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HomeMy WebLinkAbout01-6400KRISTY GREEN Plaintiff VS. WESTON GREEN, JR. Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. Ol-GqdO CIVIL ACTION - LAW .COMPLAINT FOR CUSTODY 1. The Plaintiff is Kristy Green, residing at 161 Frytown Road, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is Weston Green, Jr., residing at 155 East North Street, Apartment A, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff seeks custody of the following child: Name Present Residence &qe Kayleigh Green 161 Frytown Road, Carlisle, PA 7 ¥2 months The child was born on March 20, 2001. She is presently in the custody of Plaintiff, Kristy Green, who resides at 161 Frytown Road, Carlisle, Pennsylvania. During the child's lifetime, she has resided with the fallowing persons and at the following addresses: Name ~. Kristy and Weston Green, Jr~ 2. Kristy Green Address 155 East North Street Apartment A Carlisle, PA 17013 _Date birth to 11/9/01 161 Frytown Road 11/9/01 to present Carlisle, PA 17013 The mother of the child is Kristy Green, currently residing at 161 Frytown Road, Carlisle, Pennsylvania. She is marriec~, The father of the child is Weston Green, Jr. currently residing at 155 East North Street, Apartment A, Carlisle, Pennsylvania. He is married. 4. The relationship of Plaintiff to the child is that of Mother. 5. The relationship of Defendant to the child is that of Father. 6. The 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 any other court. 7. The Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 8. The 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. 9. The best interest and permanent welfare of the child will be served by granting the relief requested for reasons including the following: a. The mother has been the primary caregiver of the child from her birth, She has: 1.) planned and prepared meals 2.) bathed, groomed and dressed the child 3.) purchased, cleaned and cared for the child's clothing 4.) arraigned medical care, including nursing and trips to physicians 5.) arranged alternative daycare 6.) put the child to bed nightly, attended the child in the middle of the night b. The child has a psychological bond with Mother; c. Mother has been extremely accommodating to Father's work schedule and has remained flexible to allow his visitation; d. Mother continues to provide a stable environment for the child; T0. Each parent whose parental rights to the child have not been terminated has been named as parties to this action. WHEREFORE, the Plaintiff prays that This Honorable Court grant her primary physical custody of their child. Date: November 9, 2001 Respectfully submitted, ABOM & KUTULAKIS, L.L.P. J~ '~ 'Jasor~ P. !U~ir e i.D. #80411 8 South Hanover Street, Suite 204 Carlisle, PA 17013 (717) 249-a900 Attorney for Plaintiff I, Kristy Green, hereby verify that the facts set forth in the foregoing Custody Complaint are true 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 unswom falsification to authorities. Date: November 9, 2001 Kristy tSreen KRISTY GREEN : PLAINTIFF V, WESTON GREEN, JR DEFENDANT : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COLrNTY, PENNSYLVANIA 01-6400 CIVIL ACTION LAW IN CUSTODY AND NOW, Monda}r, November 26, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gflroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, December 20, 2001 at 8:30 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 or~ter. 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. FORTHE COURT, By: /s/ Hubert X. Gilrov. Esa. 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 © KRISTY GREEN, Plaintiff V WESTONE GREEN, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : : NO. 01-6400 CIVIL : IN CUSTODY COURT ORDER AND NOW, this ~(~{~ day of December, 2003, this case coming before the conciliator on the request of the Court Administrator to address the outstanding referral for a conciliator and the conciliator being advised that the parties had previously resolved the matter without the need of further involvement of the conciliator, the conciliator relinquishes jurisdiction. BY THE COURT, . Hubert. Gll~y C~/~ Concd~ator