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HomeMy WebLinkAbout07-4164YOU 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 BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 2 Diane S. Baker, Esquire I.D. No. 53200 27 South Arlene Street P.O. Box 6443 Harrisburg, PA 17112-0443 (717)671-9600 MELINDA JO BENYOU, Plaintiff vs. JOHN P. BLESSING, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes Plaintiff, MELINDA JO BENYOU, by and through her attorney, Diane S. Baker, Esquire, and files this Complaint, based upon the following: 1. Plaintiff, MELINDA JO BENYOU, is an adult individual residing at 94 Juniper Drive, Etters, York County, Pennsylvania, 17319. 2. Defendant, JOHN P. BLESSING, is an adult individual residing at 21 South 24th Street, camp Hill, Cumberland County, Pennsylvania, 17011. 3. Plaintiff seeks to confirm primary physical custody of Bethany M. Blessing, born July 8, 1993. Plaintiff is the natural mother of the child and Defendant is the natural father of the child. The child was born in wedlock. The child is currently in the primary physical custody of Plaintiff. 3 4. For the past five (5) years, the child has resided with the following persons and at the following addresses: Plaintiff 393 Pleasantview Road, 2002- 2003 New Cumberland, PA Defendant 1925 Columbia Ave 2003-2006 Camp Hill, PA Defendant 21 S. 24~' Street 2006-6/8/07 Camp Hill, PA Plaintiff 94 Juniper Drive 6/8/07-present Etters, PA 5. Plaintiff has not participated as a party or a 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. Plaintiff does not know of a person not party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 6. Each parent whose parental rights to the child that have not been terminated and the person who has physical custody of the child have been named as parties to this action. 7. The best interest and permanent welfare of the child will be served by granting the relief because Plaintiff can provide a safe home and a stable and loving environment for the child. 4 WHEREFORE, Plaintiff requests Your Honorable Court to grant her shared legal and primary physical custody of the minor child, Bethany M. Blessing with Defendant having periods of partial physical custody as agreed upon by the parties. DATE: ©~ Post Office Box 6443 Harrisburg, PA 1 7 1 1 2-0443 (717) 671-9600 Supreme Court ID #53200 27 South Arlene Street VERIFICATION 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. Section 4904 relating to unsworn falsification to authorities. ~~ ME DA JO BENY 6 C7 Lam`',-, ~~} -°-+ y +( ~t ~ , ~~' ~ r=- ~V p1 1 (~'~ ~ V ~ ~ i'C~ ~ v -~. ``' a - MELINDA JO BENYOU IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JOHN P. BLESSING DF,FENDANT • 07-4164 CIV[L ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, July 23, 2007 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective co~msel appear before Dawn S. Sunday, Esq. ,the conciliator, at_ ~ _.__ 39 West Main Street, Mechanicsburg, PA .17055 on Tuesday, August 28, 2007 at 9:00 AM 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 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 ail 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/ Dawn S. Sunda 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 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, GU TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South I3edti~rd Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~ ~o.h~'G rr~~ ~ ~ G ~ --~i~ ,, ..'~`.. ~, r 'i~ ,, -~' . :, Diane S. Baker, Esquire I.D. No. 53200 27 South Arlene Street P.O. Box 6443 Harrisburg, PA 17112-0443 (717)671-9600 MELINDA JO BENYOU, Plaintiff vs. JOHN P. BLESSING, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . NO. 07 • v iG Y ~ l ~-, CIVIL ACTION -LAW CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes Plaintiff, MELINDA JO BENYOU, by and through her attorney, Diane S. Baker, Esquire, and files this Complaint, based upon the following: 1. Plaintiff, MELINDA JO BENYOU, is an adult individual residing at 94 Juniper Drive, Etters, York County, Pennsylvania, 17319. 2. Defendant, JOHN P. BLESSING, is an adult individual residing at 21 South 24`x' Street, camp Hill, Cumberland County, Pennsylvania, 17011. 3. Plaintiff seeks to confirm primary physical custody of Bethany M. Blessing, born July 8, 1993. Plaintiff is the natural mother of the child and Defendant is the natural father of the child. The child was born in wedlock. The child is currently in the primary physical custody of Plaintiff. 3 4. For the past five (5) years, the child has resided with the following persons and at the following addresses: Plaintiff 393 Pleasantview Road, 2002- 2003 New Cumberland, PA Defendant 1925 Columbia Ave 2003-2006 Camp Hill, PA Defendant 21 S. 24t" Street 2006-6/8/07 Camp Hill, PA Plaintiff 94 Juniper Drive 6/8/07-present Etters, PA 5. Plaintiff has not participated as a party or a 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. Plaintiff does not know of a person not party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 6. Each parent whose parental rights to the child that have not been terminated and the person who has physical custody of the child have been named as parties to this action. 7. The best interest and permanent welfare of the child will be served by granting the relief because Plaintiff can provide a safe home and a stable and loving environment for the child. 4 WHEREFORE, Plaintiff requests Your Honorable Court to grant her shared legal and primary physical custody of the minor child, Bethany M. Blessing with Defendant having periods of partial physical custody as agreed upon by the parties. fitted, DATE: ~ ~~ ~ v/ ' e S. Baker, Esquire Supreme Court ID #53200 27 South Arlene Street Post Office Box 6443 Harrisburg, PA 17112-0443 (717)671-9600 5 VERIFICATION 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. Section 4904 relating to unsworn falsification to authorities. ME DA JO BENY 6 t`~ z,~-a ±`7 c~ -si ~, ~ "' Ui _p - _ _ , _ ;: W ~~~ s} Q r.~ _. ._.; ~G MELINDA JO BENYOU Plaintiff vs. JOHN P. BLESSING Defendant JAN 4 7 2008 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 07-4164 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 CUSTODY OF Bethany M. Blessing July 8, 1993 Mother 2. A custody conciliation conference was held on August 28, 2007, with the following individuals in attendance: the Mother, Melinda Jo Benyou, with her counsel, Diane S. Baker, Esquire, and the Father, John P. Blessing, who is not represented by counsel in this matter. 3. The Mother filed this Complaint for Custody seeking primary physical custody of the Child. During the conference, the parties discussed serious concerns regarding the Child's mental health issues and issues related to school. At that time, the Child was under the care of both a psychotherapist and a psychiatrist. The parents established a plan whereby they would jointly contact the professionals providing treatment for the Child to schedule a meeting to obtain guidance on arrangements that would be most conducive to the Child's therapy and mental health both as to school attendance and custodial matters. Both parents agreed that it would be important to implement the guidance provided by the mental health professionals. 4. It was agreed that this matter would be held in the conciliator's office pending the parties' meeting with the Child's psychotherapist and psychiatrist and that the parties would contact the conciliator to request the scheduling of a follow-up conciliation conference or submission of an Order, if appropriate or necessary. 5. The conciliator, having determined from the Mother's counsel that the Mother is not proceeding with her request for custody at this time, hereby relinquishes jurisdiction. No further Order is necessary at this time. J~~~ ~- ~ Date Dawn S. Sunday, Esquire Custody Conciliator P^~ ~^~ V -Y t~ E...- i ~~ „~, -, ~., ., 4,LW 5 ~,) ~ . .. „" ~ ~ T...l ~ Yr • ~ w h