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HomeMy WebLinkAbout03-2664IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -- LAW LONNIE GROSS, SR., Plaintiff, VS. MEGHANN K. STACK, Defendant. No. i~X?~/- ~t Action in Custody CUSTODY COMPLAINT 1. The Plaintiff is Lonnie Gross, Sr., who currently resides at 760 Chickies Drive, Columbia, Lancaster County, Pennsylvania. 2. The Defendant is Meghann K. Stack, who currently resides at 228 South 15th Street, Camp Hill, Cumberland County, Pennsylvania. Plaintiff seeks Partial Physical Custody of the following child: Name Age Date of Birth Brian T. Stack 1 year 5/18/02 Present Residence 228 South 15th St. Camp Hill, PA 4. The child was bom out of wedlock to Plaintiff and Defendant. 5. The child, Brian T. Stack is presently in the custody of the Defendant, who resides at 228 South 15th Street, Cumberland County Pennsylvania. 6. During the past five years, the child has resided with the following individuals and at the following addresses: a. From birth until the present with the Defendant at 228 South 15th Street, Camp Hill, PA 7. The relationship of Plaintiff to the child is that of Father, and the Plaintiff currently resides at 760 Chickies Drive, Columbia, PA, with his Wife and two children. 8. The relationship of Defendant to the child is that of Mother, and the Defendant currently resides at 228 South 15th Street, Camp Hill, PA. 9. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child pending in a court of this Commonwealth. 10. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 11. 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 rights with respect to the child. 12. The best interest and permanent welfare of the child will be served by granting the requested relief because the Plaintiff is desirous of developing a parental relationship with his child. 13. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiffrequests your Honorable Court to grant Partial Physical Custody of the child, Brian T. Stack, to Plaintiff. Respectfully submitted, By: l~aVid'J. Na/an, Esquire Attorney for Plaintiff Attorney I. D. No. 58054 53 North Duke St., Suite 216 Lancaster, PA 17602 (717) 399-9755 VERIFICATION I verify that the statements made in the foregoing document are tree and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Dated: ~- ~'"'~0 .,~ ~__ Lonnie Gross, Sr. Plaintiff LONNIE GROSS, SR. : PLAINTIFF : MEGHANNK. STACK DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-2664 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, June 11, 2003 ., 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 301 Market Street, Lemoyae, PA 17043 on _ Thursday, July 17, 2003 at _8:30 AM 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 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/ Melissa P. Gree~Jy. 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 ItAVE 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 32 South Bedford Street Carlisle, Pennsylvania 170 l 3 Telephone (717) 249-3166 LONNIE GROSS, SR., Plaintiff V. MEGHANN K. STACK, Defendant NOV 1 2 2003 iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2664 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this /? day of November, 2003, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. The prior Order of this Court dated August 13, 2003 is VACATED and replaced with the following. 2. Le.qal Custody. The Mother, Meghann K. Stack, shall have sole legal custody of the minor child, Brian T. Stack, born May 18, 2002. Father's rights of partial custody which shall be arranged as the parties agree. Physical Custody. Mother shall have primary physical custody subject to Dist: ~,E'onnie Gross, Sr., 760 Chickies Drive, Columbia, PA 17512 /Anthony T. McBeth, Esquire, 407 N. Front Street, Harrisburg, PA 17101 LONNIE GROSS, SR., Plaintiff MEGHANN K. STACK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2664 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT, IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child who is the subject of this litigation is as follows: NAME Brian T. Stack DATE OF BIRTH CURRENTLYIN THE CUSTODY OF May 18, 2002 Mother 2. A Custody Conciliation Conference was held on November 3, 2003 with the following individuals in attendance: the Father, Lonnie Gross, Sr., attended pro se; the Mother, Meghann K. Stack, and her counsel, Anthony T. McBeth, Esquire. Date Melissa Peel Greevy, Esquire Custody Conciliator :220713