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Home My WebLink About07-4326DUSTIN COHICK, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. NO: d ~- w 3 3C~ ~i.~n=l fi1.~- CIVIL ACTION -LAW GINA O'DONEL, IN CUSTODY Defendant. COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, Dustin Cohick, by and through his attorneys, Mancke, Wagner, Spreha & McQuillan, and files the following Complaint for Custody: 1. The Plaintiff, Devon Cohick, is an adult individual residing at 133 N. Second Street, Newport, Perry County, Pennsylvania. 2. The Defendant, Gina O'Donel, is an adult individual residing at 35 W. Locust Street, Mechanicsburg, Cumberland County, Pennsylvania. 3. The parties are the natural parents of one (1) child, Madison, born February 15, 2005. 4. The child was born out of wedlock. 5. The Plaintiff, Dustin Cohick, is the natural father of the child, and the Defendant, Gina O'Donel, is the natural mother of the child. 6. The child has resided since birth with the Defendant, Gina, O'Donel, at the address contained in paragraph 2 above. 7. Plaintiff knows of no other person seeking custody or partial custody of the child. 8. Neither party is a member of the Armed Forces of the United States or any of its Allies. 9. Plaintiff believes and therefore avers that it is in the best interests of the child to grant shared legal custody unto the parties, and a schedule a partial custody unto the Plaintiff herein. WHEREFORE, Plaintiff requests the Court to grant the relief as requested. Respectfully submitted, Mancke, Wa.g~fer, Spreha & McQuillan Esquire ZZ33 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Plaintiff Date: `1 ~~ D -2- VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. ,~ c_ _ ' u DATE: ~'/jd/~7 (=) N r- 11 4 a ~~y V 1 Q - r J ~~~~ ~ . ~ -~ Q ~'~.) '7r 'fir ~^r. ~ - ~ ~ t t`. _t ..s :: l iY, DUSTIN COHICK IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA v. GINA O'DONEL DEFENDANT 2007-4326 CLVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, July 30, 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 Wednesday, August 22, 2007 at 10:00 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 all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 4$ hours prior to scheduled hearing, FOR THE COURT, By: /s/ ohn .Man an 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 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. 1F 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 y~~ ~ ~ ~,a~y ~ ~ C ~ ~g 9~ ~ 1 Wd Z- ~fi~ LOOl A"t4~1f3~~ivr~li.;',~~ ?Hl ~Q ~~L:~~-{~~i~ r .. DUSTIN COHICK, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. : N0.07-4326 CIVIL TERM GINA O'DONEL, : IN CUSTODY Defendant PRAECIPE FOR ENTRY OF APPEARANCE To Curtis R. Long, Prothonotary: Please enter my appearance on behalf of the Defendant, Gina O'Donel, in the above captioned case. Date: ~ • a~ • ~- Je i a H~llst, Esquire enn Legal Services 401 E. Louther Street Carlisle, PA 17013 (717) 243-9400 i Respectfully submitted, ~' ... 1 DUSTIN COHICK, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. : N0.07-4326 CIVIL TERM GINA O'DONEL, : IN CUSTODY Defendant CERTIFICATE OF SERVICE I, Jessica Holst, Esquire, of MidPenn Legal Services, attorney for the Defendant, Gina O'Donel, hereby certify that I have served a copy of the foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following date and in the manner indicated below: U.S. First Class Mail. Postage Pre-Paid P. Richard Wagner, Esquire 2233 North Front Street Harrisburg, PA 17110 Date: ~ ~ ' ~- M~idPenn Legal Services 401 E. Louther Street Carlisle, PA 17013 (717) 243-9400 i m ±' ~-- ~-r~ r --~' ~ ,.:.~ : ~ ~j- .. ~ =~' _ 1 ?' i _ ~ ,,,-e. ~' ~ ~'~"1 , i < ` ~ ~ AUG S g2DDl DUSTIN COHICK IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. No. 07-4326 Civil Term GINA O' DONEL Defendant :ACTION IN CUSTODY COURT ORDER AND NOW, this 2f~'day of August, 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that: 1. Legal Custody: The Father, Dustin Cohick and the Mother, Gina O'Donel, shall enjoy shared 1ega1: custody of the minor child, Madison O'Donel, born February 15, 2005. The parties sha11 have an equal right, to be exercised jointly with the. other parent, ~to: make all major non-emergency decisions affecting the child's general well-'being including, but not limited to, all decisions regarding her health, education: and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the :records and information of reasonable use to the other parent. 2. Physical Custody: The Mother shall have primary physical custody subject to Father's rights of partial physical custody which shall be arranged as the parties may mutually. agree. 3. This matter is continued generally until such time as the parties can come to an agreement as to a visitation schedule, or lack thereof. Either party, or their counsel, may contact the assigned conciliator to arrange for said status update conciliation. 4. This Order is entered pursuant to a Custody Conciliation Conference. The parties may. modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. V ~`~ ~~z ti ~~ ~4~: N's:~~ 4 V ~~~ i Y# V~ V! l Y ` V V Y ~~~~r.~~~_~~~l~ r gichard w~~ Esq~e Cc H:olst, Esgwre Jessica So~- 7. Mangan, Esquire d DUSTIN COHICK Plaintiff v. GINA O'DONEL Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07-4326 Civil Term ACTION IN CUSTODY CONCII.IATION CONFERENCE SUMMARY R~P't)RT IN ACCORDANCE` WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.,3-8(B),ahe undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is: as follows: Madison O'Donel born February 15, 2005, currently in the primary physical custody of the Mother. 2. A Conciliation Conference was held on August 22, 2007 with the following. individuals in attendance: The Father, Dustin Cohick with his counsel, Richard Wagner, Esquire The Mother, Gina'O'Donel, with her counsel, Jessica Holst, Esq. 3. The parties agreed to the entry of an Order in the form as attached. Date: 2 3~d J .Meagan, uire . ~ ustody Conciliator LAW OFFICES OF DILS &DILS DIANE M. DILS, ESQUIRE Attorney I.D. No. 71873 1400 North Second Street, First Floor, Front Harrisburg, PA 17102 Telephone No. (717) 233-8743 Attorney for Plaintiff, Dustin Cohick DUSTIN COHICK Plaintiff, vs. GINA O'DONEL Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.07-4326 Civil Term CIVIL ACTION -LAW IN CUSTODY PRAECIPE Please enter my appearance on behalf of the Plaintiff, Dustin Cohick in the above captioned matter. Respectfully submitted, Y: Diane M. Dils, Esquire 1400 North Second Street Harrisburg, PA 17102 (717) 232-9724 I.D. No. 71873 Date: June 20, 2008 M ~~ p `.a ~ ' " ~ - ~~~ , ~ . ~1 {1 ~_. +~.~ V t ..., ~,F C~~ ~." ,~'. ~,. r...1 / 4 ¢ AUG 21 2008 ~{~ C DUSTIN COHICK IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. No. 07-4326 Civil Term GINA O'DONEL Defendant : ACTION IN CUSTODY Prior Judge: Kevin A. Hess, J. COURT ORDER AND NOW, this 2 ~ . day of August 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that: Pursuant to an executed private agreement and representations of counsel, Plaintiffls custody complaint is hereby WITHDRAWN and the instant matter is hereby DISMISSED without prejudice. BY THE COURT, ,(~~ J. Cc: ~ane Dils, Esquire ~sica Holst, Esquire ~6hn J. Mangan, Esquire y ~ ~ Cif t.L t , y } ~i'G` ~ ~iV ~ ~= ] f..},.. ~ ~~ ~ t ~" .. a DUSTIN COHICK Plaintiff v. GINA O'DONEL Defendant Prior Judge: Kevin A. Hess, J. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07-4326 Civil Term ACTION IN CUSTODY CONCILIATION CONFERENCE SU1VIIViARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(B), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Madison O'Donel, born February 15, 2005, currently in the primary physical custody of the Mother. 2. A Conciliation Conference was held on August 22, 2007, an Order was issued August 28, 2007 and an status update conference was held August 21, 2008 with the following individuals in attendance: The Father, Dustin Cohick with his counsel, Diane Dils, Esquire The Mother, Gina O'Donel, with her counsel, Jessica Holst, Esq. 3. The parties agreed to the entry of an Order in the form as attached. Date: ~ ~~ ~ ~~ Jo gan, Esquire Cu od Conciliator