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Home My WebLink About01-03461 '. JUN 11 200j rJl , , J DONALD McCAUSELYN Plai ntiff/Petitioner IN THE COURT OF COMMON I"I:.~;AS OF CUMBERLAND COUIIITY, PENI'IS1LVANij.\ NO: 01- 3'-1<.../ C-Wd ,............ v. LEISA WYATT, Defendant/Respondent CiVIL ACTION . FAMILY DIIIISIOi'.1 CUSTODY ORDER OF COURT AND NOW. this '1 fL day of :t \j l] ,2001, after consideral:iu I of liE Plaintiff's Petition for Custody, it is hereby ordered and decreed that Plaintiff, Dona':! . kC is granted joint legal and primary physical custody of the minor child, Aaron ChristoprH McCauselyn, subject to liberal periods of temporary custody in the Defendant, as agn,.d b between the parties. IT is FURTHER ORDERED, Defendant, Leisa Wyatt, is granted joint 10:" .1 ar,l primary physical custody of the minor child, Andre", Jeul Mc8auselyn, subject to lib"). I pHi.: . i '" temporary custody in the Defendant, as agreed to between the parties. BY THE COURT: ~(L- -h~~>",,",,:;,:,,_ ~"_-', _".' ,_ , -~ '1. r . ~~.: = , s J. - ~ -~~~- "'1 if 1. t t:' ~ ~ f. '- ...... , c:, , ._~~_T.:1~r M'L . ~. " \~ii\'~-li\ll ,"~' I~!:-) I 1 t'.'r:'i~'-,.:.:'-I '/\?,:.;!\-:?~. ,-., ~\ r i', 1 I, ,:,' ~- . ~,,' :, !,f',l,' I:) - - ~I, d. '_. _' ! '__10 ., I :.... :-1 ."J jl .. ! f' ~!. I' 1\ ~J "~ _ " '1 "~" ~ ,~,~ ~ -~ ........~ I!1jJ_~",," "",!,,~~~~~~1!\~f~,;"i<;"'l!"'H"'-i'-,rf;'-r-ar"',ij^"'M?--I,itit'4~Fi'!'r;~I~~I,-1Y?I:w.:~ijL<ji(Jjl''1'\*~1't1.,'Mi<i'f#l1@'~~llWiI'V$il~~~';'f , '. v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 0/- 3'11./ ~,___ CIVIL ACTION - FAMILY DIVISmN CUSTOOY DONALD McCAUSLIN Plaintiff/Petitioner LEISA WYATT, Defendant/Respondent PETITION FOR CUSTODY AND NOW, comes Plaintiff DONALD McCAUS'-IN, and by his attornel', .'Jdi:h F. Dolgos, respectfully represents as follows: COUNT I. CUSTODY OF AARON CHRISTOPHER McCAUSLIN 1. Plaintiff, DONALD McCAUSLIN, is an adult individual sui iJlrLs., residing at 1445B Holly Pike, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant, LEISA WYATT, is an adult individual sui juris., resicl:ng at 856 Old Forge Road, New Cumberland, Cumberland County, Pennsylvania. 3. Plaintiff and defendant have been bonafide residents of this Commonwealth for at least six (6) months immediately previous to the filing of this Petition. 4. Plaintiff requests an award of joint legal custody and primary pi'ysicai custody of the minor child, Aaron Christopher McCauslin, born March 26, 198E. 5. The child is presently in the physical custody of the plaintiff. 6. The mother of the cflild is Leisa Wyatt, defendant in the instc.nt action. 7. The father of the child is Donald McCEluslin, plaintiff in the ins':" lt a:t,,,.', 8. The minor child, Aaron Christopher MsCauslin, has resided at t:le fcilowing addresses with the following persons: ':'..J'iiJf. - ,,-, , ~ ~___- -" _,"'-'31,_ -', -~', ". , .- . ~"- -'-'~- ~-~ , a. From his birth on March 26, 1988 un1il1993, said minor child (,as ,'esided with both plaintiff and defendant and with Andrew JU.31 McCauslin, born August 9, 1989. b. Since mid 1993 until mid 1994, said minor child has resided with defendant and Andrew Juel McCauslin. c. Mid 1994 until 1996 with defendant and Andrew Juel M::Causlin in Florida. d. Mid 1996 until fall of 1998 with defendant and Andrew': uel McCauslin in Tennessee. e. Fall of 1998 with defendant and her husband, Chad Wyatt and Andrew Juel McCauslin in Pennsylvania. f. December 1998 until April 2000 with plaintiff and his wUe l\t1idori McCauselyn at 1445B Holly Pike, Carlisle, Cumberland County, Pennsylvania, i 7013. g. April 2000 with defendant and her husband, Chad Wyatt and Andrew Juel McCauslin at 856 Old Forge Road, New Cumberland, Cumberland County. Pennsylvania. h. Summer of 2000 lIntil present with plaintiff and his wife l\t1iciod McCauslin at 1445B Holly Pike, Carlisle, Cumberland County, Pennsylvania, 1 ;:)13. 9. Plaintiff and defendant were parties te. a previous custody action resulting from a PFA in Cumberland County in 1992, at no. 210 Civil 1992, this action "as dismissed on February 12, 1996. 10. No person(s) not a party to this transaction are known to the pi2.intl',' TJ have had physical custody or claims to custody or visitation with regard to the saie minor child. 1;'1fi\j.m- "'",_"'-_",_< ~; _ "'~_. _ _~ '_, _ ,'~ _ _T ~"_C 1'-' .'''n '. 11. The best interest and permanent welfare of the said child will be served by granting legal custody and primary physical custody to plaintiff, with liberal :J8(iod,; of temporary custody to defendant, as agreed to between the parties, because oflurrerou5 benefits to the child which would result from this ongoing stable relationship ClI,d the:are and love that would be provided to him. 12. Each parent whose parental rights to the child have not been le-mir' "ted and the person who has physical custody of the child have been named as parties':o this action. WHEREFORE, Plaintiff requests this Honorable Court to enter an Order gramillg joint legal and primary physical custody of the minor child, Aaron Christopher !i~cC5uslin, to plaintiff, subject to liberal periods of temporary custody in the defendant, as agl?ed to between the parties. COUNT II. CUSTODY OF ANDREVi' JUEL McCAUSUN 13. Paragraphs 1 through 3 above are incorporated herein and ma,~,e a part hereof as if set forth in full. 14. Plaintiff requests an award of joint legal custody and primary pLysical custody of the minor child, Andrew Juel McCauslin, born August 9, 1989 be ITic.de to defendant in this matter. 15. The child is presently in the physical custody of the plaintiff. 16. The mother of the child is Leisa Wyatt, defendant in the instmt action. 17. The father of the child is Donald McCcluslin, plaintiff in the instdt 8:t!on. 18. The minor child, Andrew Juel McCausin, has resided at the foil':wirg addresses with the following persons: ::{J,. ". ~'f"- "'", ,,~ 'M . _~",__, r \'- ,? -- ',.-,' ... "" - ~ .........",," .;;;:.::. ~ ' ,. '"< , a. From his birth on August 9,1989 until 1993, said mino! ch c! has resided with both plaintiff and defendant and with Aaron Christopher McCaLslin, born March 26, 1988. b. Since mid 1993 until mid 199!j., said minor child has (, .ic!e{j with defendant and Aaron Christopher McCauslin. c. Mid 1994 until 1996 with defendant and Aaron Chris'cpiler McCauslin in Florida. d. Mid 1996 until fall of 1998 with defendant and Aaron Christopher McCauslin in Tennessee. e. Fall of 1998 with defendant and her husband, Chad Wyatt and Aaron Christopher McCauslin in Pennsylvania. f. December 1998 until April 2000 with plaintiff and hi~. wr'e ~hlor, McCauselyn at 14458 Holly Pike, Carlisle, Cumberland County, Pennsylvaniil, '.7013 and Aaron Christopher McCauslin. g. April 2000 with defendant and her husband, Chad Wyat1 and Aaron Christopher McCauslin. h. Summer of 2000 until present with plaintiff and his wife Midori McCauslin at 14458 Holly Pike, Carlisle, Cumberlanc! County, Pennsylvania, lIOD. 19. Plaintiff and defendant were parties to a previous custody action re~uitlng from a PFA in Cumberland County in 1992, at no. 210 Civil 1992, this action,\'3s dismissed on February 12, 1996. 20. No person(s) not a party to this transaction are known to the p:zinCf to have had physical custody or claims to custody or visitation with regard to tl'"g saie! minor child. 21. The best interest and permanent welfare of the said child will be served bl! granting legal custody and primary physical custody to defendant, with liberal 'jeriocl, of temporary custody to plaintiff, as agreed to between the parties, because of rIIrl1el~!L'S ,,,,., " -, . II i-'-., . ,~~ -" ,"" , " " benefits to the child which would result from this ongoing stable relationship c.~d t:le:are and love that would be provided to him. 22. Each parent whose parental rights to ,he child have not been te.minated and the person who has physical custody of the child have been named as pal'lies TO this action. WHEREFORE, Plaintiff requests this Honorable Court to enter an Order gra.lting joint legal and primary physical custody of the minor child, Andrew Juel McCauslin. to defendant, subject to liberal periods of temporary custody in the plaintiff, as agreed to between the parties. Respectfully submitted, Date: C); flU S/NI'>OI By: Ju h F. DOlgOS,*-' Attorney ID 68738 P.O. Box 60809 Harrisburg, PA 17106.{)".09 (717) 541.9660 Attorney for Plaintiff 1J!.~__ S '-.'-." ." ._,,,,~-":'.>;;1,,t~_'''',,._,::-~-,,~--,,c_,,,,/-_''~'''''''~-'''' , ~ :"1_' J" 1".' , ,.' ~. ; , ,- , ;-~'~"IiI!!_.1. '.. " -," " . " VERIFICATION I verify that the statements made in this Petition for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4901 relating to unsworn falsifications to authorities. Dated: :TtjA,L 5" 2001 rlJJJiJJ1d ~ Donald Mccau~ {f"/L _ ., . ~_ , 0", _, . I' .,. ~ - ,." ~ .' , , v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: O/~ 3'1l../ C-...;:;;;t ,,,- CIVIL ACTION . FAMILY DIVISION CUSTODY DONALD McCAUSLIN Plaintiff LEISA WYATT, Defenda nt JOINDER FOR CUSTODY AND NOW, comes Defendant, LEISA WYATT, and respectfully represents as follows: 1. The address of defendant is 856 Old Forge Road, New Cumberi2nd, Cumberland County, Pennsylvania. 2. Defendant is the mother of the minor children, Aaron Christoph'll' McCauslin and Andrew Juel McCauslin. 3. Plaintiff is the father of the minor children, Aaron Christopher !';'cCauslin and Andrew Juel McCauslin. 4. Defendant has reviewed plaintiff's Petition for joint legal custody and p':ma~y physical custody of the said minor children and jOins in plaintiff's request that primm) physica! custody of Aaron Christopher McCauslin be with the plaintiff, subject to periods of L :c,'al temporary custody in the defendant as agreed to between the parties. 5. Defendant further joins in plaintiff's request that she be granted joint iegal and primary physical custody of Andrew Juel McCauslin subject to periods of liberal temporary custody in plaintiff as agreed to between the parties. 6. Plaintiff and defendant agree that such custody arrangement is in the b,"st interest of the minor child. -~JJ:!i, . ~ ',-<c"'"""-,>,_,,,,,,- - ',( ,- I' , ,~-- <., - _.~ . . . -:'~ - _,r,"" .. , . WHEREFORE, Defendant LEISA WYATT, joins with plaintiff in requesting this Honorable Court grant the plaintiff hereto joint legal and primary physical custody of minor child Aaron Christopher McCauslin, and joint legal and primary physical custody of Andrew Juel McCauslin be granted to defendant, subject to periods of temporary custody as agreed to between the parties. Dated: b - ~ -0 I ft<;,~ ) 6. tJ!jdJ LEISA WYATT r .,-' _ "I T ,. ,- . . \ .~ I DONALD McCAUSEL YN, Pia i ntiff/Petitioner v. IN THE COURT OF COMIVION F'I..EAS DF CUMBERLAND COUNTY, PENI'ISYLW\[\JIA NO: "1_ 3'ft../ ~ IJ..-. LEIS/\. WYATT, Defendant/Respondent CIVIL ACTION . FAMILY DIVISICIt,j ENTRY OF APPEARANCE To the Prothonotary: Please enter my appearance on behalf of Plaintiff, DONALD McCAUS:: ."N, n thE above custody matter. Respectfully submitted By: ith F. Dolgos, Esqu: torney I D 68738 P.O. Box 60809 Harrisburg, PA 17106.(E.9 (717) 541.9660 Attorney for Plaintiff i}J , l"v r"o-,,-, ~" . ,to -~.I ,. '. -~ , ,~ t.,_ . . JUN 2 5 2001~ DONALD McCAUSELYN, Plaintiff IN THE CXlORT OF CXlMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . . : vs. : NO. 01-3461 CIVIL TERM . . : CIVIL ACTION - LAW LEISA WYATT, : Defendant : IN CUSTODY aIDER OF COORT AND NOii, this 2200 day of June, 2001, the Conciliator, being advised by Plaintiff's counsel that all custody issues have been resolved by agreement of the parties, here-by relinquishes jurisdiction in this case. The Custody Conciliation Conference scheduled for July 3, 2001 is canceled. FOR THE COURT, Dawn S. Sunday, Esquire Custody Conciliator !;,;-,~" - ,<- . - ~ 1].".., 00iT -~.f9'IIllliII!il~... ;j .!Jfjr~." ,p~,~-~ , ['5 ('0 f\..;. ',,", en C~i ,~ , "n ~~~~tl'Et-~"4'lJI!B,,!!!!,%";';%j~,~1'l'J\~-"':'!!'I"~1W~..,'\>J!IM~~~i!WJJ'~~! , , SEP 0 :3 2002 .5 t , Donald McCauslin IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. Leisa Wyatt 01-3461 CIVIL ACTION-FAMILY DIVISION CUSTODY Defendent ORDER OF COURT AND NOW, this ~day of ~_, 2002, after consideration of the Plaintiff's Petition for Custody, it is hereby ordered and decreed that Plaintiff, Donald McCauslin is granted joint legal and primary physical custody of the minor child, Andrew Juel McCauslin, subject to liberal periods of temporary custody to the Defendant, as agreed to between the parties. Donald McCauslin is therr of temporary custody, as agreed to between the parties. c;:r; ~ ~Kf t: 6: {)eft 'PLPr o..tt.r' lJ D\ ~ o~ BY THE COURT ~" '''-'-,' - '-:;- _, w. , or ~ ,," =..,- ';~l-!i"''''lf' i II !U~~i~~~Ii1~::l~i:~;~~l'rW"i:~~Hi,';Biil!~-k.'!*k~~ or: OZ SF? '''"'''''''''''!.ilL 'j" ~~-_.i!'J!"MNII:jj~.1lII 1 ~:p j,::C\-.(>!fF\CE ,/ ,_\~,.;:: ""~":'>~C:\'~07l\.r.r, " .-. t) I\!~"t IO~ ~ C. t'lll' .,J;) .' '''''U,rrv Cl \MP,tJ\Lf:\;>l~) lj..J \ 'oj i I u PEN~\S,{L\jAN\A . ,. .. 1 . . Donald McCauslin IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. 01-3461 CIVIL ACTION LAW Leisa Wyatt Defendant IN CUSTODY PETITION TO MODIFY CUSTODY ORDER Come now Donald McCauslin, Plaintiff and Leisa Wyatt, Defendant to petition the court to modify custody of Andrew Juel McCauslin to grant joint legal and primary physical custody of the minor child Andrew McCauslin to Plaintiff, Donald McCauslin, subject to liberal periods of temporay custody to the Defendant as agreed to between the parties. WHEREFORE, said plaintiff Donald McCauslin,and defendant Leisa Wyatt;request that the Court enter an order granting joint legal, and primary physical custody of the minor child, Andrew Juel McCauslin to the plaintiff and liberal periods of temporary c~~~~~s agreed to between the parties. DONALD M~SLIN Plaintiff !/.-/~4>) G 4LJ~ LEISA WYATTj Defendant STATE OF PENNSYLVANIA S5: COUNTY OF CUMBERLAND Before me, a Notary Public in and for said County personally appeared Donald McCauslin, who acknowledged execution of the foregoing to be his voluntary act j,fd verified the truth thereof. ~ t1 .. ~~ESS my hand and Notarial Seal this ~t day of 1'fV~7L~--, 2002. and State, the deed and Notar Pu lic Residing in Cumb rland County, pennsylv My Commission Expires NOTARIAL SEAL . ROBERT F. SUMBURY, NotarY PublIC Mechanlcsburg, Cumberland County u My Commission I"yo;'"$, November 7, 2lI05 i:,~_,_, . -: -~-, ~,',- i~' - - ''', _ . ~"". _,_, _ . -,11, . ~ ~ ... I' ~ , . . STATE OF TENNESSEE ss: COUNTY OF CUMBERLAND Before me, a Notary Public in and for said County and State, personally appeared Leisa Wyatt, who acknowledged the execution of the foregoing to be her voluntary act and deed and verified the truth thereof. WITNESS my hand ~, 2002. Mn Co~ission Expires -'tfJ.J.j[J.L..JJr ,) m t:. ~ and Notarial Seal this _1:- day of ." . Jd-j Public Residing in rland County,Tennessee ", " ,~- '- '/ - "'-~',~ -_'__"~ ~'''''c,_~~ "~'. ~__ , ,,'~,"__, , ~ , . . VERIFICATION I, Donald McCauslin, certify that the statements made in the foregoing PETITION TO MODIFY CUSTODY AND STIPULATION OF THE PARTIES, are true and correct to the best of my knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. C, 4904, relating to unsworn falsification to authorities. Dated: 8!x/02- :'",.-- _ ,_ ^'<-". u ,",,,",' _~ _ . . ''''-'1'< ,.". ", , L - - ~, ~ ~ .__.~ ~ , r ~Q. ~ 0 c:> Q, C N ~ ~ S :JO> :~ 0> ""0 CD c:: ~;1?J ';2fT1 G, t; ;:I:I W ''i''".rn ZC <10 Cl ~~ ;;:.~ 0 ~.,)A 0 r;::c.: "-..:!.~-:'. 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