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Home My WebLink About09-2083 I Thomas J. Williams, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 17512 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff BETH A. WEARY f/k/a IN THE COURT OF COMMON PLEAS OF BETH A. WASHINGTON, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. THOMAS M. WASHINGTON, Defendant PLAINTIFF'S COMPLAINT FOR CUSTODY 1. Plaintiff is Beth A. Weary, f/k/a Beth A. Washington, an adult individual currently residing at 1850 Pine Road, Newville, Cumberland County, Pennsylvania. 2. Defendant is Thomas M. Washington, an adult individual currently residing at 1621 Putnam Street, Harrisburg, Dauphin County, Pennsylvania. 3. Plaintiff seeks custody of the child, Hannah Renee Washington, who was born on July 1, 2000. The child was born in wedlock. 4. Since the child's birth, the child has resided with the following persons at the following addresses for the following periods of time: Time Persons Birth-8/31/03 Parties 9/1/03-6/05 Plaintiff NO. 09- b `?'3 c ?" I CIVIL ACTION - LAW IN CUSTODY Location 118 East Penn Avenue, Cleona, PA 118 East Penn Avenue, Cleona, PA 6/05 to present. Plaintiff, Stepfather, stepbrothers 1850 Pine Road, Newville, PA 5. The relationship of the Plaintiff to the child is that of Mother. She is married and living separately. The Plaintiff currently resides with the following: Name Relationship Bryan D. Weary. Husband Hannah R. Washington Daughter Devon Bryan Weary Step-son 6. The relationship of the Defendant to the child is that of Father. He is single and living separately. The Defendant currently resides with person or persons unknown. 7. The parties have not participated in previous litigation concerning the custody of the child in this court or any court. 8. The Plaintiffhas no information of a custody proceeding concerning the child pending in any other court. 9. The best interest and permanent welfare of the child will be served by granting full physical and legal custody to the Plaintiff. The child has been solely in the custody of Mother since the parties separated on September 1, 2003. Father has seen the child only occasionally since then. 10. Plaintiff does not know of any person not a party to these proceedings who claims to have custody or visitation rights with respect to the child. WHEREFORE, Plaintiff requests your Honorable Court to set a time and place for a hearing at which Plaintiff requests the Court to grant Plaintiff the Custody Order. Pending said hearing, Plaintiff requests full legal and physical custody. MARTSON LAW OFFICES By 'CLvHn,A t& ? Thomas J. Williaffis, Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Date: April 2, 2009 VERIFICATION The foregoing Complaint for Custody is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the Complaint and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. i Beth A. Weary Wa Beth 29Washi gton PTILESTlieats16297 Wwy%297A.custodycomplaiot RBD--*' OF 2go AT&t PR -3 AM T 52 cuwgi,,-?4.o COUNTY t4 oj ? ? r d ?f47 BETH A. WEARY F/K/A BETH A. IN THE COURT OF COMMON PLEAS OF WASHINGTON PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. THOMAS M. WASHINGTON DEFENDANT 2009-2083 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Tuesday, April 07, 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 Thursday, May 14, 2009 at 10:00 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 pennanent 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/ john j. Mangan, 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 (71.7) 249-3166 OF THE PR n?OTP Y 2989 APR _8 Ph 2. 39 v.g ov eevE copy n,a,.?d ? a4 alzeu.y ?f 8 D9 `Vlo?cc;? a' ? Li 8O9 l')?" pQaaed 44.' a? a'° 1-4 JUN U 4 Ziluy&I BETH A. WEARY F/K/A BETH A. WASHINGTON, Plaintiff V. THOMAS M. WASHINGTON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 09-2083 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW thisday of June 2009, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. Legal Customs: The Mother, Beth Weary, shall have primary legal custody of Hannah Renee Washington, born 07/01/2000. The Mother shall have the right to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. 2. Physical Custody: Mother shall have primary physical custody of the Child. Father shall have physical custody of Hannah as the parties may agree upon reasonable notice by Father of his request for custody. 3. Mother shall keep Father updated as to her address (and of the Child) and her phone number so that Father may contact her to request physical custody or visitation. 4. The non-custodial parent shall have liberal telephone contact with the Child on a reasonable basis. 5. Holidays: The parents shall arrange a holiday schedule as agreed upon. 6. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other party, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Child. 7. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 8. During any periods of custody or visitation, the parties shall not possess or use controlled substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 9. This Order is entered pursuant to 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. Upon a change in circumstances, nothing in this Order shall preclude Father or Mother to file a Petition to Modify Custody. By the Court, Q?v Distribution: omas Washington, 1621 Putnam Street, Harrisburg, PA, 17104 omas Williams, Esquire ,,- ohn J. Mangan, Esquire ?o P F{LE.D-" FriCE. T OF TKI pE ir?C'' ,,ARY 2009 JUN -9 Am l l : 38 PENtF4' r`LV, .I?dtA BETH A. WEARY F/K/A BETH A. WASHINGTON, Plaintiff V. THOMAS M. WASHINGTON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 09-2083 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH 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 Child who is the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Hannah Renee Washington 07/01/2000 Primary Mother 2. A Conciliation Conference was held with regard to this matter on May 26, 2009 with the following individuals in attendance: The Mother, Beth Weary, with her counsel, Thomas Williams, Esq. The Father, Thomas Washington, pro se 3. The parties agreed to the entry of an Order in the form as attached. ----?.?( ------------ Date Jo an, squire C tody onciliator