HomeMy WebLinkAbout08-2875MATTHEW ROBINSON
Plaintiff,
V.
ANTOINETTE ROBINSON
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 08 - CIVIL TERM
IN CUSTODY
COMPLAINT FOR CUSTODY
NOW comes the Plaintiff, Matthew Robinson, by and through his attorney, Mark F.
Bayley, Esquire, and presents the within complaint for custody, representing as follows:
1. The Plaintiff, Matthew Robinson, is an adult individual residing at 2204 Ritner
Highway, Shippensburg, PA 17257.
2. The Defendant, Antoinette Robinson, is an adult individual residing at 16 Rays
Drive, Newville, PA, 17241.
3. Plaintiff seeks custody of the following children:
Name
Present Residence
Age D/OB
Kandice Robinson 2204 Ritner Highway, Shippensburg, PA 7 3-20-01
Damian Robinson 2204 Ritner Highway, Shippensburg, PA 5 7-15-02
4. The children were not born out of wedlock.
5. The relationship of the Plaintiff to the children is that of natural father. The
Plaintiff currently resides with the children and:
Name
Lester Robinson
Gloria Robinson
Relationship (to the children)
Grandfather
Grandmother
He is not married.
6. The relationship of the Defendant to the children is that of natural mother. The
defendant currently resides at 16 Rays Drive, Newville, Pennsylvania.
She is not married.
7. During the past five years, the children have resided with:
Name
Matthew Robinson
Lester Robinson
Gloria Robinson
Address
2204 Ritner Highway
Shippensburg, Pa 17257
Date
7/2006-Present
Matthew Robinson
Antoinette Robinson
39 Spring Garden Estates
Carlisle, PA 17013
2001-7/2006
8. The 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 any other Court.
9. Plaintiff has no information of a custody proceeding concerning the children
pending in any Court of this Commonwealth or any other state.
10. Plaintiff does not know of a person nor a party to the proceeding who has physical
custody of the children or claims to have custody or visitation rights with respect to the children.
11. The best interests and permanent welfare of the children require Plaintiff to have
primary physical custody and for Defendant to have specified periods of partial physical custody
at times and in a manner which may be agreed upon by the parties or otherwise be determined by
the Court.
WHEREFORE, Plaintiff requests this Honorable Court to schedule a custody
conciliation conference.
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Date:
Respectfully submitted,
BAYLEY & MANGAN
Mark F. Bayley, Esquire
17 West South Street
Carlisle, PA 17013
(717) 241-2446
Supreme Court ID # 87663
Attorney for Plaintiff
MATTHEW ROBINSON : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
ANTOINETTE ROBINSON : NO. 08 - CIVIL TERM
Defendant. : IN CUSTODY
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. Cons. Stat. § 4904 relating to
unsworn falsification to authorities.
Matthew Robinson, Plaintiff
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Venator Group Corporate Services, Inc. 3543 Simpson Ferry Road Cramp Hill, PA 17011
MATTHEW ROBINSON IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
ANTOINETTE ROBINSON
DEFENDANT
2008-2875 CIVIL ACTION LAW
. IN CUSTODY
ORDER OF COURT
AND NOW, Wednesday, May 14, 2008 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, June 05, 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/ 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
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
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JUN 0 9 2008
MATTHEW ROBINSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v : CIVIL ACTION - LAW
ANTOINETTE ROBINSON, NO. 2008-2875
Defendant IN CUSTODY
COURT ORDER
AND NOW, this -eday of 4? 2008, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
1. The father, Matthew Robinson, and the mother, Antoinette Robinson, shall enjoy shared
legal custody of Kandace Robinson, born March 20, 2001, and Damian Robinson, born July
15, 2002.
2. The father shall enjoy primary physical custody of the minor children.
3. The mother shall enjoy periods of temporary custody with the minor children pursuant to the
schedule that the parties have had in place over the past year or so. Until mother obtains a
new home, overnights with the children shall continue to be at the maternal grandmother's
home. The parties shall work between themselves to arrange a schedule.
4. Neither party shall consume or be under the influence of alcohol or illegal drugs when they
have custody of the minor children.
5. In the event a disagreement arises with respect to mother's periods of temporary custody,
either party may petition the court to have the case again scheduled with the custody
conciliator for a conference.
J.
cc: ark F. Bayley, Esquire
Antoinette Robinson
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MATTHEW ROBINSON,
Plaintiff
v
ANTOINETTE ROBINSON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
NO. 2008-2875
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 children who are the subject of this litigation
is as follows:
Kandace Robinson, born March 20, 2001, and Damian Robinson, born July 15, 2002.
2. A Conciliation Conference was held on June 5, 2008, with the following individuals in
attendance:
The father, Matthew Robinson, with his counsel, Mark F. Bayley, Esquire, and the
mother, Antoinette Robinson, who appeared without counsel.
3. The parties agree to the entry of an Order in the form as attached.
Date:
Hubert X. Troy, Esquire
Custody Conciliator