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HomeMy WebLinkAbout03-6587JOSEPH A. BEDARD, PLAINTIFF VS. TAMMY K. BEDARD, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY COMPLAINT IN CUSTODY AND NOW comes the Plaintiff, JOSEPH A. BEDARD, by his attorney, Samuel L. Andes, and makes the following Complaint for Custody: 1. The Plaintiff is JOSEPH A. BEDARD, an adult individual who resides at 1237 Hunter's Ridge Drive in Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is TAMMY K. 8EDARD, an adult individual who resides at 1044 Memory Lane in Mechanicsburg, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant are husband and wife, having been married on 26 April 1986. They separated in early April of 2003 and remain separated to this day. 4. The Plaintiff and Defendant are the parents of two minor children, Brianna K. Bedard, age 15, born 29 March 1988, and Gregory J. Bedard, age 13, born 6 November 1990. 5. Plaintiff seeks an award of shared legal and partial physical custody of the said minor children. 6. The children were not born out of wedlock and are presently in the custody of the Defendant. 7. During the past five years, the minor children have resided with the following persons at the following addresses: 1994 through March 2003 1044 Memory Lane Plaintiff & Defendant Mechanicsburg, PA 17055 Early April 2003 to present 1044 Memory Lane Mechanicsburg, PA 17055 Defendant only 8. The father of the children is the Plaintiff who resides at the address set out above. above. 10. alone. 11. The mother of the children is the Defendant who resides at the address set out The Plaintiff is the natural father of the children. Plaintiff currently resides The Defendant is the natural mother of the children. Defendant currently resides with the children. 12. The Plaintiff has not participated as a party or in any other way in any litigation concerning the custody of the children in this or any other court. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of this or any other jurisdiction. Plaintiff knows of no other person not a party to this action already who has physical custody of or claims to have custody or visitation rights to the said children. 13. The best interests and permanent welfare of the children will be served by granting the relief requested by Plaintiff for the following reasons: A. Plaintiff wishes to establish and maintain a proper parent-child relationship with both of his children. B. Plaintiff has instructed his access to the children and his opportunity to develop or maintain a parent child relationship with them; and C. It is in the best interest of the children that Plaintiff participate in decisions regarding them and that he have regular, frequent, and lengthy periods of temporary custody of them to foster a healthy parent child relationship. 14. 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 parties to this action. WHEREFORE, Plaintiff prays this court to award him shared legal custody of the two minor children, Brianna K. Bedard and Gregory J. Bedard and to award him reasonable and frequent periods of partial custody of the children. Attorney for Plaintiff Supreme Court ID # 17225 525 North 1 2th Street Lemoyne, Pa 17043 (717) 761-5361 verify that the statements made in this document are true and correct, understand that any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: JOSEPH A. BEDARD PLAINTIFF V. TAMMY K. BEDARD DEFENDANT 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-6587 CIVIL ACTION LAW IN CUSTODY _ORDER OF COURT AND NOW, Thursday, January 08, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. _, the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Monday, February 02, 2004 at 9:30 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 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: /si Melissa P. Greevy. 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 TIlE 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 V'"!J I'"',-=n 'm JOSEPH A. BEDARD, Plaintiff VS. TAMMY K. BEDARD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-6587 CIVIL TERM IN CUSTODY ACCEPTANCE OF SERVICE AND ENTRY OF APPEARANCE I hereby enter my appearance for the Defendant, Tammy K. Bedard, in the above- captioned action. I acknowledge receipt of a true and correct copy of the Complaint filed in the above action. J~rbara Sumple-Sullivan Attorney for Defendant 549 Bridge Street New Cumberland, PA 17070 Supreme Court ID # ~_~ HAR 0 2 2004¢ "o JOSEPH a. BEDARD, : Plaintiff : : V, : TAMMY K. BEDARD, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-6587 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this '~ r J day of ~ ~'-L , 2004, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Brianna shall participate in counseling with Melinda Eash of Reigler, Shienvold & Associates. Father and/or Mother shall participate in Brianna's sessions upon the request of therapist. Grog shall also participate in counseling with parental participation as indicated by the therapist as well. 2. The unreimbursed costs of counseling sessions attended by Father shall be paid for by Father and the unreimbursed costs of counseling sessions attended by Mother shall be paid for by Mother. In the event that the children attend counseling without either parent, the parties shall share equally any unreimbursed costs of those counseling sessions. Dist: BY THE COURT: Samuel L, Andes, Esquire, PO Box 168, Lemoyne, PA 17043 Barbara Sumple-Sullivan, Esquire, 549 Bridge Street, New Cumberland, PA 17070 JOSEPH A. BEDARD, Plaintiff V. TAMMY K. BEDARD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-6587 CIVIL TERM CIVIL ACTION - LAW iN CUSTODY 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 DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Brianna K. Bedard Gregory J. Bedard March 29, 1988 November 6, 1990 Mother Mother 2. A Custody Conciliation Conference was scheduled for February 23, 2004 as a result of Father's December 26, 2003 filing of a Complaint in Custody. Present for the conference were: the Father's counsel, Samuel L. Andes, Esquire; the Mother, Tammy K. Bedard, and her counsel, Barbara Sumpie-Sullivan, Esquire. The Father did not attend. 3. Plaintiff's counsel spoke with his client and obtained the authority for the agreement in the form as attached. Date ' '" Melissa Pee~uire Custody Conciliator :224909