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Home My WebLink About01-05314.~. , TERRY E. WOLF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF 01-5314 CIVIL ACTION LAW v. LUCY W. WOLF DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, September 18, 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 Main Street, Mechanicsburg, PA 17055 on Wednesday, October 17, 2001 at 11:30 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 appeaz 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/ Dawn S. Sunda~Esc~. ~/ 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 _. ~~- ~~~- ~~ ~ ~~~' ~~ is-o~~d 1 t~(1~1~r1 P~,4~IPd~d f ~ _ JF .r~ ,,, r: SEP ~ 4,001 .~\~ IN THE COURT OF COMMON PLEAS FOR THE NINTH JUDICIAL DISTRICT, CUMBERLAND COUNTY, PENNSYLVANIA TERRY E. WOLF Plaintiff, v. LUCY W. WOLF Defendant NO. ~~- ~~ Civil Action -Custody ORDER AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appeaz before the Custody Conciliator .Esquire, on the day of 2001 at .m. at the following location, _ 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 nazrow 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 upon request of either party. Failure to appeaz at the Conference may provide grounds for entry of a temporary or permanent Order. Date: FOR THE COURT Custody Conference Officer YOU SHOULD TAKE TffiS 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 FLr~D OUT WHERE YOU CAN GET LEGAL HELP. Cumberland Co. Baz Association 2 Liberty Ave. Carlisle, PA 17013 (717)249-3166 ,, , Law Offices of Hazlett & Oesterling 20 South Mazket Street Mechanicsburg, PA 17055 (717)-790-0490 IN THE COURT OF COMMON PLEAS FOR THE NINTH JUDICIAL DISTRICT, CUMBERLAND COUNTY, PENNSYLVANIA TERRY E. WOLF Plaintiff, v. LUCY W. WOLF Defendant NO. d /- 53~y Civil Action - Clastody COMPLAINT FOR CUSTODY 1. The Plainfiff is Terry E. Wolf, an adult individual, sui juris, who resides at 283 Frost Road, City of Gardners, County of Cumberland, Commonwealth of Pennsylvania, 17324. 2. The Defendant is Lucy W. Wolf, an adult individual, sui juris, who temporarily resides at 283 Frost Road, City of Gardners, County of Cumberland, Commonwealth of Pennsylvania, 17324. 3. Plaintiff seeks custody of the following children: Name Present Residence Age Victoria C. Wolf 283 Frost Road, Gardners, PA 17324 11 y/o (9-9-90) Crystal M. Wolf 283 Frost Road, Gardners, PA 17324 9 y/o (10-25-91) 4. The children were born in wedlock. 5. The children are presently in the custody of Plaintiff. 6. During the past five years, the children have resided with the following persons and at the following addresses: Person Address Dates Terry E. and Lucy W. Wolf 283 Frost Road, Gardners, Pa 1998 to present # . . Terry E. and Lucy W. Wolf 928 Goodyear Road, Gardners, Pa 7. The mother of the child is Lucy W. Wolf. 8. She is married. 9. The father of the child is Teny E. Wolf. 10. He is married. 11. The relationship of plaintiff to the child is that of biological father. 12. The plaintiff currently resides with the following persons: Name Relationship Lucy W. Wolf Wife Victoria Wolf Daughter Crystal Wolf Daughter 13. The relationship of defendant to the child is that of biological mother. 14. The defendant currently resides with the following persons: Name Terry E. Wolf Victoria Wolf Crystal Wolf Husband Daughter Daughter 1989-1998 15. 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. 16. Plaintiff has no information of a custody proceedmg concerning the child pendmg in a court of this Commonwealth. 17. Plaintiff does not lmow 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. 18. The best interest and permanent welfare of the child will be served by granting the relief requested because: Relationship a. Plaintiff has been the custodian and caregiver of the children since birth. .~-, t:, b. Plaintiff has maintained a relationship with the children that has provided for the physical, intellectual, emotional and spiritual well being of the children. c. Plaintiff has maintained the children's contacts with extended family and friends. d. Plaintiff has legal right to continued residence in the marital residence to which the children are familiar and comfortable with. e. Plaintiff avers that defendant is engaged in an extramarital affair and that she has threatened to remove the children from the marital residence thus causing great dismption to their lives. 19. 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. All other persons, named who are known to have or claim a right to custody or visitafion of the child will be given notice of the pendency of this action and the right to intervene: Name NONE Address Basis of Claim WI~REFORE, plaintiff, Terry E. Wolf, requests the court to grant him custody of the children. Respectfully Submitted, HAZLETT / ,~ Lee E. Oesterl~ire w Attorney LD.# 71320 20 South Market Street Mechanicsburg, PA 17055 (717)790-0490 Attorney for Plaintiff, Terry E. Wolf VERIFICATION I verify that upon personal knowledge or information and belief that the statements made in this Complaint are hue and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unswom falsi icafion to authorities. Terry E. Wolf laintiff ~, // Date: i S ~ Y-~~ wti ~s~ ~ • F f j ~'S ( ~ w Y S.r zi .m s n ~ G~ ~~• ~ ~ -.. a ~ f_1 ~"j ^: tl' ~i~I ~~~ ('} _~f ^~] tr, -C F ~~ TERRY E. WOLF, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. LUCY W. WOLF, Defendants NO. 01-5314 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 17th day of October, 2001, the Conciliator, being advised by Plaintiff's counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction. The Custody Conciliation Conference scheduled for today, October 17, 2001 is canceled. FOR THE COURT, ~~~~~~~ Dawn S. Sunday, Esquire Custody Conciliator ~ ~ ~ iii ft-: -~ . 7 ,~ --~'~'~"1 r C ~' ~a _r `~ ~ m