HomeMy WebLinkAbout04-0820JULIE LINDSAY,
v.
DANIEL MORTON, SR.,
IN THE COURT OF COMMON PLEAS
Petitioner, : CUMBERLAND COUNTY, PENNSYLVANIA
Respondent.
NO: CY4
4
PETITION FOR INVOLUNTARY TERMINATION
OF PARENTAL RIGHTS
AND NOW, comes your Petitioner, Julie Lindsay, by and through their attorneys,
Mancke, Wagner & Spreha, and files the following Petition for Involuntary Termination
of Parental Rights:
1. Your Petitioner, Julie Lindsay, is an adult individual residing at 109 Woodview
Drive, Mt. Holly Springs, Cumberland County, Pennsylvania.
2. The Respondent, Daniel Morton, Sr., is an adult individual residing at 671
Willow Grove Road, Carlisle, Cumberland County, Pennsylvania.
3. Petitioner and Respondent are the natural parents of one child, Jacob Lehman,
born January 8, 1997.
4. Petitioner, Julie Lindsay, is married unto Todd Lindsay, and resides together at
the address contained in paragraph 1 above.
5. It is the intent of the Petitioner herein and her husband, Todd Lindsay, to file a
Petition for Adoption of Jacob Lehman, in the event that the Petition for Involuntary
Termination of the natural father is granted.
6. It is the intent of the Petitioner and her husband to assume custody of the child
until such time that an adoption proceeding is concluded.
7. Petitioner herein desires to terminate involuntarily the parental rights of the
Respondent based upon the following facts:
A. Respondent has not visited with, nor sought visitation with the child
for a period in excess of six (6) months;
B. Respondent herein has not called the child nor inquired about the
well-being of the child for a period of time well in excess of six (6)
months;
C. Respondent herein as forwarded no cards or letters to the child for a
period in excess of six (6) months;
D. For Christmas, 2003, the Respondent provided no presents, no cards,
made no contact or attempt to make contact with the child for
purposes of celebrating the holiday;
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E. The child's birthday, January 8', was concluded without any contact
from, presents from, and/or cards or letters from the Respondent;
F. Respondent most recently wrote a letter indicating that he desires not
to visit the child unless and until support which he is currently
paying is lowered;
G. Respondent's only effort concerning the child is the payment of
court ordered support;
H. Respondent has indicated that unless Petitioner lowers the support
payment, he intends not to have any contact with the child until such
time that the child is eighteen (18) years of age; and
1. The Respondent herein has exhibited for a period of time well in
excess of six (6) months a settled purpose of failing or refusing to
perform parental duties.
8. It is the intent of the Petitioner herein to immediately file a Petition for
Adoption, should the Petition for Involuntary Termination be granted.
-3-
WHEREFORE, the Petitioner requests this Court to grant its Petition to Terminate
Parental Rights of the natural father.
Respectfully submitted,
Mancke, Wagner & Spreha
P,-Richard Wagner, Esquire
I.D. #23103
2233 North Front Street
Harrisburg, PA 17110
(717) 234-7051
Attorneys for Petitioner
/v7?/C y
Date:
-4-
VERIFICATION
I verify that the statements made in the foregoing
document are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904, relating to unsworn falsification to authorities.
DATE : a19?6 `J
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C
Curtis R. Long
Prothonotary
office of the Vrotbonotarp
QCumberlaub Countp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
- 820 CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2.
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square 0 Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573