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Home My WebLink About04-0398MARY LECRONE, Plaintiff V. SHAWN FREEMAN, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY NO. 04- ~t~' CIVIL TERM COMPLAINT FOR CUSTODY The plaintiff, Mary Lecrone, by her attomeys, the Family Law Clinic, sets forth the following cause of action: 1. The plaintiff is Mary Lecrone, residing at 1533 Spring Road, Carlisle, Cumberland County, Pennsylvania, 17013. 2. The defendant is Shawn Freeman, residing at 699 Balitmore Pike, Old Town Run Mountain Lodge, Gardners, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following children: Name Present Residence Date of Birth Zebadiah Freeman 1533 Spring Road July 28, 2001 Carlisle, PA The parties were not married when the child was bom. The child is presently in the custody of Plaintift; who resides at 1533 Spring Road, Carlisle, PA 17013. During the past three years, the children have resided with the following persons and at the following addresses: Persons Mary Lecrone Sarah Lecrone Serenna Lecrone Address 1533 Spring Road Carlisle, PA Dates 7/28/01- present The mother of the child is Mary Lecrone, currently residing at 1533 Spring Road, Carlisle, Cumberland County, Pennsylvania, 17013. She is single. The father of the child is Shawn Freeman, currently residing at 699 Baltimore Pike, Old Town Run Mountain Lodge, Gardners, Cumberland County, Pennsylvania. 4. The relationship of the plaintiffto the child is that of mother. The plaintiffresides with the following persons: Name Sarah Lecrone Sererma Lecrone Relationship Daughter Daughter 5. The relationship of defendant to the child is that of father. The defendant currently resides with the following persons: Name Relationship Unknown 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: a) Mother has been the primary caretaker of the children since birth; b) Mother provides the children with a home with the necessary moral, emotional, and, physical surroundings to meet the children's needs; c) Mother is best able to provide the care and nurturing which the children need for a healthy development; d) Mother continues to exercise parental duties on behalf of the children and enjoys the love and affection of the children; e) Mother is willing to grant Father frequent periods of custody, in order for the children to develop a strong parent/child relationship with both parents; 8. Each parem whose parental rights to the children have not been terminated have been named as parties to this action, WHEREFORE, plaintiff requests the court to grant primary custody of the children. Date: Carolyn M.Fenton Certified Legal Intern ANNE MACDONALD FOX Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 VERIFICATION I verify that the statements made in this Custody Complaint are true and correct to the best of my personal knowledge 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. Date: I~ o~g'Oq~ Mary Lecro~, Plaintiff MARY LECRONE, Plaintiff SHAWN FREEMAN, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : IN CUSTODY : NO. 04-~1~ CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow Mary Lecrone, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attomeys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Carolyn M. Fenton Certified Legal Intern ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 MARY LECRONE PLAINTIFF SI-lAWN FREEMAN DEFENDANT 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-398 CIVIL ACTION LAW IN CUSTODY ORDER OFCOURT AND NOW, Thursday, February 05, 2004 _, upon consideration of the attached Complaint, it is hereby d/rected that parties and their respective counsel appear before Hubert X. Gilro~v, Es .rk~' the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday February. 26, 2004 at 10:30 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 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: Is/ 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 }lAVE 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 AS¥'.LONOFLLOSd 3Hi ~0 30!~0-0391J MARY LECRONE, Plaintiff V SHAWN FREEMAN, Defendant I I/ R 0 2004 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION : NO. 04-398 : IN CUSTODY COURTO~ER AND NOW, this ~-~ day of March, 2004, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. The mother, Mary Lecrone, shall enjoy primary legal and physical custody of Zebadiah C. Freeman, born July 28, 2001. 2. The father, Shawn Freeman, shall enjoy periods of temporary physical custody with the minor child at such times and under such circumstances as agreed upon by the mother. 3. It is noted that there is an issue with respect to whether father had received notice of the conciliation conference scheduled in this case. The mother's representative is directed to serve a copy of this order and the attached custody conciliation report on the father. In the event the father desires to modify this order, the father may petition the court to have the case again scheduled before the Custody Conciliator. BY THE COURT, ge CC: Georgia Reed Shawn Freeman x~7°'x~'~ OF l~Hc. MARY LECRONE, Plaintiff V SHAWN FREEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION NO. 04-398 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: Zebadiah C. Freeman, born July 28, 2001. A Conciliation Conference was held on February 26, 2004, with the following indivi~!~ls in attendance: The mother, Mary Lecrone, and Georgia Reed of the Dickinson School of Law Family Law Clinic. The father did not attend, and there is a question as to whether the father was served with notice of the conciliation conference. The history of this case is that mother obtained a PFA against father back in August of 2002 at which time mother was granted custody of the minor child. That PFA has expired. Father had been seeing the minor child sporadically on Sundays with no overnights and normally supervised by his mother. The Plaintiff in these proceedings indicated to the Conciliator that the father has seen the child 3 or 4 times over the past 3 months. 4. Based upon the above, the Conciliator recommends an order in the form as attached. Hubert ~.~G'droy, Esqmre Custody Conciliator MARY LECRONE, Plaintiff v SHAWN FREEMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION : : NO. 04-398 : IN CUSTODY CO~TO~ER AND NOW, this ..~ day of March, 2004, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: CUMBERLAND COUNTY COURT ADMINISTRATOR ONE COURTHOUSE SQUARE CARLISLE, PA 17013 Shawn Freeman 699 Baltimore Pike Oldtown Run Mountain Lodge Gardners, PA 17324 INSUFFICIENT ADDRESS ATTEMPTED NOT KNOWN C30TNE~ %~INO SUCH NUMBER/STREET ~il~NOT DELIVERABLE AS ADDRESSED "UNABLE TO FORWARD MARY LECRONE, Plaintiff SHAWN FREEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : IN CUSTODY : : NO. 04-398 CIV1L TERM VERIFICATION OF SERVICE Understanding that the making of any false statement would subject The Family Law Clinic to the penalties of 18 Pa. C.S. §4904 (relating to unsworn falsification to authorities), the undersigned verifies that Carolyn M. Fenton mailed a true copy of a Custody Conciliation Order on the Defendant by placing the same in the U.S. Mail, certified no. 7002 0860 0001 5847 8646, restricted delivery, return receipt requested, postage prepaid, on the 9th day of March, 2004 addressed as follows: Shawn Freeman 410 North Bedford Street Carlisle, PA 17013 Sender's receipt no. 7002 0860 0001 5847 8646 is attached hereto and incorporated by reference. On the 18th day of March, 2004, green return receipt no. 7002 0860 0001 5847 8648 was delivered to the Family Law Clinic, bearing the Signature of Perry Witman and showing a date of service of March 13, 2004. The return receipt is attached hereto and incorporated by reference. Dated: Carolyn 19I. Fenton Certified Legal Intern FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, PA 1701:3 717-243 -2968 · Complete items 1,2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, o~ on the front if space permits. 1. Article Addressed to: [] Agent D. Is delivery address diffract ~Tom ~tern 1 ? if YES, enter delivery address below: [] No i Service Type I~1 Certified Mai[ [] Express Mail [] Registered ~iReturn Receipt for Merchandise I-3 Insured Mail [] C.O.D. · Restricted Delivery? (Extra Fee) ~Yes -- 2~ticle Number (Copy from service label) P~Form 38t 1, July 1999 Domestic Re~um Receipt 102595-99-Mo1789 MARY LECRONE, Plaintiff SHAWN FREEMAN, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : C1VIL ACTION - LAW : IN CUSTODY : :.NO. 04-398 CIVIL TERM VERIFICATION OF SERVICE Understanding that the making of any false statement would subject The Family Law Clinic to the penalties of 18 Pa. C.S. §4904 (relating to unswom falsification to authorities), the undersigned verifies that Carolyn M. Fenton mailed a true copy ora Custody Conciliation Order on the Defendant by placing the same in the U.S. Mail, certified no. 7002 0860 0001 5847 8653, restricted delivery, return receipt requested, postage prepaid, on the 9th day of March, 2004 addressed as follows: Shawn Freeman 699 Baltimore Pike Old Town Run Mountain Lodge Gardners, PA 17324 Sender's receipt no. 7002 0860 0001 5847 8653 is attached hereto and incorporated by reference. On the 18th day of March, 2004, green return receipt no. 7002 0860 0001 5847 8653 was delivered to the Family Law Clinic, bearing the Signature of Shawn Freeman and showing a date of service of March 10, 2004. The return receipt is attached hereto and incorporated by reference. Dated: Carolyn M. Fenton Certified Legal Intern FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 717-243-2968 m · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. A~ticle Addressed to: 2. Attic PS For, A. Received by (P~ase P~nt Clearly) O. Is delive~ address different from item 1 ? r-i Yes If YES, enter delivery address below: [] NO 3. Se ice Type ,~Certified Mail [] Express Mail []' Registered ;:~ R~urn Receipt for Merchand~e [] Insured Mail [] C.O.D. 4. Restricted Deliverv? (Extra Fee} ~ Yes