Loading...
HomeMy WebLinkAbout03-2576iHENRY MORRIS, Plaintiff COLLETE ROSE MORRIS, Defendant IN THE COURT OF CO MMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA NO. 0a- (76 CIVIL - CUSTODY CUSTODY COMPLAINT 1. Plaintiff is Henry Morris, who resides at 354 Grahams Woods Road, Carlisle, Pennsylvania, 17013. 2. Defendant is Collette Rose Morris, who resides at 354 Grahams Woods Road, Carlisle, Pennsylvania, 17013. 3. Plaintiff seeks Full Custody of the following children: NAME PRESENT RESIDENCE AGE Dutra Ernest Henry Morris (D.O.B. 6/8/91) 354 Grahams Woods Road · Dominique John Dutra Morris 354 Grahams Woods Road 7 (D.O.B. 10/21/95) 11 4. During the past five years, the minor children have resided in Cumberland County with their Plaintiff and Defendant at 354 Grahams Woods Road, Carlisle, PA 17013. 5. The relationship of the Plaintiff to the children is that of natural father. 6. The relationship of the Defendant to the children is that of natural mother. 7. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children, Durra Ernest Henry Morris and Dominique John Dutra Morris, in this or any other court. 8. Plaintiff has no information of a custody proceeding concerning the children pending in any court of this Commonwealth or any other state. 9. 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 fights with respect to the children. 10. 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 agreement. 11. The best interests and permanent welfare of the children will be served by granting the relief requested because: · The parties are married and living together, however, lead separate lives; · Defendant has admitted her interest in no longer participating in a marriage with Plainti~ · Defendant has recently stated on many occasions that she would be moving out of the marital home; · Defendant has chosen to work two jobs such that she currently spends approximately only 45 minutes each day with her children~ Defendant has chosen to pursue extra-marital relationships instead of nurturing her children; · Defendant's consumption of alcohol and ephedrine is excessive and as a consequence she is irritable, defensive, and hostile; · Defendant's consumption of alcohol and ephedrine is excessive and as a consequence she can not ensure that her actions will be protective of the children's safety and welfare; · Defendant has chosen a "party" lifestyle that will be detrimental to the healthy development of her children; · Plaintiff has chosen to devote his non-working time to the betterment of his children's mental, emotional, and physical well being; · Plaintiff's actions, both in his children's presence and in his children's absence, set a healthy moral example for his children; · Plaintiff has helped provide for his children's fundamental needs since their birth; · Plaintiff has nurtured in his children an interest in participating in the School and Church; and · Plaintiff's lifestyle can provide stability, guidance, and motivation for his children. WHEREFORE, Plaintiff requests this Court to grant his request for Custody of the children. for the Plaintiff John C. Porter Pa Sup. Ct. ID# 90152 61 West Louther Street Carlisle, Pennsylvania 17013 VERIFICATION I veri~ that the statements made in this complaint are true and correct. I understand that false statements made herein are subject to the penalties under 18 Pa. C S. Sec. 4904 relating to unsworn falsification to authorities. P(ainliff ~ HENRY MORRIS PLAINTIFF COLLETE ROSE MORRIS DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 03-2576 CIVIL AC'liON LAW : : IN CUSTODY ORDER OF COURT AND NOW, Friday, June 06, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqlueline M. Verney, Esq. , the conciliator, at 4thFIoor, Cumberland County Courthouse, Carlisle on Tuesday, July01,2003 at 1:30 PM 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 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 al)pear 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 TItE COURT, By: /s/ _lacqueline 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 om' 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 TItlS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TItE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 HENRY MORRIS Plaintiff COLLETE ROSE MORRIS Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-2576 CIVIL ACTION - LAW IN CUSTODY CERTIFICATE OF SERVICE I, John C. Porter, Counsel for the Plaintiff, Henry Morris, hereby certify that tree and correct copies of the Order of Court and Custody Complaint in the above captioned case were served upon Collete Rose Morris, in the following manner: First Class Prepaid Postage to Collete Rose Morris 354 Grahams Woods Road Carlisle, PA 17013 on this 9'h day of June, 2003. Counsel for Plaintiff PA Sup. Ct. ID# 90152 61 W. Louther St. Carlisle, PA 17013 717-249-1177 HENRY MORRIS, Plaintiff COLLETE ROSE MORRIS, Defendant/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2003-2576 CIVIL TERM : : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 9th day of March, 2004, this matter having been continued on July 1, 2003 and not hearing from counsel to schedule the matter, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, °Jacq~line M. Vemey~-ssqhire, Cust~toi