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HomeMy WebLinkAbout08-3647 TAMMY WALBORN Plaintiff, V. STEWARD H. PORTER, III Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :NO. 08- 3t, y 7 CIVIL TERM : IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, Tammy Walborn, by and through her attorney, Mark F. Bayley, Esquire, and presents the within complaint for custody, representing as follows: 1. The Plaintiff, Tammy Walborn, is an adult individual residing at 1000 S. Hanover St., Carlisle, PA 17013. 2. The Defendant, Steward H. Porter, III, is an adult individual residing at 1177 Easy Rd., Carlisle, PA 17013. 3. Plaintiff seeks custody of the following child: Name Present Residence Age D/OB Dakota Porter 1000 S. Hanover St, Carlisle, PA 15 months 3-9-07 4. The child was born out of wedlock. 5. The relationship of the Plaintiff to the child is that of natural mother. The child currently resides with the Plaintiff and Melody (Sister). Plaintiff is not married. 6. The relationship of the Defendant to the child is that of natural father. Defendant currently resides with Shirley Porter (Paternal Grandmother) and Steward Porter, II (Paternal Grandfather). Defendant is not married. r 7. Name During the past five years the child has resided with: Tammy Walborn Address Date 1000 S. Hanover St., Carlisle, PA 3/9/07-Present 8. 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 any other Court. 9. Plaintiff has no information of a custody proceeding concerning the child pending in any Court of this Commonwealth or any other state. 10. Other than as noted above, Plaintiff does not know of a person nor a parry to the proceeding who has physical custody of the child or claims to have custody or visitation rights with respect to the children. 11. The best interests and permanent welfare of the child requires Plaintiff to assume primary physical custody and for Defendant to have contact with the child which may be agreed upon by the parties, at conciliation, or otherwise be determined by the Court. WHEREFORE, Plaintiff requests this Honorable Court to schedule a custody conciliation conference. -off Date: _ lC Respectfully submitted, BA EY & GAN Mark F. Bayley, squire 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court ID # 87663 Attorney for Plaintiff TAMMY WALBORN : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW STEWARD H. PORTER, III : NO. 08- CIVIL TERM Defendant. : IN CUSTODY 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. Cons. Stat. § 4904 relating to unworn falsification to authorities. 1 Tammy Wal rn, Plaintiff 11-1 ? a c s. C? T-1 cv, w c.? c:7 TAMMY WALBORN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-3647 CIVIL ACTION LAW STEWARD H. PORTER, III IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, June 24, 2008 -, 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 Monday, July 28, 2008 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 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/ aq uelrrle M. Verne 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 fiv zs :c wd sz Nor BOOZ i -4 C7 Hl _-';o ',' I1. " it 1 - L TAMMY" WALBORN : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW STEWARD H. PORTER, III : NO. 2008 - 3647 CIVIL TERM Defendant. : IN CUSTODY STIPULATION The undersigned parties hereby stipulate as follows: L Mother (Plaintiff) shall have sole legal custody of Dakota Parker, born on March 9, 2007. 2. Mother shall have primary physical custody of child. 3. Father (Defendant) shall have periods of custody at times agreed upon by the parties. Wherefore, the undersigned request the above provisions to be entered as an Order of Court. Dated:_? -. Q!5 (? -a ") ?_r") Tammy Walb , Plaintiff I Dated: Steward H. Porter, III, Defen ant TAMMY WALBORN Plaintiff, V. STEWARD H. PORTER, III Defendant. JUL ?9 2008 c_rj IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008 - 3647 CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW, this 3 day of _? a , 2008, based upon stipulation by the parties, it is hereby ordered and directed as follows: 1. Mother (Plaintiff) shall have sole legal custody of Dakota Parker, born on March 9, 2007. 2. Mother shall have primary physical custody of child. 3. Father (Defendant) shall have periods of custody at times agreed upon by the parties. Distribution: Tammy Walborn Steward H. Porter, III JAI,- (Y7 J, Sol ilia vino }? :.? _ .. P\..1 TAMMY WALBORN : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW STEWARD H. PORTER, III : NO. 2008 - 3647 CIVIL TERM Defendant. : IN CUSTODY STIPULATION The undersigned parties hereby stipulate as follows: 1. Mother (Plaintiff) shall have sole legal custody of Dakota Parker, born on March 9, 2007. 2. Mother shall have primary physical custody of child. 3. Father (Defendant) shall have periods of custody at times agreed upon by the parties. Wherefore, the undersigned request the above provisions to be entered as an Order of Court. Dated: -7 cQ5 - ??S Dated: 7`R5' _ 6 6- Tammy Walb , Plaintiff Steward H. Porter, III, Defen ant r--? vr> TAMMY WALBORN, Plaintiff V. STEWART H. PORTER, III, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-3647 CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 21St day of August, 2008, being advised that the parties have reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, /V( acq ine M. Verney, Esquire, Custody nciliator rv T-j f77 X ..1 NJ ^. ?: C.n