceedings. Plaintiff avers that Defendant stated to him that she intended to "change the color of [her] hair" and continue to move from one location to another in order to prevent the children from being located. 5. Plaintiff visited the last known residence of the Defendant and it appears vacant 6. Plaintiff avers that Defendant has no apparent financial resources or other ability to properly care for the children while she is on the run, so to speak, and that the children have been removed from school, and that their general safety and welfare is apparently at risk so long as they are being moved about surreptitiously by Defendant 7. Since birth, the children have resided with the following persons at the following addresses: Name J\ddress Date With both parties 48 E. Main St 1-16-95 to 4-1-95 Mechanicsburg, P J\ With Defendant unknown - York County 4-1-95 to 6-1-95 With Defendant Enola, pJ\ 6-1-95 to Est'd 6-1-97 With Defendant Enola, pJ\ 6-1-97 to Est'd 2-1-99 With Defendant Mechanicsburg, pJ\ 2-1-99 to Est'd 10-1-99 With Defendant Lemoyne, pJ\ 10-1-99 to 9-23-2000 Unknown Unknown 9-23-2000 to present 8. The Plaintiff currently lives alone. 9, Plaintiff has no idea with whom the Defendant may currently reside. .,1 ,_ ~ ~ =-. , -, - '.-' 1-~..l.,~",,-'_; 10. The best interest and permanent welfare of the children will be served by granting the relief requested. The quality of the children's physical, intellectual, moral, and spiritual environment would be improved by Plaintiffs proposed custody and supervision. WHEREFORE, Plaintiff requests the Court to grant him custody of the children. ,","f.11Y ~"'~ I / II lBY: \,^ l. ~. Lagurl., Jr., EsquIre Supreme Court 1\D. No.: 75900 Attorney for Plaintiff Date: /2. il'rloU I f -----... LAGUNA REYES MALONEY, LLP 15 North Front Street, Suite 203 Stee1ton, PA 17113 (717) 939-4429 . , ,..; '-.!--,-~ - ;" VERIFICA nON I verify that the statements made in the foregoing pleading are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein may subject me to the penalties of 18 Pa.eS. Section 4904 relating to unsworn falsification to authorities, Jfhj'.!) tJ~ Dennis Wilson ~~.,",,"-- , DENNIS WILSON, Plaintiff v. RUTH HENSLEY, Defendant " 1_' ,..;: i~, ~,..:. I " .~ . --ihl.1iL~~"'_<: ~ ~ ~ ~ ~ ~ ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION -LAW CUSTODYNISITATION NO. CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I served a certified copy 9?t~~dY Complaint filed in the above-captioned matter upon the Defendant, by teft~d mail, return receipt requested on /? /170, ) , addressed to: , I ", Dote' /L// ~ Ruth Hensley 708 Hummel Avenue Lemoyne, P A 17043 / n , ! f , I ; . 'aguna, Jr., Esquire rlm~~~(~~~~~~~~'iiOi1f~@!~'OW!4l~~'''""~.R~illlll ." ~~ '- ~ C> <:> ~ ?\ '~ - '-l '" .," "r ',_," ^ ~"," ~1:". , ~- ~ Ii.t o 2~~ 7i':;) 0-;;)-:" ~~j ~(":"~. ,,;.:- c-' 2 :::! ~........-. - 0,_, . "~~~,' J ~ c^"5 ~, \~ ~':J ''I ,,~) (" " 'I . ~') "', '.':' "''_ c~ -,,-; -f.J ~.- ~~~~ ~"-i :1'J "" :" Iv . ~ I I F I '<Ii i I " l~lI -4:; ~ (:;, ~ ~ ,01 ~ d '" c- e Ci d <A <:! f ~ f s; ."J"-"J"~~~_'" JAN 3 0 20~ DENNIS WILSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, NO, 00-8645 RUTH HENSLEY, 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 Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Dennis D, Wilson Robert T, Wilson January 16, 1995 November 6, 1996 Mother Mother 2, A Custody Conciliation Conference was scheduled for January 22, 2001, Shortly before the Conference tirne of 11 :00 a.m, the Conciliator was informed that counsel for Plaintiff had not been able to complete service on the Defendant. Subsequent to the December 18, 2000, Order of Judge Bayley, Plaintiff has not been able to locate the Defendant nor his Children, It is, therefore, the recommendation of the Conciliator that the Order of December 18, 2000, granting the Plaintiff, Dennis Wilson, sole legal and physical custody of the minor Children remain in full force and effect. The matter may be rescheduled for a Custody Conciliation Conference upon proper petition of either party once the Defendant has been located and properly served, /--~b ~61 Date ~~ Melissa Peel Greevy, Esquire Custody Conciliator ^ .~- . , "~.," ~ .,=11' ..' ~~ "I ,~' - - ~ ~~-<- Cli -- ;~;I';::~~~;'~F!CE 'C'.., ,rr:rtr'TiRY ""'. ,,,)f!--\ 01 Fnl _ r n ',. j rl1 3: 0 J CUI .. Ir""n .,,~,)' "'< }Y~"...nLf~;\jf i r,;"", . I"ENNSYLi;AN~uNTY ",' W!l;~%~W'~~)1"1{'l-~!i1:@:~~ ~~ 1\'1!_!~_""",",___ y.-'._~ ~_ _,"'('