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HomeMy WebLinkAbout99-05545 (2) il o ' i ? r Y .{ l ? A r1r1 A Zvi Y yl k V ; F?f f Y ? "4 s R rR y _ - 4 kf r yt "'W f 4 y e '4fi ?q y H I µ y r '5 r rr.' x r n),: t r ar F , 1 :M1 k: } t!5 ! r ' NY" SEP ; tqg ROBERT A. YOUNG, JR. and IN THE COURT OF COMMON PLEAS JANET M. YOUNG, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. NO. 99. 5545 CRAIG A. ROY and LORI ANN YOUNG, CIVIL ACTION-LAW Defendants CUSTODY ORDER OF COURT AND NOW, this is day of S-dt4-La 1999, upon consideration of the attached Petition for Emergency Relief Seeking Primary Physical and Legal Custody of the Minor Child, Petitioners' requested relief is hereby GRANTED. Petitioners are awarded temporary primary physical and legal custody of the minor child, Justin M. Young, born March 9, 1991, until further Order of Court. Lori Ann Young is hereby granted liberal visitation as the parties may agree. Any party to this action may request a Hearing before the Court. Petitioners shall attempt to serve all parties to this action with a copy of this Order via State Constable or Sheriffs Department BY THE COURT -l 1/9a, 7 -R„r 1, T J. '... ,j? ..1 Qw1 11? i (1 I `i ?J..i C?Jh J?`:1 1 ROBERT A. YOUNG, JR. and IN THE COURT OF COMMON PLEAS JANET M. YOUNG, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. NO. 99- 5545 CRAIG A. ROY and LORI ANN YOUNG, CIVIL ACTION-LAW Defendants CUSTODY ORDER OF COURT AND NOW, this day of 1999, upon consideration of the attached Petition for Emergency Relief Seeking Primary Physical and Legal Custody of the Minor Child, Petitioners' requested relief is hereby GRANTED. Petitioners are awarded temporary primary physical and legal custody of the minor child, Justin M. Young, born March 9, 1991, until further Order of Court. Lori Ann Young is hereby granted liberal visitation as the parties may agree. A Hearing is hereby scheduled for the day of 1999, at o'clock _ m. in Courtroom of the Cumberland County Courthouse. Petitioners shall attempt to serve all parties to this action with a copy of this Order via State Constable or Sheriffs Department BY THE COURT, PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 ROBERT A. YOUNG, JR. and JANET M. YOUNG, Plaintiffs V. CRAIG A. ROY and LORI ANN YOUNG, Defendants Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- 5545 CIVIL ACTION-LAW CUSTODY AND NOW, COME the Plaintiffs, Robert A Young and Janet M. Young, by and through his attorney, Peter J. Russo, Esquire, and respectfully submits the following in support of Plaintiffs' Petition for Emergency Relief Seeking Sole and Full Custody: 1. The Plaintiffs are, Robert A Young, and Janet M. Young, husband and wife, residing at 5227 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant Roy, is Craig A Roy, with a last know address of 2nd Street, Harrisburg, Dauphin County, Pennsylvania 17102. 3. Defendant Young, is Lori Ann Young, with a last know address of Molly Pitcher Hotel, 13 South Hanover Street 2nd Street, Carlisle, Cumberland County, Pennsylvania 17013. 4. Plaintiffs seeks custody of the following child: Nam Present Residence Justin M. Young 5227 Royal Drive ?1 Mechanicsburg, PA 5. The child was bom out of wedlock 6. ' The child is presently in the custody of the Plaintiffs, Robert A. Young and Janet M. Young, who reside at 5227 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 7. In the last five years the children have resided with the following persons and at the following address: Name Address Dates Defendant Molly Pitcher Hotel 1/96 - 6/99 Defendant Manion Inn 6/99 - 7/99 Defendant Lincoln Motel 7/99 - 6/99 Defendant Molly Pitcher Hotel 9/99 -9/10/99 6. Defendant Roy, is the father of the child, with a last know address of 2nd Street, Harrisburg, Dauphin County, Pennsylvania 17102. His marital status is unknown. Defendant Roy currently resides with the following persons: Name Relationship Unknown 9. Defendant Young, is the mother of the child, with a last know address of Molly Pitcher Hotel, 13 South Hanover Street 2nd Street, Carlisle, Cumberland County, Pennsylvania 17013. She is single. Defendant Young currently resides with the following persons: Name Relationship Unknown 10. The Plaintiffs, Robert A Young and Janet M. Young, are the maternal grandparents of the subject minor child and reside alone at 5227 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 11. Plaintiffs have not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 12. Plaintiffs have no information of a custody proceeding conceming the child pending in a court of this Commonwealth. 13. Plaintiffs do 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 right with respect to the child. 14. The best interest and permanent welfare of the child will be served by granting the relief requested because of the facts alleged herein: a. Plaintiffs have filed a Custody Complaint in the Court of Common Pleas of Cumberland County. A true and correct of said Complaint is attached hereto as Exhibit A. b. The natural mother has become homeless. c. The natural father has had no contact with the natural mother or his child since the child's birth. d. The child is eight years old and must be enrolled in school. e. As natural mother has no permanent address and cannot care for the needs of her son, the Plaintiffs have agreed to take over responsibility for the minor child's welfare. f. The natural mother has executed an affidavit which has been attached hereto as Exhibit 8 which supports Plaintiffs' Petition. 15. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim NONE WHEREFORE, Plaintiff requests this Honorable Court to order that primary physical and legal custody of the minor child, Justin M. Young, be placed with Plaintiffs. Respectfully submitted, Peter J. Russo Attorney for Plaintiffs Date: q 1 (0 1 g y VERIFICATION I, Robert A. Young, verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. *A.oung, Robert Jr. Dated: 9 a VERIFICATION I, Janet M. Young, verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. J M. Young Dated: 6 'IoL 61 VERIFICATION I, Lori A. Young, verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. Dated: 711019q A. LV U on A. Young EXHIBIT A AFFIDAVIT Lori A. Young, the undersigned aver as follows: I am the natural mother of Justin M. Young, born March 9, 1991. 2. 1 have been the primary caretaker of my child since his birth. 3. The child's natural father Craig Foy has had no contact with our son since its birth. 4. Presently, I am without a permanent residence and can not provide for my child's needs or safety. 5. 1 believe it would be in my child's best interest to reside with my parents, Robert A. Young, Jr. and Janet M. Young, until I can provide reasonable appropriate living conditions. 6. 1 am in agreement that this matter requires Robert A. Young, Jr. and Janet M. Young's involvement in this matter and I consent to their appointment as legal custodian and primary physical custodian of my child. I verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. 9 /U ?q Date Date lM Lo&A. Young ?? OTAMALSM NotaryNOWMWB,co,vn CWAM MAY SW ?reo!ON- EXHIBIT B ROBERT A. YOUNG, JR. and JANET M. YOUNG, Plaintiffs V. CRAIG A. ROY and LORI ANN YOUNG, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- CIVIL ACTION-LAW CUSTODY ORDER OF COURT AND NOW, this day of , 1999, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before the Conciliator, at on the day of , 1999, at _.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 may at the request of either attorney or party, be present at the conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT, By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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 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 Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 61 West Loather Street Carlisle, PA 17013 (717) 249-2721 ROBERT A. YOUNG, JR, and JANET M. YOUNG, Plaintiffs V. CRAIG A. ROY and LORI ANN YOUNG, Defendants Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 89- CML ACTION-LAW CUSTODY PETITION FOR CUSTODY AND NOW, COME the Plaintiffs, Robert A Young and Janet M. Young, by and through his attorney, Peter J. Russo, Esquire, and respectfully submits the following: 1. The Plaintiffs are, Robert A Young, and Janet M. Young, husband and wife, residing at 5227 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant Roy, is Craig A Roy, with a last know address of 2nd Street, Harrisburg, Dauphin County, Pennsylvania 17102. 3. Defendant Young, is Lori Ann Young, with a last know address of Molly Pitcher Hotel, 13 South Hanover Street 2nd Street, Carlisle, Cumberland County, Pennsylvania 17013. 4, Plaintiffs seeks custody of the following child: Name Present Residence DOB Justin M. Young 5227 Royal Drive 3/9/91 Mechanicsburg, PA 5. The child was born out of wedlock 6. The child is presently in the custody of the Plaintiffs, Robert A Young and Janet M. Young, who reside at 5227 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 7. In the last five years the children have resided with the following persons and at the following address: NAM Address Dates Defendant Molly Pitcher Hotel 1/96 - 6/99 Defendant Marvon Inn 6199 - 7/99 Defendant Lincoln Motel 7/99 - 6/99 Defendant Molly Pitcher Hotel 9/99 - 9/10/99 6. Defendant Roy, is the father of the child, with a last know address of 2nd Street, Harrisburg, Dauphin County, Pennsylvania 17102. His marital status is unknown. Defendant Roy currently resides with the following persons: Name Relationship Unknown 9. Defendant Young, is the mother of the child, with a last know address of Molly Pitcher Hotel, 13 South Hanover Street 2nd Street, Carlisle, Cumberland County, Pennsylvania 17013. She is single. Defendant Young currently resides with the following persons: Name Relationship Unknown 10. The Plaintiffs, Robert A Young and Janet M. Young, are the maternal grandparents of the subject minor child and reside alone at ,5227 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 11. Plaintiffs have not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 12. Plaintiffs have no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 13. Plaintiffs do 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 right with respect to the child. 14. The best interest and permanent welfare of the child will be served by granting the relief requested because of the facts alleged herein: a. The natural mother has become homeless. b. The natural father has had no contact with the natural mother or his child since the child's birth. c. The Plaintiffs can provide a stable home and provide for the needs of the subject minor child. 15. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim NONE WHEREFORE, Plaintiff requests this Honorable Court to order that primary physical and legal custody of the minor child, Justin M. Young, be placed with Plaintiffs. t I submitte , Pe er J. Russo gate: 9 (to) Attorney for Plaintiffs qq VERIFICATION I, Robert A. Young, verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. E g? Robert . Young, r. Dated: 9 /o VERIFICATION I, Janet M. Young, verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. J M. Young Dated: O VERIFICATION I, Lori A. Young, verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unswom falsification to authorities. e. ` T A .Young Dated: -3 1 /0 1 lf' I?f C. l1 ? ? V. Cd r SEP 10 1999 ROBERT A. YOUNG, JR. and IN THE COURT OF COMMON PLEAS JANET M. YOUNG, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. CRAIG A ROY and NO. 89- 5545 Cu Q T? cfrt LORI ANN YOUNG, CIVIL ACTION-LAW Defendants CUSTODY ORDER OF COURT AND NOW, this day of 1999, upon consideration of the attached Complaint, it is hereby directs that e a'n'd their respective counsel appear before _?]N?1r? ?, .C c?r1g? r c the Conciliator, the day of 1999, at _.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 may at the request of either attorney or party, be present at the conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT, Custody Conciliator t ) By '. The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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 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 Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 I , PETER J. RUSSO, ESQUIRE Attorney for Plaintiff PA Supreme Court ID: 72897 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 ROBERT A. YOUNG, JR. and IN THE COURT OF COMMON PLEAS JANET M. YOUNG, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. CRAIG A. ROY and NO. 99? Jr `._& j? LORI ANN YOUNG, CIVIL ACTION-LAW Defendants CUSTODY PETITION FOR CUSTODY AND NOW, COME the Plaintiffs, Robert A Young and Janet M. Young, by and through his attorney, Peter J. Russo, Esquire, and respectfully submits the following: 1. The Plaintiffs are, Robert A Young, and Janet M. Young, husband and wife, residing at 5227 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant Roy, is Craig A. Roy, with a last know address of 2nd Street, Harrisburg, Dauphin County, Pennsylvania 17102. 3. Defendant Young, is Lori Ann Young, with a last know address of Molly Pitcher Hotel, 13 South Hanover Street 2nd Street, Carlisle, Cumberland County, Pennsylvania 17013. 4. Plaintiffs seeks custody of the following child: Name Present Residence DOB Justin M. Young 5227 Royal Drive 319/91 Mechanicsburg, PA 5. The child was bom out of wedlock. 6. The child is presently in the custody of the Plaintiffs, Robert A Young and Janet M. Young, who reside at 5227 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 7. In the last five years the children have resided with the following persons and at the following address: Name Address Dates Defendant Molly Pitcher Hotel 1/98-6/99 Defendant Marvon Inn 6/99 - 7/99 Defendant Lincoln Motel 7/99 - 8199 Defendant Molly Pitcher Hotel 9/99 - 9/10/99 8. Defendant Roy, is the father of the child, with a last know address of 2nd Street, Harrisburg, Dauphin County, Pennsylvania 17102. His marital status is unknown. Defendant Roy currently resides with the following persons: Name Relationship Unknown 9. Defendant Young, is the mother of the child, with a last know address of Molly Pitcher Hotel, 13 South Hanover Street 2nd Street, Carlisle, Cumberland County, Pennsylvania 17013. She is single. Defendant Young currently resides with the following persons: Name Relationship Unknown 10. The Plaintiffs, Robert A. Young and Janet M. Young, are the maternal grandparents of the subject minor child and reside alone at 5227 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 11. Plaintiffs have not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 12. Plaintiffs have no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 13. Plaintiffs do 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 right with respect to the child. 14. The best interest and permanent welfare of the child will be served by granting the relief requested because of the facts alleged herein: a. The natural mother has become homeless. b. The natural father has had no contact with the natural mother or his child since the child's birth. C. The Plaintiffs can provide a stable home and provide for the needs of the subject minor child. 15. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim NONE WHEREFORE, Plaintiff requests this Honorable Court to order that primary physical and legal custody of the minor child, Justin M. Young, be placed with Plaintiffs. 7er II submitte , usso Date : g110)gq Attorney for Plaintiffs VERIFICATION I, Robert A. Young, verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. Robert . Young, Tr. ` Dated: 9/ /off g VERIFICATION I, Janet M. Young, verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. J M. Young Dated: O VERIFICATION I, Lori A. Young, verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. i A. Young Dated: A / 'J S ? = Oo eonc,A .r SEP I ROBERT A YOUNG, JR and JANET M. YOUNG, Plaintiffs V. CRAIG A. ROY and LORI ANN YOUNG, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. W SSg5 CIVIL ACTION-LAW CUSTODY ORDER OF COURT AND NOW, this day of , 1999, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before at the Conciliator, . "-,n n# 41- M. for a Pre-Hearing Custody solve the issues in dispute; or and to enter into 2 ?os to be heard by the Court, either attorney to it older may at the request of may provide groin QQ ^ _ e to appear at the Conference ?- L? (? ,?-fxl R nt Order. j t THE COURT, ;ustody Conciliator The Court of C uired by law to comply the Americans with 9?ro f99 about accessible faciities and reasonable accL.... _ jals having business before the court, please cordactour afr"., All anangwiaa iw ,,.,.... _.i mad at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. the dc Conference. At su! I this cannot be ai 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 Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166 1991 SEP 1 0 19991 ROBERT A. YOUNG, JR. and IN THE COURT OF COMMON PLEAS JANET M. YOUNG, CUMBERLAND COUNTY, PENNSYLVANIA Plaintifs V. CRAIG A. ROY and NO. 99- 55 S LORI ANN YOUNG, CML ACTION-LAW Defendants CUSTODY ORDER OF COURT AND NOW, this day of , 1999, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before the Conciliator, at an the day of , 1999, at .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 may at the request of either attorney or party, be present at the conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT, By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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 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 Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 PETER J. RUSSO, ESQUIRE Attorney for Plaintiff PA Supreme Cant ID: 72897 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 ROBERT A. YOUNG, JR. and IN THE COURT OF COMMON PLEAS JANET M. YOUNG, CUMBERLAND COUNTY, PENNSYLVANIA PlaintUfs v. r, NO. 99- CRAIG A. ROY and LORI ANNA NAG, CCIVIL OACT ON-LAW , PETITION FOR CUSTODY < n AND NOW, COME the Plaintiffs, Robert A Young and Janet M. Young, by and through his attorney, Peter J. Russo, Esquire, and respectfully submits the following: 1. The Plaintiffs are, Robert A Young, and Janet M. Young, husband and wife, residing at 5227 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant Roy, is Craig A Roy, with a last know address of 2nd Street, Harrisburg, Dauphin County, Pennsylvania 17102. 3. Defendant Young, is Lori Ann Young, with a last know address of Molly Pitcher Hotel, 13 South Hanover Street 2nd Street, Carlisle, Cumberland County, Pennsylvania 17013. 4. Plaintiffs seeks custody of the following child: Name Present Residence DOB Justin M. Young 5227 Royal Drive 3/9/91 Mechanicsburg, PA t 5. The child was bom out of wedlock 6. The child is presently in the custody of the Plaintiffs, Robert A Young and Janet M. Young, who reside at 5227 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 7. In the last five years the children have resided with the following persons and at the following address: Name Address Dates Defendant Molly Pitcher Hotel 1/98 - 6199 Defendant Marvon Inn 6/99 - 7199 Defendant Lincoln Motel 7/99 - 8/99 Defendant Molly Pitcher Hotel 9/99 -9110/99 8. Defendant Roy, is the father of the child, with a last know address of 2nd Street, Harrisburg, Dauphin County, Pennsylvania 17102. His marital status is unknown. Defendant Roy currently resides with the following persons: Name Relationship Unknown 9. Defendant Young, is the mother of the child, with a last know address of Molly Pitcher Hotel, 13 South Hanover Street 2nd Street, Carlisle, Cumberland County, Pennsylvania 17013. She is single. Defendant Young currently resides with the following persons: Name Relationship Unknown 10. The Plaintiffs, Robert A. Young and Janet M. Young, are the maternal grandparents of the subject minor child and reside alone at 5227 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 11. Plaintiffs have not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 12. Plaintiffs have no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 13. Plaintiffs do 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 right with respect to the child. 14. The best interest and permanent welfare of the child will be served by granting the relief requested because of the facts alleged herein: a. The natural mother has become homeless. b. The natural father has had no contact with the natural mother or his child since the child's birth. c. The Plaintiffs can provide a stable home and provide for the needs of the subject minor child. 15. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim NONE WHEREFORE, Plaintiff requests this Honorable Court to order that primary physical and legal custody of the minor child, Justin M. Young, be placed with Plaintiffs. spectf I submitt? Peer J. Russo Date: 011I01qq Attorney for Plaintiffs VERIFICATION I, Robert A. Young, verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unswom falsification to authorities. qI Robert . Young, r. Dated: 9 /o VERIFICATION I, Janet M. Young, verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. J M. Young m Dated: O VERIFICATION I, Lori A. Young, verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unswom falsification to authorities. A. Young Dated: q) /6 Iqq SEP 10 1999 ROBERT A. YOUNG, JR. and IN THE COURT OF COMMON PLEAS JANET M. YOUNG, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. NO. W5-9 4 5 CL? l ecm CRAIG A. ROY and CML ACTION-LAW ANNYOUNG$ LORI Defendants CUSTODY ORDER OF COURT AND NOW, this day of 1999, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before the Conciliator, at on the day of , 1999, at _ 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 may at the request of either attamey or party, be present at the conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT, By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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 HAE SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU E LAWYER OR CANNOT AFFORD ONE, O TO OR TELEPHONE H NOT OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 SEP 10 1999 ROBERT A. YOUNG, JR. and IN THE COURT OF COMMON PLEAS JANET M. YOUNG, CUMBERLAND COUNTY, PENNSYLVANIA Plainuffs V. NO. 99- 5545 CAP Term CRAIG A. ROY and LORI ANN YOUNG, CIVIL ACTION-LAW Defendants CUSTODY ORDER OF COURT AND NOW, this day of . 1999, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before the Conciliator, at on the day of , 1999, at _.m. for a Pre-Hearing Custody Conference. At such Conference, an effort will be made to resolve the issues in dispute; or N 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 at the request of either attorney or party, be present at the conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT, By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable aocommodations available to disabled individuals having business before the court, please contact our office. Al 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 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 Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 ROBERT A. YOUNG, JR. and JANET M. YOUNG, Plaintiffs V. CRAIG A. ROY and LORI ANN YOUNG, Defendants IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY No. 99.5545 CIVIL TERM CIVIL ACTION - LAW CUSTODY PRAECIPE TO CHANGE CAPTION TO THE PROTHONOTARY: Kindly enter this Praecipe to Change Caption in the above-captioned matter to the following, noting the change in the Defendant's Roy's name: ROBERTA. YOUNG, JR. and JANET M. YOUNG, Plaintiffs IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY V. CRAIG A. FOY and LORI ANN YOUNG, Defendants No. 99-5545 CIVIL TERM CIVIL ACTION - LAW CUSTODY Re§pectfu I ly_auhrnitted, Peter J. Russo 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 Dated: 10 1 1 19 9 ' ? O r1:L ? =) r SEP 10 1999 ROBERT YOUNG, JR. and CIN THE COURT OF COMMON PLEAS UMBERLAND COUNTY, PENNSYLVANIA JANET M. . YOUNG, Plaintiffs NO. 99- 5545 C°? -VV Cry) CRAIG A. ROY and LORI ANN YOUNG, CIVIL ACTION-LAW Defendants CUSTODY ORDER OF COURT AND NOW, this day of , 1999, upon consideration of the attached Complaint, it is hereby directe that the parties and their respective counsel appear before J k , the Conciliator, at U. z on the day of 1999, at -.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 may at the request of either attorney or party, be present at the conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT, By:?i Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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 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 Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 h PETER J. RUSSO, ESQUIRE Attorney for Plaintiff PA Supreme Court ID: 72897 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 ROBERT A. YOUNG, JR. and CIN THE COURT OF COMMON UMBERLAND COUNTY, JANET M. YOUNG, PENNSYLVANIA • Plaintiffs V. NO. 99- 5S45 Co _v Q-Term CRAIG A. ROY and LORI ANN YOUNG, CIVIL ACTION-LAW Defendants CUSTODY PETITION FOR CUSTODY AND NOW, COME the Plaintiffs, Robert A Young and Janet M. Young, by and through his attorney, Peter J. Russo, Esquire, and respectfully submits the following: 1. The Plaintiffs are, Robert A Young, and Janet M. Young, husband and wife, residing at 5227 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant Roy, is Craig A. Roy, with a last know address of 2nd Street, Harrisburg, Dauphin County, Pennsylvania 17102. 3. Defendant Young, is Lori Ann Young, with a last know address of Molly Pitcher Hotel, 13 South Hanover Street 2nd Street, Carlisle, Cumberland County, Pennsylvania 17013. 4. Plaintiffs seeks custody of the following child: Name Present Residence DOB Justin M. Young 5227 Royal Drive 3/9/91 Mechanicsburg, PA 5. The child was born out of wedlock. 6. The child is presently in the custody of the Plaintiffs, Robert A Young and Janet M. Young, who reside at 5227 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 7. In the last five years the children have resided with the following persons and at the following address: Name Address Dates Defendant Molly Pitcher Hotel 1/98 - 6199 Defendant Marvon Inn 6/99 - 7/99 Defendant Lincoln Motel 7/99 - 8/99 Defendant Molly Pitcher Hotel 9199 - 9/10/99 8. Defendant Roy, is the father of the child, with a last know address of 2nd Street, Harrisburg, Dauphin County, Pennsylvania 17102. His marital status is unknown. Defendant Roy currently resides with the following persons: Name Relationship Unknown 9. Defendant Young, is the mother of the child, with a last know address of Molly Pitcher Hotel, 13 South Hanover Street 2nd Street, Carlisle, Cumberland County, Pennsylvania 17013. She is single. Defendant Young currently resides with the following persons: Name Relationship Unknown 10. The Plaintiffs, Robert A. Young and Janet M. Young, are the matemal grandparents of the subject minor child and reside alone at 5227 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 11. Plaintiffs have not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 12. Plaintiffs have no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 13. Plaintiffs do 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 right with respect to the child. 14. The best interest and permanent welfare of the child will be served by granting the relief requested because of the facts alleged herein: a. The natural mother has become homeless. b. The natural father has had no contact with the natural mother or his child since the child's birth. c. The Plaintiffs can provide a stable home and provide for the needs of the subject minor child. 15. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim NONE WHEREFORE, Plaintiff requests this Honorable Court to order that primary physical and legal custody of the minor child, Justin M. Young, be placed with Plaintiffs. 7er II sui tted, usso Attorney for Plaintiffs q ? Date: 1 0 ) VERIFICATION I, Robert A. Young, verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. Robert . Young, r. Dated: 9 // °/? ° VERIFICATION I, Janet M. Young, verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. m. J M. Young Dated: i VERIFICATION I, Lori A. Young, verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. e i A. Young n? LO Dated: /O Iqq V OQ O O ? t?l i rt cn a C _ ?J SEP ?iqq ROBERT A. YOUNG, JR. and IN THE COURT OF COMMON PLEAS JANET M. YOUNG, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. NO. 99- SSA CRAIG A. ROY and LORI ANN YOUNG, CIVIL ACTION-LAW Defendants CUSTODY ORDER OF COURT AND NOW, this io day of 1999, upon consideration of the attached Petition for Emergency Relief Seeking Primary Physical and Legal Custody of the Minor Child, Petitioners' requested relief is hereby GRANTED. Petitioners are awarded temporary primary physical and legal custody of the minor child, Justin M. Young, bom March 9, 1991, until further Order of Court. Lori Ann Young is hereby granted liberal visitation as the parties may agree. Any party to this action may request a Hearing before the Court. Petitioners shall attempt to serve all parties to this action with a copy of this Order via State Constable or Sheriffs Department BY THE COURT, X94 ? ?i/, a. ? `la, y lj T J. VNVOSWId t 1 :z ;,I j 0 d3S 6 ^ ,'fry] i ?? ROBERT A. YOUNG, JR. and JANET M. YOUNG, Plaintiffs V. CRAIG A. ROY and LORI ANN YOUNG, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- 55 4 S CML ACTION-LAW CUSTODY ORDER OF COURT AND NOW, this day of 1999, upon consideration of the attached Petition for Emergency Relief Seeking Primary Physical and Legal Custody of the Minor Child, Petitioners' requested relief is hereby GRANTED. Petitioners are awarded temporary primary physical and legal custody of the minor child, Justin M. Young, born March 9, 1991, until further Order of Court. Lori Ann Young is hereby granted liberal visitation as the parties may agree. A Hearing is hereby scheduled for the day of 1999, at o'clock . m. in Courtroom of the Cumberland County Courthouse. Petitioners shall attempt to serve all parties to this action with a copy of this Order via State Constable or Sheriffs Department BY THE COURT, PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 ROBERT A. YOUNG, JR. and JANET M. YOUNG, Plaintiffs V. . CRAIG A. ROY and LORI ANN YOUNG, . Defendants Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- 55yS CML ACTION-LAW CUSTODY AND NOW, COME the Plaintiffs, Robert A Young and Janet M. Young, by and through his attorney, Peter J. Russo, Esquire, and respectfully submits the following in support of Plaintiffs' Petition for Emergency Relief Seeking Sole and Full Custody: 1. The Plaintiffs are, Robert A Young, and Janet M. Young, husband and wife, residing at 5227 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant Roy, is Craig A Roy, with a last know address of 2nd Street, Harrisburg, Dauphin County, Pennsylvania 17102. 3. Defendant Young, is Lori Ann Young, with a last know address of Molly Pitcher Hotel, 13 South Hanover Street 2nd Street, Carlisle, Cumberland County, Pennsylvania 17013. 4. Plaintiffs seeks custody of the following child: Name Present Residence DOB Justin M. Young 5227 Royal Drive 3/9191 Mechanicsburg, PA 5. The child was bom out of wedlock. 6. ' The child is presently in the custody of the Plaintiffs, Robert A Young and Janet M. Young, who reside at 5227 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 7. In the last five years the children have resided with the following persons and at the following address: Name Address Dates Defendant Molly Pitcher Hotel 1/98 - 6/99 Defendant Marvon Inn 6199 - 7/99 Defendant Lincoln Motel 7/99 - 8/99 Defendant Molly Pitcher Hotel 9/99 - 9/10/99 8. Defendant Roy, is the father of the child, with a last know address of 2nd Street, Harrisburg, Dauphin County, Pennsylvania 17102. His marital status is unknown. Defendant Roy currently resides with the following persons: Name Relationship Unknown 9. Defendant Young, is the mother of the child, with a last know address of Molly Pitcher Hotel, 13 South Hanover Street 2nd Street, Carlisle, Cumberland County, Pennsylvania 17013. She is single. Defendant Young currently resides with the following persons: Name Relationship Unknown 10. The Plaintiffs, Robert A Young and Janet M. Young, are the maternal grandparents of the subject minor child and reside alone at 5227 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 11. Plaintiffs have not participated as a parry or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 12. Plaintiffs have no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 13. Plaintiffs do 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 right with respect to the child. 14. The best interest and permanent welfare of the child will be served by granting the relief requested because of the facts alleged herein: a. Plaintiffs have filed a Custody Complaint in the Court of Common Pleas of Cumberland County. A true and correct of said Complaint is attached hereto as Exhibit A. b. The natural mother has become homeless. c. The natural father has had no contact with the natural mother or his child since the child's birth. d. The child is eight years old and must be enrolled in school. e. As natural mother has no permanent address and cannot care for the needs of her son, the Plaintiffs have agreed to take over responsibility for the minor child's welfare. f. The natural mother has executed an affidavit which has been attached hereto as Exhibit B which supports Plaintiffs' Petition. 15. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim NONE WHEREFORE, Plaintiff requests this Honorable Court to order that primary physical and legal custody of the minor child, Justin M. Young, be placed with Plaintiffs. Respectfully submitted, (3 JL Peter J. Russo Attorney for Plaintiffs Date: g l t o l ctq VERIFICATION I, Robert A. Young, verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. Robert A. oung, Jr. Dated: 9 a VERIFICATION I, Janet M. Young, verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. ?LZA?m J M. Young Dated: /b., 4Aq VERIFICATION I, Lori A. Young, verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. Dated: 1 7 V (•tk on A. Young EXHIBIT A AFFIDAVIT I, Lori A. Young, the undersigned aver as follows: 1. I am the natural mother of Justin M. Young, born March 9, 1991. 2. 1 have been the primary caretaker of my child since his birth. 3. The child's natural father Craig Foy has had no contact with our son since its birth. 4. Presently, I am without a permanent residence and can not provide for my child's needs or safety. 5. 1 believe it would be in my child's best interest to reside with my parents, Robert A. Young, Jr. and Janet M. Young, until I can provide reasonable appropriate living conditions. 6. 1 am in agreement that this matter requires Robert A. Young, Jr. and Janet M. Young's involvement in this matter and I consent to their appointment as legal custodian and primary physical custodian of my child. I verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. p., 9ro 4 9 c O' f '(,;,/ /9? r Date Lo ' . Young pr- -, ? .-TAR" SEA? Notarya, "°Tna? co ,an WWW COMOUM a?._. w?r EXHIBIT B ?,;;. ? ?. ?: _.. _ _- •?,,?- ROBERT A. YOUNG, JR. and JANET M. YOUNG, Plaintiffs V. CRAIG A. ROY and LORI ANN YOUNG, Defendants . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- CML ACTION-LAW CUSTODY ORDER OF COURT AND NOW, this day of , 1999, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , the Conciliator, at on the day of 1999, at -.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 may at the request of either attorney or party, be present at the conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT, By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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 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 Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 ROBERT A. YOUNG, JR. and JANET M. YOUNG, Plaintiffs V. CRAIG A. ROY and LORI ANN YOUNG, Defendants Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- CIVIL ACTION-LAW CUSTODY PETITION FOR CUSTODY AND NOW, COME the Plaintiffs, Robert A Young and Janet M. Young, by and through his attorney, Peter J. Russo, Esquire, and respectfully submits the following: 1. The Plaintiffs are, Robert A Young, and Janet M. Young, husband and wife, residing at 5227 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant Roy, is Craig A Roy, with a last know address of 2"d Street, Harrisburg, Dauphin County, Pennsylvania 17102. 3. Defendant Young, is Lori Ann Young, with a last know address of Molly Pitcher Hotel, 13 South Hanover Street 2"d Street, Carlisle, Cumberland County, Pennsylvania 17013. 4. Plaintiffs seeks custody of the following child: Name Present Residence DOB Justin M. Young 5227 Royal Drive 3/9/91 Mechanicsburg, PA 5. The child was born out of wedlock. 6. The child is presently in the custody of the Plaintiffs, Robert A Young and Janet M. Young, who reside at 5227 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 7. In the last five years the children have resided with the following persons and at the following address: Name Address Dates Defendant Molly Pitcher Hotel 1/98 - 6/99 Defendant Marvon Inn 6/99 - 7/99 Defendant Lincoln Motel 7/99 - 8/99 Defendant Molly Pitcher Hotel 9/99 - 9/10/99 8. Defendant Roy, is the father of the child, with a last know address of 2nd Street, Harrisburg, Dauphin County, Pennsylvania 17102. His marital status is unknown. Defendant Roy currently resides with the following persons: Name Relationship Unknown 9. Defendant Young, is the mother of the child, with a last know address of Molly Pitcher Hotel, 13 South Hanover Street 2"d Street, Carlisle, Cumberland County, Pennsylvania 17013. She is single. Defendant Young currently resides with the following persons: Name Relationship Unknown 10. The Plaintiffs, Robert A. Young and Janet M. Young, are the maternal grandparents of the subject minor child and reside alone at 5227 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 11. Plaintiffs have not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 12. Plaintiffs have no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 13. Plaintiffs do 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 right with respect to the child. 14. The best interest and permanent welfare of the child will be served by granting the relief requested because of the facts alleged herein: a. The natural mother has become homeless. b. The natural father has had no contact with the natural mother or his child since the child's birth. c. The Plaintiffs can provide a stable home and provide for the needs of the subject minor child. 15. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim NONE WHEREFORE, Plaintiff requests this Honorable Court to order that primary physical and legal custody of the minor child, Justin M. Young, be placed with Plaintiffs. II submitted, 7erP J. Russo Attorney for Plaintiffs Date: 9 I l o ) q C( VERIFICATION I, Robert A. Young, verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. GGI Winn Robert . Young, r. ` Dated: VERIFICATION I, Janet M. Young, verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. m. Ja&d M. Young Dated: fie, l o, / j? 9T I, Lori A. Young, verify that the statements made in the forgoing document are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unswom falsification to authorities. ei Young Dated: ID 19 c r.? . ?7 n ? ??_, r.7 ? - ? _? r? ?" i _J {?.. .. -`? .J `,t r"?.._ .. _?`- 6" ? + "'G Cn ? SEP 1 0 1999 ROBERT A. YO1 JANET M. YOUI Plaintiffs V. CRAIG A. ROY LORI ANN YOU Defendai PLA_ ?C¢ M ire UDQ-- 9 soh? DURT OF COMMON PLEAS LAND COUNTY, PENNSYLVANIA 55-5 nON-LAW Y T AND NOW, this day of , 1999, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , the Conciliator, at on the day of , 1999, at _.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 may at the request of either attorney or party, be present at the conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT, By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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 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 Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 ROBERT A. YOUNG, JR. and JANET M. YOUNG, Plaintiffs V. CRAIG A. ROY and LORI ANN YOUNG, Defendants Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO 99- CIN L ACTION-LAW CUSTODY PETITION FOR CUSTODY rI: J AND NOW, COME the Plaintiffs, Robert A Young and Janet M. Young, by and through his attorney, Peter J. Russo, Esquire, and respectfully submits the following: 1. The Plaintiffs are, Robert A Young, and Janet M. Young, husband and wife, residing at 5227 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant Roy, is Craig A Roy, with a last know address of 2nd Street, Harrisburg, Dauphin County, Pennsylvania 17102. 3. Defendant Young, is Lori Ann Young, with a last know address of Molly Pitcher Hotel, 13 South Hanover Street 2"d Street, Carlisle, Cumberland County, Pennsylvania 17013. 4. Plaintiffs seeks custody of the following child: Name Present Residence DOB Justin M. Young 5227 Royal Drive 3/9/91 Mechanicsburg, PA 5. The child was born out of wedlock. 6. The child is presently in the custody of the Plaintiffs, Robert A. Young and Janet M. Young, who reside at 5227 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 7. In the last five years the children have resided with the following persons and at the following address: Name Address Dates Defendant Molly Pitcher Hotel 1/98 - 6/99 Defendant Marvon Inn 6/99 - 7199 Defendant Lincoln Motel 7/99 - 8/99 Defendant Molly Pitcher Hotel 9199 - 9110/99 8. Defendant Roy, is the father of the child, with a last know address of 2nd Street, Harrisburg, Dauphin County, Pennsylvania 17102 His marital status is unknown. Defendant Roy currently resides with the following persons: Name Relationship Unknown 9. Defendant Young, is the mother of the child, with a last know address of Molly Pitcher Hotel, 13 South Hanover Street 2nd Street, Carlisle, Cumberland County, Pennsylvania 17013. She is single. Defendant Young currently resides with the following persons: Name Relationship Unknown 10. The Plaintiffs, Robert A. Young and Janet M. Young, are the maternal grandparents of the subject minor child and reside alone at 5227 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 11. Plaintiffs have not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 12. Plaintiffs have no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 13. Plaintiffs do 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 right with respect to the child. 14. The best interest and permanent welfare of the child will be served by granting the relief requested because of the facts alleged herein: a. The natural mother has become homeless. b. The natural father has had no contact with the natural mother or his child since the child's birth. c. The Plaintiffs can provide a stable home and provide for the needs of the subject minor child. 15. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim NONE WHEREFORE, Plaintiff requests this Honorable Court to order that primary physical and legal custody of the minor child, Justin M. Young, be placed with Plaintiffs. ? I submitted, Peer J. Russo Date: °C I lo) Attorney for Plaintiffs R q VERIFICATION I, Robert A. Young, verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unswom falsification to authorities. T?tz--?eql Robert . Young, Tr. Dated: 9// "?2 ?: VERIFICATION I, Janet M. Young, verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. m. A &M. Young Dated: / O, / VERIFICATION I, Lori A. Young, verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unswom falsification to authorities. UD N q LO i A. Young Dated: ID 12 9 "I'll", ROBERT A. YOUNG, JR. and IN THE COURT OF COMMON PLEAS JANET M. YOUNG, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs . V. NO. 99- 5545 OLLxDTerm CRAIG A. ROY and LORI ANN YOUNG, CIVIL ACTION-LAW Defendants CUSTODY ORDER OF COURT AND NOW, this day of , 1999, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , the Conciliator, at on the day of , 1999, at -.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 may at the request of either attorney or party, be present at the conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT, By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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 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 Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 SEP 0 799.9 ROBERT A. YOUNG, JR. and JANET M. YOUNG, Plaintiffs V. CRAIG A. ROY and . LORI ANN YOUNG, . Defendants . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- 554jS Cu,?.Q Term CIVIL ACTION-LAW CUSTODY ORDER OF COURT AND NOW, this day of , 1999, upon consideration of the attached Complaint it is hereby directed that the parties and their respective counsel appear before , the Conciliator, at on the day of , 1999, at _.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 may at the request of either attorney or party, be present at the conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or pemranent Order. FOR THE COURT, By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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 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 Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 ROBERT A. YOUNG, JR. and JANET M. YOUNG, Plaintiffs v CRAIG A. ROY and LORI ANN YOUNG, Defendants IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY No. 99-5545 CIVIL TERM CIVIL ACTION - LAW CUSTODY PRAECIPE TO CHANGE CAPTION TO THE PROTHONOTARY: Kindly enter this Praecipe to Change Caption in the above-captioned matter to the following, noting the change in the Defendant's Roy's name: ROBERT A. YOUNG, JR. and JANET M. YOUNG, Plaintiffs v CRAIG A. FOY and LORI ANN YOUNG, Defendants IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY No. 99-5545 CIVIL TERM CIVIL ACTION - LAW CUSTODY ReQ ctfullyitted, Peter J. Russo 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 Dated: 101, )q C) n ? c u? O {7'1 Z n ? .YTI " F71 _° - - fi 3> m ? U ? t'V -1t ?