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Home My WebLink About01-03440 , CHRISTOPHER D. MARTSON PLAINTIFF V. JACQUELINE A. MARTSON DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-3440 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, ~onday,June11,2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West ~ain Street, ~echanicsburg, FA 17055 on Tuesday, July 10, 2001 at 11:30 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 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. 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 honrs prior to scheduled hearing. FOR THE COURT, By: Isl Dawn S. Sunday. Esq.tJ;? 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 infonnation 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 "'<'~""," ...,,-- - 'r-" '" ~ , .'n, !~li~H1i!':illlIIm.'i8"4.;';''''\,:)!~l&;ld;d^_,),{,:...>.y,"'C,H_k''-M'Jb,?jrAi",,nli-lil\'"-";:'~;"""!u_ct"'"_c""!"!"_"""'f,';,,mi2-,1,",,,,,,r,,-.,;,~~I!!l1r.~~SIMt""'-"'"~"'" ''''''''''' ' ~~"""~""_'M_ " ~ - '-'-'.,~,-- ^ -~ ~~'" - .~-'. ~ -, ~ . """.'''ii!i~--~ '~'M'<I:il ",-,.._-,~l."if.l~~-~" -~ ' ~-~;:j "~~ ~"'l ~FiCE <C\r')Ti~,HY Oi .llm I~: FH 3: 1..12 CUM6EFiL/\i\O COUNTY PENNSYLVANIA l /~ -()/ iR' /CJ.. -0/ k </;l. -01 .>..,-, 0.. W-to/1~ ~4~ 71~,~ Z ':!fI- ~ ~~ ~ a4 ~::;- 03 $:] w, CHRISTOPHER D. MARTSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 01- 3ef'lo CIVIL TERM JACQUELINE A. MARTSON, Defendant : CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, this day of , 2001, upon consideration of the attached Petition, it is hereby directed that the parties and their respective counsel appear before Esquire, Custody Conciliator, at on the day of , 2001, at o'clock _.m., for a Prehearing 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 THE COURT, By: 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. LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, P A 17013 (800) 990-9108 cc: Lisa Marie Coyne, Esquire Attorney for Plaintiff Jacqueline A. Martson, Defendant Custody Conciliator ,4l>~_ ~~.~_ ,.'- -! , -~~- ,,- I' ,^ ~ CHRISTOPHER D. MARTSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 6/- ?<f'lb CIVIL TERM JACQUELINE A. MARTSON, Defendant : CIVIL ACTION - CUSTODY COMPLAINT OF CUSTODY TO TJIE HONORABLE, TJIE JUDGES OF SAID COURT: AND NOW COMES, the Plaintiff, CHRISTOPHER D. MARTSON, by and through IS attorneys, Coyne & Coyne, P .C., and avers the following in support of this complaint of custody: I. Plaintiff is CHRISTOPHER D. MARTSON, an adult individual, whose current address is 39 BROAD STREET, NEWVILLE, Cumberland County, Pennsylvania. 2. Defendant is JACQUELINE A. MARTSON, an adult individual, now residing at RR 3, BOX 816, MILLERS TOWN, Perry County, Pennsylvania. 3. Plaintiff seeks custody of the following children: ELIAKIM CHRISTOPHER MARTSON, born August 10, 1998; EMMANUEL CHRISTOPHER MARTSON, born November 2, 1999; and JOSEPH CHRISTOPHER MARTSON, born January 3, 2001. 4. The children were not born out of wedlock. 5. The children are presently in the custody of the Defendant who resides at RR 3, Box 816 MiIlerstown, Perry County, Pennsylvania. 1 ^~'~"~~~"'-"=' ~""""""'-', "-"'-1....".:-"'.,.~-~,..," -~,~^ , 6. During the past five years, the child has resided with the following persons and at the following addresses: Name: Residence: Dates: Parties 39 Broad Street Newville, P A 5/1/200 I to 5/9/200 I Parties 51 Garden Parkway Carlisle, P A 5/1/2000 to 5/1/200 I 7. The Mother of the children is the Defendant and she is married to the Plaintiff. 8. The Father of the children is the Plaintiff and he is married to the Defendant. 9. The relationship of the Plaintiff to the children is that of father. The Plaintiff currently resides alone since the Defendant removed herself and the children from the marital home. 10, The relationship of the Defendant to the children is that of mother. The Defendant currently resides with her stepfather, Tom McVoy. I L Plaintiff has not participated as a party or wi1ness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 12. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. 13. Plaintiff does not know of a person not a party to the proceedings that has physical custody of the children or claims to have custody or visitation rights with respect to the children. 14. The best interest and permanent welfare of the child will be served by granting the relief requested because given the age of the children and the fact that the Mother removed herself from the marital horne and at the same time refused to allow father to have contact with his children. It is in the best interest of the children to have regular and steady contact with both parents as well as keeping the 2 .~~,r" '1'" t. . . children together and as such Plaintiff seeks shared legal and physical custody of the children with the children spending equal time with the parties on a regular and routine basis. 15. Each parent whose parental rights to the children has not been terminated and the person who has physical custody of the children have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the children will be given notice of the pendancy of this action and the right to intervene: None. WHEREFORE, Plaintiff requests this Honorable Court to grant Plaintiff shared legal and physical custody of the children. Respectfully submitted, COYNE & COYNE, P.C. Dated: (p ~ :;> -<>1 <7t: SA MARIE CO 3901 Market Street CampHill,PA 17011-4227 (717) 737-0464 Pac S. Ct. No. 53788 Attorneys for Plaintiff 3 :~ -, ,...".,_^~:t "'-' .. , , .,." ~ , - . ,~~ .~~ ""Jt ".-._.__.~.._':'" ~.., -... '.,...- - , VERIFICATION The facts set forth in the foregoing are true and correct to the best of the unn..mgJ1M'S knowledge. information and belief and are verified subject to the penalties for unsworn. falsification to authorities UDder 18 Pa. C.S.A. ~4904. Dated: t;-Z-ul "i'''",;;I!W~m"=_' ~/'""-. "I ;ili.< ~, '.-rl"> I"'~' .-, ~~>o=-r . , :7::::Jf::> tt.~ - ~ ...c.. B ~ tv. v f cyr ~ ~ () c ;;: "UQJ ~mnc.. -r e- (JJ --- -<5'-- ~c ~Q =c' .....c z :<! [$ [0 0' C- c.:: Z I (.Ji o -n ;yt :cr~~ ~'g0 r) .i.. .::1 C) :t-=r~ (J----' -'5~O C)m --t :; =< .U :x e-:J f'-' .fJteiC~~"'~W'l!:lh-jMJ~~'5IIl!i~~'\!!-l~~~,~~\lllIl~JW_"j,~il/!'tr'!'T"[<$'-'iVi~:'<--~t"i-YT~,,~__,'n,,'<";;;:'Y"'ff'(;',i"'-'i!'~',,~i:,1i-,:S')loT~~;i-,.,-,<,,"_,,_on, -'-"i",,)I~'-"\"-J:{":: --:i"'i-','B".1i'f1''I'i'I''',P.'40YIf~ CHRISTOPHER D. MARTS ON, Plaintiff AUG 2 0 L~ IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. 01-3440 civil action law AUG 2 0 2001 JACQUELINE A. MARTSON, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 13th day of August, 2001, the Conciliator, having received no request from either party to reschedule the Custody Conciliation Conference originally scheduled for July 10, 2001, hereby relinquishes jurisdiction in this case. FOR THE COURT, Dat2~~ Custody Conciliator '" ~. ,'. ,"' .-"-'?",-- "~'"" ,- . ^, - .~ -~, . - " 1,... . , """"lilI_ . "~, .. k'~"" ",_r..""_1 -~ "' , .~,,"- ,"'........... 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