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Home My WebLink About08-3909MARIA P. COGNETTI & ASSOCIATES MARGARET M. SIMOK, ESQUIRE Attorney I.D. No. 89633 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 9094060 Attorneys for Plaintiff DAVID E. RALPH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. Oy - 3 4 0 9,? ??.-- DEBRA ECKSTINE RALPH, CIVIL ACTION -LAW Defendant : IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is David E. Ralph, residing at 121-A South Chestnut Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Debra Eckstine Ralph, residing at 555 Harvest Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff seeks custody of the following child: Name Present Address Ate. e Denae Ralph 555 Harvest Lane 12 Years Mechanicsburg, PA 17055 4. The child was not born out of wedlock. The child is presently in the custody of Defendant, who resides at 555 Harvest Lane, Mechanicsburg, Cumberland County, PA 17055. 5. During the past five (5) years, the child has resided with the following persons at the following address(es): Name Debra Ralph Danielle Long Mark Lanie Jeriah David Ralph Debra Ralph Danielle Long Mark Lanie Jeriah Address 555 Harvest Lane Mechanicsburg, PA 17055 555 Harvest Lane Mechanicsburg, PA 17055 Dates 6/24/08 to present 6/01/08 to 6/24/08 David Ralph 555 Harvest Lane 8/02 to 6/01/08* Debra Ralph Mechanicsburg, PA 17055 *Note: Danielle Long and her children have been in and out of the Harvest Lane address for the past six years. 6. The mother of the child is currently residing at 555 Harvest Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. She is married. 7. The father of the child is currently residing at 121-A South Chestnut Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. He is married. 8. The relationship of Plaintiff to the child is that of father. Plaintiff currently resides alone. 9. The relationship of Defendant to the child is that of mother. Defendant currently resides with the following persons: Name Denae Ralph Danielle Long Mark (surname unknown) Relationship Daughter Daughter of Debra Boyfriend of Danielle Lanie Jeriah Daughter of Danielle Son of Danielle 10. Plaintiff has not participated as a party or a witness, or in any other capacity in other litigation, concerning the custody of the child in this or any other Court. 11. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 12. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 13. The best interest and permanent welfare of the child will be served by granting the relief requested. 14. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff requests the Court to grant him primary custody of the child. Respectfully submitted: MARIA P. COGNETTI & ASSOCIATES Date: (,-30-08 By; b?±? ro Ay-,4 MARGA T M. SIMOK, ESQUIRE Attorney I.D. No. 89633 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff VERIFICATION I, David E. Ralph, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn verification to authorities. a David E. Ralph DATE: G130/0e r " o cx 17 C -i R? I3 DAVID E. RALPH IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-3909 CIVIL ACTION LAW DEBRA ECKSTINE RALPH IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, July 10, 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 Friday, August 01, 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, Es q. 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 AINnim 6 S :1 WJ I I `finr 8002 AUAGNi H101 3 3Hi 30 3Jlii 0?3`If3 MARIA P. COGNETTI & ASSOCIATES MARGARET M. SIMOK, ESQUIRE Attorney I.D. No. 89633 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Plaintiff DAVID E. RALPH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-3909 CIVIL TERM DEBRA ECKSTINE RALPH, CIVIL ACTION -LAW Defendant IN CUSTODY AFFIDAVIT OF SERVICE I, Margaret M. Simok, Esquire, do hereby certify that a true and correct copy of the Complaint for Custody was served upon Debra Eckstine Ralph, Defendant, by certified mail, return receipt requested, delivery to addressee only, on the 23rd day of July, 2008. The original signed receipt, No. 7007 2680 0000 9824 2470, is attached hereto and made a part hereof. MARIA P. COGNETTI & ASSOCIATES Date: 7 - Xt?-08 By: MARL ET M. SIMOK, ESQUIRE Attorney I.D. No. 89633 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Plaintiff Postal Service RTIFIFD MAIL RECEIF (Domestic Mail Only; No Insurance Coverage Provided) 1 For delivery information visit our voebsite at www.usps.c7,, ru co U, O - M Retum Receipt Fee O (Endorsement Required) Restricted Delivery Fee M (Endorsement Required) CO N Total Postage & Fees r%- C3 C3 r%- 0 Comphle, 2. Wid 3. Also 0MV19te, dGW ¦ Print yow name and Add on ft mve18® so VW we can noun the OW to you. ¦ Att ch this card m the beak of the mallplelm or on the front N opwo permits. 1. Article AddrelNed to: rc.lSs?ine Re4k .?55 ?4 o-i-vest LQQ ?- rq, k" ,0-sbw(? QIR 17055 A. Ag" D. Is dtarvety MWWOMM lam 1? 7 U Y" ityM enter ddvay often below: a Service Iwo ¦'c«mw d O Pvreee Mel 0 Relplelwed WRetlrrn Rene" for Men; WMfte 0 kmaed Mell 0 C.O.D. 4. Rebated Delvwy4 Mktra Feel gybe L ^WeNUMber 7007 2680 0000 9824 2470 MWAar Rom a rv on kw M Farm 3611, February 2004 Domeenc Ream, ROW ? +??? t t? J,' . z SE 0 3 20Ub 6? 91, DAVID E. RALPH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW DEBRA ECKSTINE RALPH, NO. 2008-3909 Defendant IN CUSTODY COURT O R AND NOW, this day of , 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: The father, David E. Ralph, and the mother, Debra E. Ralph, shall enjoy shared legal custody of Denae' Ralph, born June 26, 1996. 2. Physical custody of the minor child shall be handled as follows: A. Father shall have physical custody on Sunday, Monday and Wednesday evenings with the custody to be overnight subject to Denae's desires; B. Father shall also have physical custody on alternating Fridays or Saturdays of each weekend subject to a schedule as worked out between the parties; and C. Mother shall have physical custody when Father does not have custody. 3. The parties shall work between themselves with respect to a holiday schedule that would accommodate their desires and Denae's desires. If the parties can't agree, they shall generally share the holidays. 4. In the event either party becomes dissatisfied with this Order and desires a more specific custody Order that sets forth a specific time schedule, that party may petition the Court to have the case again scheduled with the Custody Conciliator for a conference. Z cc: Margaret M. Simok, Esquire ?Ms. Debra A. Ralph T r)r,?11 LCCL I 99?a6 co ' I ` 1- f ? J C"i DAVID E. RALPH, Plaintiff vs. DEBRA ECKSTINE RALPH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-3909 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Denae' Ralph, born June 26, 1996 2. A Conciliation Conference was held on August 28, 2008, with the following individuals in attendance: the father, David E. Ralph, with his counsel, Margaret M. Simok, Esquire, and the mother, Debra E. Ralph, who appeared without counsel. 3. The parties agreed to the entry of an Order in the form as attached. Date: August a q , 2008 Hubert X. Giyoy, Esquire Custody Co ciliator MARIA P. COGNETTI & ASSOCIATES MARGARET M. SIMOK ESQUIRE Attorney I.D. No. 89633 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Plaintiff DAVID E. RALPH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 0$- 390`j DEBRA ECKSTINE RALPH, CIVIL ACTION -LAW Defendant IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of David E. Ralph, Plaintiff, in the above-captioned matter. MARIA P. COGNETTI & ASSOCIATES Date: 10& By; - /I Ae-4? MARGA M. SIMOK, ESQUIRE Attorney I.D. No. 89633 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 - . .- _ ?. ??- .:? .. y ? " 4;.1 ''s