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HomeMy WebLinkAbout08-5060PAUL S. MOHR, JR. Plaintiff vs. MICHELLE ANN MOHR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. Or- SO (o O Civil Term IN CUSTODY CUSTODY COMPLAINT 1. Plaintiff is Paul S. Mohr, Jr., who currently resides at 1053 Rebecca Street, Cumberland County, Carlisle, Pa. 17013. 2. Defendant is Michelle Ann Mohr, whose current address is 101 G Colonial Drive, Shillington, Berks County, Pa. 19607. 3. Plaintiff is the Father of the following children and seeks a custody order regarding the following children: NAME DOB/AGE ADDRESS Roy "R.J." Mohr 7/24/97 (11) 1053 Rebecca St., Carlisle, Pa. 17013 Hayden Mohr 4/17/04 (4) 101 G Colonial Dr., Shillington, Pa. 19607 Sophie Mohr 7117/06 (2) 101 G Colonial Dr., Shillington, Pa. 19607 Mother and Father were married on September 23, 1996 in Berks County, and a divorce is currently pending in Berks County. The parties currently share physical custody of the children. During the past five years, the children have resided with the following persons and at the following addresses: NAME ADDRESSES DATES Paul S. Mohr, Jr. 1313 Old River Road 2003 - June 2006 Michelle Ann Mohr Birdsboro, Pa. 19508. with R.J. and Hayden MOTHER'S HISTORY OF RESIDENCES AFTER SEPARATION Michelle Ann Mohr Wernersville, Pa. Angie Reeser (mother's sister) with Sophie (born July 2006) Michelle Ann Mohr with Sophie 101 G. Colonial Dr. Shillington, Pa. 19607 Michelle Ann Mohr with Sophie and Hayden 101 G. Colonial Dr. Shillington, Pa. 19607 June 2006 - Feb. 2007 Feb. 2007 - June 2007 June 2007 - present FATHER'S HISTORY OF RESIDENCES AFTER SEPARATION Paul S. Mohr, Jr. with R.J. and Hayden 1313 Old River Road Birdsboro, Pa. 19508. June 2006 - June 2007 Paul S. Mohr, Jr. with R.J. Paul S. Mohr, Jr Wendy Nissel with R.J. 1313 Old River Road Birdsboro, Pa. 19508. 1053 Rebecca St. Carlisle, Pa. 17013 June 2007 - May 30, 2008 May 30, 2008 - present The mother of the child is Michelle Ann Mohr. She currently resides at 101 G. Colonial Drive, Shillington, Pa. 19607. She is married to Paul S. Mohr, Jr. The father of the child is Paul S. Mohr, Jr. He currently resides at 1053 Rebecca St., Carlisle, Pa. 17013. He is married to Michelle Ann Mohr. 4. The relationship of plaintiff to the children is that of Father. The plaintiff currently resides with his son Roy "R.J." Mohr and Wendy Nissel. 5. The relationship of defendant to the child is that of Mother. The defendant currently lives with her children, Hayden Mohr and Sophie Mohr. 6. 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 another court, other than as follows: A divorce is pending in Berks County, however. Defendant has indicated that a custody order has not been entered in that county. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: The parties separated in June 2006. A divorce is pending in Berks County. Pennsylvania For unknown procedural reasons a custody order was denied in Berks County. Father is seeking a custody order which would provide for custody of the children This request is the in the best interest of the children because it would provide stability for the children and ensure that the children maintain contact with both parents. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiff requests the court to enter a custody order regarding the children. Respectfully submitted, Date: a 0 11A 0'( 'P/ O? JJ Adams, squire o.79465 South St. le, Pa. 17013 245-8508 RNEY FOR PLAINTIFF VERIFICATION I verify that the statements made in this Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. OSI Date. Mohr Jr., Plaintiff -r3 71 ` t- PAUL S. MOHR, JR. IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-5060 CIVIL ACTION LAW MICHELLE ANN MOHR IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, August 27, 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 Tuesday, September 30, 2008 at 9:30 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/ ac ueline 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 A6V LZ SIM ROOZ 4, :a - SEP 19 zuub ?? PAUL S. MOHR, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-5060 CIVIL ACTION - LAW MICHELLE ANN MOHR, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 19h day of September, 2008, being advised that the matter is being heard in Berks County, Pennsylvania, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, cq line M. Verney, Esquire ustody Conciliator cn ?-? ? Y ? ?4ry ,+? w +? ?; ?° ? ? '? 4