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HomeMy WebLinkAbout04-0313RHONDA M. CARBAUGH, Plaintiff V. JASON C. YOUNKER Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C ILACTION-LAW & IN CUSTODY COMPLAINT IN CUSTODY AND NOW, this ~2 ~ day of ,_J,~c.~ ,2004, comes PlaintiffRhonda M. Carbaugh, by and through her attorney, Andrew C. Spears, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb, P.C., and files the within Complaint of which the following is a statement: 1. PlaintiffRhonda M. Carbaugh is an adult individual currently residing at 25 Heckman Road, Newville, Cumberland County, Pennsylvania, 17241. 2. Defendant Jason C. Younker is an adult individual with a last known address of 533 Bracken Drive, Chambersburg, PA 17201. 3. Plaintiff seeks primary physical custody and pr/mary legal custody of the following Minor Child: Name Kaylah R. Younker Present Address 25 Heckman Road Newville, PA 17241 Date of Birth 11/28/1994 Child. Plaintiff and Defendant are the natural parents of the above-mentioned Minor following addresses: Name Rhonda M. Carbaugh The Minor Child was bom out of wedlock. The Minor Child is presently in the custody of Plaintiff. For the past five years, the Minor Child has resided with the Plaintiff at the Rhonda M. Carbaugh Address 7500 Molly Pitcher Hwy. Lot 11 Shippensburg, PA 17257 25 Heckman Road Newville, PA 17241 Date From 1998 until June 2002 June 2002 until present The mother of the Minor Child is PlaintiffRhonda M. Carbaugh who currently resides at 25 Heckman road, Newville, PA, 17241. The father of the Minor Child is Defendant Jason C. Younker whose last known address is 533 Bracken Drive, Chambersburg, PA 17201. 6. The relationship of Defendant to the Minor Child is that of natural father. The Defendant is believed to reside with the following persons: Name Relationship Unknown 293507-1 VERIFICATION I, Rhonda M. Carbaugh, verify that the statements made in the foregoing Complaint in Custody are tree and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Dated: Document #265685 CERTIFICATE OF SERVICE I, Andrew C. Spears, Esquire, of the law firm ofMetzger, Wickersham, Knauss & Erb, P.C., hereby certify that I served a tree and exact copy of the Complaint for Custody with reference to the foregoing action by first class mail, prepaid, this'~/sLday of ~D~ ,2004, on the following: Jason C. Younker 533 Brackon Drive Chambersburg, PA 17201 Andrew C. Spears, Esquire Document #265685 RHONDA M. CARBAUGH PLAINTIFF JASON C. YOUNKER DEFENDANT N THE COUR~i OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 04-313 CIVIL ACTION LAW : : IN CUSTODY ORDER OF COURT AND NOW,_ ~, February 0~5, 2004 _, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa p. Gree , Esv~5~q:~, the conciliator, at 301 Market Street, Lemoy_ne, PA 17043_~_2~ on Monday, March 01, 2004 · at I:00 PM for a Pre-Hearing Custody Conference. At such conference, an eftbrt 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 l~resent 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: /s/ -~/I~a P~, F~ 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 hav/ng 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 TItIS 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 RHONDA M. CARBAUGH, Plaintiff V. JASON C. YOUNKER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-313 CIVIL TERM CIVIL ACTION - LAW iN CUSTODY ORDER OF COURT AND NOW, this ~'X" day of March, 2004, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The Mother, Rhonda M. Carbaugh, shall have primary legal custody with regard to the child's health, education and religious upbringing. However, Father shall retain the right to participate in extraordinary, non-routine, medical decisions. Should such a circumstance arise, Mother will attempt to contact Father, consult with him, and make available to him the name and phone number of the medical professionals involved in previding care to the parties' child. 2. This Order shall not be read to prevent Mother from obtaining a passport for the child or to prevent Mother and the child from going on vacation outside of the United States of America. matter. Cumberland County Court of Common Pleas shall retain jurisdiction of this 4. Physical Custody. Mother shall have primary physical custody of the child and shall be entitled to have custody of the child for a period of one (1) week during the Summer school recess in 2004. Dist: Andrew C. Spears, Esquire, P.O. Box 5300, Harrisburg, PA 17110-0300 Jason C. Younker, 3580 Keller Road, St. Thomas, PA 17252 RHONDA M. CARBAUGH, Plaintiff V. JASON C. YOUNKER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-;313 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 Kaylah R. Younker DATE OF BIRTH November 28, 1994 CURRENTLY IN THE CUSTODY OF Mother 2. A Custody Conciliation Conference was held on March 1, 2004 following Mother's filing of a Complaint in Custody on January 23, 2004. Present for the conference were: the Mother, Rhonda M. Carbaugh, and her counsel, Andrew C. Spears, Esquire; the Father, Jason C. Younker, participated pro se. Date The p,arties reached an agreement in the~ I~f'pm'r~an Order as attached. Melissa Peel Greevy, Esquire[ Custody Conciliator :225034