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HomeMy WebLinkAbout08-1847 DOUGLAS A. TAYLOR, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. No. LAURA D. LAUBACH, CIVIL ACTION - AT LAW - CUSTODY Defendant COMPLAINT FOR CUSTODY The Plaintiff, Douglas A. Taylor, by and through his attorneys, the Law Offices of Patrick F. Lauer, Jr., L.L.C., seeks to obtain custody of his minor child and makes the following averments in support thereof- 1 . The Plaintiff is "Father", Douglas A. Taylor, and is an adult individual who currently resides at 131 Elm Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is "Mother", Laura D. Laubach is an adult individual who currently resides at 176 Virginia Avenue, Carlisle, Cumberland County, Pennsylvania 17013. 3. There is one dependent child, namely, Matteo D. Taylor, born November 20, 2006 (age 1). The child was born out of wedlock. 4. The Plaintiff seeks physical custody of the child. 5 The minor child is presently in the custody of the Defendant, who resides at 176 Virginia Avenue, Carlisle, Cumberland County, Pennsylvania 17013. 6. During the past five years, the child has resided at the following address with the following persons: Dates: Addresses: List All Persons: Birth - present 176 Virginia Avenue Mother, Laura D. Laubach Carlisle, PA 17013 Father, Douglas A. Taylor 7. The relationship of Plaintiff to the child is that of natural father. He currently resides with Rich Almeida, his wife Jen Almeida their three children. 8. The relationship of Defendant to the child is that of natural mother. She currently resides with the child. 9. 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 another court. 10. The Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 11. 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. 12. The best interest and permanent welfare of the child will be served by granting the relief requested, because: a. Defendant currently does not allow Plaintiff to see the child; b. Plaintiff would accommodate the child developing a healthy relationship with both parents ; C. Plaintiff is willing to look out for the child's best interest. 13. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as patties to this action. No other persons are known. to have or claim a right to custody or visitation, and therefore no notice will be given of the pendency of this action and the right to intervene, save as to the Defendant. WHEREFORE, The Plaintiff respectfully requests this Honorable Court approve any settlement reached between the parties; or, in the event they are unable to reach a settlement, grant the Plaintiff rights of legal and physical custody. Respectfully Date: 3/Z4/09 Marlio !Mavkley, Esquire Law Offices f Patrick F. Lauer, Jr., L.L.C. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 DOUGLAS A. TAYLOR, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. No. LAURA D. LAUBACH, CIVIL ACTION - AT LAW - CUSTODY Defendant VERIFICATION I verify that the statements made in this 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: b3/?fi! a8' -?X L Do 4 s A. Taylor E =? ?3 n ;- ?,3 ry??p ry , C? ? ? ? ? SF i ? ? :.} ? U? DOUGLAS A. TAYLOR IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. LAURA D. LAUBACH DEFENDANT 2008-1847 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, March 28, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. the conciliator, at_ 4th Floor, Cumberland Country Courthouse, Carlisle on Monday, April 28, 2008 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. 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/ John . Man an r. Es . 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 5a- r-// 5a- r-h .Y(2- £ 1/