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HomeMy WebLinkAbout07-5925IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DNISION JAMES P. HALL, Plaintiff, vs. TERE5A M. WILSON, Defendant. COMPLAINT FOR CUSTODY 1. The Plaintiff, James P. Hall, is an adult individual who resides at 580 Middle Road, Newville, Pennsylvania 17241. 2. The Defendant, Teresa M. Wilson, is an adult individual who resides at 578 Middle Road, Newville, Pennsylvania 17241. 3. The Plaintiff seeks custody of the following child: Name Present Residence Awe Natasha R. Hall 580 Middle Road 11 Newville PA The child was born out of wedlock. The child is presently in the custody of the Plaintiff, James P. Hall who resides at 580 Middle Road, Newville, Pennsylvania. During the past five (5) years, the child has resided with the following persons at the following addresses: Persons James P. Hall Heather Hess (James' girlfriend) Addresses 580 Middle Road Newville PA Dates 7/06 to present James P. Hall Paul S. Hall (James' father) Kathy S. Hall (James' mother) 556 Middle Road Newville PA 1996 to 7/06 The father of the child is James P. Hall, currently residing at 580 Middle Road, Newville, Pennsylvania. He is single. The mother of the child is Teresa M. Wilson currently residing at 578 Middle Road, Newville, Pennsylvania. She is single. 4. The relationship of the Plaintiff to the child is that of father. The Plaintiff currently resides with his girlfriend, Heather Hess and the subject minor child. 5. The relationship of the Defendant to the child is that of mother. The Defendant currently resides with her mother, Connie Wilson, her father, Ken Wilson, and her brother, Ken Wilson, Jr. 6. The Plaintiff has not participated in other litigation concerning the child in this or any other state. 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. 7. The best interests and permanent welfare of the child will be served by granting the relief requested because the Plaintiff is in the best position to provide a more wholesome and complete home environment than that which can be provided by the Defendant. Recently, it was learned by the Plaintiff, that the minor child does not have her own bedroom at Defendant's home; the Defendant has left the minor child at home alone; has also left the minor child home alone and in charge of babysitting her cousin, who is four (4) years of age and has mental disabilities. Also, it has been learned by the Plaintiff that the Defendant's brother, Ken Wilson, Jr., is under investigation for possible child molestation charges and rape of a minor charge. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, the Plaintiff respectfully requests this Honorable Court enter an Order granting custody of the child, Natasha R. Hall to him. Respectfully submitted, ^ ~ 7 ~ '/• G J es P. Hall 580 Middle Road Newville PA (717) 776-5544 VERIFICATION I, JAMES P. HALL, verify that the statements made in the foregoing 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. ~ ~ ~ f } J es P. Hall Date: September j0 , 2007 W~ hV, 7~.! V t U 1 ((~. `~.-r C ~~ ^J "C} C i'Cf t ~'! ~,' (.._: C~~: ;. t~' i^. ~_) .'= ev c7 c~ ..., Q C" 1 --# t '"L? tJ7 O 'O 27 r`^ ..} ~1 ~1y '-~'^rro l"~} i'f7 _A~ "G . ~_ JAMES P. HALL PLAINTIFF V. TERESA M. WILSON DEFENDANT AND NOW, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • 2007-5925 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT Friday, October 12,.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, November 06, 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 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/ Jacgueline 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 `e'rr ~^~ "y' r'- 0 ~J v.~ ~~ ~ 6~ ~ZI sad 9 i .~30 tOZ t ~' `~~ ~~ CQ~~I~~/ htiblG 4C?t-~. ~~~ ~N.I 34 ~~~~;~t ~-~~1~ NOV 0 72007 0~~ JAMES P. HALL, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : N0.2007-5925 CIVIL ACTION -LAW TERESA M. WILSON, Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of , 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, James P. Hall and the Mother, Teresa M. Wilson, shall have shared legal custody of Natasha R. Hall, born March 16, 1996. 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 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 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. The parents shall have shared physical custody on a week on/week off basis with the exchange day and time being Friday after school. Mother's week shall begin Friday, November 9, 2007 and the parties shall alternate physical custody thereafter on a week on/week off basis. 3. Thanksgiving shall be shared such that Father shall always have physical custody of the child from 9:00 a.m. to 3:00 p.m. and Mother shall always have physical custody of the child from 3:00 p.m. to 9:00 p.m. 4. Christmas shall be divided into two Blocks. Block A shall be from 12:00 noon Christmas Eve to 12:00 noon Christmas Day. Block B shall be from 12:00 noon Christmas Day to 12:00 noon December 26. Mother shall have Block A in odd numbered years and Block B in even numbered years and Father shall have Block A in even numbered years and Block B in odd numbered years. 5. Ken Burrell shall have absolutely no contact with the child. 6. This Order is entered pursuant to an agreement of the parties at 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. BY J. cc: James P. Hall, pro se 580 Middle Road Newville, PA 17241 Teresa M. Wilson, pro se 578 Middle Road Newville, PA 17241 I //~Q/o7 8 ~ ~~ #~~ 6- lt4N I~OZ A~.tGN~J~-~~~d 3N~. ~C? `~'!~'d ~` I ZOf~l JAMES P. HALL, Plaintiff V. TERESA M. WILSON, Defendant PRIOR JUDGE: None 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 Natasha R. Hall IN THE COURT OF COMMON PLEA5 Ol+' CUMBERLAND COUNTY, PENNSYLVANIA N0.2007-5925 CIVIL ACTION - LAVA IN CUSTODY DATE OF BIRTH CURRENTLY IN CUSTODY OF March 16, 1996 Father 2. A Conciliation Conference was held in this matter on November 6, 2()07, with the following in attendance: The Father, James P. Ilall, pro se and the Mother, Teresa M. Wilson, pro se. 3. The parties agreed to an Order in the form as attached. ~ l~ -o ~(- (/ __ Date acq line M. Verney, Esquire Custody Conciliator