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HomeMy WebLinkAbout03-1924RAMESH K. SHARMA, Plaintiff V. NAYNA R. SHARMA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW IN CUSTODY PLAINTIFF'S COMPLAINT TO CONFIRM CUSTODY 1. Plaintiff is Ramesh K. Sharma, an adult individual currently residing at Ten East Louther Street, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Nayna R. Sharma, an adult individual currently residing at 297 Central Avenue, Apartment 3, Jersey City, New Jersey 07307. 3. Plaintiff seeks custody of the children, Ann R. Sharma, who was born March 11, 1997, and Karn R. Sharma, bom December 22, 1999. The children were not born out of wedlock. Since they were bom, the children have resided with the following persons at the following addresses for the following periods of time: The children resided with the parties at Ten East Louther Street, Carlisle, PA 17013. The children still reside at the above address with the Plaintiff. 4. The relationship of the Plaintiff to the child is that of father. He is married and living separately. The Plaintiff currently resides with the following: Name Relationship Ann R. Sharma Daughter Karo R. Sharma Son 5. The relationship of the Defendant to the child is that of mother. She is married and living separately. The Defendant currently resides with the following: Name Relationship Unknown Friend 6. The parties have not participated in previous litigation concerning the custody of the children in this court or any court. 7. The Plaintiff has no information of a custody proceeding concerning the children pending in any other court. 8. The best interest and permanent welfare of the child will be served by granting custody to Plaintiff because: He can provide a stable and nurturing environment for his children. 9. Plaintiff does not know of any person not a party to these proceedings who claims to have custody or visitation rights with respect to the children. WHEREFORE, Plaintiffrequests your Honorable Court to set a time and place for a hearing at which Plaintiff requests the Court to grant him the Custody Order. Pending said hearing, Plaintiff requests temporary custody. MARTSON DEARDORFF WILLIAMS & OTTO Thomas J. W~liams, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs Date: VERIFICATION The foregoing Complaint to Confirm Custody is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the Complaint and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. RAMESH K. SHARMA : PLAINTIFF : V. : NAYNA R. SHARMA DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-1924 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, April 30, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, C.mberland County Courthouse, Carlisle on Thursday, May 29, 2003 at 10:00 AM 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. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /si Hubert X. Gilroy, Esq. 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 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3,166 ~,N~A'IASNN~ct F:kFILES\DATAF1LE\General~Documents\ 10818-2.aos Created: 4/22/03 1:13:01 PM Revised: 4/24/03 2:18:59 PM RAMESH K. SHARMA, : Plaintiff : : V. : : NAYNA R. SHARMA, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1924 CIVIL ACTION -LAW IN CUSTODY ACCEPTANCE OF SERVICE I, Nayna R. Sharma, the named Defendant in a Custody Complaint filed in the Cumberland County Court of Common Pleas, and that as such, I have authority to accept service of said Complaint and state that I accepted service of said Custody Complaint on April ¢c/ , 2003. Nayna R. Sharma ,]UN 1 0 003 RAMESH K. SHARMA, Plaintiff V NAYNA R. SHARMA, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 03 - 1924 CIVIL : IN CUSTODY CO~TO~ER AND NOW, this /~ ~ day of June, 2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: The Father, Ramesh K. Sharma, and the Mother, Nayna R. Sharma, shall enjoy shared legal custody of Ann R. Sharma, born March 11, 1997; and Karn R. Sharma, born December 22, 1999. 2. The Father shall enjoy primary physical custody of the minor children. The Mother shall enjoy periods of liberal temporary custody of the minor children at such times as agreed upon by the parties. In the event that Mother is ever dissatisfied with the amount of temporary custody provided to her by Father, Mother may petition the court to have the case again scheduled for a conference with the conciliator. CC: Thomas J. Williams, Esquire BY THE COURT, Nayna R. Sharma 297 Central Avenue, Apt. Jersey City, NJ 07307 RAMESH K. SHARMA, Plaintiff V NAYNA R. SHARMA, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 03 - 1924 CIVIL : IN CUSTODY Prior Judge: CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8Co), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the children who are the subject of this litigation is as follows: Ann R. Sharma, born March 11, 1997; and Karn R. Sharma, born December 22, 1999. A Conciliation Conference was held on May 29, 2003, with the following individuals in attendance: The Father, Ramesh K. Sharma, with his counsel, Thomas J. Williams, Esquire; and the Mother, Nayna R. Sharma, who appeared without counsel. The parties agree to the entry of an order in the form as attached. Hubert X. G'~y, Esqmre Custody Conciliator