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HomeMy WebLinkAbout03-2929TAMMY ANDERSON, Plaintiff JAMES E. ANDERSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CHILD CUSTODY NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property, or other rights important to you, including child custody, or child visitation. 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 TAMMY ANDERSON, Plaintiff JAMES E. ANDERSON, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO.- .291c/ : CIVIL ACTION - LAW : CHILD CUSTODY COMPLAINT FOR CHILD CUSTODY AND NOW comes the Plaintiff, Tammy Anderson, by and through her attorney, Mark T. Silliker, Esquire, and respectfully requests this Honorable Court award her custody of the subject minor child, and in support thereto, avers the following: 1. Plaintiff is Tammy Anderson, an adult individual residing at 4270 Wertzville Road, Enola, Cumberland County, Pennsylvania. 17025. 2. Defendant is James E. Anderson, an adult individual residing at 46 Betty Nelson Court, Lot 127, Carlisle, Cumberland County, Pennsylvania. 17013. 3. The subject child is Amanda K. Anderson, bom October 29, 2002. 4. The relationship of the Plaintiffto the subject minor child is that of natural mother. of natural father. The relationship of the Defendant to the subject minor child is that 6. The minor child has resided at the following addresses, in the custody of the following individuals: A. From birth until June 14, 2003, the subject minor child resided at 46 Betty Nelson Court, Lot 127, with Mother and Father. B. From June 14, 2003 to the present, the subject minor child has resided at 4270 Wertzville Road, Enola, Cumberland County, Pennsylvania with Mother, Maternal Grandmother, Maternal Grandmother's companion and his aunt Susan Miller. 7. There have been no prior actions for custody of the subject minor child in this or any other jurisdiction. 8. The Plaintiff is not aware of the existence of any other individuals who have any type of claim whatsoever regarding the custody of the subject minor child. 9. The Plaintiff believes and therefore avers that she is much better able to meet the needs of the subject minor child than the Defendant. 10. The Plaintiff believes and therefore avers that it is in the best interest of the subject minor child that she be placed in her legal and physical custody. WHEREFORE, Plaintiff requests this Honorable Court award her custody of the subject minor child. Respectfully submitted, THE LAW OFFICES OF 5922 Linglestown Road Harrisburg, PA 17112 (717) 671-1500 I.D. No. 33671 Attorney for Plaintiff TAMMY ANDERSON, Plaintiff JAMES E. ANDERSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW CHILD CUSTODY AFFIDAVIT Subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities, I, Mark T. Silliker, Esquire, declare that I am the attorney for Plaintiff; that I am authorized to make this verification on her behalf; that the facts set forth in the aforegoing Custody Complaint are based upon information supplied to me by my client and upon my own knowledge which I believe to be tree and correct, and time is of the essence. Date: Silliker, Esquire TAMMY ANDERSON PLAINTIFF V. JAMES E. ANDERSON DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 03-2929 CIVIL ACTION LAW : : IN CUSTODY ORDER OF COURT AND NOW, _ Tuesday, June 24, 2003 , upon con~gideration 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, Mechaniesburg, PA 17055 on Wednesday, July 16, 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 TIlE COURT, By: /s/ Dawn S. Sunday. 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 facilihes 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 ]rlELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 TAMMY ANDERSON, Plaintiff VS. UUL ~ u LUU...1 IN THE CO[TRT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-2929 C1VIL ACTION LAW JAMES E. ANDERSON Defendant IN CUSTODY ORDER OF COURT AND NOW, this ~_~1~ day of po~g' _, 2003, upon consideration of the attached Custody Conciliation [ it is ordered and directed as follows: 1. The Mother, Tammy Anderson, and the Father, James Anderson, shall have shared legal custody of Amanda K. Anderson, born October 29, 2002. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 2. The parties shall have physical custody of the Child as follows: A. The Father shall have supervised periods of custody at his sister's residence on Wednesday, July 16, 2003 from 4:00 pm until 6:00 pm, on Saturday, July 19, 2003 from 3:00 pm until 5:30 pm and on Sunday, July 20, 2002; from 12:00 noon until 6:00 pm. B. The Father shall have a period of unsupervised custody with the Child at his residence on Tuesday, July 22, 2003 from 12:00 noon until 4:00 pm. C. Thereafter, the parties shall cooperate in expanding the Father's contact with the Child, by agreement in accordance with the Child's ,ongoing adjustment to a more shared arrangement. D. The Mother shall have custody of the Child at all times not otherwise specified for the Father in this Order. 3. Beginning with the Father's period of custody on July 22. 2003, the parties shall exchange custody of the Child at the Hess gas station on Route 11, between Enola and Carlisle. 4. The Father shall obtain the Child's playpen from the Mother's residence at a time arranged by agreement between the parties. The parties agree to share the Mother's car seat for the Child's use until the Father obtains an appropriate car seat for his vehicle. 5. In the event the parties are unable to establish ongoing custody arrangements by agreement, counsel for either party may contact the conciliator within three months of the date of this Order to schedule an additional custody conciliation conference. 6. This Order is entered pursuant to an agreement of the pm'ties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. cc: '~Vlark T. Silliker, Esquire - Counsel for Mother JJoan Carey, Esquire and Amy Kruzel, Legal Intern - Counsel fi)r Father TAMMY ANDERSON, Plaintiff VS. JAMES E. ANDERSON Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-2929 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 DATE OF BIRTH CURRENTLY IN CUSTODY OF Amanda K. Anderson October 29, 2002 Mother 2. A Conciliation Conference was held on July 16, 200:3 with the following individuals in attendance: The Mother, Tammy Anderson, with her cotmsel, Mark T. Silliker, Esquire, and the Father, James E. Anderson, and his counsel, Joan Carey, Esquire and Amy Kruzel, Legal Intern. 3. The parties agreed to entry of an Order in the form as attached. Date Custody Conciliator