HomeMy WebLinkAbout01-06400
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KRISTY GREEN
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
01-6400 CIVIL ACTION LAW
WESTON GREEN, JR
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW, Monday, November 26, 2001 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Thnrsday, December 20, 2001 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, alld Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: Isl
Hubert X. Gilroy. 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 acconimodations
available to disabled individuals having business before the court, please contact our office. AU 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 ATIORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumber land County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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KRISTY GREEN
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA.
VS.
NO. (j 1- (J; 4 GO
WESTON GREEN, JR.
Defendant.
CIVIL ACTION -LAW
COMPLAINT FOR CUSTODY
1 . The Plaintiff is Kristy Green, residing at 161 Frytown Road, Carlisle,
Cumberland County, Pennsylvania.
2. The Defendant is Weston Green, Jr., residing at 155 East North Street
Apartment A Carlisle, Cumberland County, Pennsylvania.
3. The Plaintiff seeks custody of the foiiowing chiid:
Name
Present Residence
Aae
Kayleigh Green
161 Fry town Road, Carlisle, PA
7 Y2 months
The child was born on March 20, 2001. She is presently in the custody of
Plaintiff, Kristy Green, who resides at 161 Frytown Road, Carlisle, Pennsylvania.
During the child's lifetime, she has resided with the following persons and
at the following addresses:
Name
Address
Date
1.
Kristy and Weston Green, Jr. 155 East North Street
Apartment A
Carlisle, PA17013
birth to 11 /9/01
2.
Kristy Green 1 61 Fry town Road
Carlisle, PA 17013
11/9/01 to present
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The mother of the child is Kristy Green, currently residing at 161 Frytown
Road, Carlisle, Pennsylvania. She is married.
The father of the child is Weston Green, Jr. currently residing at 155 East
North Street, Apartment A Carlisle, Pennsylvania. He is married.
4. The relationship of Plaintiff to the child is that of Mother.
5. The relationship of Defendant to the child is that of Father.
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 any
other court ,
7. The Plaintiff has no information of a custody proceeding
concerning the child pending in a court of this Commonwealth,
8. The 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.
9. The best interest and permanent welfare of the child will be served
by granting the relief requested for reasons including the following:
a. The mother has been the primary caregiver of the child from her
birth. She has:
1.) planned and prepared meals
2.) bathed, groomed and dressed the child
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3.) purchased, cleaned and cared for the child's clothing
4.) arraigned medical care, including nursing and trips to physicians
5.) arranged aiternative daycare
6.) put the child to bed nightly, attended the child in the middle of
the night
b, The child has a psychological bond with Mother;
c. Mother has been extremely accommodating to Father's work
schedule and has remained flexible to allow his visitation;
d. Mother continues to provide a stable environment for the child;
10. Each parent whose parental rights to the child have not been
terminated has been named as parties to this action.
WHEREFORE, the Plaintiff prays that This Honorable Court grant her primary
physical custody of their child.
Respectfully submitted,
ABOM & KUTULAKIS, L.L.P.
Date: November 9, 2001
Jaso P. Kutuiakis, Esquire
1.0. #80411
8 South Hanover Street Suite 204
Carlisle, PA 17013
(717) 249-0900
Attorney for Plaintiff
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VERIFICATION
I, Kristy Green, hereby verify that the facts set forth in the foregoing
Custody Complaint are true and correct to the best of my knowledge, information and
belief.
I rmderstand that false statements herein are made subject to the penalties
of 18 Pa.C.S. ~4904, relating to rmswom falsification to authorities.
Date: November 9, 2001
~~L
Kristy reen
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LAW OFFICES OF
STEPHENJ. HOGG
19S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
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ROSE BROWN,
Plaintiff
: IN THE COURT
: OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
v.
CIVIL ACTION-LAW
COURTYARDS OF CARLISLE,
YOUR TOWNE BUILDERS, INC.,
and JACK GAUGHEN REALTORS,
Defendants
: NO. 01-6409
: CIVIL TERM
: JURY TRIAL DEMANDED
PRAECIPE FOR DISSMISSAL
TO THE PROTHONOTARY OF SAID COURT:
Please dismiss the Complaint in the above captioned matter
with prejudice.
Respectfully Submitted,
Date:
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,KRISTY GREEN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
CIVIL ACTION - LAW
WESTONE GREEN, JR.,
Defendant
NO. 01 - 6400 CML
IN CUSTODY
COURT ORDER
Ct
AND NOW, this <.{'t' day of December, 2003, this case coming before the
conciliator on the request of the Court Administrator to address the outstanding referral for
a conciliator and the conciliator being advised that the parties had previously resolved the
matter without the need of further involvement of the conciliator, the conciliator
relinquishes jurisdiction.
BY THE COURT,
o
. Gilroy
Conciliator
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