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Home My WebLink About07-7133DEDRICK LAMARR TINKER, PLAINTIFF VS. LAQUITA CHISOLM, DEFENDANT : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA NO. 4)7 -7113 CIVIL TERM : CIVIL ACTION -LAW : IN CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the Plaintiff. You may lose money, property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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 2 Liberty Avenue Carlisle PA 17013 (717) 249-3166 1-800-990-9108 DEDRICK LAMARR TINKER, PLAINTIFF VS. LAQUITA CHISOLM, DEFENDANT : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA NO. 67- 7133 CIVIL TERM CIVIL ACTION -LAW IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, DEDRICK LAMARR TINKER, by and through his counsel, Susan Kay Candiello, Esquire, of the Law Firm of Susan Kay Candiello, P.C., and files this Complaint for Custody upon a cause of action of which the following is a statement: 1. The Plaintiff (hereinafter sometimes referred to as "Father") is DEDRICK LAMARR TINKER, who currently resides at 16072 Kline Young Road, Stewartstown, York County, Pennsylvania, 17363. 2. The Defendant (hereinafter sometimes referred to as "Mother") is LAQUITA CHISOLM, who currently resides at 2207 Cedar Run Drive, Apt. A, Camp Hill, Cumberland County, Pennsylvania, 17011. 3. Plaintiff seeks Shared Legal and Partial Physical Custody of the following children: Name Present Residence Date of Birth DEDRICK LAMARR TINKER, JR. 2207 Cedar Run Drive, Apt A February 8, 2002 Camp Hill, PA LEILAH JACQUE TINKER 2207 Cedar Run Drive, Apt A November 16, 2004 Camp Hill, PA 4. The children were born out of wedlock. 5. The children are presently in the custody of the Defendant, who resides at 2207 Cedar Run Drive, Apt. A, Camp Hill, Cumberland County, Pennsylvania, 17011 6. Since birth the children have resided with the following persons at the following addresses: PERSONS ADDRESS DATES Plaintiff and Defendant Defendant 2207 Cedar Run Drive, Apt A to Present Camp Hill, PA 7. The Mother of the child is the Defendant, LaQuita Chisolm, who currently resides at 2207 Cedar Run Drive, Apt. A, Camp Hill, Cumberland County, Pennsylvania, 17011. Father and Mother were never married. 8. The Father of the child is the Plaintiff, Dedrick Lamarr Tinker, who currently resides at 16072 Kline Young Road, Stewartstown, York County, Pennsylvania, 17363. 9. The relationship of the Defendant, LaQuita Chisolm, to the children is that of the Natural Mother. Mother resides at 2207 Cedar Run Drive, Apt. A, Camp Hill, PA 17011. 10. The relationship of the Plaintiff, Dedrick Lamarr Tinker, to the children is that of the Natural Father. Father resides at 16072 Kline Young Road, Stewartstown, PA 17363. 11. The Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 12. Plaintiff has not participated as a party in any prior custody agreement concerning the custody of the children in any other court in Pennsylvania. 13. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth at this time. 14. The best interests and permanent welfare of the children will be served by granting the relief requested because: A. Father has great love and concern for his children; B. Father has always been involved and active in the children's lives; C. Depending upon Mother's decisions at any given time she will not allow Father to see his children; D. Father believes it is in the best interests of his children for him to be actively involved in their lives; E. Father wants to be a part of his children's lives all the time, not just when Mother agrees he can be. 15. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as a party to this action. WHEREFORE, Plaintiff, DEDRICK LAMARR TINKER, requests this Honorable Court award the Plaintiff, DEDRICK LAMARR TINKER and the Plaintiff, LAQUITA CHISOLM, SHARED LEGAL CUSTODY of the parties' minor children, DEDRICK LAMARR TINKER, JR. and LEILAH JACQUE TINKER and the Defendant, LAQUITA CHISOLM, PRIMARY PHYSICAL CUSTODY and the Defendant, DEDRICK LAMARR TINKER, PARTIAL PHYSICAL CUSTODY of the minor children, DEDRICK LAMARR TINKER, JR. and LEILAH JACQUE TINKER. Respectfully submitted, LAW FIRM OF SUSAN KAY CANDIELLO, P.C. Dated: November, 2007 Sugan Kay C ' , Esgi Counsel for Pla' tiff PA I.D. # 6 9 4010 Glenfinnan Place Mechanicsburg PA 17055 (717) 724-2278 VERIFICATION The undersigned hereby verifies that the facts averred in the foregoing document are true and correct to the best of her knowledge, information, and belief. This verification is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities. DATED: r- a v r o? OO. 0/ DEDRICK LAMARR TINKER `V f? /v?A) U1 d F`J r- r-a CD r.? ra Q -n .L _?cr? DEDRICK LAMARR TINKER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 2007-7133 CIVIL ACTION LAW LAQUITA CHISOLM IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, December 06, 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 Tuesday, January 08, 2008 at 9:00 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. 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/ Daum S. Sunda Es q, 1) vej 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 j3r33 yew l4cpZ) LO !_?:Tj f „l U11N 11200f'' DEDRICK LAMARR TINKER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2007-7133 CIVIL ACTION LAW LAQUITA CHISOLM Defendant IN CUSTODY ORDER AND NOW, this 8TH day of January , 2008 the conciliator, having scheduled a custody conciliation conference for January 8, 2008 for which neither of the parties appeared, and having subsequently determined from 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 .A. A FT I r cn 33 L