The URL can be used to link to this page

Home My WebLink About07-5116Rebekka A. Wright, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Shane A. Wright, No. ~ `~ - .i ~`~ ~, CIVIL Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Rebekka A. Wright, residing at 8 Larch Drive, Shippensburg, Cumberland County, Pennsylvania 17257. 2. The defendant is Shane A. Wright, residing at 2/3 Echo Co. WPNS PLT MCBH, Kaneohe Bay, Hawaii 96863. 3. Plaintiff seeks custody of the following child: Name Present Residence DOB Age Joshua Allen Wright 8 Larch Drive 12-03-06 8 Months Shippensburg, Pa 17257 The child was not born out of wedlock The child is presently in the custody of Rebekka A. Wright, residing at 8 Larch Drive, Shippensburg, Cumberland County, Pennsylvania 17257. During the past five years, the child has resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Rebekka A. Wright 8 Larch Drive Shippensburg, Pa Birth to Present 4. The mother of the child is Rebekka A. Wright, residing at 8 Larch Drive, Shippensburg, Cumberland County, Pennsylvania 17257. She is married. The father of the child is Shane A. Wright, residing at 2/3 Echo Co. WPNS PLT MCBH, Kaneohe Bay, Hawaii 96863. He is married. The relationship of plaintiff to the child is that of Mother. The plaintiff currently resides with the following persons. Name Relationship Terry Linn Father Chris Linn Mother Katherine Linn Sister Abagail Miley Niece Joshua A. Wright Son 6. The relationship of defendant to the child is that of Father. The defendant currently resides with the following persons. Name Relationship Unknown- Marine Corp Base 7. 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. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. 8. The best interest and permanent welfare of the child will be served by granting the relief request because: Plaintiff has undertaken and performed the primary parental responsibilities for the minor child. Plaintiff is best able to provide the care and nurture which the child needs for a healthy development. Defendant is active in the Marines and is believed to be leaving for Iraq in the near future. Defendant does drink alcohol, uses profanity and is believed to have fines against him for carrying a switchblade and is therefore unreliable as custodian of the child. WHEREFORE, Plaintiff requests this Court grant primary physical custody to Plaintiff. Respectfully submitted, ROMINGER & ASSOCIATES Date: U ~? ~~~ ~= Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. #81924 Attorney for Plaintiff Rebekka A. Wright, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Shane A. Wright, No. O?- 5J l !~ CIVIL Defendant IN CUSTODY 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. X4904 relating to unsworn falsification to authorities. ----~. Rebekka A. Wright, Plaintiff Rebekka A. Wright, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Shane A. Wright, No. CIVIL Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Kazl E. Rominger, Esquire, attorney for Plaintiff do hereby certify that I this day mailed a copy of the within Complaint for Custody upon the following by depositing same in the United States mail, postage prepaid, at Cazlisle, Pennsylvania, addressed as follows: LCPL Shane Wright 2/3 Echo Company WPNS PH Kaneohe Bay, Hawaii 96863. Date: a~lU j ~-- Kazl E. Rominger, Esquire 155 South Hanover Street Cazlisle, PA 17013 (717) 241-6070 Supreme Court LD. #81924 Attorney for Plaintiff ""` ~~Sl ~ '^„ S ~ \~ ~`. c~ ~?~"'- _ r'--, l.~ ~ ~ - J `~ ~_ ...2 4~ t yy' :.: S \ N hi(. ~ i °;~ , . ~a ., _~. a __.s ~~ (~ ~~; . s t REBEKKA A. WRIGHT IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. SHANE A. WRIGHT DEFENDANT • 2007-5116 CIVIL ACTION LA W IN CUSTODY ORDER OF COURT AND NOW, Tuesday, August 28, 2007 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacquetiae M. Verney, Esq. ,the conciliator, at 4th Floor, Cumberland Couuty Courthouse, Carlisle on Tuesday, October 02, 2007 at 9:30 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 alder 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: /s/ ac veline M. Verne 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, 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 ,~ ca,~p d ~ ~~ ~~'t ~qOZ ~:~L~~j~ '~~~`11~ OCT 2 420D7 / 1 REBEKKA A. WRIGHT, Plaintiff VI. SHANE A. WRIGHT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2007-5116 IN CUSTODY ORDER OF COURT CIVIL ACTION -LAW AND NOW, this 1 s' day of Och 6~ , 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Rebekka A. Wright and the Father, Shane A. Wright, shall have shared legal custody of Joshua. Allen Wright, born December 3, 2006. Each parent shall 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 his 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 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. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 2. Mother shall have primary physical custody of the child. 3. Father shall have periods of partial physical custody as agreed by the parties. 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. y is ' 1f,". ~,,... `1 ` ~t.. ~ ~ ~ ~ ~ ~~ .~~ ~Q~ A~t":l..'~i~sr~~.u~~ 3N.I ~0 ca~Kaz . Rominger, Esquire, COfin ane A. Wright, pro se 2/3 Echo Co. WPNS PLT MCBH BY THE COURT, Kaneohe Bay, Hawaii 96863 REBEKKA A. WRIGHT, Plaintiff V. SHANE A. WRIGHT, Defendant PRIOR JUDGE: None IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2007-5116 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 Joshua Allen Wright DATE OF BIRTH CURRENTLY IN CUSTODY OF December 3, 2006 Mother 2. A Conciliation Conference was held in this matter on October 23, 2007, with the following in attendance: The Mother, Rebekka A. Wright, with her counsel, Karl E. Rominger, Esquire. Father, Shane A. Wright, although served with notice of the conciliation conference, did not appear. 3. Mother requested an Order of Court in the form as attached. IU-~3~o I"~- Date acq line M. Verney, Esquire Custody Conciliator