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HomeMy WebLinkAbout01-0589 FX . ~ <~~~~~.. ._~~ " '"l:~~', , , ,.. , JAN 30 ?{P Colin Jeffrey LeVert , Plaintiff iN THE COURT OR COMMON PLEAS CUMBERLAND COUNTY , PENNSYLVANIA v. CIVIL ACTION - CUSTODY Ot-SP'7 C~L{ I~ S 2000 Christine A. Hodge , Defendant NO. 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 the Custody Conference Officer, on the day of , 200_, at at a.m./p.m. at Harrisburg, Pennsylvania, at 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 need only be present upon request of the Custody Conference Officer. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent Order. 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 Lawyer Referral Service 213 North Front Street Harrisburg, PA 17101 (717) 232-7536 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumb~rlandCounty is required by law to comply with the Americans with Disabilities Act of 199d. 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. FOR THE COURT: Date Custody Conference Officer "'-@l"g:: ., --~ .1 - ~ . - l>~' . . , Colin Jeffrey LeVert Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. S 2001-- S-fq ~ T~ CIVIL ACTION - LAW CUSTODY ACTION Christine A. Hodge Defendant CUSTODY COMPLAINT 1. The plaintiff is Colin Jeffrey LeVert , residing 611 Reily Street Harrispurg PA 17105 ,Dauphin County, PA (717) 257-4445 (717) 257-4440 (home phone) (work phone) 2 . The defendant is Christine A. Hodge 148 North West Street Carlisle PA 17013 , residing at 'Cumberland County, PA His phone number at home is N/A and at work is N/A 3. Plaintiff seeks custody of the following child/ren: Name Present Residence Date of Birth Lamar Parrish Hodge 148 North West Street Carlisle PA 17013 09/06/84 4. The child/ren were born in/bUtt of wedlock; The child/ren are presently in the custody of Richard Hodge , who resides at 1356 Grand View Court Carlisle PA 17013 , PA. ",~~r-'~ ~ _~o~ "-'_~ ~ - ,-=-- .~ ....,~. '"~_.c.~.l. ,. ,.... "~-~ """"., 5. During the past five years, the child/ren have resided with the following persons and at the following addresses: Persons Helena Davis (Deceased) Addresses 154 West North St. Dates 10/84 - 5/00 151 North St. The mother of the child/ren is Janine Yvette Hodge currently residing at Atlanta GA , , PA. She is E\'itJil.<tIft.,e/married. 6. The relationship of plaintiff to the child/ren is that of Mother/f~~~r' The Plaintiff currently resides with the following persons: N/A Name Relationship ~{J L!;! / - ;;J-1-0j , j. F" cD ~"clf'E IL~' 'Vrr v 0- c', '- ..t'~-, '~NIOT,MY 't? ""\_ c, L !(;";J ,I, l ,-,,1-, ."_"_"!\"" 01 ,Wi 29 PH /: OS CUtv/8b'iLAND CCUNJ)' PENNSYLVANIA ~"j-,,~-" ~" ~ ~ .....- . "--""~I ",0 . . .,- I 7. The relationship of defendant to the child/ren is Grand . that of Father/Mdu~bV. The defendant currently resides with the following persons: Name Relationship N/A Male Companion 8 . Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child/ren in this or another court. Plaintiff has no information of a custody proceeding concerning the child/ren pending in a court of this Commonwealth or any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child/ren or claims to have custody or visitation rights with respect to the chil d/ ren . If any of the above are not true, cross it out and explain: Tne Defendant is the Grandmother Great Grandmother who had physical custody passed away in May 2000 current custody of child is unknown 9. The best interest and permanent'welfare of the child/ren will be served by granting the relief requested because Paternal Father is presently the only Parent residing in State (PA) Its to the child best welfare he reside wi his The child needs Supervision p~rATn~l F~rhp.r (Parent) .,-""~-~-' - ~ , ~> , - ~ "~.,~ I I 10. Each parent whose parental rights to the child/ren have not been terminated and that person who has physical custody of the child/ren have been named as parties to this action. WHEREFORE, pursuant to the Custody Act, 23 Pa. C.S. Section 5301, et seq., Plaintiff requests the court to grant me ~s~odY/visitation of the child/ren. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made cubjce' to 'hc p","'cc ef ,. Pc. c.,. "'0' r~~ 'e unsworn falsification to authorijfjs. J ~J' ~yf ~ January 24, 2001 ~Jef y LeVert Date Plaintiff, Pro Se (717) 257-4445 257-4440 Phone Number , , . r ~ FIt FD--QFFICE Ot' 1',"=I,h'0NOTAHY 01 JMI29 Pi'! I: OS ~'''H'" ""("U'ITY vUf\/!t)!:dU\('{) C0 t' PEN~jSYlVANlA '=rJ:. ~. I I I I ~ ~ ~ ~ , c.y ~ ~ " .~ ~ '~ I ,;11 !j -~! (~, ~ ,~ ill I ~ ~. ~~, '=0-""""""'" ~ . " .. ,,~~ -, ,- . 0" i Colin Jeffrey LeVert IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. S 2001 ~ >SP7 - ~{ Christine A. Hodge CIVIL ACTION - LAW )~ Defendant CUSTODY ACTION ORDER GRANTING LEAVE TO PROCEED IN FORMA PAUPERIS AND NOW, this 24 day of January ,2001 ,upon presentation and consideration of the within petition and attached Certification, we grant the relief prayed for, and grant Petitioner leave to proceed with this case in forma pauperis, without the need to pay any costs connected therewith, all of which is pursuant to Pa.R.C.P. No. 240. BY THE COURTI ,J. ,M"W~... "" .. .~ , ,....l ,~." '~ ~~,~ ~''''.'; . . , Colin Jeffrey LeVert IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY: PENNSYLVANIA v. NO. S 200 Christine A. Hodge CIVIL ACTION - LAW Defendant CUSTODY ACTION PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS TO THE HONORABLE JUDGES OF SAID COURT: Pursuant to Pa. R.C.P. No. 240, I hereby certify that I am without financial resources to pay the costs associated with my custody case, and therefore believe that I am entitled to proceed in forma pauperis. In support of my petition, I have attached to it a certification of indigency and incorporate it herein by reference, a certification which fully and truthfully describes my overall financial condition at the present time. WHEREFORE, the undersigned asks leave of court to proceed in forma pauperis, without the need to pay any costs in connection with the instant custody/visitation action. January 24, 2001 R/feCtf,llY sUbmitte7 -'-- ~J.Lv~ Colin Jeffrey LeVert Date Petitioner, Pro Se ~~ ~ " ~~. ;~~W --'- -~-l.f? . . \ Colin Jeffrey LeVert Plaintiff IN THE COURT OF COMMON PLEAS cuMBERLAND COUlifTY, PENNSYLVANIA v. NO. 9 200 CIVIL ACTION - LAW CUSTODY ACTION Christine A. Hodge Defendant CERTIFICATE OF INDIGENCY 1. I am the (Pf~A~*tt) (defendant) in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting or defending the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct: (a) Name: Colin Jeffrey LeVert Address: 611 Reily Street (Bethesda Mission) Harrisburg PA 17105 Social Security Number: 378-66-5034 (b) Employment If you are presently employed, state Employer: N/A Address: Salary or wages per month: N/A 2i.o-.J"" , "'""'" . . \ ~~ ., 'j" ~'''''~'''''ot;, 'Type of work: Accountant If you are presently unemployed, state Date of last employment 4/00 Salary or wages per month: N/A (c) Other income within the past twelve months Business or profession: N/A Other self-employment: N/A Interests: N/A Dividends: N/A Pensions and annuities: N/A Social Security benefits: N/A Support payments: N/A Disability payments: N/A Unemployment compensation and supplemental benefits: PBC 78 WBR 193A Workman's compensation: N/A Public Assistance: N/A Food Stamps per month (average) Other: $130 per month March 2001 (d) Other contributions to your household support (Wife) (Husband) Name: N/A If your (wife) (husband) is employed, state Employer: N/A Salary or wages per month: N/A ~-m .. " ,- ,- ~ ,- ," .- ~~< " . Type of work: N/A Contributions from children: N/A Contributions from parents: N/A Other contributions: N/A (e) Property owned Cash: $0.00 Checking account: Savings account: 378665034 PSECU Certificates of deposit: N/A Real estate (including home) : N/A Motor vehicle: Make N/p.,. Year Cost $ Amount Owed $ N/A Stocks; bonds: Other: (f) Debts and obligations - average per month Mortgage: N/A Rent: N/A Loans: N/A Clothing: N/A Electricity: N/A Gas: N/A Telephone: N/A Transportation: $24.00 PAT PASSES Food: N/A Non-food household goods: N/A ll',","'b"..._,.~" - ~ " .' ~~~1\z' '>" Other: N/A (g) Persons dependent upon you for support (Wife) (Husband) Name: Children, if any: Name: Lamar Parrish Hodge Age: 16 Other persons: Name: N/A Relationship: 4. I understand that I have a continuing obligation to inform the 90urt of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are being made subject to the penalties. of 18 pa.. C.S~4904, relating to unsworn falsification;1O ::I::Jrit~~v~ ~ January 24, 2001 ~ff LeVert Date Petitioner '''''~~..~.~. ~.~ ,J .' ~.,- -~' - ~- .~"""'"~ t. COLIN JEFFREY LEVERT PLAINTIFF V. CHRISTINE A. HODGE DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-589 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 14TH day of February, 2001, upon consideration of the attaehed Complaint, it is hereby direeted that the parties and their respective eounsel appear before Hubert X. Gilroy, Esq. , the eoneiliat at 4th Floor, Cumberland County Courthouse, Carlisle on the 15th day of Marcb , 2001, at 10:30 a.m. for a Pre-Hearing Custody Conferenee. At sueh eonferenee, an effort will be made to resolve the issues in dispute; or if this eannot be aeeomplished, to define and narrow the issues to be heard by the eourt, and to enter into a temporary order. All ehildren age five or older may also be present at the eonferenee. Failure to appear at the eonferenee may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: /s/ ubert X. Gilro Es Custody Coneiliato The Court of Common Pleas of Cumberland County is required by law to eomply with the Americans with Disabilites Aet of 1990. For information about aceessib1e facilities and reasonable aeeommodations available to disabled individuals having business before the eourt, please eontaet our offiee. All arrangements must be made at least 72 hours prior to any hearing or business before the eourt. You must attend the seheduled eonferenee 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 TIlE OFFICE SET FORTIl 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 .. ~ " ~ "r". d /;;7./ /tJ/ d/::<.t!or r""~ "9'""'=~ , .'<' ., ~ "". J~ e ~," '>"" cn' ') 'I U j I ~_.,._l t_ ,>, i'j: 11 : \; l'~ , . n, "c. ......i".,..1 Il'\-IV vUr'f;L';C;'"\i...J"'i'lt.J \..,1V'_' 'l I PENNSYLV/\Nlf\ tJ- t~ ~ ;{; 1/, v-f ~~~ -/1-.>1/4#. -8' . .,~~,>-'ll'!l!'I~il'~*-i1<!"J~~""'~"<F~~"!"'f~"'W!"'m",~'C!~'ii':!l!~-"~r~,~~~f>-1i'~~~"<~~'r"'~' "f~;,"j .. . .~ ~,- )f' COLIN JEFFREY LEVERT Plaintiff "'--~'".-" . , ~-~ ",- '."'--~ ",-- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW CHRISTINE A. HODGE, Defendant NO. 01-589 CIVIL TERM ORDER OF COURT AND NOW, this 1st day of February, 2001, upon consideration ofP1aintiff's request to proceed in forma pauperis, Plaintiff is granted leave to file the custody complaint in the above matter without payment of the usual filing fee. BY THE COURT, Colin J. LeVert 611 Reily Street Harrisburg, PA 17105 Plaintiff, Pro Se ,W"l<y 01~, ". I!r. ~ {\ ~~,O\ G O'):'~ Christine A. Hodge 148 North West Street Carlisle, PA 17013 Defendant, Pro Se ;rc () C' _~.Z' f/~n'; ~,.jJ;f %F/ !21~}"~ ::;: '~- ~~(S! C ~? ~ :\,j (:J ..., ,''''"1 "" , 01 {; :'?:. r.- L:-) (") ~r-f :.:~.j i : ': .~.I] ,~~;;'?] -;~) .:-";.":) gF:? "" ';:". :0 -<; , - Co'_ .-'-, -.', ." .':'" - ,-",:< -,~--.--,;,,--, -'i'._'.,,; ~ MAY 0 8200;0 COLIN 1. LEVERT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v CHRISTINE A. HODGE, Defendant NO. 2001 - 589 CIVIL IN CUSTODY COURT ORDER AND NOW, this " day of May, 2001, upon eonsideration of the attached Custody Coneiliation Report, it is ordered and direeted as follows: 1. The minor child, Lamar Parrish Hodge, born September 6, 1984, shall remain in the physical custody of Richard Hodge pending circumstances as set forth below. 2. Upon the Father, Colin 1. Levert, obtaining a primary residence in Carlisle, physical eustody of the minor child, Lamar Parrish Hodge, shall be transferred to the Father, Colin 1. Levert. 3. The Mother, Janine Hodge, the maternal uncle, Richard Hodge and the maternal grandmother, Christine Hodge, shall eontinue to enjoy periods of temporary custody of the minor child as the parties agree. 4. In the event circumstances change and any party desires to modifY this order, that party may contact the Conciliator directly, at whieh time the Conciliator will proceed with scheduling another Custody Conciliation Confu . this case. / ec: Julie Miller Dickinson School of Law Family Law Clinic 1. Colin 1. Levert 1918 Green Street, Apt. 3 Harrisburg, P A 1711 0 Janine Hodge 3331 Sims Street Hapeville, GA 30354-1469 ~ < ~ s./f-l:>, '-1v'-- . Richard Hodge 1356 Grandview Court Carlisle, PA 17013 OF i';~D)~~::'I:j:T~lARY ~'\ . DI11!1Y II Ml iO: S2 CUI 'l,'<"'L'" "-, {V'L'f,rnl ~1cch hi\;LJ vV 'lJi J PENNSYL'~~NIA I I I I ! , '" ~~ J . ...-.', 0,. __ '" "L,n, ,__ -_'-~_-- ~,',~__",";,." ',-'J>'?" "'_-'~", "~=,,,,,~'~'_H-.,,_""-_~_. ", ";----'<-"'~1 ~ COLIN 1. LEVERT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW CHRISTINE A. HODGE, Defendant NO. 2001 - 589 CIVIL IN CUSTODY Prior Judge: CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Lamar Parrish Hodge, born September 6, 1984. 2. A Conciliation Conference was held on May 4, 2001, with the following individuals in attendance: The Father, Colin J. Levert, who appeared without counsel; and the maternal grandmother, Christine A. Hodge, who appeared with Julie Miller of the Dickinson School of Law Family Law Clinic. The natural Mother, Janine Hodge, lives in Georgia and has minimal contact with the child. The child is currently living with Richard Hodge who is the maternal uncle. 3. The parties all agree that the child at this point wants to live with his Father once his Father relocates from Harrisburg to Carlisle. 4. The Conciliator recommends the entry of an order in the form as attached to accomplish that desire. 5111 O( DATE Hubert X. Gilroy squire Custody Concihator J..:$ I . -. . ~" "I ,- "' "- ~"' _'-;.' i ,<,"'1'-;;',,',D"'-'_',-._i';',"_-,",-. "-':k , MAR 3 0 200,1>J COLIN J. LEVERT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW CHRISTINE A. HODGE, Defendant NO. 2001 - 589 CIVIL IN CUSTODY COURT ORDER r'1 AND NOW, this J'l day of March, 2001, the Coneiliator has determined that another Conciliation Conference is required and that additional parties need to be notified of this Conference. Accordingly, a second Coneiliation Conferenee is scheduled on Friday, May 4, 2001 at 9:30 a.m. in connection with the case of Lamar Parrish Hodge, born September 6, 1984. The following parties are invited to attend: Mr. Colin J. LeVert 611 Reily Street Harrisburg, PA 17105 Christine A. Hodge 148 North West Street Carlisle, P A 17013 Richard Hodge 1356 Grandview Court Carlisle, P A 17013 Janine Hodge 3331 Sims Street Hapeville, GA 30354-1469 BY TIIE COURT, ~ cc: lI5tephen Boell Dickinson School of Law Family Law Clinic Hubert X. Gilroy, Esquire . \. ~ Custody Conciliator ~ ~()4-Dq-O\ ~'#