HomeMy WebLinkAbout01-6668JOHN R. TOLAN,
Petitioner
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ROBERT W. DICK,
Respondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
:~,01~ 6 6 ~ J~CIVIL TERM
: IN CUSTODY
PETITION FOR CUSTODY
AND NOW, this 27th day of November 2001, comes thc Petitioner, John R. Tolan, by
his attorneys, Irwin, McKnight and Hughes, and presents the following Petition for Custody.
The Petitioner is John R. Tolan, an adult individual residing at 1 West Penn Street,
Carlisle, Cumberland County, Pennsylvania 17013.
The Respondent is Robert W. Dick, an adult individual with the last known address being
Mercer State Prison, 138 South Diamond Street, Mercer, Pennsylvania 16137.
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The subject of this Petition for Custody is Shelby Desiray Tolan, age sixteen (16), born
May 6, 1985.
The Petitioner is the natural maternal grandfather of Shelby Desimy Tolan.
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The mother of Shelby Desiray Tolan was Kathleen L. Tolan who died on July 28, 2001.
The child, Shelby Desiray Tolan, has resided at the following addresses:
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From October 1, 2001, to the present with the Petitioner, John R. Tolan,
at 1 West Penn Street, Carlisle, Pennsylvania 17013.
From July 28, 2001, to October 1, 2001, with a neighbor, Sheila Hicks,
2057 Niblick Drive, #124, Jacksonville, Pennsylvania 32210.
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From May 1, 2000, to July 28, 2001, with her mother, Kathleen L. Tolan,
2058 Niblick Drive, #122, Jacksonville, Pennsylvania 32210.
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From May 1, 1999, to May 1, 2000, with her mother, Kathleen L. Tolan,
315 Albert Walk, San Antonio, Texas.
The Petitioner, John R. Tolan, desires primary physical and legal custody of Shelby
Desiray Tolan.
The best interest of Shelby Desiray Tolan requires that the Court grant the Petitioner's
request as set forth above.
WHEREFORE, Petitioner, John R. Tolan, respectfully seeks the entry of an Order of
Court seeking primary physical and legal custody of Shelby Desimy Tolan.
By:
Respectfully submitted,
IRWIN, Mc~IIGHT~ ~I~UGHES
~larcustA. MeKn~I ~ III, Esquire
Attorney f~ etitioner
60 West Pomfret Street
Carlisle, Pennsylvania 17013
(717) 249-2353
Supreme Court I. D. No. 25476
Date: November 27, 2001
VERIFICATION
The foregoing Petition for Custody is based upon information which has been gathered
by counsel and myself in the preparation of this action. I have read the statements made in this
document and they are tree and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unsworn falsification to authorities.
Date: November 27, 2001
JOHN R. TOLAN
PLAINT~F
V.
ROBERT W. DICK
DEFENDANT
1N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:
01-6668 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 10:30 AM
for a Pre-Heating 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/ Jacqueline M. Verney. Esq.
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 heating.
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
JOHN R. TOLAN,
Plaintiff
Ve
ROBERT W. DICK,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 2001-6668 CIVIL TERM
:
: CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this 2na day of January, 2003, as the parties have not contacted the
Conciliator since January 10, 2002 to request a conference, the Conciliator hereby
relinquishes jurisdiction in this matter.
FOR THE COURT,
Sficq~line M. Vemey, E~luire, Cus~o~ Conciliator