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HomeMy WebLinkAbout03-3409 JASON R. COLLINS, Sr., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. Defendant CIVIL ACTION - LAW - NO. () 3 - 3 '10 q (l~:;.J J..t-- IN CUSTODY MANDY L. COLLINS COMPLAINT FOR CUSTODY AND NOW, this /{,"'" day of ~!.::t. ,2003, comes Plaintiff, Jason R. Collins, Sr., by and through is attomey, The Law Office of Darrell C. Dethlefs in support of his custody complaint avers the following: 1. The Plaintiff, Jason R. Collins, Sr., is an adult individual with a residence located at 207 Edna street, Wormleysburg, Pennsylvania, Pennsylvania 17043. 2. Defendant, Mandy L Collins, is an adult individual with a residence located at 183 Woods Drive, Mechanicsburg, Pennsylvania, 17050. 3. Plaintiff and Defendant are the natural parents of Jason Russell Collins, Jr., bom February 1, 1999. 4. plaintiff and Defendant are the parents of Tiffany Marie Collins, bom June 21, 1997. 5. Plaintiff and Defendant were married on December 31.1997 in Marysville, Pennsylvania. 6. Since birth, the children here resided with Plaintiff and Defendant at 183 Woods Drive, Mechanicsburg, Cumber1and County, Pennsylvania 17050. 7. Neither Plaintiff nor Defendant is in the military or naval selVice of the United states or its allies within the provisions of the Soldier's and Sailor's Civil Relief Act of 1940 or any amendments thereto. 8. Plaintiff and Defendant are citizens of the United states of America. 9. The best interest in the permanent welfare of the children will be selVed by granting custody to the Plaintiff, Jason R. Collins, Sr. WHEREFORE, Plaintiffs request that the Court grant primary physical custody of the children to Plaintiff. Jason R. Collins, Sr. f} Ie 7~\ ~. Zellner, Esquire Attorney 10 # 59262 Law Office of Darrell C. Dethlefs 3805 Market Street Camp Hill, PA 17011 (717) 975-9446 ATTORNEY FOR THE PLAINTIFF JASON R. COLLINS, Sr., : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. CIVIL ACTION - LAW MANDY L. COLLINS, Defendant NO. IN CUSTODY CERTIFICATE OF SERVICE I, Brian K. Zellner, Esquire, hereby certit'y that Defendant, Mandy L. Collins, was served with the Complaint for Custody in this matter by Certified Mail, Return Receipt Requested on July 17, 2003. I hereby verify that the statements offact made in the foregoing are true and correct to the best of my knowledge, information, and belief. I tmderstand that any false statements therein are subject to criminal penalties contained in 18 Pa.S.C.S. Section 4909, relating to unsworn falsification to authorities. LAW OFFICE OF DARRELL C. DETHLEFS Date: '(PI OJ (l!cf) Brian K. Zellner, Esquire 3805 Market Street Camp Hill, Pennsylvania 17011 Attorney Id. No.: 59262 Attorney for Plaintiff, Jason R Collins, Sr. VeRIFICATION I verify that the statements made in this document are true and correct to my personal knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ;7-/4- -(7 S ~ ~ ............. ~ ~ ~ ~ ~ -....J -I..j (') ~ -t:>t- < ~ \,JI"' __. co L;_, c:s ~= i .. ~) ~ ~;:l ~ ~F; .... . c r- ::< ~ - :::. ';' -<c' . 1:J C",) , '::::.:: nCV -.;'1 ._", r= _1 ~'" ,,) .0 =< JASON R. COLLINS, SR. PLAINTIFF IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNIY, PENNSYL VANIA V. 03-3409 CIVIL ACTION LAW MANDY L. COLLINS DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, Jnly 23, 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, P A 17043 on Thnrsday, August 21, 2003 at 1 :00 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, Special Relief orders, and Custody orders to the couciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: Is! Melissa P. Greevy. Esq. Custody Conciliator L' The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable 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 TInS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE. GO TO OR TELEPHONE TIlE 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 ~ ~ ~ ~ ~l ['~ U'-J., n 'Z ~ ~u, @- E:C-L ~~:Z ~49;r? E7J.EI"L, \f1NIfI\l,\S~NE;t " I ,.~,!('n'-) (....~\,'1 \1'-1:,::/,,1\ :8 f"\..!,.:\"" ',' ., .,' ,.~"/ ,', ,c~ C F~ ~v 01;' i-;':J '. (, 11l\ L :)v."" 0, AUG 2 1 2003 JASON R. COLLINS, SR., Plaintiff : In the Court of Common Pleas of : Cumberland County, Pennsylvania vs. : No. 03-3409 Civil Term MANDY L. COLLINS, Defendant : Custody CUSTODY ORDER AND NOW, this .2.1Jday of ~ 2003, th,~ following Order is entered by consent of the parties with regard to custody of the parties' children, Tiffany Collins, born 6/21/97, and Jason Collins, Jr., born 2/1/99: 1. Plaintiff, Jason R. Collins, Sr., hereinafter referred to as the father, and Defendant, Mandy L. Collins, hereinafter referred to as the mother, shall share legal custody of the children. 2. The mother shall have primary physical custody of the children. 3. The father shall have partial custody of the children according to the following schedule: a. Alternating weekends from Friday at 5:00 p.m. until Sunday at 5:00 p.m., and b. At other times mutually agreed upon by the: parties. 4. The parties shall share or alternate having custody ofthe children on holidays as follows: a. NEW YEARS/ MEMORIAL DAY/ JULY 4TH/ LABOR DAY: The parties shall alternate the above holidays from 9:00 a.m. until 7:00 p.m. The mother shall have the children on Memorial Day and Labor Day in odd numbered years, and the father shall have the children for these holidays in even numbered years. The mother shall have the children on July 4th and New Years Day in even numbered years, and the father shall have the children for these holidays in odd numbered years. The mother shall commence the schedule by having the children on Labor Day in 2003. b. THANKSGIVING/ CHRISTMAS/ EASTER: The father and mother shall share the Thanksgiving Day, Christmas Day, and Easter Day holidays with one parent having the children on the respe<:tive holidays from 9:00 a.m. until 3:00 p.m. (hereinafter Block A), and the other parent having the children from 3:00 p.m. until 9:00 p.m. (hereinafter Block B). In odd numbered years, the mother shall have Block A, and the father shall have Block B. In even numbered years, the father shall have Block A, and the mother shall have Block B. The mother shall commence the: schedule by having the children during Block A on Thanksgiving in 2003. c. MOTHER'S DAY/ FATHER'S DAY: The mother shall have the children on Mother's Day from 9:00 a.m. and keep them for the remainder of the day. The father shall have the children from 9:00 a.m. until 7:00 p.m. on Father's Day. S. Both the father and mother shall have the right to have the children for one uninterrupted week of summer vacation. The mother and the father shall give each other two weeks notice as to when the period of summer custody will take place. If either party takes the children for overnight periods away from home, that parent shall give the other addresses and telephone numbers at which the children can be contacted. Both the mother and the father may contact the children by phone when they are in the custody of the other parent. 6. The mother and father shall share transportation, with the parent receiving custody of the children picking them up. The mother shall pick up the children at the paternal grandmother's residence, and the father shall pick up the children at the mother's residence. 7. The mother and father agree that each shall notify the other immediately of medical emergencies that arise while the children are in that parent's care. 8. Neither party shall do anything which may eslrange the children from the other parent, or injure the opinion of the children as to the other parent or which may hamper the free and natural development of the children's love or respect for th.e other parent. By the Court, (1- R cd , Judge ason Collins, Sr., Plaintiff ~ Ie.. ~ Brian K. Zellner, Attorney for Plaintiff Law Office of Darrell C. Dethlefs 3805 Market Street Camp Hill, P A 17011 pursuant to the consent of Plaintiff and Defendant: , fY\~lf\{~"-CJ Mandy Collin , D fendant '71- t--cJ.. '1../ 0-/'cL<--/ Joan Carey" Attorn6' for Defendant MidPenn L1egal Services 8 Irvine Row Carlisle, P A 17013 ~' - ~ ~-'- c/v ~/,i1./ 10J 4 q. t1'lJJ(.J ..-r-.. C? ~-:;;; <'" -or;. ~\';; ~~ r::-; 'JC' , ~~. (~~:\ ;1> ,_. ~ .::S {-.) (::.. ~.~-~ '-:? .-1 "J) -'. SEP u 2 2003 ~ JASON R. COLLINS, SR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3409 CIVIL TERM NO. 03-3448 CIVIL TERM CIVIL ACTION - LAW v. MANDY L. COLLINS, Defendant IN CUSTODY ORDER TO RELINQUISH JURISDICTION AND NOW, this 25th 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. BY: f)--\ elissa Peel Greevy, Esquire Custody Conciliator :217526 VINV^lASNN3d ,\LNnCCi (11.;.nH~J8l"1no 6S:5 WJ i]- d3S SO Ai:N1Ci'U,u. . :10 :1::;\J:,o .ij Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA OIP'" RECEIVED MAY 2 7 20~ NO. 03 - 3409 CIVIL TERM JASON A. COLLINS, SA., v. MANDY L. COLLINS, CIVIL ACTION - CUSTODY Defendant CUSTODY ORDER AND NOW, this ~ day of tNl7 [_, 2005, the following Order is entered by consent of the parties with regard to custody of the parties' children, Tiffany Collins, born 6/21/97, and Jason A. Collins, Jr., born 2/1/99: 1. Plaintiff, Jason A. Collins, Sr., hereinafter referred to as father, and Defendant, Mandy L. Collins, hereinafter referred to as the mother, shall share legal custody of the children. 2. The father shall have primary physical custody of the children. 3. The mother shall have partial custody of the children according to the following schedule: a. Alternating weekends from Friday at 5: 00 p.m. until Sunday at 5:00 p.m., and b. At other times mutually agreed upon by the parties. 4. The parties shall share or alternate having custody of the children on the holidays as follows: a. NEW YEARSIMEMORIALDAYIJULY 4THILABOR DAY: The parties shall "n \1"" U1.) ~ A\i \- r co.i\7 \\ :1'0\.>.... ..,' I \ :.\-\l:\U ;>J".:':f _\~~,.';~'~,/\ _;~'~"'" ,'. ~', ~~\ _"_' ~3-\H ",).,.,.". ,,-, - At alternate the above holidays from 9: 00 a.m. until 7:00 p.m. The father shall have the children on Memorial and Labor Day in odd numbered years, and the mother shall have the children for these holidays in even numbered years. The father shall have the children on July 4th and New Years Day in even numbered years, and the mother shall have the children for these holidays in odd numbered years. b. THANKSGIVING/CHRISTMASIEASTER: The father and mother shall share the Thanksgiving Day, Christmas Day, and Easter Day holidays with one parent having the children on the respective holidays from 9:00 a.m. until 3:00 p.m. (hereinafter Block A), and the other parent having the children from 3:00 p.m. until 9:00 p.m. (hereinafter Block B). In odd numbered years, the father shall have Block A, and the mother shall have Block B. In even numbered years, the mother shall have Block A, and the father shall have Block B. c. MOTHER'S DAYIFATHER'S DAY: The mother shall have the children on Mother's Day from 9: 00 a.m. and keep them the remainder of the day. The father shall have the children from 9:00 a.m. until 7:00 p.m. on Father's Day. 5. Both the father and mother shall have the right to have the children for one uninterrupted week of summer vacation. The mother and father shall give each other two weeks notice as to when the period of summer custody will take place. If either party takes the children for overnight periods away from home, that parent shall give the other addresses and telephone numbers at which the children can be contacted. Both the mother and the father may contact the children by phone when they are in the custody of the other parent. 6. The mother and father shall share transportation, with the parent receiving custody of the children picking them up. The mother shall pick up the children at the paternal grandmother's residence, and the father shall pick up the children at the mother's residence. 7. The mother and father agree that each shall notify the other immediately of , medical emergencies that arise while the children are in the parent's care. 8. Neither party shall do anything which may estrange the children from the other parent, or injure the opinion of the children as to the other parent or which may hamper the free and natural development of the children's love or respect for the other parent. By the Court, -r This Order is entered pursuant to the consent of the Plaintiff and Defendant: ---.. ~ son R. Collins, Sr. , Plaintiff irc-t ~ -- rian K. Zellner, EsqUire Attorney for the Plaintiff 2132 Market Street P.O. Box 368 Camp Hill, PA 17001 (717) 975 - 9446 Attyld. No. 59262 .~.~ f-1( ~ iAfI. ....;J '~. 4., {;.OI'05 C)-..