HomeMy WebLinkAbout04-1087WILLIAM COLEMAN,
Plaintiff,
JESSICA STOCKSLAGER,
Defendant.
: I N THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
t '7
: CIVIL ACTION - LAW
: IN CUSTODY
COMPLAINT FOR CUSTODY
AND NOW, comes the Plaintiff, William Coleman, by and through his attorneys,
Mancke, Wagner & Spreha, and files the following Complaint for Custody:
1. The Plaintiff, William Coleman, is an adult individual having as an address
P.O. Box 18, Bowmansdale, Cumberland County, Pennsylvania.
2. The Defendant, Jessica Stockslager, is an adult individual having as an address
6403 Glenwood Street, Apt. #3, Mechanicsburg, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant are the natural parents of two (2) children, Thomas
Coleman, born June 29, 2000, and Halley Coleman, born June 11, 2001.
4. Plaintiff is the natural father of the aforementioned children, and Defendant is
the natural mother of the aforementioned children.
5. The children were born out of wedlock.
6. Plaintiff herein believes and therefore avers that there is no other person
exerting a claim for custody or partial custody of the children other than the parties
herein.
7. The parties resided together with the children from November of 1999, to
approximately February of 2003, at which time the parties had an understanding whereby
the custody schedule provided that the Defendant would have every Monday and Tuesday
overnight, Plaintiff would have every Wednesday and Thursday overnight, and the parties
thereafter alternating weekends.
8. Since approximately the beginning of 2004, the parties have exercised through
an oral understanding a custodial arrangement whereby the Defendant has Monday and
Tuesday overnights, and the Plalntiffherein has Wednesday, Thursday, Friday, Saturday,
and Sunday overnight,
9. Plaintiffbelieves and therefore avers that it is in best interests of the children to
grant shared legal custody of the children unto the Plaintiff and Defendant herein;
primary physical custody of the children unto the Plalnfiffherein, since Plaintiff herein is
able to take care of the day to day needs of the children, has exercised primary custody
for at least the last two month period of lime and presents a home in which the children
are comfortable and able to be cared for by the Plaintiff,
-2-
10. Plaintiff believes and therefore avers that the Defendant may be moving to
California, indicating that she may be leaving the jurisdiction.
11. To the extent that this may be true, Pla'mtiffrequests this Court to have a
provision in the Order that neither party may remove the children from the jurisdiction
pending further Order of Court.
WHEREFORE, Plaintiff requests this Court to grant the relief as requested.
Respectfully submitted,
Mancke, Wagner & Spreha
By
" ~233 North Front Street
Harrisburg, PA 17110
(717) 234-7051
Attorneys for Plaintiff
Date:
-3-
VERIFICATION
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.
WILLIAM COLEMAN :
PLAINTIFF :
:
V.
JESSICA STOCKSLAGER
DEFENDANT
iN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
04-1087 CiViL ACTION LAW
1N CUSTODY
ORDER OF COURT
AND NOW, Thursday, March 18, 2004 _, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear be~bre Melissa P. Greevy~, the conciliator,
at 301 Market Street, Lemoyne, PA 17043 on Tuesday, April 27, 2004 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. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry ora 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/
MeHssa P. Greev? Esq,
Custody Conciliator
mhc
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) 24%3166