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Home My WebLink About01-2996FX .- - . , , , ,. {"J "'oc'" _ Weston Green, Jr., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYL VANIA vs. NO. 01- ;199(" CIVIL TERM Kristy Green, Defendant CUSTODY 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 conciliator, at on the _ day of ,2001, 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. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. This court hereby directs the parties to furnish any and aU existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. By the Court, Date Custody Conciliator 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, P A 17013 (717) 249-3166 OR (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 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 hours prior to any hearing or business before the court, You must attend the scheduled conference or hearing. I.. . >-~--." 4~' Weston Green, Jr., IN THE COURT OF COMMON PLEAS OF Plaintiff vs. CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01- J, qq(., CIVIL TERM Kristy Green, Defendant : CUSTODY COMPLAINT FOR CUSTODY 1. Theplaintiffis Weston Green, Jr., residing at 155 East North Street, Carlisle, Cumberland County, Pennsylvania. 2. The defendant is Kristy Green, residing at 161 Frytown Road, Carlisle,Cumberland County, Pennsylvania. 3. The plaintiff seeks custody of the following child: Name Kayleigh Green Present Residence 161 FrytownRoad Carlisle, P A Age March 20, 2001- Date of Birth The child was not born out of wedlock. The child is presently in the custody ofKristy Green, who resides at 161 Frytown Road, Carlisle, Pennsylvania. During the child's lifetime, she has resided with the following persons and at the following addresses: Name Weston Green, Jr. Kristy Green Address 155 East North Street Carlisle, PA 17013 Date 3/20/01 to 5/10/01 Kristy Green Marilyn Jumper Calvin Jumper 161 Frytown Road Carlisle, P A 17013 5/1 % 1 to present The mother of the child is Kristy Green, currently residing at 161 Frytown Road, Carlisle, Pennsylvania. She is married. The father of the child is Weston Green, Jr., currently residing at 155 East North Street, Carlisle, Pennsylvania. He is married. 4. The relationship of the plaintiff to the child is that off ather. The plaintiff currently is residing at 155 East North Street, Carlisle, P A. 5. The relationship of the defendant to the child is that of mother. The defendant currently resides with the following persons: Name Marilyn Jumper Calvin Jumper Kayleigh Green Relationshio Mother Father Child 6. The plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 7. The plaintiffhas no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 8. 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. 9. The best interest and permanent welfare of the child will be served by granting the relief requested for reasons including, but not limited to, the following: a. Plaintiff(Father) has lived with the child since her birth, and has provided and can continue to provide for the child's physical, emotional and fmancial needs including a stable environment. b. The child has been with the father since her birth and she has bonded with him, and Defendant (Mother) has not acted in the child's best interest by removing her from her father, denying him reasonable contact with her, and limiting him to sporadic, supervised visits. c. The father has concerns for the child if she remains primarily in the mother's care for reasons including, but not limited to, the following: 1. The mother has a history of mental instability which has resulted in periods of extended hospitalization at least twice. ..~ ~ -'.- J -I,-,J. --". ,~;,:..-'; 2. The mother has impulse control issues which could adversely effect the child. For example, ten days before the child's birth the mother became angry at the father and punched her arm through a window resulting in her receiving approximately sixteen (16) stitches. 10. 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. WHEREFORE, the plaintiff requests that this Court grant him physical and legal custody of the child and any other relief which is just and proper. ~~OOrittod, 00 . Carey Attorney for Plaintiff MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 // ,. J . .' -'~d 1".,1--, "' <' - - - ,',- -,;).'" ,.~iW. ~.,,'- ---c- .). 'l\jl~" VERIFICATION The above-named Plaintiff, Weston Green, Jr., verifies that the statements made in the above Complaint are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904. relating to unsworn falsification to authorities. Date: f) -tlr- 01 'j-v'.-5=/;.: ~ Weston Green, Jr., Plaintiff ~~~~\(:!!;J,~~l'li~.t"liii>'i'li1lllffu.@Jii;PJ:i~~~~91!1-i:..1*..j"i'''#;7-i{'1i>:'':_i~1ATi<'*"""lliii-'h'ilil,,;'i~,-o;;:iti',jb~"W.iwll~M"~ jj.!lll!llilt1:~~,,*,~ilIUif..~i!it.~ !.\!t'l. ... J.lllf*rll'iII,iMNSfMI.1'" ~ --" ~~ 0 <::I ,. C ._,J "TI $: ~ -0 C~~1 J~1"o< rilr,n, -< "",I Z:'T' Z C.= (/) "-.,1 t -< ~.. r':l.-J --n Pc Z~' , ~- )>l.o :....) ~- ,T't ~> C C) ~ w );1 (-.) :~) -< - ~ , .~~-,~~ ~ _~,I ~ _. . '-"I...J - ".~ . -, ,-".,e,-.,- -,~,_- __ ;, " _ "'~ :~, WESTON GREEN, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. KRISTY GREEN, NO. 01-J19L CIVIL TERM Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Weston Green, Jr., Plaintiff, to proceed in forma pauperis. I, Joan Carey, attorney for the party proceeding in forma oauoeris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. Jo Carey Attorney for Plaintiff MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 ~~ 'I~I--" ~,- ,-;"'~,,'';;;' -",O---~-__'""';.W,,"..'~' .'..[., "'h;.j WESTON GREEN, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. KRISTY GREEN, NO. 01- CIVIL TERM Defendant AFFIDAVIT IN SUPPORT OF PETITION FOR LEA VB TO PROCEED IN FORMA PAUPERIS 1. I am the Plaintiff in the above matter and because of my fmancial condition am unable to pay the fees and costs of prosecuting, defending, or appealing 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: Weston Green. Jr. Address: 155 E. North St. Carlisle. PA 17013 (b) Social Security Number: 188-60-9389 If you are presently employed, state Employer: N/A Address: Salary or wages per month: Type of work: If you are presently unemployed, state Date of last employment: 4/01 Salary or wages per month: $1700 Type of work: . Frequency design engineer ( c) Other income within the past twelve months Business or profession: N/A Other self-employment: N/A Interest: N/A Dividends: N/A Pension and annuities: N/A Social Security benefits: N/A Support payments: N/A Disability payments: N/A Unemployment compensation and supplemental benefits: $1063/month(gross) Workman's compensation: N/A Public Assistance: N/ A Oth~: WA (d) Other contributions to household support (Wife)(Husband) Name: If your (husband) (wife) is employed, state Employer: Salary or wages per month: '" """'I.olI ' " ,,-, ,-". .'_ ',"'0' ~, t-" -,., ~ -., 'I...J;;J---" ,_""- ",to.,. ~. - 't-._,,,,;; - --- - (-~-,~', -', l"l! \ Type of work: Contributions from children: (e) Property owned Cash: Checking Account: Savings Account: $250.00 $0.00 $450.00 N/A N/A Certificates of Deposit: Real Estate (including home): Motor vehicle: Make Ford. Probe Cost $3600 Year 1991 Amount owed $0 Make Honda Accord Year 2000 Cost $21000 Stocks; bonds: Other: (t) Debts and obligations Mortgage: Rent: $465 Loans: $71.00/month (school loans): car loan $340 Monthly Expenses: Groceries $150: TeltWhone $40: Electric $100: Gas for vehicle $140: Cellular phone $30: Credit card debt $140 (est) (g) Persons dependent upon you for support (Wife) (Husband) Name: Children, if any: Name: Kayleil!:h Green Age: 2 months 4. I understand that I have a continuing obligation to inform the court 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 made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Date: &---'6-01 ~.A.h-- A, ~~ -/-. WeSton Green, Jr., Plaintiff ~wl~fi!~~!dJ;;;'W.'lIllO!li<l;gO'1il~i""II~-...G;~_"""""f.>IjL,i-_H~,".w.!'.-";~~;l~J':~",-,~;,~"";;l~,,,,l>f.l~,!i~IUiil>>J~1~~~'i1.l~~ """,~~ I - ._~- .---, '-'~-"'"'' ._~~ " "'" "~. '" oli!I>>IlUlJlllllBHI .~j I !:1 "I' i I I I (") D C -, ':'"-".D :::'J~ r") v " :l'];~ m r';' -< , Z -r, zF rn (/) ,:;,:::~ -.i ;:;:-] -<"".::.. (~) r:" ,"". ~'-./ " "To :':'C~ ~...... " Z 0 \.,",' (') )>0 ~.?:: c: W () m Z --{ W '> =< 5:J .- -< ".~,j - ~ I ~' ,,1 i ,j ." ,,~'" ." ,. '~ ' -" '~"C', ~ WESTON GREEN, JR. PLAINTIFF V. KRISTY GREEN DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 01-2996 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, May 24, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Veruey, Esq. , the conciliator, at 4th Floor, Cumherland County Courthouse, Carlisle on Weduesday, June 20, 2001 at 1:30 p.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. 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: Isl Jacqueline M. Vern~. Esq. /fJ 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 1HIS 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 [ "'~~~ ^~,-~-,~ S- c)l/O / 5-dV-(){ 5;)((-01 " " i ~ '" ~~ -~,,>< . ~ . <' ~~ .-~~ i .~' , ~) rL~" ,) FH ?: b3 CUivl~.~H0,<;'<\~) ;,~:,~iJi\;-CY 1+1'1f\'SYl\ u" I" ~_ 'i i, <,/-1,:\/\ w.~. ~~ -h )<".5" '-W10~#4~ t~ ~~M-v d4 ~t7p' ~ _fi\"'''!Il''lII~MJ:1IfI'lII!m~*,-,iW"~'F.!''g>!Jij-e'"<m'''J,,'r~"'!',.'''''''''''''l''''"'_'~WP''"''''.'''~!'m'!l!J:W''l~~_f'N'''\'lf'rml~rnj!I'iI'~'1'~''~j'''..,:iPf# -. - ~ :- ' c. ':), . Complete Iteml1: 2. and3:Aiso OOnllllei" . . item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so th~t we can return the card to you. . Attad~ this card to the back of the mail piece, or o~MP,e front if space permits. 1. ArtICI~~~ressed to: -~'.".'".' I-~ {ioyfYVIG c.J. p>o!}f 8Cf~ \5{. .1'JltfntUli /lrtn-- 1"7 be? (/ 2. Articlei ';1 ,',.., ..J( .., -, PS Filrm Iss,T,Ju/YTggg-- - Domestic-Retlirn ReceTpt ",...1' I' o Agent o Addressee DYes j);'No o Express Mail o Return Receipt for Merchandise o C.O.D. i->fei: ------ -ro2595-0Q.M-0952 'j. ,'.J' 'y,\ " --, ,"po --~,~-.,._ '" ~"< C.",,, --'-"'I.lliJ"'~ - ,,C. -_ .;', ~_"",.,~;__.j;'~"_' ''''~c' ;;"..~- ~'" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Kathy J. Gorman, Plaintiff : No. 2001-3096 : Civil Action - Law vs. : In Divorce Jerry L. Gorman, Defendant AFFIDAVIT OF SERVICE H. Anthony Adams, Esquire being duly sworn according to law deposes and states that an amended complaint in divorce was mailed to Jerry L. Gorman, of P.O. Box 362, St. Thomas, Pennsylvania, 17252, certified mail, return receipt requested on May 30, 2001 and was accepted on delivery by Jerry L. Gorman on June 2, 2001 as shown by the attached receipt. H. Anthony Adams, squire Attorney for Plaintiff 128 E. King Street Shippensburg, PA 17257 (717)-532- 3270 Sworn to and subscribed this 18th day of June, 2001. ~b.(Jm /Yb/lj~ Notary Public My Commission Expires: ~, . , ....., 8eaI ~~~~ .' ~Feb.5.~ '. ~r,o -""""'''.iijlt'i "",,--- f~" ~-"-~-='>-- ~c~,. ~";;d,k._;;; '0>: '-""'-"-11 " ~',-"-,~, ., ~"." ~ ,~~-- , -iii" .~. ,. ~ , ...-.... o ~; ~~c 6:,-;:--: ------. ~t. c:c ?~~.:-, )>c. ~'- :;! C) L-_ s:; f>',) (=\ :-:~: I.':' ~ ~-< :..fl CD !'Il AUG 2 3 2001/0 WESTON GREEN, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : NO. 2001-2996 CIVIL TERM KRISTY GREEN, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 23rd day of August, 2001, the Conciliator being notified that the parties have reconciled and are presently living together with the child, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, ~/V; ine M. Verney, Esquire, Custody onciliator idl.~'iliw!m_~~tI.~t;!H_.llil!!~i\m;:~~,~"",,"...'..;,&i"'~"'.Jffll":E!"'>116l1H.,.J;iJ[1~I~""""' ,l., ! L__".1I.J ,""."_',~.. , "="',.~ ..,,- _"~'"W~, ., ".'U' ~__. C, N "0 ~r'L W'~._'''''iW'' o S ffj ij,i ~JS~:- t-;-'. ,-' ~?:f." i~~.: "" ~< -' _<:1 :.j L) ~o/ c-:; U) .--" '", "