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HomeMy WebLinkAbout03-3197KAREN C. ADAMS, Plaintiff RONALD E. ADAMS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 0,~- : 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 KAREN C. ADAMS, Plaintiff RONALD E. ADAMS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 7 CIVIL ACTION - LAW CHILD CUSTODY COMPLAINT FOR CHILD CUSTODY AND NOW comes the Plaintiff, Karen C. Adams, by and through her attorney, Mark T. Silliker, Esquire, and respectfully requests this Honorable Court award her custody of the subject minor children, and in support thereto, avers the following: 1. Plaintiff is Karen C. Adams, an adult individual residing at 8 East Willow Terrace, Mechanicsburg, Cumberland County, Pennsylvania. 17050. 2. Defendant is Ronald E. Adams, an adult individual residing at 8 East Willow Terrace, Mechanicsburg, Cumberland County, Pennsylvania. 17050. 3. The subject children are Kelsey R. Adams, bom March 30, 1990 and Logan R. Adams, born September 21, 1992. 4. The relationship of the Plaintiff to the subject minor children is that of natural mother. 5. The relationship of the Defendant to the subject minor children is that of natural father. 6. The minor children have resided at the following addresses, in the custody of the following individuals: A. The children have resided at 8 East Willow Terrace, Mechanicsburg, Cumberland County, PA, in the care and custody of Plaintiff and Defendant since birth. 7. There have been no prior actions for custody of the subject minor children 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 children. 9. The Plaintiff believes and therefore avers that she is much better able to meet the needs of the subject minor children than the Defendant. 10. The Plaintiff believes and therefore avers that it is in the best interest of the subject minor children that they be placed in her legal and physical custody. WHEREFORE, Plaintiff requests this Honorable Court award him/her custody of the subject minor children. Respectfully submitted, Mark T. Silliker, Esquire 5922 Linglestown Road Harrisburg, PA 17112 (717) 671-1500 I.D. No. 33671 Attorney for Plaintiff AFFIDAVIT 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. 4909 relating to unswom falsifications to authorities. Dated: KAREN C. ADAMS PLAINTIFF V. RONALD E. ADAMS DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-3197 CIVIL ACTION LAW : : IN CUSTODY ORDER OF COURT AND NOW, _ Friday, July 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, Lemoyne, PA 17043 on Thursday, August 14, 2003 at 12:30 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 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, Si~ecial Relief orders, and Custody orders to the conciliator 48 hours l~rior to scheduled hearinl~. FOR Tilt COURT, By: /s/ Melissa P. Greevy. 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. Fox' 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 befure 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 THE 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 KAREN C. ADAMS, Plaintiff RONALD E. ADAMS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. : CIVIL ACTION - I_AW : CHILD CUSTODY STIPULATION FOR CHILD CUSTODY AND NOW, this °tg°~ t~day of the undersigned, Karen C. Adams and Ronald E. Adams, parties herein, hereby voluntarily and otherwise knowingly agree to the following: ,2003, 1. The parties hereto are the natural parents of two subject minor children, namely Kelsey R. Adams, born March 30, 1990 and Logan R. Adams, born September 21, 1992. 2. It is the intention of the parties and the parties agree that they will have shared legal custody of the subject minor children. The parties agree that major decisions concerning their children, including, but not necessarily limited to, the children's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the children's best interest. Each party agrees not to impair the other party's rights to shared legal custody of the children. Each party agrees not to attempt to alienate the affections of the children from the other party. Each party shall notify the other of any activity or circumstance concerning their children that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the children at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party as a parent pursuant to 23 Pa.C.S.A. 392. 3. Karen C. Adams shall be entitled to primary physical custody of the subject minor children. 4. Ronald E. Adams shall be entitled to reasonable, liberal and frequent periods of partial custody, including shared holidays and summer vacation periods, with the exact details to be agreed upon between the parties. 5. It is agreed between the parties that they shall take whatever steps are necessary to ensure that the subject minor children reside in an environment free from the use of alcohol products, as well as illegal narcotics, during their custodial periods. It is further understood that a failure to adhere to this provision shall constitute a direct violation of this Order of Court, and it could well expose the offending party to a loss of custody and]or visitation, as well as possible fines and imprisonment. IN WITNESS WHEREOF, the respective parties, intending to be legally bound, do hereby place their signatures and seals on the day and year first written above. Wimess ~'~Wlt~ss K~(enC~Adams (~' ~(~.~2~z_ KAREN C. ADAMS, Plaintiff RONALD E. ADAMS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 03-3197 CIVIL : : CIVIL ACTION - LAW : CHILD CUSTODY ORDER OF COURT AND NOW, this t~Xday °f ~ terms and conditions of the attached Stipulation for Child Custody are hereby incorporated and made an Order of this Honorable Court. ,2003, the KAREN C. ADAMS, Plaintiff RONALD E. ADAMS, Defendant AL ! 2003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-319'7 CIVIL TERM CiViL ACTION - LAW IN CUSTODY ORDER TO RELINQUISH JURISDICTION. AND NOW, this 14th day of August, 2003, the parties having reached an agreement which has been memorialized in a Stipulation and filed with this Court, the Conciliator hereby relinquishes jurisdiction of the above captioned matter. Custody Conciliator :217179