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HomeMy WebLinkAbout03-3817LISA M. BRADLEY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO.- 3f17 ; JUSTIN D. MULLIS, : Defendant : IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, LISA M. BRADLEY, by and through her attorney, ROBERT B. LIEBERMAN, ESQUIRE and respectfully represent as follows: 1. The Plaintiff is LISA M. BRADLEY, residing at 300 Longmeadow Street, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is JUSTIN D. MULLIS residing at 2625 East Memorial Drive, Muncie, Delaware County, Indiana. 3. Plaintiff seeks custody of the following child: Name Residence Age Jessica L. Mullis 300 Longmeadow Street 4 years Mechanicsburg, Pennsylvania The child was bom out of wedlock to Plaintiffand Defendant. The child is presently in the custody of Plaintiff, LISA M. BRADLEY, who resides at 300 Longmeadow Street, Mechanicsburg, Cumberland County, Pennsylvania. The child has resided with the following persons and at the following addresses: Persons Addresses Dates Plaintiff and Defendant Pompano Beach, Florida 11/4/98 to 04/05/00 Plaintiff Pompano Beach, Florida 04/05/00 to 01/30/02 Plaintiff and Jason Bradley and Calista Bradley Plaintiff and Jason Bradley and Calista Bradley 4978 SW 208 Terrace Aloha, Oregon 01/30/02 to 05/01/03 300 Longmeadow St. 05/01/03 to Present Mechanicsburg, Pennsylvania The mother of the child is LISA M. BRADLEY, currently residing at 300 Longmeadow Street, Mechanicsburg, Cumberland County, Pennsylvania. She is married. The father of the child is JUSTIN D. MULLIS, currently residing at 2625 East Memorial Drive, Muncie, Delaware County, Indiana. He is single. 4. The relationship of Plaintiff to the child is that of Mother. The Plaintiff currently resides with the following persons: Name Jason Bradley Jessica Mullis alone. Relationship Husband Daughter Calista Bradley Daughter 5. The relationship of Defendant to the child is that of Father. He currently resides -2- 6. Plaintiff has 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. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. Plaimiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interests and permanent welfare of the child will be served by granting the relief requested because Plaintiff is ready, willing and able to provide a stable home environment for the child. 8. Each party 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. WHEREFORE, Plaintiff requests this Honorable Court to grant her legal and primary physical custody of the subject minor child. Respectfully submitted, DATED:2' 3t~'O3' ROBERT B. LIEBERMAN, ESQUIRE 500 North 3ra Street, 12t~ Floor P.O. Box 1004 Harrisburg, PA 17108-1004 (717) 236-1485 Attorney for Plaintiff -3- VERIFICATION I verify that the statements made in the foregoing Complaint for Custody are true and correct based upon my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities. LISA M. BRADLEY : PLAINTIFF : JUSTIN D. MULLIS : DEFENDANT : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-3817 CiVIL ACTION LAW IN CUSTODY ORDER OFCOURT AND NOW, _ Monday, August 11, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Gree ,~LE~q. , the conciliator, at301 Market Street, Lemoyne, PA 17043.. on _ Monday, September 15, 2003 at 10:30 AM 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 conciliator 48 hours prior to scheduled hearing. FOR TIlE COURT, By:_/s/ 3/Ielissa 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 TIlE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania !t 7013 Telephone (717) 249-3166 LISA M. BRADLEY, Plaintiff JUSTIN D. MULLIS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2003-3817 IN CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA: : SS. COUNTY OF DAUPHIN : Personally appeared before me, a Notary Public, in and for said Commonwealth and County, ROBERT B. LIEBERMAN, ESQUIRE, who, being duly sworn according to law, deposes and says: 1. That on August 3, 2003, a Complaint for Custody was filed on behalf of Plaintiff and against Defendant in the above case. 2. That on August 15, 2003, I forward by certified mail, return receipt requested, a certified copy of the Complaint for Custody to Defendant, JUSTIN D. MULLIS, c/o Judy Mullis, 2625 E. Memorial Drive, Muncie, Delaware County, Indiana. 3. That the aforesaid copy of the Complaint for Custody sent to Defendant, JUSTIN D. MULLIS, was delivered on August 19, 2003, as evidenced by the return receipt card signed by Defendant and attached hereto. 4. That to the best of my information and belief, the signature on the return receipt card is, in fact, the signature of JUSTIN D. MULLIS. I~OBERT B. LIEBERMAN, Esquire Attorney for Plaintiff SWORN AND S.U..BS.CRIBED before me this -~Co~'~ day of A~ c,. o x~- ,2003. Notary~Sublic O My Commission Expires: NOTARIAL SEAL CHERYL L. FERGUSON, No.fy Public Harrisburg, Dauphin County L_~ comm ss on Expires April 6, 2004 2.30 Postmark 1.75 08/15/03 $ 4.65 · Complete items 1, 2, a~nd 3. Al~o compiete ~~ ri Agent ~ 4 if Restricted Delivery is desired. [] Addressee · I~tnt your name and address on the reverse w. oyou. · Attach this card to the back of the mai Justin D. ~iullis ~r / ~~ c/o Judy Mullis 2625 E. Memorial Drive Muncte, IN 47302 2023-1 Bradley 4, me~r~'~d Deliv~y? (Extra Fee) [] Yes O'~.~t~m~,icotat~O 7002 1000 0005 3929 7647 PS Form 3811, August 2001 Domestic Return Receipt 102595-02-M-0835 LISA M. BRADLEY, Plaintiff JUSTIN D. MULLIS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3817 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this ~1,~ ~1~ day of September, 2003, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Le.qal and Physical Custody. The Mother, Lisa M. Bradley, shall have primary legal custody and primary physical custody of the minor child, Jessica L. Mullis, born November 4, 1998. 2. The Father, Justin D. Mullis, shall have periods of partial custody at such times and places as the parties may agree. 3. In the event that Father is aggrieved by the terms of this Order, upon proper Petition filed with the Prothonotary, a Custody Conciliation Conference will be scheduled. 4. Counsel for Mother shall serve a copy of this Order on the Defendant and file a Return of Service with the Court, indicating that this Order has been served. 5. Cumberland County Court of Common Pleas for the Pennsylvania shall retain jurisdiction of this matter. Commonwealth of Dist: · '~'obed B. Lieberman, Esquire, PO Box 1004, Harrisburg, PA 17108-1004 · ~'~stin D. Mullis, 2625 E. Memorial Drive, Muncie, IN 47302 LISA M. BRADLEY, JUSTIN D. MULLIS, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3817 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Jessica L. Mullis November 4, 1998 Mother 2. A Custody Conciliation Conference was held on September 15, 2003 following Mother's filing of a Complaint for Custody on August 3, 2003. Present for the Conference were: the Mother, Lisa M. Bradley, and her counsel, Robert B. Lieberman, Esquire; the Father, Justin D. Mullis, did not attend the Conference. Mr. Lieberman filed a Return of Service with the Court based on a restricted delivery certified letter to the Defendant. 3. Mother represents that she has had primary physical custody since the parties separated on April 5, 2000. She seeks an Order confirming the status quo and because that request was unopposed, the Order will be grant~d~) Date - ' sa Peel Greev~, Esquire Custody Conciliator :218410 LISA M. BRADLEY, Plaintiff JUSTIN D. MULLIS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA .. : CIVIL ACTION - LAW : NO. 2003-3817 _- .. : IN CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS. Personally appeared before me, a Notary Public, in and tbr said Commonwealth and County, ROBERT B. LIEBERMAN, ESQUIRE, who, being duly sworn according to law, deposes and says: 1. That on September 29, 2003 an Order of Court was entered by the Honorable Edward E. Guido. 2. That on October 2, 2003, I forward by certified mail, return receipt requested, a certified copy of the aforesaid Order of Court and Custody Conciliation Summary Report to Defendant, JUSTIN D. MULLIS, c/o Judy Mullis, 2625 E. Menrtorial Drive, Muncie, Delaware County, Indiana. 3. That the aforesaid copy of the Order of Court and Custody Conciliation Summary Report sent to Defendant, JUSTiN D. MULLIS, was delivered ,on October 8, 2003, as evidenced by the return receipt card signed by Defendant and attached hereto. 4. That to the best of my information and belief, th,.' signature on the remm receipt card is, in fact, the signature of JUSTIN D. MULLIS. ROBERT 13. LIEBERMAN, Esquire Attorney for Plaintiff SWORN AND SUBSCRIBED before me this [ ¢14x day of C) e--co e,~¢_ ,2003. Notary l~blic ' 6 My Commission Expires: NOTARIAL SEAL CHERYL L. FERGUSON, Notary Public Harrisburg, Dauphin County M'.,.Oo~m sS.? .E.x_~ re_.Js April 8, 2004 $ .37 2.30 Postmark 1.75 10/02/03 $ 4.42