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HomeMy WebLinkAbout01-6670CRAIG T. HOUGHTON, Plaintiff Vo CATHERINE D. HOUGHTON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. O I : IN CUSTODY COMPLAINT FOR CUSTODY CIVIL TERM Plaintiff is Craig T. Houghton, an adult individual currently residing at 1058 Stony Bridge Drive, Chambersburg, Franklin County, Pennsylvania. Defendant is Catherine D. Houghton, an adult individual currently residing at 1259 Means Hollows Road, Shippensburg, Cumberland County, Pennsylvania. o The parties are the natural parents of two children, namely, Connor Malloy Houghton, bom August 10, 1986, and Sarah McFerran Houghton, bom June 20, 1991. The children were not bom out of wedlock. For the past five (5) years, or since the children's birth, the children have resided with the following persons at the following addresses for the following periods of time: Craig T. Houghton, Catherine Houghton Catherine Houghton 1259 Means Hollow Road Shippensburg, PA 17257 1259 Means Hollow Road Shippensburg, PA 17257 Birth to August 27, 2001 August 27, 2001, to Present The natural mother of the children is Catherine D. Houghton who resides as aforesaid. She is married. The natural father of the children is Craig T. Houghton who resides as aforesaid. He is married. The relationship of the Plaintiff to the children is that of natural father. The Plaintiff currently resides alone. The relationship of the Defendant to the children is that of natural mother. Defendant currently resides with the children at issue. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning custody of the children. Plaintiff has no information of any custody proceedings concerning the children pending in any Court of this Commonwealth. It is in the best interest and permanent welfare of the children to grant the relief requested because: From the time of the children's birth until the time of the parties' separation in August 27, 2001, Plaintiff was equally involved in the care and control of the children; b.) Since the parties' separation, Plaintiff has attempted to maintain his relationship with the children, but Defendant will not cooperate in making the children available for Plaintiff; c.) Since separation, Plaintiff has requested numerous periods of partial custody and made several proposals in an effort to come to an agreement, but Defendant has not agreed with any request. d.) Since separation, Defendant has cooperated to allow Plaintiff to visit with his children without her present on only two occasions. e.) For approximately the past four years of the parties' marriage, Plaintiff was the primary caretaker during the summer months and the Christmas holiday. f.) Plaintiff has the ability and desire to provide for the financial, physical and emotional needs of the children; and g.) Plaintiff is equally capable in caring for and providing for the children. 10. Plaintiff does not know any person not a party to these proceedings who claims to have custody or visitation rights with respect to the children. WHEREFORE, Plaintiff requests your Honorable Court to schedule Custody Conciliation Conference followed by a hearing at which time he should be granted shared physical custody of the children. Respectfully submitted, Maryl0u~tas, Esqilife Attorney fo~ Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom falsifications to authorities. DATE: CRAIG T. HOUGHTON PLAINTIFF V. CATHERINE D. HOUGHTON DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 01-6670 CIVIL ACTION LAW : : IN CUSTODY AND NOW, Wednesday, December 05, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jaequeline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, January 08, 2002 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. All children age five or older may also be present at the conference. 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/ Jacqueline M. Verney. Eso. 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 VlNVA'tAS'NN3a JAN 1 6 2802 CRAIG T. HOUGHTON, Plaintiff V. CATHERINE D. HOUGHTON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001-6670 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT ~*'~*[ ~ ,2002, upon AND NOW, this day of consideration of the attached Custody Conl~iliation RelJort, it is ordered and directed as follows: 1. The Father, Craig T. Houghton, and the Mother, Catherine D. Houghton, shall have shared legal custody of Connor Malloy Houghton, born August 10, 1986 and Sarah McFerran Houghton, born June 20, 1991. Each parent shall have an equal right, to be exemised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. The Mother shall have primary physical custody of the children. 3. The Father shall have the following periods of partial physical custody: A. One evening per week with each child. B. Three or four hours every weekend, either Saturday or Sunday with both children, unless otherwise agreed by the parties, with an goal toward alternating overnight weekend periods. C. Such other times as the parties agree. 4. The parties shall begin family counseling as soon as practicable. Counsel for the parties shall together select the counselor. The cost is to be shared equally by the parties in the event the cost is not covered by insurance. 5. Father shall be responsible for all transportation. 6. After three months of family counseling, either party may contact the Conciliator to schedule another Conciliation Conference. 7. Both parties shall encourage the children to comply with this Order. 8. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE ~ cc: Marylou Matas, Esquire, Counsel for Father Lynn Y. MacBride, Esquire, Counsel for Mother JUL 2 2 2007 CRAIG T. HOUGHTON, Plaintiff CATHERINE D. HOUGHTON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001-3~!~ CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT AND NOW, this 22Nv day of July, 2002, the Conciliator being notified that the Petitioner withdrew his request for a conciliation conference, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, Es~Stody ~acq~eiine M. Vemey, Conciliator CRAIG T. HOUGHTON, Plaintiff V. CATHERINE D. HOUGHTON, Defendant PRIOR JUDGE: None IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2001-6670 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Connor Malloy Houghton August 10, 1986 Darah McFerran Houghton June 20, 1991 Mother Mother 2. A Conciliation Conference was held in this matter on January 16, 2002, with the following individuals in attendance: The Father, Craig T. Houghton, with his counsel, Marylou Matas, Esquire, and the Mother, Catherine D. Houghton, with her counsel, Lynn Y. MacBride, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date ~ quOline M. Vemey, Esquire Custody Conciliator