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Home My WebLink About04-0589COLLEEN CHRISTOPHER, Plaintiff 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04- CIVIL ACTION - LAW 1N CUSTODY COMPLAINT Plaintiff is Colleen Christopher, who currently resides at 309 Burnt House Road, WILLIAM CHRISTOPHER, Defendant Carlisle, Pennsylvania 17013. 2. Defendant is William Christopher, who currently resides at 251 McKnight Street, Carlisle, Pennsylvania 17013. 3. Plaintiff seeks sole physical and legal custody of the child, Nicole Marie Christopher, who was bom on November 16, 1988. The child was not born out of wedlock. For the past five years, the child has resided at the following addresses: a. February 5, 2004 to present: 309 Burnt House Road, Carlisle, PA 17013 b. May of 1996 to February 4, 2003:18 Sheeley Lane, Boiling Springs, PA 17007. 4. As of January 1, 2004, the child has been in the custody of Plaintiff. 5. The relationship of the Plaintiff to the child is that of mother. She is married and living separately. Plaintiff is currently residing with the following: Name Relationship Nicole Marie Christopher Daughter Luther Monntz Father Anna Mae Mountz Mother The relationship of the Defendant to the child is that of father. He is married and following: Nanle Raymond Christopher Mary Ellen Christopher Relationship Father Mother living separately. To the best of Plaintiffs knowledge, Defendant is currently residing with the 7. The parties have not participated in previous litigation concerning the custody of the child in this court or any court. 8. The best interest and permanent welfare of the child will be served by granting custody to Plaintiff because she is best able to provide a stable and nurturing environment for her daughter. Furthermore, Defendant has a history of alcohol abuse and is physically and mentally abusive to the child. 9. Each parent whose parental rights to the child have not been terminated and the person who has physical custody, Plaintiff, have been named as parties to this action. WHEREFORE, Plaintiff requests your Honorable Court to set a time and place for a hearing at which Plaintiff requests the Court to grant her the Custody Order. Date: MARTSON DEARDORFF WILLIAMS & OTTO Steven J. S~hhnahan, Esquire Attorney ID No. 90917 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff VERIFICATION I verify that the statements contained herein are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904, relating to unswom falsification to authorities. Colleen Christopher COLLEEN CHRISTOPHER, Plaintiff WILLIAM CHRISTOPHER, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-589 CIVIL ACTION - LAW IN CUSTODY AFFIDAVIT OF SERVICE OF COMPLAINT IN CUSTODY COMMONWEALTH OF PENNSYLVANIA ) :SS. COUNTY OF CUMBERLAND ) I hereby certify that a copy of the Complaint in Custody was mailed to Defendant William Christopher at 251 McKnight Street, Carlisle, PA 17013 on February 10, 2004, by certified mail, restricted delivery, return receipt requested. Attached is the Post Office return receipt signed "William Christopher" and dated February 12, 2004. MARTSON DEARDORFF WILLIAMS & OTTO BY Ste~h'~ ~/--~. 'a~, E~ qui~ eX'~ Attorney ID No. 90917 Ten East High Street Carlisle, PA 1 ;7013 (717) 243 -3341 Swom to and subscribed before m/p4fis February 17~004. / / Notary Public ~qCTOI~IA L OTTO, ~OTAR'Y PUBLIO I CARLISLE BORO., CUMBERLAND COU~ LMY COMMISSION EXPIRES DEC. 2, 2005~ (Endorsement Required) rtl CERTIFICATE OF SERVICE I, Steven J. Shanahan, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Affidavit was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Mr. William Christopher 251 McKnight Street Carlisle, PA 17013 Dated: February 17, 2004 MARTSON DEARDORFF WILLIAMS & OTTO Steven J. Shanahan Ten East High Street Carlisle, PA 17013 (717) 243-3341 COLLEEN CHRISTOPHER PLAINTIFF WILLIAM CHRISTOPHER DEFENDANT : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : 04-589 CIVIL ACTION LAW : : iN CUSTODY ORDER OFCOURT AND NOW, Monday, February 23, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, March 16, 2004 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 corn:t, 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: /s/ ]acqueline M. Verney, 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 befbre 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 COLLEEN CHRISTOPHER, Plaintiff V. WILLIAM CHRISTOPHER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-589 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this ~t ¥* day of r~a~/~ ,2004, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Colleen Christopher, shall have sole legal and physical custody of Nicole Marie Christopher, bom November 16, 1988. 2. The parties may modify the terms of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, / cc: Steven J. Shanahan, Esquire, Counsel for Mother William Christopher 251 McKnight Street Carlisle, PA 17013 /,b~fJ.OfXOFLLO~d ~qj COLLEEN CHRISTOPHER, Plaintiff V. V~ILLIAM CHRISTOPHER, Defendant MAR 2 3 200,4 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA _- : 2004-589 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY PRIOR JUDGE: None 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 Nicole Made Christopher DATE OF BIRTH CURRENTLY IN CUSTODY OF November 16, 1988 Mother 2. A Conciliation Conference was held in this matter on March 23, 2004, with the following in attendance: The Mother, Colleen ClmSstopher, with her counsel, Steven J. Shanahan, Esquire. Father did not attend the cortference although he had notice. 3. A PFA was emered by the Honorable J. Wesley Oler on February 6, 2003. It did not contain any custody provisions 4. Mother requested an Order of Court in the form as attached. Date /l. Vem y, q ' Custody Conciliator