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Home My WebLink About09-1707P. Richard Wagner, Esquire PA Supreme Court ID# 23103 Mancke, Wagner, Spreha & McQuillan 2233 North Front Street Harrisburg, PA 17110 Telephone (717) 2347051 Fax (717) 2347080 Attorney for Petitioner ASHLEY LYNN BECRAFT, V. Plaintiff BENJAMIN J. BECRAFT, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO: og -707 0i..' 6 CIVIL ACTION -LAW IN CUSTODY COMPLAINT TO CONFIRM PRIMARY CUSTODY AND NOW, comes the Plaintiff, Ashley Lynn Becraft, by and through her attorneys, Mancke, Wagner, Spreha & McQuillan, and files the following Complaint to Confirm Primary Custody: 1. The Plaintiff, Ashley Lynn BecraB, is an adult individual residing at 41 Salt Road, Enola, Cumberland County, Pennsylvania. 2. The Defendant, Benjamin J. BecrA is an adult individual residing at 420 S. Hanover Street, Carlisle, Cumberland County, Pennsylvania. 3. The parties are the natural parents of two (2) childern, Cameron, born 7/8/07, and Maddison, born 1/28/09. 4. Plaintiff is the natural mother of the aforementioned children, and Defendant is the natural father of the aforementioned children. 5. The child, Cameron, was born out of wedlock, and the child, Maddison, was born during wedlock. 6. The children have resided with the following people at the following addresses for the following periods of time: A. Cameron, from birth for approximately 4 months with the Plaintiff and Defendant at the maternal grandparents, Daniel Gilham and Tonyia Woods' home at 20 Hillcrest Road, Enola, Cumberland County, Pennsylvania; B. From approximately the end of 2007 for approximately 1 year, the child, Cameron, resided with Plaintiff and Defendant at an apartment in Mt. Holly Springs, Cumberland County, Pennsylvania; C. From approximately the end of 2008 until the present time, Cameron has resided with the Plaintiff and Defendant at the address contained in paragraph 1 above, and as of 1/28/09, the child Maddison, resided at the address contained in paragraph 1 above. 7. Plaintiff is aware of no other party asserting a right to physical custody or partial custody of either of the children. 8. At the time of the preparation and filing of this Complaint, neither party is a member of the Armed Services, however, the Defendant Benjamin, is scheduled to be ordered to basic training in the Navy as of April 15, 2009. -2- 9. Plaintiff believes and therefore avers that it is in the best interests of the children to grant primary physical custody and sole legal custody of the children unto the Plaintiff. WHEREFORE, Plaintiff prays this Court to grant the relief as requested. Respectfully submitted, Mancke, Wagner, Spreha & McQuillan Wagner, Esquire I.D. #23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Plaintiff Date: .1 / D D -3- VERIFICATIQN I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.5.A. §4904, relating to unworn falsification to authorities. nh4ucA ? ?¢PrnD Date: 6 - q - r vi d ?J n r ev a a .xa rya r v ASHLEY LYNN BECRAFT IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. BENJAMIN J. BECRAFT DEFENDANT 2009-1707 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Wednesday, March 25, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Monday, April 27, 2009 at 8:30 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/ qhn . Man an r. 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 1 :a H'd 9z r d 60oz P. Richard Wagner, Esquire PA Supreme Court I.D. #23103 Mancke, Wagner, Spreha & McQuillan 2233 North Front Street Harrisburg, PA 17110 Telephone (717) 234-7051 Fax (717) 234-7080 Attorney For Plaintiff ASHLEY LYNN BECRAFT, Plaintiff, V. BENJAMIN J. BECRAFT, Defendant. TO THE PROTHONOTARY: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO: 2009-1707 CIVIL ACTION - LAW IN CUSTODY PRAECIPE Please withdraw the Complaint in Custody in the above-captioned matter. Wagner, Esquire I.D. #23103 2233 North Front Street Harrisburg, PA 17110 Attorneys For Plaintiff Date: `` FILED-OF xCE OF THEE PF-C7TH.r)NOTAPY 2009 APR 15 PM 2: 59 3