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Home My WebLink About08-7494IN THE COURT OF COMMON PLEAS OF ('t ?m?' s\r,nrA_ COUNTY, PENNSYLVANIA FAMILY DIVISION Petitioner VS. Case Number# ?g ?7 7 -kA? De.t-?1cl )- ? Z' . Respondent IN FORMA PAUPERIS STATEMENT petitioner, pro se, hereby states under penalties provided by 18 Pa. C.S.A. §4904, relating to unworn falsifications to authorities, that the following is m support of the In Forma Pauperis Statement: 1. I am the petitioner in the above captioned matter and that because of my financial condition I am unable to pay the following fees and costs of prosecution in this matter. 2. My responses to the questions below relating to my ability to pay the fees and costs are true and correct to the best of my knowledge, information, and belief. (A) Are you presently employed? O YES X NO (1) If the answer is YES, state the amount of your salary or wages per month and give the name and address of your employer: (2) If the answer is NO, state the date of last employment, salary or wages earned: Dc 2C'?1 o. Nay- ( Sa-,kiA 2 Acxt Ash (B) Have you received within the past twelve (12) months, any income from a business, profession, or other form of self employment, or in the form of rent payments, interest, dividends, pensions, annuities;, social sec-"ity benefits, support payments or other viable source? O YES I& NO (1) I the answer is YES, describe the source of income, and state the amount received from each source during the last twelve (12) months: (C) Do you have a checking account or savings account(s): O YES 19 NO (1) If the answer is YES, state the amount in each account: (D) List the persons (if any), who are dependent upon your support and state their relationship to you: he ??;tne F? ['.Yv" 10nr\p T'V+uL le r -c ucah*f (E) List all outstanding debts and obligations: ;r\ ?, N - - a ??, . -??, - ? ?? _T ? , _ , 6r ` ? .. .r.. °r ) : CT't r.'_ ? ? N y Ch: ..e IN THE COURT OF COMMON PLEAS OF Cl ?m1a= r IC?nC? COUNTY, PENNSYLVANIA CIVIL PROCEDURE Defendant vs. NO: D D w 7 Y j L APPLICATION FOR ASSIGNMENT OF COUNSEL TO THE HONORABLE JUDGE OF SAID COURT: AND NOW, to writ this 20day of -t1je_r_ mbU , c?? comes the Petitioner acting pro se and petitions this Court to appoint Counsel unto her pursuant to PA. Rules of Civil Procedure. Petitioner assigns the following therefore: 1. That petitioner is incarcerated at the State Correctional Institute at Cambridge Springs, 451 Fullerton Ave, Cambridge Springs, PA 16403-1238. 2. That your petitioner is a layperson in the study of law. 3. Petitioner is in need of counsel to help prepare the case the petitioner is now appealing. 7C 4. Petitioner has filed with Honorable Court a Forma Pauperis Petition to let her proceed as an indigent party. 5. Petitioner is unable to obtain private counsel because of her being indigent. 6. Petitioner was previously represented by ;,,-, ?-,,w WHEREFORE, petitioner prays this Honorable Court to appoint counsel unto her so that she may proceed in this matter. Respectfully submitted, -:-? off, s ? ?? ar -? j CrN N CY^ ,any, ` _ V or I Cn onr% .LAP 1Pb,?Ae Plaintiff VS Defendant IN THE COURT OF COMMON PLEAS OFC,aI T,Y1, PENNSYLVANIA NO.?7q Q T COMPLAINT FOR I? 1. The Plaintiff is CAVFA %%n j In ?.?Inr residing at SCI Cambridge Springs, 451 Fullerton Avenue, Cambridge Springs, PA. 2. The defendant is Ap ?\V?..,ijer Sr residing at ?,C) FQZ?? 3. The plaintiff seeks ex n?ual rn of the following child(ren): Name Present Address Birth Date 1 rY,hPr 2.1 A? tYf? (a) The child(ren) (was) was not born out of wedlock. (b) The child(ren) (is) (161)) presently in the custody of .J2W who resides atp n„-,? ?,???,n A \\ (c) During the past five years, the child(ren) (has) ave resided with the following persons and at the following addresses: List the Persons List the Addresses Dates 3UAOL j F\ ??yJll?r ??? \1?2 ?P ?? ?[1r\l ?? \1??c1 ,?Y? fY-? - Qt11r? Crl?nn x .rte 10 ?? . ?? \ P r l?\lD :b Y > a \lr Cc?r\.•?\ v tom, tti F. ?1 ine (?'-l - .1(?r? 2 [Yl`? \4\O L?eh°kNr \? C n \?clc RZ \'(???l ?ro l7`?- ?nr,? . (d) The mother of the child(ren) is currently residing at 11ri\ A.i- C'r..t hr,1.,0 R, 11OA r e (e) She is (married) divorced) single). (f) The father of the child(ren) is \eW Sc. , currently residing at a? Enp 21 nn (g) He is (married) divorce (single). 4. The relationship of the plaintiff to the child(ren) is that of fe?• The plaintiff currently resides with the following persons: Name Relationship to Plaintiff ?lr,es. The defendant currently resides with the following persons: Name Relationship to Defendant C.r"rz?" nor, 6. The plaintiff (has) has not participated as a party or witness or in another capacity, in other litigation (court case) concerning the custody of the child in this or another court. The court, term and number, and its relationship to this action is: (a) The plaintiff (has) (has no information of a custody proceeding con- cerning the child(ren) pending in a court of this Commonwealth. The court term and number and its relationship to this action is: (b) The plaintiff knows does not know) of a person, not a party to the pro- ceedings, who has physical custody of the child(ren) or claims to have custody or visitation rights with respect to the child(ren). The name and address of such person is: C? X10 ?? S?rc?? AK,? \\ Mk \\? \??Qc?^ ;?,. 1?lOlLyS 7. The best interest and permanent welfare of the child(ren) will be served by granting the relief requested because: m ?AC\ l+t'Y?\ .Sic n \ i p c-c-?? (?tY? \ C'a,,.r? ` \c \? n\ y c? Tr,y p c {?,1c?res r. C h Wce cc? c, r \ i ?Ctcri \ cy>c-ctt. \c??t'\c?-arY ` v..? \ Sk)Ci ? o C% C"..'& ?rn C+ r'" G O n lam=YIF? `c?11 C % `F??c'x??. CICSC'P P\?(1P Yl? ?k-CLY? l :fix o C\mint cCO Mxu o = r mvrm?kc?_ZOQ N\ n ;\L\LOJ\ m saA 11 ?r &1 CSC pt C & c v. vyoA0 Nc, C ? ce Ivu) isU LCi,61Mar'1 2 t+2 m zi 0 ? ?[YQ (\ ?e (-, V11 V%g a ?? . ii Se \ C1?k10 5, °-•?--• Cl ? o Pr `?r?t `1S 1 n6a)oA nlr? hey ax--, f'Ar?r \n oank roP ha >T?e V?e n\m 1 iL't1 C,(> rY? o pl-y- :ter-3c-? \O ?.o ?'x? c?ra f1P? Ufl \ O Mrs . 7 c'`f'`l n' y?- \ \ 'c sr hml le }'} t hS Cnyw"q ?"?.?,, ?? ?S " Mhl? t'l1rY (?C? 1Y\lli? f \ _}t\O ((?? A. 5. The relationship of the defendant to the child(ren) is that of ,'\ , r r 7. Continued... ?L hp n Arc, o !P-e n-c i> >? n \c, v?? \?c?1 0 lC1S cv?? Q -4 em ? 11it" t %P S • C.'I)? L _Qg-, \C-" \e8 j ;P0-?lQ )a tiY\\f e _ C\C-C o <NcAk-%voc JSp \ ?eP \ AAne 1c' ?cP st _kn_ I fea''r N!-,, -?n b2 jr, MW. c o'c ? " ? %Wn?me??c?oy?c,o 1 app c nNc c? `t 8. Each parent whose parental rights to the child(ren) have not been term- inated and the person who has physical custody of the child(ren) have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation with the children will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim lh7yy RAq-A iSA??? 4?121U9y r.o ,Qsroa C-,?c "NOVOer Wherefore, the plaintiff requests the court to grant CD C '&Qtg' QR Plaintiff I verify that the statements made in this 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. Plaintiff Z r.. = an ,+ L, CL CIQ r LLI C-) ? t t `xa _ CV 0 4 d rn 3 Q T M C a = ra CD <D O 'p 7 CO CD y 7 Dm rn A 0 w m w ?( ) 00 1+? tw r Ell ? J J do LO Qa rli _ FI i m a? o° N uN"r-0s+ ?? . N A N O 01 N? I W 0o O X `S 19 d: G) G CATHERINE DETWILER, Plaintiff V. JEFF DETWILER, SR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 08-7494 CIVIL TERM IN RE: APPLICATION TO PROCEED IN FORMA PAUPERIS and APPLICATION FOR ASSIGNMENT OF COUNSEL ORDER OF COURT AND NOW, this 6t' day of January, 2009, upon consideration of Plaintiff's application to proceed in forma pauperis and application for assignment of counsel in this custody case, it is ordered and directed as follows: 1. Plaintiff's application to proceed in forma pauperis is granted; and 2. Plaintiff's application for the assignment of counsel is denied. BY THE COURT, ZCatherine Detwiler, OL-7723 451 Fullerton Avenue Cambridge Springs, PA 16403 Plaintiff, pro Se -' Jeff Detwiler, Sr. 20 East Street Apt. 11 Mount Holly Springs, PA 17065 Defendant, pro Se :rc 2 ` QS m?.t l G? r?'1 ..l f;? '..,,? t t 7 CATHERIN LYN DETWILER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-7494 CIVIL ACTION LAW JEFF EUGENE DETWILER, SR. IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, January 23, 2009 , 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, February 06, 2009 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. Grlro Es o. 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 /'B'' ?? G? ,?"?''?' ?''°? Win- .i ?`. p ,? t F? ? ?t ??t 1? ??? ? r? y 1 ? y? .. -;? ±r. , R?,?Si?,;,..1? i '?.J ..? :911 .::+J ._ ?:??? %,a 1. /1 CATHERIN LYN DETWILER, Plaintiff VS. JEFF EUGENE DETWILER, SR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-7494 IN CUSTODY COURT ORDER AND NOW, this _ day of February, 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The father, Jeff Eugene Detwiler, Sr., shall enjoy legal and physical custody of Jeff Detwiler, Jr., born June 13, 2004, and Cheyenne Detwiler, born September 24,2005. 2. The mother, Catherin Lyn Detwiler, upon her release from prison, shall enjoy periods of temporary physical custody of the minor children as the parties agree. 3. Upon mother's release from prison and in the event she desires more custody with the minor children, the mother at that time may file a Custody Petition with the Court which will be assigned to the Custody Conciliator for a conference. 4. In light of the fact that the mother has been incarcerated for the past two years and has not seen the children during that time frame, mother's complaint for custody/visitation is denied at this time. BY THE COURT, cc: Jane Adams, Esquire .2. 13-6 9 Ms. Catherin Lynn Detwiler -? n a cn u? co --' ?u U- a.a c C) N . it FL76 00206 CATHERIN LYN DETWILER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW JEFF EUGENE DETWILER, SR., NO. 2008-7494 Defendant 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 children who are the subject of this litigation is as follows: Jeff Detwiler, Jr., born June 13, 2004, and Cheyenne Detwiler, born September 24, 2005. 2. A Conciliation Conference was held on February 6, 2009, with the following individuals in attendance: The father, Jeff Eugene Detwiler, Sr., with his counsel, Jane Adams, Esquire,. 3. Mother filed this petition seeking primary physical custody of the minor children. However, mother is currently incarcerated at SCI Cambridge Springs. Mother did not attend the hearing and no attorney attended on her behalf nor did anyone contact the Custody Conciliator with respect to the Conciliation Conference. The father related that the mother has been incarcerated since January of 2007. She has not seen either of the children since that time. 4. Based upon the above circumstances, the Conciliator recommends an Order in the foam as attached. Date: February -` , 2009 Hubert X. G' roy, Esquire Custody C ciliator