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HomeMy WebLinkAbout08-0132NOTICE 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 prompt action. You are warned that if you fail to o so, you may lose rights and visitation of your child. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFF] ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE i CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford St. Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to compl3 Americans with Disabilities Act of 1990. For information about accessible facili, reasonable accommodations available to disabled individuals having business bei please contact our office. All arrangements must be made at least 72 hours prior business before the court. You must attend the scheduled conference or hearing. HIRING A E MAY BE 'HAT MAY R, NO FEE. with the ies and ire the court, o any hearing or ANGELA S. MICKLO, Plaintiff vi. JAMES E. FELTS, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVI, CIVIL ACTION - LAW IN CUSTODY : NO. o f. > 3 -1- CIVIL TERM COMPLAINT FOR CUSTODY The Plaintiff, ANGELA S. MICKLO, by her attorneys, the Family Law Clir the following cause of action in custody. 1. The Plaintiff is ANGELA S. MICKLO, residing in Cumberland County, Plaintiff wishes to keep her address confidential at this time. 2. The Defendant is JAMES E. FELTS, residing at 820 York Road, County, Pennsylvania 17013. 3. Plaintiff seeks primary custody of: Name Present Residence Alexzandrea James The child is presently with her Mother Felts (born November 6, 2007) The child was born out of wedlock. The child is presently in the custody of Mother who requests that her confidential. Since birth, the child has resided with the following persons at the Persons Address 1. Angela S. Micklo and 820 York Road James E. Felts Carlisle, PA 17013 2. Angela S. Micklo undisclosed location sets forth lvania. Cumberland remain addresses: October of 2007- Dece ber 17, 2007 17,2007- 2 r. The Mother of the child is Angela S. Micklo. She is currently married to Jeffrey S. Micklo. Mother filed a Complaint i Divorce No. 07-6580 on October 30, 2007. The Father of the child is James E. Felts. He is not married. 4. The relationship of Plaintiff to the child is that of Mother. The Plaintiff resides with the following persons: Name Relationship Mother requests that her current address be kept confidential. 5. The relationship of Defendant to the child is that of Father. The resides with the following persons: Name Phyllis Feeser Relationship Mother t currently 6. Plaintiff has not participated as a party or witness, or in another capacity, n other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child ending in a court of this Commonwealth, or any other state. Plaintiff does not know of a person not a party to the proceedings who ha physical custody of the child or claims to have custody or visitation rights with res ect to the child. 7. The best interest and permanent welfare of the child will be served by grating the relief requested because: a. Plaintiff has acted as the child's primary caretaker since birth; b. Plaintiff will permit continuous contact between the Defendant an the child; c. Plaintiff is willing to accept custody of the child. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody to the child have been named as parties to this WHEREFORE, Plaintiff respectfully requests the Court to grant legal custody and primary physical custody of the child, with Father haN partial custody. Respectfully submitted, Date: ? Certified Legal Intern M. PLACE ROBERT E. RAINS LUCY JOHNSTON-W) ANNE MACDONALD. MEGAN RIESMEYER Supervising Attorneys THE FAMILY LAW 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 shared periods of Verification I verify that the statements made in this Complaint are true and correct. I that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Angela c Plaintiff N may. (( JJ ri, ANGELA S. MICKLO, : IN THE COURT OF COMMON PLEAS ( Plaintiff : CUMBERLAND COUNTY, PENNSYLV. V. : CIVIL ACTION - LAW IN CUSTODY JAMES E. FELTS, Defendant. : NO. CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Angela S. Micklo, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauper's, certifies that we believe the party is unable to pay the costs and that we are providing free 1 gal service to the party. Respectfully submitted, Date, ly y Mean M. Michael Certified Legal Intern F ROBERT E. RAINS o THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 -n Co crt ANGELA S. MICKLO IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JAMES E. FELTS DEFENDANT 2008-0132 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, January 15, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, February 01, 2008 at 10:30 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. 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/ Hubert X. Gilro Es q. jit 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'o 9 1 :C 1 48 S 1 Mvp 0001 ?' Ii/ / -J// uaK s o = 10 ANGELO S. MICKLO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION -LAW JAMES E. FELTS, : NO. 2008-0132 Defendant : IN CUSTODY COURT ORDIER Y? AND NOW, this c)q day of AA/ , 2008, the Conciliator being advised that the Complaint has been withdrawn by the parties, the Conciliator relinquishes jurisdiction. _0b(-)Qz Hubert X. Gilroy, squire Custody Concilia r t- r':?s ANGELA S. MICKLO, Plaintiff V. JAMES E. FELTS, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY : NO. 2008-0132 CIVIL TERM PRAECIPE TO WITHDRAW COMPLAINT IN CUSTODY To the Prothonotary: Please withdraw the Complaint in Custody filed in the above-captioned matter on January 8, 2008. 0 J nary 30, 008 //-?l wryq ?j -4 " Me Michael Certified Legal Intern Megan esmeyer Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 cr% ANGELA S. MICKLO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY JAMES E. FELTS, Defendant. : NO. 2008-0132 CIVIL TERM CERTIFICATE OF SERVICE I, Megan M. Michael, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving a time-stamped copy of the Praecipe to Withdraw the above-captioned Custody Complaint on James E. Felts, residing at 820 York Road, Carlisle, PA 17013 by depositing a copy of the same in the United States mail, postage prepaid on January 30, 2008. t l e Meg Michael Certified Legal Intern Meganesmeyer Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 tR ?' ?;? " ?'