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HomeMy WebLinkAbout99-03917 1 3 1 i rE Z KENNETH F. LEWIS, ESQUIRE I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff ANNA V. WIEBNER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999 - 3917 Civil Term TROY L. ADAMS, Defendant CIVIL LAW - CUSTODY AFFIDAVIT OF SERVICE I, KENNETH F. LEWIS, ESQUIRE, depose and say that I am the attorney for Plaintiff and that I did mail a true and correct copy of the custody Complaint to Defendant by certified mail, return receipt requested, restricted delivery, addressee only and that Defendant did sign for the Complaint (see green card with Defendant's signature attached hereto). I verify that the statements made in this Affidavit of Service by Mail are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. DATED: 7/20/99/J)!I? (`uL7 KENNETH F. LEWIS ,....won 1 trno'or z for add"b" SWOONS. ,Pde Items e, N. and 4b. Yow nsme and mddrm on au rfr re of Mh form to that wti ?Wq?m?lto youf, m to am from of"mallpbN. or w the Nck If sjZ ATM Ret m Auelpt wl? ftqU*O*d* on the to whom the kd?vM bilow the ankle NYwrW and t deRvered. Tod NOX A P-13'11 6 O S-Mi 40 e ll ualcck Creek, At /SGZI ?ed By: (P f ?s? Ray/-lit csr.? .. I also wish to receive the following eervlces (for an en return Me BxttB fee): ose nol t. ? resese's Addrsse ?t 4 UmbW. 2. Restricted Delivery tL? Consult Postmaster for lee. R. Article Number z.3? ?o899g 3. SeMoe Type ? I Registered ¢ V Certilled I Express Mell? O Insured 5 ! ? Return Receipt O COD Date of Dellve ,?-/(,- C l a Addressee's Address(Onlyl/requested C and lee is paid) c d rF] cr. F? w of mac, N _?'.?s elf. - U L' U JUL z 0 199011 KENNETH F. LEWIS, ESQ. Counsel for Plaintiff; ID #69383 1101 N. Front St., Hbg., PA 17102 (717) 234-3136 ANNA V. WIEBNER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999 - 3917 Civil Term TROY L. ADAMS, Defendant CIVIL LAW - CUSTODY ORDER OF COURT AND NOW, this day of July, 1999, upon consideration of the Petition for Custody filed June 28, 1999, it is hereby directed th t he p rties and thei respective counsel appear t Yea q ? j ?g l ?, Custody before ???CC \ l`'l"'? Conciliator on the a day of 1999, at ?' p0 m., 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 shall also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: By : )mikgn ? 1 ) Custody Conciliato I ) 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. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4th FLOOR CARLISLE, PA 17013 (717) 240-6200 Lan s ,..* ?nn? F YNan Fl EDTO PLEAD /7 ? l.ECVLS ED:WRHIN (20) DAYS REOF:OR"A DEFAULT ATTORNEY AT LAW A)C BE ENTERED 1101 NORTH FRONT STREET HARRISBURG. PENNSYLVANIA 17102 ITORNEY TELEPHONE (717) 2343130 ?? y v4 L ? a>a {i i' f, Y ti y }fh' W z :.M v?: r rr?`,?R? WE DO*EREBV CV MK;.,, 4 KENNETH F. LEWIS, ESQUIRE I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff ANNA V. WIEBNER, Plaintiff V. TROY L. ADAMS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA / NO. S 1999 clot CIVIL LAW - CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you, a custody order may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. 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. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4th FLOOR CARLISLE, PA 17013 (717) 240-6200 KENNETH F. LEWIS, ESQUIRE I.D. $69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff ANNA V. WIEBNER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. .8' 1999 - TROY L. ADAMS, Defendant CIVIL LAW - CUSTODY COMPLAINT IN CUSTODY 1. Plaintiff is Anna V. Wiebner, who currently resides at 49 E. Columbia Road, Enola, Cumberland County, PA 17025. 2. Defendant is Troy L. Adams, who is currently incarcerated at the State Correctional Institute at Retreat, 660 State Routell, Hunlock Creek, PA 18621. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff seeks primary custody of the parties' child, William R. Adams, born October 1, 1995. The child was born out of wedlock. 5. The child is presently in the custody of Plaintiff. 6. Since birth, the child has resided with the Plaintiff, Plaintiff's Mother (Darlene Riedl) and Plaintiff's Stepfather (John Riedl) at Plaintiff's address given above. 7. The relationship of the Plaintiff to the child is that of the natural mother. The Plaintiff currently resides with the subject child, her mother and stepfather. She is single. S. The relationship of the Defendant to the children is that of the natural father. The Defendant is currently incarcerated at the State Correctional Institute at Retreat. He is single. 9. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in any Court of this Commonwealth. 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 children. 10. The best interest and permanent welfare of the child will be served by granting primary custody to Plaintiff as she has been the primary caretaker since the child's birth and will be able to provide maximum stability for the parties' children. Defendant has never lived with the child, nor has ever had a parental role with the child. Defendant saw the child only sporadically until his incarceration in October of 1995, when visits stopped. 11. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the children has been named as parties to this action. 12. It is hoped that the parties will be able to enter into an custody agreement and will request the Court to enter their agreement as an Order of Court. WHEREFORE, Plaintiff requests the Court to grant her primary custody of the parties' child. DATE: 6/28/99"'t?!' KENNETH F. LEWIS, ESQUIRE Attorney I.D. ,#69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. y 4904, relating to unsworn falsification to authorities. DATED: 60M A( ) AMA `?, J / )7A"1 ? ' ,? ?? ? ? n= ? ?? D p '? ? ? ? ? ? ? ?? ? N_ ?\ ANNA V. WIEBNER, ) Plaintiff ) VS. ) TROY L. ADAMS, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3917 CIVIL TERM CIVIL ACTION - LAW CUSTODY ORDER AND NOW, this day of , 1999, it appearing that, the Mother and her counsel appeared for the conciliation and the Father was served with the conciliation notice but because of his incarceration could not appear at the conciliation, it is hereby ordered and directed as follows: 1. Mother shall have primary legal and physical custody of their minor child, William R. Adams, d.o.b. October 1, 1995. 2. Father can petition this court to review an appropriate visitation schedule upon his release from incarceration. Kenneth F. Lewis, Esquire Attorney for Plaintiff Troy L. Adams, pro se mlb _- - ;;.?? .,?. _ „1i, 55 ANNA V. WIEBNER, Plaintiff Vs. TROY L. ADAMS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3917 CIVIL TERM CIVIL ACTION - LAW CUSTODY JUDGE PREVIOUSLY ASSIGNED: None. CUSTODY CpprCILLaTION ?p?rLrHam OM2 RY EP01111 IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), 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 BIRTHDATF CURRENTLY IN CUSTODY OF William R. Adams October 1, 1995 Plaintiff 2. A Conciliation Conference was held on September 2, 1999, and the following individuals were present: the Plaintiff and her attorney, Kenneth F. Lewis, Esquire; the Defendant did not appear. 3. Items resolved by agreement: See attached Order. 4. Issues yet to be resolved: See attached Order. 5. The Plaintiff's position on custody is as follows: See attached Order. 6. The Defendant's position on custody is as follows: See attached Order. 7. Need for separate counsel to represent child: Neither party requested. 6. Need for independent psychological evaluation or counseling: None requested and the Conciliator does not believe any is necessary. Date: September 12, 1999 Micnaei L. Bang Custody Concili y o w ? 5 3"? M a ` ? ? ? n r ? W r ? a S M i4 F? U < r. n U .?i.? ? ..i J 'Jjl: V,.