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Home My WebLink About08-1044KATHY R. ERICKSON, Plaintiff V. JULIA M. ERICKSON, Defendant V. MARCUS ROSE, Additional Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW NO. 0i- /oY yCIVIL TERM IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Kathy R. Erickson an adult individual currently residing at 604 North Baltimore Avenue, Apartment H, Mount Holly Springs, Cumberland County, Pennsylvania. 2. The Defendant is Julia M. Erickson, an adult individual currently residing at an unknown location in Texas. 3. The Additional Defendant is Marcus Rose, an adult individual currently living at an unknown location in Jamaica. 4. The Defendants are the natural parents of one (1) child, namely, Malajah Avion Erickson, born February 24, 1998. The Plaintiff is the maternal grandmother of the child. The child was born out of wedlock. For the past five (5) years, or since the child's birth, the child has resided with the following persons at the following addresses for the following periods of time: NAME ADDRESS Kathy R. Erickson and 604 N. Baltimore Ave., Apt. 4 Dariel Lapre Erickson (sister) Mt. Holly Springs, PA 17065 Kathy R. Erickson and Dariel Lapre Erickson (sister) 102 West High Street Carlisle, PA 17013 Kathy R. Erickson and Dariel Laprd Erickson (sister) Julia M. Erickson and other unknown people 134 N. Hanover St., Apt. 9 Carlisle, PA 17013 Unknown locations DATES May 2007 to Present May 2006 to May 2007 February 13, 2006 May 2006 Unknown dates The natural mother of the child is Julia M. Erickson, who resides as aforesaid. She is single. The natural father of the child is Marcus Rose, who resides as aforesaid. He is single. The Plaintiff is the maternal grandmother of the child, and resides as aforesaid. She is single. 5 6. The relationship of the Plaintiff to the child is that of maternal grandmother. The Plaintiff currently reside with the child at issue and the child's sister, Dariel Lapre Erickson. The relationship of the Defendant, Julia M. Erickson, to the child is that of natural mother. It is unknown with whom the Defendant currently resides. 7. The relationship of the Additional Defendant, Marcus Rose, to the child is that of natural father. It is unknown with whom the Defendant currently resides. 8. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning custody of the child. 9. Plaintiff has no information of any custody proceedings concerning the child pending in any Court of this Commonwealth or in any other state. 10. It is in the best interest and permanent welfare of the child to grant the relief requested for the following reasons: a. The child was abandoned by Defendant, her mother, and Additional Defendant, her father, was deported to Jamaica in or about 2001 such that Plaintiff is the party most capable for providing for the day to day needs of the child. b. The Plaintiff can provide a stable environment for the child. C. The Plaintiff is best able to take care of the educational, medical, psychological, emotional, and mental upbringing of the child. 11. Plaintiff does not know any person not a party to these proceedings who claims to have custody or visitation rights with respect to the child. 12. A Petition for Special Relief is being filed simultaneously with the Custody Complaint in regards to a temporary Order requesting that sole legal and physical custody of the child be granted to Plaintiff and that notice requirements be waived in regards to Defendant. WHEREFORE, Plaintiff requests your Honorable Court to enter the Order scheduling a conciliation conference and at the same time granting the relief requested in the Petition for Special Relief. Respectfully submitted, 01• ''» o n .n _111 0, -5 ? Hannah Herman-Snyder, Esqu e Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements -made in the foregoing document 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 unsworn falsifications to authorities. DATE: ?( - O g KAT Y R. _ERJCII? ON ?? S Q O C17 A 00 - J rn KATHY R. ERICKSON, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. JULIA M. ERICKSON, CIVIL ACTION - LAW Defendant/Respondent V. NO.OP- iv 0CIVIL TERM MARCUS ROSE, Additional Defendant/Respondent: IN CUSTODY PETITION FOR SPECIAL RELIEF 1. Petitioner is Kathy R. Erickson, the above named Plaintiff, an adult individual currently residing at 604 North Baltimore Avenue, Apartment 4, Mount Holly Springs, Pennsylvania. 2. Respondents are the Julia M. Erickson, the above named Defendant, an adult individual currently residing at an unknown location in Texas, and Marcus Rose, the above named Additional Defendant, an adult individual currently residing at an unknown location in Jamaica. 3. The Defendants are the natural parent of one child, namely Malajah Avion Erickson, born February 24, 1998. 4. On or about February 13, 2006, Respondent, Julia M. Erickson, left her children, Dariel Lapre Erickson, and Malajah Avion Erickson with the children's maternal grandmother, Kathy R. Erickson, and left a letter, a copy of which is attached hereto and incorporated herein by reference as Exhibit "A". 5. Respondent, Marcus Rose, was deported to Jamaica in or about 2001, and while the child speaks with said Respondent sporadically, she last spoke to him around Christmas in 2006, and she has never met Respondent. 6. Petitioner does have a telephone number for Marcus Rose's mother, with whom there has been some contact, last being around Christmas in 2006. 7. Petitioner has been caring for the children's educational, medical, psychological, emotional, and mental needs since February 13, 2006. 8. While Petitioner has had no direct contact with Respondent, Julia M. Erickson, since February 13, 2006, it is believed and therefore averred that said Respondent has sporadic contact with her daughters via their cell phones, although she has not seen the children since February 13, 2006. 9. Respondent, Julia M. Erickson, last spoke with her daughters around Halloween in 2007. 10. Respondent, Julia M. Erickson, has numerous warrants out for her arrest in the state of Pennsylvania, including warrants for unpaid support and offenses related to drugs, alcohol, and prostitution. 11. In regards to attempts to obtain contact information for both Respondents, Petitioner, through counsel, has attempted the following: a. Petitioner, personally and through counsel, attempted to contact Marcus Rose's mother, via the telephone number she has, but left a voicemail messages and there was never a response. b. Julia A. Erickson has an uncle and aunt, Richard and Christine Erickson, with whom she is sporadically in touch, last having contacted them in October 2007, and Petitioner requested any current contact information Richard and Christine Erickson may have and they represented that no contact information has been provided. c. Three Internet searches were done, via peoplefinders.com, peoplelookup.com, and public-records-now.com, and turned up no information on a Julia M. Erickson in Texas. d. Calls placed to the children's cell phones were investigated to determine if there was a number recorded for the incoming calls but no number registered. e. Petitioner contacted the hotel, in Texas, from which Julia M. Erickson once called and was informed that she was not available at said number. 12. As Petitioner has no means of discovering where Respondent, Julia M. Erickson, resides, and cannot contact her only connection regarding Marcus Rose, Petitioner requests that the notice requirements for the custody action, beginning with the service of the Custody Complaint being filed simultaneously with this Petition, be waived in regards to Julia M. Erickson and Marcus Rose. WHEREFORE, Petitioner requests this Honorable Court enter an Order waiving any notice requirements in regards to Respondents, Julia M. Erickson and Marcus Rose, and enter a temporary Order whereby Kathy R. Erickson maintains sole legal and physical custody of the children, with a conciliation conference also being scheduled pursuant to the Custody Complaint being filed contemporaneously with the Petition for Special Relief. Respectfully Submitted, N R t o k J 44? 1. Hannah Herman-Snyder, Esqui Attorney for Plaintiff/Petitioner GRIFFIE AND ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 247-5552 VERIFICATION I verify that the statements made in the foregoing documents 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 unsworn falsifications to authorities. DATE: a - l - Q KATHY R. ER KSON C'C; p 7 cy -LU uca SSiSIA,r,(`E C c? Ui c-? SLR 0 O pptc?,.,, w g - 00 r- p 7 ?? INC 0 • FEB 1 9 2006 pl ' J "I KATHY R. ERICKSON, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. JULIA M. ERICKSON, CIVIL, ACTION -LAW Defendant/Respondent V. NO. D8.1Dgy CIVIL TERM MARCUS ROSE, Additional Defendant/Respondent: IN CUSTODY ORDER OF COURT AND NOW this Zo" day of /d., o!!7 , 2008, upon consideration and review of the attached Petition, IT IS HEREBY ORDERED AND DECREED that Petitioner, Kathy R. Erickson, have sole physical and legal custody of the child, Malajah Avion Erickson, born February 24, 1998, and IT IS FURTHER ORDERED AND DECREED that all notice requirements in regards to the custody action, beginning with service of the Custody Complaint, are waived in regards to Julia M. Erickson and Marcus Rose. By the Court, J. m?1 ??,?( Cc: Hannah Herman-Snyder, Esquire /,or Attorney for Plaintiff/Petitioner "`?- a?2o(o9 r E ,?,.:1a' =ICJ KATHY R. ERICKSON IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JULIA M. ERICKSON V. MARCUA ROSE DEFENDANT 2008-1044 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, February 25, 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 Wednesday, March 05, 2008 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. 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. Gilroy, Esq jWj Custody Conciliator P,? 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 F!_ tL ! CL t y1ruk L ?- IL6 Sfc?y ; Y C. a/ J ?Y ?y? 1406 MAR 0 6 200804 KATHY R. ERICKSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW JULIA M. ERICKSON V. MARCUA ROSE, NO. 2008-1044 Defendant IN CUSTODY COURT ORDER AND NOW, this 7' day of March, 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The maternal grandmother, Kathy R. Erickson, shall have sole legal and sole physical custody of Malajah Avion Erickson, born February 24, 1998. 2. In the event the mother, Julia M. Erickson, or the father, Marcua Rose, seeks any temporary custody or other custodial rights with the minor child, those parties may petition the Court at which time the case will again be referred to the Custody Conciliator for a conference. cc: Lannah Herman-Snyder, Esquire J ? G r,. BY THE COURT, VI N Al,kS+ lN: r_; •'1??3(( 8 S .C Wd L- 8VW 9002 AWONOHIOt d Mi J0 10 KATHY R. ERICKSON, Plaintiff v JULIA M. ERICKSON V. MARCUA ROSE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2008-1044 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Malajah Avion Erickson, born February 24, 1998. 2. A Conciliation Conference was held on March 5, 2008, with the following individuals in attendance: The maternal grandmother, Kathy R. Erickson, with her counsel, Hannah Herman-Snyder, Esquire. 3. The mother delivered custody of the minor child to the maternal grandmother in February of 2006 and has not been back to see the child since. The father was deported to Jamaica approximately seven years ago and has not had any contact with the child. 4. The Conciliator recommends an Order in the form as attached. Date: ubert X. Gilroy, E uire Custody Conciliat r