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HomeMy WebLinkAbout07-5580RONALD E. WILSON, II, Plaintiff V. KAREN E. MALIN, Defendant 1. Plaintiff is Ronald E. Wilson, II, who currently resides at 7 Watson Drive, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Karen E. Malin, who currently resides at 15 Watson Drive, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff is the Father of the following children and seeks a custody order regarding the following children: NAME DOB/AGE ADDRESS Brooke E. Wilson 4/12/94 (14) 15 Watson Drive, Carlisle, Pa. 17013 Allison J. Wilson 11/25/96 (10) 15 Watson Drive, Carlisle, Pa. 17013 Mother and Father married on June 6, 1992 and were divorced on July 13, 2005. The parties currently share legal custody of the children. Mother has primary physical custody of the children. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. D 7. 5 5 M Civil Term CIVIL ACTION - LAW CUSTODY CUSTODY COMPLAINT During the past five years, the children have resided with the following persons and at the following addresses: NAME ADDRESSES DATES Ron and Karen Wilson 7 Watson Dr., Carlisle, Pa. Sept. 2002 - Feb. 2005 Karen Wilson 487 Highland Dr., Carlisle, Pa. Mar. 2005 - July 2005 Karen Wilson and Mark Malin 15 Watson Dr., Carlisle, Pa. July 2005 - Feb. 2007 Karen Malin and Mark Malin 15 Watson Dr., Carlisle, Pa. Feb. 2007 - present The mother of the child is Karen E. Malin, formerly known as Karen E. Wilson. She currently resides at 15 Watson Drive, Carlisle, Pa. 17013. She is married to Mark Malin. The father the child is Ronald E. Wilson. He currently resides at 7 Watson Drive, Carlisle, Pa. 17013. He is married to Mary Ann Wilson. 4. The relationship of plaintiff to the child is that of father. The plaintiff currently resides with his wife, Mary Ann Wilson. 5. The relationship of defendant to the child is that of mother. The defendant currently lives with her husband, Mark Malin, the children, and her husband's children. 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 other than as follows: The parties were divorced in 2005. A Decree was entered in Cumberland County under Docket No. 05 - 1529. The parties negotiated a custody stipulation during that action but the stipulation was never entered as an Order of Court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a party to the proceedings who has physical custody of the child or anyone who claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: The parties divorced in 2005. The parties' custody stipulation was never entered as an Order of Court. Father is requesting that an updated custody Order be entered which would better provide for the current situations of theparties. The children are getting older, circumstances have changed and the parties now live within a block of each other. Therefore Father is requesting that phMical custody be shared equally, on a 50/50 basis Father believes that such arrangement in an Order would be in the best interest of the children because it would provide stability for the children,provide ample access with both parents and better define the periods of custody with both parents 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the children has been named as parties to this action. WHEREFORE, Plaintiff requests the court to enter a custody order regarding the children. Respectfully submitted, Date: Ci.al .? ie Adams, Esquire No. 79465 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF VERIFICATION I verify that the statements made in this Custody 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. Date: o. Q 7 Ronald E. Wilson, II, Petitioner C-) .; 44 ( { C- ? c? r RONALD E. WILSON, 11 IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. KAREN E. MALIN DEFENDANT 2007-5580 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, September 27, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on _ Tuesday, October 30, 2007 _ at 9:30 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 THE COURT, By: /s/ Jacqueline M. Verney, 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 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 a + `? cur ° L Z ?t JAN Z 8 2008 r RONALD E. WILSON, II, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-5580 CIVIL ACTION - LAW KAREN E. MALIN, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 28 h day of January, 2008, the plaintiff's counsel having requested the matter by cancelled, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, /?' U cq ine M. Verney, Esquire, Cust dy Conciliator Rte} ?'?+,. r ft I i tom./