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Home My WebLink About08-0895RONNIE M. WALBORN, Plaintiff VS. DAVID L. ROBERTSON, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNA NO. CF'-WS 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 or property or other rights important to you. 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 HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 RONNIE M. WALBORN, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNA VS. :NO. ?q 5' Civil Term DAVID L. ROBERTSON, : CIVIL ACTION - LAW Defendant : IN CUSTODY NOTICIA USTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar acci6n dentro de veinte (20) dias a partir de la fecha en que recibi6 la demanda y el aviso. Usted debe presentar comparecencia esrita en persona o por abogado y presentar en la Corte por escrito sus defensas o sus objeciones a las demandas en su contra. Se le avisa que si no se defiende, el caso puede proceder sin usted y la Corte puede decidir en su contra sin mas aviso o notificaci6n por cualquier dinero reclamado en la demanda o por cualquier otra queja o compensaci6n reclamadas por el Demandante. USTED PUEDE PERDER DINERO, O PROPIEDADES U OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE O NO CONOCE UN ABODAGO, VAYA O LLAME A LA OFICINA EN LA DIRECCION ESCRITA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 RONNIE M. WALBORN, Plaintiff VS. DAVID L. ROBERTSON, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNA :NO. -0p- k96' Civil Term : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, TO WIT, this A day of fry<? !? 52008 comes the Plaintiff, Ronnie M. Walborn, by and through her attorney, Jane M. Alexander, Esquire, and files this Complaint of which the following is a statement: 1. Plaintiff is Ronnie M. Walborn, an adult individual who currently resides at 83 Country View Estate, Newville, Cumberland County, Pennsylvania 17241. 2. Defendant is David L. Robertson, an adult individual who currently resides at 604 Copper Circle, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff and Defendant are the natural parents of a minor child; Katie Lee Robertson, age 1, born October 5, 2006. 4. Plaintiff seeks joint legal custody and primary physical custody of the said child with the Defendant having scheduled visitation because of his varied work schedule and has no independent living arrangement. 5. Plaintiff seeks primary physical custody of the child because from the date of the child's birth the Plaintiff has always been the primary care giver of the child. 6. The child was born out of wedlock. 7. The child has resided with the following persons at the following address since date of birth: From date of birth to July 2007 From July 2007 to date with both parties at 83 Country View Estate, Newville, PA 17241 with Plaintiff only at 83 Country View Estate, Newville, PA 17241 8. The relationship of the Plaintiff to the child is that of natural mother. 9. The relationship of Defendant to the child is that of natural father. 10. Plaintiff has not participated as a parry or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 11. Plaintiff has no information of a custody proceeding concerning the child pending in any other court of this Commonwealth. 12. 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. 13. The best interest and permanent welfare of the child will be best served by granting Plaintiff joint legal and primary physical custody of the child because Plaintiff can and has provided a stable home life for the child. She is presently employed and is able to provide for the care of the child. WHEREFORE, Plaintiff requests your Honorable Court to grant her joint legal custody and primary physical custody of the subject child with scheduled visitation to Defendant. Respectfully submitted, re AIIe`x, ner, E?6r oey fo Plaintiff orney I.D. #07355 148 S. Baltimore Street Dillsburg, PA 17019-0421 (717) 432-4514 VERIFICATION I verify that the statements made in this 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 unworn falsification to authorities. DATE:` ?W'61&w Ronnie M. Walborn COMMONWEALTH OF PENNSYLVANIA COUNTY OF YORK : S. S. Before me, the undersigned officer, a Notary Public, in and for the said Commonwealth and County, Personally appeared Ronnie M. Walborn who, being affirmed according to law, deposes and says that the facts and matters set forth in the foregoing Complaint are true and correct to the best of her knowledge, information and belief. Sworn to and subscribed before me this 6-L" day of qua , 2008. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Narurnoi Alexander, Notary Public Dplsburg Boro, York County My Car nission Expires Apr. 7, 2010 ember, Pennsvivania Association of Notaries onrue M. Walborn D ZI %JO 'SY RONNIE M. WALBORN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-895 CIVIL ACTION LAW DAVID L. ROBERTSON IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, February 13, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Monday, March 10, 2008 at 2:100 PM 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 order, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ ohn . Man an r. Es q. j.A 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 i A?l1V4,,jV/ ;\SNN3d 81;3! WJ ? 1 833 SDOZ 30H:10-Q11A