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HomeMy WebLinkAbout07-6694 CARRIE L. DOHERTY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. Q 7 - 64- 9V Civil Term MARK WEIST, ACTION IN QJAJVbp Defendant CUSTODY COMPLAINT 1. Plaintiff is Carrie L. Doherty, who currently resides at 5223 Eton Place, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant is Mark Weist who lives at 578 D. Hershey Road, Hummelstown, Dauphin County, Pa. 17036. 3. Plaintiff is the Mother of the following child and seeks a custody order regarding the following child: NAME DOB/AGE ADDRESS Dominick Weist 2/9/4(3) 5223 Eton Place Mechanicsburg, Pa. 17055 Mother and Father are not married. Mother currently has primary physical custody of the child. During the past five years, the child has resided with the following persons and at the following addresses: NAME ADDRESSES DATES Carrie L. Doherty Allison Morgan(Sibling) Carrie L. Doherty Mark Weist Allison Morgan(Sibling) 5223 Eton Place Mechanicsburg, Pa. 17055 5223 Eton Place Mechanicsburg, Pa. 17055 10/28/07 - present 4/07 - 10/28/07 Carrie L. Doherty 451 Valley St. 8/05 - 4/07 Mark Weist Marysville, Pa. 17053 Allison Morgan(Sibling) It Carrie L. Doherty 451 Valley St. 2/9/04 - 8/05 Mark Weist Marysville, Pa. 17053 The mother of the child is Carrie L. Doherty. She currently resides at 5223 Eton Place, Mechanicsburg, Cumberland County, Pa. She is not married. The father the child is Mark Weist. He currently resides at 578 D. Hershey Road, Hummelstown, Dauphin County, Pennsylvania, 17036. He is not married. 4. The relationship of plaintiff to the child is that of Mother. The plaintiff currently resides with the child and the child's half-sibling, Allison Morgan, age 13. 5. The relationship of defendant to the child is that of Father. The defendant currently lives alone. 6. 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 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 separated in October 2007. Since separation, Mother has maintained primary custody regarding the child Mother is requesting a custody order which would confirm that she has primary physical custody would provide for shared legal custody, and periods of partial custody for Father as the parties agree. Mother believes that such an order would be in the best interest of the child because it would provide stability for the child. 8. 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, Plaintiff requests the court to enter a custody order regarding the child. Date: CI /a,/0 7 Respectfully submitted, Adams, Esquire No. 79465 64 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? ? Carrie L. Doherty, Plaintiff r;7 O ui .`.? CARRIE L. DOHERTY IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 2007-6694 CIVIL ACTION LAW MARK WEIST IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, November 09, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at_ 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, December 12, 2007 at 11:30 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 pennanent 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/ Dawn S. Sunday, Esc 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 VINNAWNN3d L S *£ Nd £ I AON LODZ ANiCNiri-UCdd 311 d0 901:L40-031W $'8 200 8 PN CARRIE L. DOHERTY Plaintiff VS. MARK WEIST Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2007-6694 CIVIL ACTION LAW IN CUSTODY ORDER AND NOW, this 23?d day of January, 2008 , the conciliator, being advised by plaintiff's counsel that all custody issues have been resolved by agreement between the parties, hereby relinquishes jurisdiction. FOR THE COURT, Dawn S. Sunday, Esquire Custody Conciliator tt'f V