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Home My WebLink About07-2554Michelle L. Wilson, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN CUSTODY Kevin E. Wilson, Jr., Defendant. : NO. 07- a55~} CIVIL TERM COMPLAINT FOR CUSTODY The plaintiff, Michelle L. Wilson , by her attorneys, the Family Law Clinic, sets forth the following cause of action in custody. 1. Plaintiff is Michelle L. Wilson, residing at 95 Arnold Road, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant is Kevin E. Wilson, Jr. He is currently incarcerated at Cumberland County Prison. His anticipated release date is September 2007. 3. Plaintiff seeks primary custody of: Name Trevor Wilson Present Residence 95 Arnold Road Enola, PA 17025 Age 8 years old Erica Wilson 95 Arnold Road 4 years old Enola, PA 17025 Trevor Wilson was born in wedlock. Erica Wilson was born out of wedlock. The children are presently in the custody of Michelle L. Wilson, who resides at 95 Arnold Road, Enola, Cumberland County, Pennsylvania 17025. During the past five years the children have resided with the following persons at the following addresses: Persons Michelle Wilson Heather Worley Cody Worley Address 95 Arnold Road Enola, PA 17025 Dates 2004 -present Michelle Wilson Heather Worley Cody Worley 18 East Dauphin Street Enola, PA 17025 2001-2004 Defendant lived with the children and Plaintiff at the above addresses on an sporadic basis. The mother of the children is Michelle L. Wilson. She is divorced. The father of the children is Kevin E. Wilson, Jr.. He is divorced. 4. The relationship of Plaintiff to the children is that of mother. The plaintiff currently resides with the following persons: Name Relationship Trevor Wilson son Erica Wilson daughter Heather Worley daughter Cody Worley son 5. The relationship of Defendant to the children is that of father. The defendant currently resides with the following persons: Name Unknown Relationship paramour 6. 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. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth, or any other state. 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. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: a. Plaintiff has been the children's primary caretaker for all of the children's life; b. Plaintiff provides the children with a stable home and environment with adequate moral, emotional, and physical surroundings as required to meet the children's needs; c. Plaintiff has encouraged contact between Defendant and the children and will continue to do so; d. Plaintiff is willing to accept custody of the children. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody to the child have been named as parties to this action. WHEREFORE, Plaintiff requests the court to grant her shared legal custody and primary physical custody of the children, with Defendant having periods of partial custody of the children. Respectfully submitted, Date: 7 Holly O. ughn Certified Legal Intern ~~%~ZrP~i THO AS M. PLACE ROBERT E. RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 I verify that the statements made in this Complaint 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. Michelle L. Wilson (Plaintiff) .., t.` ~ CJ - - --_, ~ R ~ ~ ~ -~ _~ - H - "; ' " -~, ~; .,d _ <<-, ~,. ._ _ ; ~ _ r - _ -~ Michelle L. Wilson, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN CUSTODY Kevin E. Wilson, Jr., Defendant. : NO.07- oZ55~/ CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Michelle L. Wilson, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. e Date Respectfully submitted, -~ Holly O. Vafikghn Certified Legal Intern ROB T E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 C 7 f,.! ~~. f~ -.,3 1~{ ~~ ~ -_ ~ °~ i-T_~ r i ~ ~~J - t~- W a ~... _ :^t+ - ~ ` _ C r-~l : t r' ~_'_ ti"".'~i ~ " } ~a ~.,,1 ~"L Michele L. Wilson, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN CUSTODY Kevin E. Wilson, Jr., Defendant. : NO.07-2554 CIVIL TERM CUSTODY AGREEMENT THIS AGREEMENT, made this ~~ay of /VG~ , 2007, between Michele L. Wilson ("Mother"), and Kevin E. Wilson, Jr. ("Father"), concerns the custody of their children: Trevor Wilson, born November 25, 1998, and Erica Wilson, born September 4, 2002 ("the children"). Mother and Father desire to enter into an agreement as to the custody of the children. Mother and Father agree to the following. 1. Mother shall have legal custody of the children. 2. Mother shall have primary physical custody of the children. 3. Father shall have partial physical custody of the children every other weekend from Friday at 5 p.m. until Sunday at 7 p.m. 4. Mother and Father shall share transportation of the children for custody exchanges as mutually agreed. 5. Mother and Father shall share custody of the children on holidays as mutually agreed. 6. Mother and Father shall be entitled to reasonable telephone access with the children while the children are in the other parent's custody. 7. Mother and Father shall notify each other of all medical care the children receive while in .the parent's care. Mother and Father shall notify the other immediately of medical emergencies which arise while the children are in that parent's care. 8. The parties shall keep one another advised of their current address and telephone number. 9. Mother and Father shall each be entitled to one week of summer vacation with the children. Each party shall notify the other in writing thirty days in advance of using their summer vacation week. 10. Neither parent shall do anything which may estrange the children from the other party, 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 and respect for the other parent. 11. Father acknowledges that the Family Law Clinic represents only Mother's interest in this matter and has given him no legal advice other than to seek the advice of his own legal counsel. 12. The parties intend to be bound by the terms of this agreement and intend for this Agreement to be made an Order of Court. . l~t~ ichele L. 'son, Plaintiff ~,,~ K in 'son, r,;- efendant ~..~' Holly Vaug Certified Legal I ern Counsel for Plaintiff ~ ,y -- ROBE INS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Counsel for Plaintiff FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 Telephone (717)243-2968 Fax (717)243-3639 r~ ._ ~ . v,; _ -r,n ---i 6'`-.? ~. ~, _~ .._.._ _. ~~ •^<: MICHELLE L. WILSON IN THE COURT OF COMMON PLEAS OF PLAINTIFF C'UMBERLANU COUNTY, PENNSYLVANIA V. KEVIN E. WILSON, JR. DEFENDANT • 07-2554 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, __ Friday, May 25, 2007 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, June 08, 2007 at 12:30 PM for aPre-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 ale five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary ar 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: _ /s/ _ johnJ. Mangan, r., Es . 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 info~7nation 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 AT'T'ORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WE-fERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 r~~vu/ ~ ~ ~9 S~ S ? ~,~.,~, ~~ ~o-sue-s' ~~ ~ 4 , ~., a ~.c~ ~ ' - ; A~~c~~ ` ` n~ }~ jj :a .+ "' a r .7 ~6l 4 l i~ MAY 882DD1/~ Michele L. Wilson, Plaintiff v. Kevin E. Wilson, Jr., Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IN CUSTODY NO.07- 02554 CIVIL TERM ORDER AND NOW, this ~ o ' " day of _j~.~, 2007, the attached Custody Agreement is approved and entered as an Order of the Court. ds ~~.:~. _'~ ;. mod. '. '~ ,i i.-~ 1. " y ~ ~ .,'~ ~' ~~, ~ ~> °, `~' ~ ~ Michele L. Wilson, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION-LAW DIVORCE Kevin E. Wilson, Jr., Defendant NO.07 - 2554 CNIL TERM CERTIFICATE OF SERVICE I, Holly O. Vaughn, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the May 30, 2007 Order of Court on Kevin E. Wilson, Jr., by depositing on this date a copy of the same in the United States mail, postage prepaid, addressed as follows: Kevin E. Wilson, Jr. 402 Ponderosa Road Carlisle, PA 17013 oAru.-tee ~, ~00~7 D~~ Holly O. aughn Certified~`L~eA,gal Intern '~ ~/~ Anne Donald-Fox, E Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 {-> ~ ~ t` '~ , ..1'.a. ....~ r~i ~~ W 1