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Home My WebLink About01-0598 FX =~. '"'" ':! WILLIAM S. THOMPSON, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0/-.59f ~ -r~ STEPHANIE L. THOMPSON, Defendant CIVIL ACTION-LAW IN CUSTODY COMPLAINT IN CUSTODY AND NOW comes WILLIAM S. THOMPSON, by and through his attorney, Judith A. Calkin, Esquire, and avers as follows: 1. The Plaintiff is WILLIAM S. THOMPSON, an adult individual who resides at 621 Harding Street, New Cumberland Cumberland County, Pennsylvania. 2. The Defendant is STEPHANIE L. THOMPSON, an adult individual, who resides at is 1502 Bridge Street, Apt. B., New Cumberland, Cumberland County, Pennsylvania. 3. Plaintiff seeks primary physical custody of the following minor child: IVY E. THOMPSON, born June 24, 1987 4. The child was not born out of wedlock. The child currently is in the shared physical custody of Plaintiff and Defendant. 5. During the last five years the child has resided at the following addresses with the following persons: With the mother at 1502 Bridge Street, Apt. B., New Cumberland, Cumberland County, Pennsylvania and with her father and stepmother at 621 Harding Street, New Cumberland, Cumberland County, Pennsylvania. She spends one week with each of her parents. 6. The mother of the child is Defendant. ~ . ~, ,~~ =,,' 7. The father of the child is Plaintiff. 8. The mother currently resides with the child. The father currently resides with the child and his 9. Wife. 10. 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 any other court. 11. The Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Connnonwealth. 12. The Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child, or claims to have custody or visitation rights with respect to the child. 13. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. There are no other persons known to have or claim a right to custody or visitation of the child and therefore, no further notice of the pendency of this action and the right to intervene shall be given, other than to the parties named herein. 14 . The best interest and permanent welfare of the child will be served by granting Plaintiff primary physical custody of the minor child with a schedule of partial custody for the purpose of visitation with Defendant because he is able to provide a safe, stable and loving environment for the child. ","', -""" ,..,,1 i I I I .1 I I ,I 1 1 I I - ..--'- n "';"1 WHEREFORE, Plaintiff requests the Court to grant him primary physical custody of the minor child. Respectfully submitted: ,~ dith A. Calkln, Esquire ttorney for Plaintiff 2201 North Second Street Harrisburg, PA 17110 (717) 238-2312 - ," '" "~-, ,-''-_'''~-, ""-.',.i<". ,., ,~ AFFIDAVIT I verify that the statements made in this Custody Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.Section 4904, relating to unsworn falsification to authorities. Date: i!~.1h~~ Sworn and Subscribed t/J. to me this .110 day of &04.V~, 200 ( . tUA/tA/ VCA14Aj)d~ Notary Public NOTARIAL SEAL ELLEN ROSENBLOOM, Notary Public City of Harrisbur ,Dauphin County !v Comm' sian -' 8~2QQ3 " ". , -, '~' ,,- - . ,"., "',- "'^.,..- ~,' , . CERTIFICATE OF SERVICE I, Judith A. Calkin, Esquire, do hereby certify that a true and correct copy of the Custody Complaint has been sent by UIlited States Mail, postage pre-paid, certified-restricted delivery to the following person: Stephanie L. Thompson 1502 Bridge Street Apt. B New Cumberland, PA 17070 Date: m FlLfD--o~nCE O~ ./' I" "'.."'"., '.",w'-ARv ['" ,i"it: I ':--;'_r; (:!"),"I,,,):t'\1 I 01 J,IN"O AM 8::1" vt"\n.J II.,..... CUMBl::F:ut,D COUNTY PENNSYLVANIA I I ~ t 'I . i I . C;;..J. il,~-J ~. ~ ," \. i. . ' "'L,i!< r WILLIAM S. THOMPSON PLAINTIFF V. STEPHANIE L. THOMPSON DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 01-598 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 6th day of February, 2001, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliat at 39 West Maiu Street, Mechanicsburg, PA 17055 on the 21st day of February ,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 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: /s/ Dawn S. Sunda E 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~'" ~"=';""'.IIl*iIfIl;lOt!Id:"!m.i>i."",!"'llii1M~~u~1fj)l1~~W:i<~,,,0!!<ti>d~)lHjJ"M~,~;Ii"i;;;i\,",u';ll!ili!llillr.":-'..,-""......."~ . ~=-~...~ "~ '-liIiI . .. ! . ~~~ rU/~c7 ,k' z ~ ~.?L; ~r1?~~~'n \fINV!ilASNN3d I I Nn~r) ('1." /-,' '~"'Aln" N. ll.).. < I, (\l~ :r-:i:itly ~ [\) 9S :f:i 1!\1 8- 81:J 10 """'~",'~ ,~<,"> '"'.._ ^ ,^ ~,__ "e,.,~~ ,~ ""I, > --, .'=, o. "',, ~_~llMft:tvTr' ~' , (C)'P 1:' I C).3. c> J CJ. 1> ' e - ~ -"" , ,:,,' -','.'y',' ," " , ~" "'''"j^I~;'' \ . WILLIAM S. THOMPSON, : IN THE COURT OF COMMON PLEAS OF plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. . NO. 01-598 CIVIL TERM . : . CIVIL ACTION - LAW . STEPHANIE L. THOMPSON, . . Defendant : CUSTODY aIDER OF COURT .) AND [Dq, this ;'d day of consideration of the attached CUstody and directed as follows: , 2001, upon Conciliation Report, it is ordered IV\~ 1. The parties shall submit themselves, their minor Child, and any other individuals deemed necessary by the evaluator, to a custody evaluation to be performed by Deborah L. Salem or other professional selected by agreement of the parties. The purpose of the evaluation shall be to obtain independent professional recommendations ccnceming ongoing custody arrangements which will best serve the interests of the Child. The parties shall sign any authorizations deemed necessary by the evaluator in order to obtain additional information pertaining to the parties or the Child. The Father shall pay 70% and the Mother shall pay 30% of all costs of the evaluation. 2. Pending completion of the custody evaluation and further Order of Court or agreement of the parties, the Father, William S. Thompson, and the Mother, stephanie L. Thompson, shall have shared legal and physical custody of Ivy E. Thompson, bom June 24, 1987. The parties agree to adjust the altemating weekly schedule so that the weekly exchange takes place on Fridays after school rather than on Mondays. To accomplish this change, the Mother shall transfer custody to the Father on Saturday, March 17, 2001, at 5:00 p.m. with the exchanges of custody thereafter to occur on Fridays. 3. Within three months after receipt of the evaluator's written custody recommendation, in the event the parties are not able to reach an agreement at that time as to ongoing custody arrangements, counsel for either party may ccntact the Conciliator to schedule an additional CUstody Conciliation Conference. 4. This Order is entered pursuant to an agreement of the parties at a <- "~' L.:.. ' , " ~',"~~ ~ ,,~ [';,OC_':, ",' <J ___"o,,",J"'1 Custody conciliaiton Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE cc: Judith A. Calkin, Esquire - Counsel for Father John J. Connelly, Jr., Esquire - Counsel for Mother J. (\ _09 D\ \..-.6\" O?f ~ ~ b . j ~ "~~"1"1,~1!i,, "" !"ll!l .. ~ , p ~" "T ~"'~,_".e ~:I r-,;',7 ',jl i','::;' :(}Tt~\RY C i"~l~:n?6 I-\[1 B: :i5 ~""llt.";:~=H' '; r'.",'l-') {')r~'1 If'!TY V...d\i;UL j,".r,,'I'- '.....Jv... PENi~SYLV/\NIA ,- -~ ",' ~'riI",.~,-,,"c,~,!%f\'Pj;ll1~F.~"fII'>$'lt!~~,.,~I!'!i'~~ .iJ.P"-L-.~ " . "',' WILLIAM S. THOMPSON, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. . NO. 01-598 CIVIL TERM . . . : CIVIL ACTION - LAW STEPHANIE L. THOMPSON, . . Defendant : CUSTODY CUSTODY OCtiCILIATI<l'l SlJl'IMARY REPCRr IN ACCCXIDANCE WITH CUMBERLAND COONTY 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 Ivy E. Thompson June 24, 1987 Father/Mother 2. A Conciliation Conference was held on March 15, 2001, with the following individuals in attendance: The Father, William S. Thompson, with his counsel, Judith A. Calkin, Esquire, and the Mother, Stephanie L. Thompson, with her counsel, John J. Connelly, Jr., Esquire. 3. The parties agreed to entry of an Order in the form as attached. ~ /0 ::JOb! Date /2,. ~.rll2<"l Dawn S. Sunday, Esquir CUstody Conciliator , ,~c;~ . I~ :';:~;