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Home My WebLink About01-04195CATHERINE J. BABNER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. DAVID L. BABNER • 01-4195 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, July 12, 2001 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, August 22, 2001 at 10:30 a.m. for aPre-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 riarrow the issues to be heard by the court, and to enter into a temporary order. Al] 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: /s/ Jacqueline M. Verney Esq. 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 ~ ~'~ ~ ~ ~-~~ ., ~~n, , ,1 /O £'/'L. ~~~~-~ /0•£/-/ .,. = - ~ Catherine J. Babner, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001- ~/l4S CIVIL TERM David L. Babner, CIVIL ACTION -LAW Defendant CUSTODY AND NOW, this day of 2001, 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 aPre-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 at the request of either attorney or party, be present at the conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT, By: Custody Conciliator 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. 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 Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 5010 E. Trindle Road Mechanicsburg, PA 17050 (717)591-1755 Attorney for Plaintiff Catherine J. Babner, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001- ~ ).q ~ CIVIL TERM David L. Babner, CIVII. ACTION -LAW Defendant CUSTODY COMPLAINT FOR CUSTODY 1. AND NOW, COMES, the Plaintiff, Catherine J. Babner, by and through her attorney, Peter J. Russo, Esquire, and respectfully submits the following in support of Plaintiffs Complaint for Custody: 2. The Plaintiff is Catherine J. Babner, residing at 159 North Locust Point Road, Mechanicsburg, Pennsylvania 17050. 3. The Defendant is David L. Babner. residing at 9 West Butler Street, Mt. Holly Springs, Pennsylvania 17065. 4. Plaintiff seeks custody of the following children: Name Present Residence DOB Bryan Babner 159 North Locust Point Road 5/3/92 Aaron Babner 159 North Locust Point Road 8/10!92 Joseph Babner 159 North Locust Point Road 3/25/94 Sazah Babner 159 North Locust Point Road 5/1/94 5. Bryan Babner, Aaron Babner, Joseph Babner and Sarah Babner were not born out of wedlock. Joseph Babner and Bryan Babner aze adopted children. 6. The children are presently in the custody of Plaintiff, who resides at 159 North Locust Point Road, Mechanicsburg, Pennsylvania 17050. 7. During the past five yeazs, the children have resided with the following persons and at the following addresses: Persons Plaintiff & Defendant Plaintiff & Defendant Plaintiff & Defendant (Bryan & Joseph) Address 159 North Locust Point Road 465 S. Middlesex Road 159 North Locust Point Road Duration 4/98-Present 8/91-4/98 6/00-Present 8. The mother of the children is Plaintiff, currently residing at 159 North Locust Point Road, Mechanicsburg, Pennsylvania 17050. The mother is married. 9. The father of the children is Defendant, currently residing at 9 West Butler Street, Mt. Holly Springs, Pennsylvania 17065. The father is married. 10. The relationship of plaintiff to the children is that of mother. The plaintiff currently resides with the following persons: Name Alyssa Babner Relationship Daughter 11. The relationship of defendant to the children is that of father. The defendant currently resides with the following persons: Name Relationship Rebecca Babner Sister Jessica Babner Niece Steve Brutko Sister's paramour Jenn Brutko Paramour's daughter 12. 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. The court, term and number, and its relationship to this action is: 13. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. The court, term and number, and its relationship to this action is: 14. 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 right with respect to the child. The name and address of such person is: 15. The best interest and permanent welfare of the child will be served by granting the relief requested because Plaintiff has been the primary caretaker of the children since birth or g adoption. Their best interest would be served be remaining in Plaintiff's care and custody. 16. Each pazent 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. All other persons named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Nsme Address Basis of Claim NONE WHEREFORE, Plaintiff requests this Honorable Court to order that primary physical and legal custody of the minor children, Bryan Babner, Aaron Babner, Joseph Babner and Sarah Babner be placed with Plaintiff. Respectfully submitted, C ~ Peter J. Russo Attorney for Plaintiff Date: J ~ ~ ~ o~ o ~ ~ PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 Catherine J. Babner, Plaintiff v. David L. Babner, Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001- CIVIL TERM CIVIL ACTION -LAW CUSTODY VERIFICATION I, Catherine J. Babner, verify that the statements made in the foregoing document are hue and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date: '-;~ "~ r (~ ` ~~`~---~ ~ w/ Catherine J. Babne ` iRSi6ee@ffiMM'%4x9P)'S~'4= r,. ~'_+~ .;f3,"~.N~". .. ~~'. T.id.6~mfN~ _ ~A~i ~, ~ ~~~~ ~l- CATHERINE J. BABNER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUN'T'Y, PENNSYLVANIA V. : N0.2001-4195 CIVIL TERM DAVID L. BABNER, :CIVIL ACTION -LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this 10~' of January, 2002, the Conciliator being notified that the parties have signed a Custody Stipulation in the above matter, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, {h. I cque ine M. Verney, Esquire, Custod Conciliator p r -`` !\U ji'~".:.. "~l'~l I~ :I~ q~w~+RSwa s ~r.i~ i =~~~ .~ m~~~n .v~.atm?r~€, ~I