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HomeMy WebLinkAbout04-0725Law Offices of Lee E. Oesterlmg, LLC 42 East Main Street Mechanicsburg, PA 17055 (717) 790-5400 IN THE COURT OF COMMON PLEAS OF THE 9TM JUDICIAL DISTRICT CUMBERLAND COUNTY, PENNSYLVANIA CHRISTINA L. HOLLINGSWORTH Plaintiff DANIEL A. HOLLINGSWORTH Defendant Civil Action- Complaint for Child Custody COMPLAINT FOR CUSTODY 1. Plaintiffis Christina L. Hollingsworth, (natural mother), an adult individual, sui juris, residing at 209 Enola Road, City of Enola, Cumberland County, Pennsylvania 17025. 2. Daniel A. Hollingsworth, (natural father), an adult individual, sui juris, residing at 7073 Carlisle Pike, Lot 211, Carlisle, Cumberland County, Pennsylvania 17013 3. Plaintiff seeks custody of the following children: Name Address Age Andrew L. Hollingsworth 6 y/o (DOB: 3-4-97) 209 Enola Road Enola, PA 17025 Joshua L. Hollingsworth 209 Enola Road Enola, PA 17025 4. The children were bom of the marriage. 3 y/o (DOB: 8-2-00) 5. The children are presently in the primary physical custody of Pla'mtiff, Christina L. Hollingsworth, subject to a shared physical custody arrangement with the father which approximates equal overnight time. 6. During the last five years the children have resided with the following person(s) and at the following addresses: Narne Christina L. Hollingsworth Jamie Shriner Christina L. Hollingsworth Daniel A. Hollingsworth Daniel A. Hollingsworth Daniel A. Hollingsworth Address 209 Enola Road Enola, PA 17025 709 Erford Road Camp Hill, PA 17011 709 Erford Road Enola, PA 17025 7073 Carlisle Pike #211 Carlisle, PA 17013 Date April, 2002 to present 11-98 to February 2002 2-02 to 7-02 July 2002 to present 7. The mother of the child is Christina L. Hollingsworth. 8. She is married. 9. The father of the child is Daniel A. Hollingsworth. 10. He is married. 11. The relationship of Plaintiff to the child is that of natural mother. The Plaintiff currently resides with the following persons: Name Relationship Jamie Shriner Friend Andrew Hollingsworth Son Joshua Hollingsworth Son 12. The relationship of Defendant to child is that of natural father. The Defendant currently resides with the following persons: Name Relationshil~ Andrew Hollingsworth Son Joshua Hollingsworth Son 13. Plaintiff, Christina L. Hollingsworth, is represented by Lee E. Oesterling, Esquire in regard to this matter. 14. Defendant, Daniel A. Hollingsworth, is represented by Herschel Lock, Esquire in regard to this matter. 15. Plaintiffhas no information of another custody proceeding concerning the children pending in a Court of this Commonwealth. 16. 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 fights with respect to the children. 17. The best interest and permanent welfare of the children will be served by granting the relief requested because: 18. Plaintiffhas been primarily responsible as custodian and caregiver of the children since birth. 19. Plaintiff has maintained a relationship with the children that has provided for the children's physical, intellectual, emotional and spiritual well being. 20. Plaintiff believes that the children need a more consistent custody arrangement during the school year that also provides for weekend and leisure time with Plaintiff. 21. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action, All other persons, named who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim 22. A copy of this Complaint has been served on Defendant and his counsel by mailing them a copy. WHEREFORE, Plaintiff, Christina Hollingsworth, requests the court grant her primary physical custody of the children. Respectfully Submitted, V~RIFICATION I verify that upon personal knowledge or reformation and belief 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 unswom falsification to authorities. Christina Lynn Hollingpworth Date: CHRISTINA L. HOLLINGSWORTH PLAINTIFF V. DANIEL A. HOLLINGSWORTH DEFENDANT : IN I~E COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : 04-725 CIVIL ACTION LAW : : IN CUSTODY ORDER OF COURT AND NOW, Tuesday, February 24, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Tuesday, March 30, 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 narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older ma,/also be present at the conference. Failure to appear at the conference ma,/ 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/ Melissa P. Greevy. 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 betbre 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 DANIEL A. HOLLINGSWORTH, Plaintiff V. CHRISTINA L. HOLL1NGSWORTH, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNI'Y, PENNSYLVANIA CIVIL ACTION - LAW 04-652 CIVIL TERM ORDER OF COURT AND NOW, this 12th day of May, 2004, the above-captioned case is consolidated with the case at 04-725, and all filings will hereafter be docketed at 04-652 Civil Term. BY THE COURT, Blair, Esq. Attorney for Daniel A. Hollingsworth ~,e E. Oesterling, Esq. Attorney for Christina L. Hollingsworth :rc ]~esley Oler,d~> '- - A~VkONORbO~4~J BHi qO 2004 CHRISTINE L. HOLLINGSWORTH, Plaintiff V. DANIEL A. HOLLINGSWORTH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-725 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY : CONSOLIDATION ORDER_ AND NOW, this !.r~_,, day of ~ 2 -'~ , 2004, the claims raised by Mother in her Complaint filed February 14, 2004, are consolidated and treated as a counter-claim in Father's Complaint filed February 17, 2004 and docketed to 04-652. BY THE COURT: BY: :228111 ~. or/.a,, F. Blair, Esquire, 5440 Jonestown Road, Harrisburg, PA 17112 Dist.: ~ E. Oesteding, Esquire, 42 East Main Street, Mechanicsburg, PA '170§5 0.5 .lq