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HomeMy WebLinkAbout03-3448MANDY COLLINS, VS, JASON COLLINS, Sr., Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03- J ~¥~ CIVIL TERM : : CUSTODY NOTICE OF COURT THE ATTACHED COMPLAINT FOR CUSTODY HAS BEEN FILED BY PLAINTIFF. YOU HAVE THE RIGHT TO 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 (717) 249-3166 OR (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 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 acconunodations available to disabled individuals having business before the court, Pease 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. MANDY COLLINS, Plaintiff VS. JASON COLLINS, SR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03- ,.~ ~t t~ CIVIL TERM CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Mandy Collins, residing at 183 Woods Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The defendant is Jason Collins, Sr., residing at 2225 North 4th Street, Harrisburg, Dauphin County, Pennsylvania. 3. The plaintiff seeks custody of the following children: Name Present Residence Age Tiffany Collins 183 Woods Drive 06/21 / 1997 Mechanicsburg, PA 17050 Jason Collins, Jr. 183 Woods Drive 02/01/1999 Mechanicsburg, PA 17050 The child, Tiffany Collins, was bom out of wedlock. The child, Jason Collins, Jr., was not bom out of wedlock. The children are presently in the custody of the plaintiff, who resides at 183 Woods Drive, Mechanicsburg, PA 17050. During the children's lifetimes, they have resided with the following persons and at the following addresses: Name Mandy Collins Jason Collins, Jr. Tiffany Collins Mandy Collins Jason Collins, Sr. Jason Collins, Jr. Tiffany Collins Mandy Collins Jason Collins, Sr. Tiffany Collins Address Date 183 Woods Drive Mid-March 2003 - Present Mechanicsburg, PA 17050 183 Woods Drive February 1999 - Mid-March 2003 Mechanicsburg, PA 17050 183 Woods Drive June 1997 - Mid-March 2003 Mechanicsburg, PA 17050 Name Relationship Tiffany Collins Daughter Jason Collins, Jr. Son The mother of the children is Mandy Collins, currently residing at 183 Woods Drive, Mechanicsburg, Cumberland County, Pennsylvania. She is married. The defendant, Jason Collins, Sr., has acted as the father to Tiffany Collins since her birth, and has held himself out to the community as her father in ways including, but not limited to, signing her birth certificate as her father. The father of the child, Jason Collins, Jr., is Jason Collins, Sr., currently residing at 2225 North 4th Street, Harrisburg, Dauphin County, Pennsylvania. He is married. 4. The relationship of the plaintiff to the children is that of mother. The plaintiff currently resides with the following persons: The relationship of the defendant to the child, Tiffany Collins, is that he has acted as the father to Tiffany Collins since her birth, and has held himself out to the community as her father in ways including, but not limited to, signing her birth certificate as her father. The relationship of the defendant to the child, Jason Collins, Jr., is that of natural father. The defendant currently resides with the following persons: Name Haley (to best of plaintiff's knowledge and last name is unknown to plaintiff) Relationship Girlfriend 6. The plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 7. The plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 8. The plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 9. The best interest and permanent welfare of the children will be served by granting the relief requested for reasons including, but not limited to, the following: a. The mother has been the primary caregiver since the children's births. The mother has provided for their emotional, physical, educational, and medical needs including establishing a stable home environment for them, and she can continue to provide for the children. b. In or about mid-March 2003, the father moved from the marital residence. The mother facilitated contact between the father and the children, and she is the parent who can best do so in the future. c. The father does not have a suitable residence for the children. d. The father's behavior has adversely affected the children in ways including, but not limited to, exposing them to dangerous situations and people. e. The father's threats to remove the children from the mother have caused the children emotional distress. 10. The mother requests that the court order the following: a. Grant her primary physical custody of the children. b. Grant the father partial physical custody with overnight visits limited to his parents' residence. 11. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, the plaintiff requests this Court to grant her primary physical custody of the children. Plaintiff further requests any other relief that is just and proper. Respectfully submitted, Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 VERIFICATION The above-named PLAINTIFF, Mandy Collins, verifies that the statements made in the above Complaint are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities. Mandy Coll~ MANDY COLLINS, Plaintiff, JASON COLLINS, SR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03- 2 gq/' CIWL T~RU : : IN CUSTODY PRAEC1PE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Mandy Collins, Plaintiff, to proceed in forma pauperis. I, Joan Carey, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that 1 am providing free legal services to the party. omey for Plaintitt MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 MANDY COLLINS PLAINTIFF V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-3448 CIVIL ACTION LAW JASON COLLINS, SR. : IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, July 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, PA 17043 on Thursday, 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 def'me and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: ~si 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. 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 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 Mandy Collins, Plaintiff VS. Jason Collins, Sr., Defendant IN THE COURT OF COMMON PLEAS OF CUIvlBERLAND COUlXTY PENNSYLVANIA No. 03- 3448 CiViL T~P.M IN CUSTODY AFFIDAVIT OF SERVICE BY MAIL I, Shaleeta Washington, do hereby swear that I served Jason Collins, Sr. with a Complaint For Custody on July 21, 2003 by certified mail, return receipt, restricted delivery, to the person and address below: Jason Collins, Sr. 207 Edna Street Wormleysburg, PA 17043 I, Shaleeta Washington, verify that the statements made in this Affidavit of Service are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: Signature: ~ · Complete items 1 2, and 3. Also c0ml~lete tern 4 if Res{dcted Delivery is desired; r · Print your name and address on the reverse so that we can re~urn the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. r-I Agent [] Addressee C. Date of Delivery D. Is delivery address ( omiteml? [] Yes If YES, enter delivery address below: [] No 2. Article Number (Transfer from service labi Ps Form 3811, August 2001 7002 2410 0007 8502-"3816 i Domestic Return Receipt I02595-02-M-1035 · sender: p~ease Print~'j~°u-~;ha~e' I~idPenn Legat Sew[ces Carlisle, PA 1'/013 ANNA M. BEITLER, Plaintiff JEFFERY E. BEITLER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION-LAW : IN PROTECTION FROM ABUSE :NO. 03- 3470 C1VILTERM ORDER OF COURT ~ AND NOW, on this ~ day of ~_A~4~ ,2003 upon consideration of the attached Petition to Vacate Order and Dismiss Action, the petition is granted. The Court vacates the Temporary Protection From Abuse Order entered on July 22, 2003, and dismisses this action without prejudice. Date 7- q-o F:~d~ Bayley, ~ffdge ANNA M. BEITLER, Plaintiff JEFFERY E. BEITLER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION-LAW : IN PROTECTION FROM ABUSE :NO. 03- 3470 CIVIL TERM PETITION TO VACATE ORDER AND DISMISS ACTION Plaintiff, Anna M. Beifler, by an through her attorneys, the Family Law Clinic, hereby requests that the Court vacate the Temporary Protection From Abuse Order entered on July 22, 2003 in the above captioned case, and dismiss this action. In support of her petition Plaintiff avers as follows: I. Plaintiff filed a Petition for Protection From Abuse with this Court on July 22, 2003. A Temporary Protection From Abuse was issued on July 22, 2003 before the Honorable Edward B. Bayley. 2. A hearing was scheduled for July 29, 2003 at 11:00 a.m. 3. The Family Law Clinic requested the hearing fo~ July 29, 2003 be mscheduled from 11:00 a.m. to 3:30 p.m. 4. Plaintiff does not want to pursue this action and requests that the Temporary Protection From Abuse Order be dismissed without prejudice. WHEREFORE, Plaintiff requests that the Court vacate the Temporary Protection From Abuse Order entered on July 22, 2003, and dismiss this action without prejudice. Respectfully Submitted, Certified Legal Intern THOM~A~ MgPLACE ROBERT E. RAINS LUCY JOHNSTON-WALSH Supervising Attorneys THE', FAMILY LAW CL1NIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 ANNA M. BEITLER, Plaintiff JEFFERY E. BEITLER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION-LAW : IN PROTECTION FROM ABUSE : :NO. 03-~70 CIVIL TERM VERIFICATION Understanding that the making of any false statement woald subject me to the penalties of 18 Pa.C.S § 4904, I verify that I am the Plainfiffin the present action, and that the facts and statements contained in the above Petition are true and correct, to the best of my knowledge, information and belief. a Beitler, Plfl~nttTf -' 07/24/03 THU lt:42 FAX 717 240 6573 CUMB CO PROTHONOTARY [~001 TX/RX NO INC0~PLETE TX/RX TRANSACTION OK ERROR *** ~ULTI TN REPORT *** 4016 01]9p2490779 0319p2405331 PSP CP OFFICE OF THE PROTHONOTARY CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA 170Y3 - 3387 (717) 24 0 - 6195 FAX (717) 240- 6573 VIA TELECOPIER TO: FAX # FROM: RE: PA STATE POLICE - CENTRAL PROCESSING CURTIS R. LONG FAXING A PFA M~SSAGE: 2 NO. 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