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HomeMy WebLinkAbout04-0372DANIEL E. MARCH Plaintiff 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NAME Tiffany M. Bridi & Tammi Bowers, Defendant's Sister ADDRESS RR1 Box 361 Shamokin, PA 17872 (see paragraph 2 above) DATES November 18, 2003 to present V. CIVIL ACTION - LAW CUSTODY/VISITATION TIFFANY M. BRIDI Defendant NO. ~1. ,.~ '7 ~,, CIVIL TERM COMPLAINT FOR CUSTODY 1. The Plaintiff is Daniel E. March, residing at 166 Cold Springs Road, Cumberland County, Pe~msylvania 17013. 2. The Defendant is Tiffany M. Bridi whose last known residence was at RR 1, Box 361, Northumberland County, Shamokin, PA 17872. It is believed that the Defendant no longer resides at ths address and refuses to provide an address to the Plaintiff. It is, however, that she may be residing with an individual by the name of Jay Clossen whose address is 577 Shuman Street, Catawissa, PA 17820. The last known phone number for the Defendant was 570-356-7489. 3. Plaintiff seeks custody of the following child: NAME RESIDENCE DOB AGE Raven Skylar March RR 1, Box 361 January 28, 2002 1 yr 11 months Shamokin, PA 17872 (see paragraph 2 above) The child was bom out of wedlock. The child is presently in the custody of Defendant, Tiffany M. Bridi. During her life, the child has resided with the following persons and at the following addresses: Daniel E. March, Tiffany M. Bridi, Irene & Marlin March, Plaintiff's parents Daniel E. March & Tiffany M. Bridi, Daniel E, March & Tiffany M. Bridi 156 Cold Springs Road Carlisle, PA 17013 166 Cold Springs Road Carlisle, PA 17013 236 N. Baltimore Ave. #8 Mt. Holly Springs, PA 17065 March 2003 to November 18, 2003 June 2002 to March 2003 birth to June 2002 The mother of the child is Tiffany M. Bridi, currently residing at RR1, Box 361, Shamokin, PA 17872. (see paragraph 2 above) She is unmarried. The father of the child is Daniel E. March, currently residing at 166 Cold Springs Road, Carlisle, PA 17013. He is unmarried. 4. The relationship of the Plaintiffto the child is that of Father. The Plaintiff currently resides with the following persons: his parents, Marlin and Irene March 5. The relationship of the Defendant to the child is that of Mother. The Defendant currently resides with the following persons: (see paragraph 2 above) 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Cormnonwealth. 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested for the following reasons: A. The Plaintiff and Defendant have shared in performing the primary parental responsibilities for the child. B. Plaintiff is best able to provide the care and nurture which the child needs for healthy development and has the support of his parents who are also able to care for the child. C. A Court Order of custody and structured visitation is desired so that the Plaintiff and the child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion. D. The Defendant's erratic and abusive behavior poses a threat of harm to the child. The Defendant has been charged with criminal harassment, drug and paraphernalia charges and domestic violence and physical assault. E. The Plaintiff continues to maintain the same family household for the child that has been maintained since March 2003. Approximately 2 months ago the Defendant moved from the residence previously maintained into the residence of her sister in Northumberland County taking the child with her. Since moving in with her sister, it is believed that she has now changed again residences but refuses to provide a residence to the Plaintiff so that the Plaintiff can see his child. It is believed that she may be living with a person by the name of Jay Clossen whose address is 577 Shuman Street, Catawissa, PA 17820. F. Despite numerous arrangements for the Plaintiff to have partial custody with the child, the Defendant has continued to deny the Plaintiff partial custody with the child. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an Order granting custody or partial custody of the child to Plaintiff. Respectfully submitted, -/t Ronald E. Joh~oh, Esq. / 78 West Port, et Street t Carlisle, PAVl7013 Telephone: (717) 243-0123 COMMONWEALTH OF PENNSYLVANIA ) :SS. COUNTY OF CUMBERLAND ) I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. DATE: ' ~) ~aniel E. March, Plaintiff DANIEL E. MARCH PLAINTIFF TIFFANY M. BR1DI DEFENDANT iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-372 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, February 05, 2004 ~, 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 Thursday, February. 26, 2004 at 9:30 AM 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 nan'ow 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 apVear 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 TItE COURT. By: /si Hubert X. Gilroy, 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 TELEPItONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cmuberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-00372 P COMMONWEALTH OF PENNSYLVkNIA: COUNTY OF CUMBERLA/qD MARCH DANIEL E VS BRIDI TIFFANY M R. Thomas Kline duly sworn according to law, says, that he made and inquiry for the within named DEFENDANT BRIDI TIFFANY M but was unable to locate Her in his bailiwick. deputized the sheriff of COLUMBIA County, serve the within COMPLAINT - CUSTODY Sheriff or Deputy Sheriff who being a diligent search and , to wit: He therefore Pennsylvania, to On March 1st , 2004 attached return from COLUMBIA Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Columbia Co 50.00 .00 87.00 o3/oz/2oo4 RONALD JOHNSON Sworn and subscribed to before me this ~ day of~ ~v3~ A.D. ~ ; Prothonotary~ , this office was in receipt of the So answers R. Thomas Kl~ne Sheriff of Cumberland County In The Court of Common Pleas of Cumberland County, Pennsylvania Daniel E. March VS, Tiffany M. Bridi SERVE: s~ne No. 04-372 civil HOW, Februarv 18, 2004 hereby deputize the Sheriff of Colunbia deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County., PA , I, SHERIFF OF CUMBERLAND COUNTY, PA, do County to execute this Writ, this NOW, within upon at by handing to a and made known to Affidavit of Service' ,20 , at o'clock M. served the copy of the original So allswer$~ the contents thereof. Sworn and subscribed before me this __ day of ,20 Sheriff of County, PA COSTS SERVICE MILEAGE AFFIDAVIT SHIL~IFF OF COILUMOIA COUNTY DANIEL MARCH TIFFANY BRIDI VS Docket # 372CFW2004 ORDER OF COURT and COMPLAINT FOR CUSTODY SHERIFF'S COST $ 50.00 PAID AFFIDAVIT OF SERVICE NOW, THIS TUESDAY, FEBRUARY 24, 2004, AT 8:50 AM, SERVED THE WITHIN ORDER OF COURT and COMPLAINT FOR CUSTODY UPON TIFFANY BRIDIAT COLUMBIA COUNTY SHERIFF OFFICE, BLOOMSBURG BY HANDING TO TIFFANY, DEFENDANT, A TRUE AND ATTESTED COPY OF THE ORIGINAL WRIT AND MADE KNOWN TO THEM THE CONTENTS THEREOF. '7¸: SWORN AND SUBSCRIBED BEFORE ME THIS THURSDAY, FEBRUARY 26, 2004 N~C~ [MY COM~,61eN ~ NOV~Efl 07, SO ANSWERS, X TIMOTHY T. CHAMBERLAIN ACTING SHERIFF X DANIEL E. MARCH, Plaintiff V TIFFANY M. BRIDI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION NO. 04-372 IN CUSTODY CO~TO~ER AND NOW, this ~l~ day of March, 2004, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. The father, Daniel E. March, and the mother, Tiffany M. Bridi, shall enjoy shared legal and shared physical custody of Raven Skylar March, born January 28, 2002. 2. For physical custody, the parties shall alternate physical custody on a week- on/week-off basis with exchange of custody to be Sunday at 5:00 p.m. unless agreed otherwise by the parties. 3. Both parties shall keep each other advised with respect to their addresses and phone numbers. 4. This is a shared legal custody arrangement such that both parties shall keep the other parent advised with respect to all medical and related issues pertaining to the minor child. 5. This is a temporary order agreed to by the parties on an interim basis pending the scheduling of a second custody conciliation conference which shall take place on May 14, 2004 at 8:30 a.m. At this second conciliation conference and in the event the parties are unable to reach an agreement on a more permanent order, the conciliator shall refer the case to court for a hearing at which time the party's agreement at this point for a week-on/week-off basis shall not prejudice either party from advancing a different position at a hearing. The alternating weekend schedule shall commence with mother delivering the minor child to the father on Sunday, February 29, 2005 at 5:00 p.m. Father shall return the child to the mother's home the following Sunday, with the parties continuing along with that schedule for exchange of custody. BY THE COURT, J~ge CC: Ronald E. Johnson, Esquire Sean M. Shultz, Esquire DANIEL E. MARCH, Plaintiff v TIFFANY M. BRIDI, Defendant MAR 0,3 2004 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION : : NO. 04-372 : 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: Raven Skylar March, born January 28, 2002. 2. A Conciliation Conference was held on February 26, 2004, with the following individuals in attendance: The father, Daniel E. March, with his counsel Ronald E. Johnson, Esquire, and the mother Tiffany M. Bridi, with her counsel, Sean M. Shultz, Esquire. 3. The party's agree to the entry of an order in the form as attached. ~/~'-~Es nire ~sbteo~yX~ ~o~rq SEP 2 9 2004 DANIEL E. MARCH TIFFANY M. BRIDI Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND cOUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. ~ CIVIL TERM : IN CUSTODY ORDER AND NOW, this 3 ~__~[!ay of September 2004, no Answer having been filed by the Plaintiff or the Defendant to the Rule issued by this Court on September 9, 2004, the Rule previously issued is hereby made absolute. Leave of Court is granted to Ronald E. Johnson, Esq. to withdraw as counsel for the Plaintiff, Daniel E. March, in the above captioned case. BY THE COURT,