Loading...
HomeMy WebLinkAbout01-04466RICHARD S. GARWOOD IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. KELLY L. GARWOOD DEFENDANT • O1-4466 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Wednesday, July 25, 2001 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. ,the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on Tuesday, September 04, 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 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 coact hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Belief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Melissa P. Greev~, 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 ~?~~- ~~ ~ ~~~~~ -~: - .„ J04~-~ /~~~L, __ ...a. ~~~~ RICHARD S. GARWOOD, Plaintiff/Petitioner vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION -LAW KELLY L. GARWOOD, n Defendant/Respondent NO. t~l - SIN~~ l~co~~ ~-t'"~ 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, the conciliator, at Pennsylvania, on the _day of 2001, at o'clock _ .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. Either party may bring the child who is the subject of this custody action to the conference, but the child's attendance is not mandatory. 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 RICHARD S. GARWOOD, Plaintiff vs. KELLY L. GARWOOD, Defendant AND NOW, the plaintiff, Richard S. Garwood, by and through his attorney, G. Patrick O'Connor, Esquire, files a Complaint For Custody of which the following is a statement: 1. The plaintiff is Richard S. Garwood, Father, who currently resides at 1130 Rana Villa Avenue, Camp Hill, 17011, Cumberland County, PA. 2. The defendant is Kelly L. Garwood, who currently resides at 1131 Rana Villa Avenue, Camp Hill, 17011, Cumberland County, PA. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. COMPLAINT FOR CUSTODY 3. Plaintiff seeks custody of the following child/children: Name Present Address Date of Birth Tristan I. Garwood Kirsten B. Garwood Devin C. Garwood 1130 Rana Villa Avenue Camp Hill, PA 1130 Rana Villa Avenue Camp Hill, PA 1130 Rana Villa Avenue Camp Hill, PA November 6, 1990 October 22, 1992 May 6, 1997 Tristan I. Garwood was born out of wedlock. Kirsten B. Garwood and Devin C. Garwood were not born out of wedlock. The children aze presently in the custody of the father who currently resides at 1130 Rana Villa Avenue, Camp Hill, Pennsylvania. During the past five (5) years, the children resided with the following persons at the following addresses: Persons Address Date Richazd S. Garwood Kelly L. Gazwood Richard S. Garwood 1130 Rana Villa Avenue Camp Hill, PA 1130 Rana Villa Avenue Camp Hill, PA Birth until 6/18/01 6/18/01 to present The mother of the children is Kelly L. Garwood, whose current address is 1131 Rana Villa Avenue, Camp Hill, PA 17011. She is married. The father of the children is Richard S. Garwood, who currently resides at 1130 Rana Villa Avenue, Carnp Hill, PA 17011. He is married. 4. The relationship of plaintiff to the children is that of father. The plaintiff currently resides with the following persons: Name Relationshin Tristan I. Garwood Son Kirsten B. Garwood Daughter Devin C. Garwood Son Shirley Hazzard His Mother 5. The relationship of defendant to the children is that of Mother. The defendant currently resides with the following persons: Name Relationshin Elmer Blumenstein Her Father Margaret Blumenstein Her Mother 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. The plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. The plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the child. The best interests and permanent welfare of the child will be served by granting the relief requested because the father is best able to provide for the child. 8. Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the children have been named as parties to this action. WHEREFORE, plaintiff respectfully requests that this Honorable Court enter an Order granting primary physical custody and shared legal custody to the plaintiff, with visitation to the defendant. DATE: ~2 `~~~/ Respectfully submitted: By: G. atrick O'Connor, Esquire 3105 Old Gettysburg Road Camp Hill, PA 17011 717-737-7760 Attorney I.D. #64720 ATTORNEY FOR PLAINTIFF VERIFICATION I, RICHARD S. GARWOOD, state that I am the PLAINTIFFlPETITIONER in the above-captioned case and that the facts set forth in the foregoing are true and correct to the best of my knowledge, information, and belief. I realize that false statements herein are subject to the penalties for unsworn falsification to authorities under 18 Pa.C.S. Sec. 4904. Date: July 20, 2001 CERTIFICATE OF SERVICE I hereby certify that I have, this day, served the herein Custody Petition to the party indicated below by depositing same in the United States mail, by regular mail and by certified mail to addressee only, postage prepaid, at Camp Hill, Pennsylvania: Kelly L. Garwood 1131 Rana Villa Avenue Camp Hi11, PA 17011 DATE: ~ ~~l ~~ ,~~~ ~~~ ~. Patrick O'Connor, Esquire Attorney No. 64720 3105 Old Gettysburg Road Camp Hill, PA 17011 (717)737-7760 Attorney for Petitioner SEP 10 ~~~~. RICHARD S. GARWOOD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. KELLY L. GARWOOD, Defendant NO. 01-4466 CIVIL ACTION -LAW CUSTODY ORDER TO RELINQUISH JURISDICTION AND NOW, this 4th day of September, 2001, in consideration of the fact that neither party appeared for the Custody Conciliation Conference scheduled this date at 10:30 a.m., the Custody Conciliator hereby relinquishes jurisdiction of the matter. In the event that either party would like an additional Custody Conciliation Conference the appropriate petition must be filed with the Court. FOR THE COURT, Melissa Peel Greevy, Esquire Custody Conciliator Dist: G. Patrick O'Connor, Esquire, 3105 Old Gettysburg Road, Camp Hill, PA 17011 Kelly L. Garwood, 1131 Rana Villa Avenue, Camp Hill, PA 17011 C7" `fiJ ~ C,) ~ .~ ~ - Cu i _ " ... ,.~ _ ~_ %p t-- '_I C a:_. r -_.. _ ` J ~~ ~)