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HomeMy WebLinkAbout03-5263MICHAEL DUNN, Plaintiff VS. EMMARHONDA DUNN-WILSON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 2003- ..¢',2 c..~ CIVIL TERM : IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is MICHAEL DUNN, residing at 143 15TM Street, Apt. 10, New Cumberland, Pennsylvania 17070 2. The Defendant is EMMARHONDA DUNN-WILSON, residing at 351 Chaparral Road, Apt. 1201, Allen, Texas. 3. The Plaintiff seeks custody of the following child, MICHAEL DUNN, JR., who resides at 143 15~ Street, Apt. 10, New Cumberland, Pennsylvania. The child was not born out of wedlock. The child is presently in the custody of MICHAEL DUNN, who resides at 143 15~ Street, Apt. 10, New Cumberland, Pennsylvania. During the past five years, the child has resided with the following persons and at the following addresses: NAME MICHAEL DUINN EMMARHONDA DUNN- WILSON ADDRESS 143 15th Street, Apt110 New Cumberland, PA various addresses in Sacramento, CA and TX FROM/TO 7/99 to present 1998 to 7/99 10. Each parent whose parental dghts to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action, WHEREFORE, the Plaintiff requests this Court to grant primary physical custody The mother of the child is EMMARHONDA DUNN-WILSON currently residing at 351 Chaparral Road, Apt. 1201, Alien, Texas. She is married. The father of the child is MICHAEL DUNN currently residing at 143 15th Street, Apt. 10, New Cumberland, Pennsylvania He is married. 4. The relationship of the Plaintiff to the child is that of Father. The Plaintiff currently resides with the following person(s): Michael Dunn, Jr.. son. 5. The relationship of the Defendant to the child is that of Mother. The Defendant currently resides with two children, aged 1 year old, and 7 years old. 6. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation concerning the custody of the child in this or another jurisdiction. 7. The Plaintiff has no information of a custody proceeding concerning the child pending in a court of the Commonwealth. 8. The Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 9. The best interest and permanent welfare of the child will be served by granting the relief requested because: a) The Plaintiff can best provide for the educational, physical and emotional needs of child. 10. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, the Plaintiff requests this Court to grant pdmary physical custody of the child to the Plaintiff. SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Plaintiff By: ~l~Dar 3~ire 26 West High Street Carlisle, PA 17013 (717) 243-6222 VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom falsification to authorities, Date: ~,t~L(~, MICHAEL DUNN PLAINTIFF V. EMMARHONDA DUNN-WILSON DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-5263 CIVIL ACTION LAW iN CUSTODY ORDER OF COURT AND NOW, Wednesday, October 08, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before J_aequeline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, November 05, 2003 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effbrt 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 TIlE COURT, By: /s/ fitcqueline M. Verney. Esq. Custody Conciiiator 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, plea..5e 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 TI-IlS 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 ItELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ,'L[NIn03 MICHAEL DUNN, : IN THE COURT OF COMMON PLEAS OF Plaintiff iCUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2003-5263 CIVIL TERM EMMARHONDA DUNN-WILSONi CIVIL ACTION - LAW Defendant : : IN CUSTODY ORDER OF COURT AND NOW, this 18th day of March, 2004, the Conciliator not being contacted for more than 90 days following a general continuance, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, q ' ,', Custod~onc~