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HomeMy WebLinkAbout09-2992AMANDA M. WANNYN, Plaintiff V. RAYMOND D. DURDEN, SR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 2009 -CIVIL TERM IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, Amanda M. Wannyn, by her attorneys, Irwin & McKnight, P.C., and presents the following Complaint for Custody. 1. The Plaintiff, Amanda M. Wannyn, is an adult individual with an address of 550 Meals Road, Gardners, Cumberland County, Pennsylvania 17324. 2. The Defendant, Raymond D. Durden, Sr., is an adult individual with an address of 40 West Green Street, Apartment B, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The parties are the natural parents of two (2) children, namely, Angel M. Durden, born January 27, 2006, and Jayden D. Durden, born March 20, 2007. 4. An Order of Court docketed at 2006-187 and dated March 21, 2006, was entered in regard to the oldest minor child, Angel M. Durden. A copy of said Order is attached hereto and marked as Exhibit "A". 5. This Complaint is in regard to their minor child, Jayden D. Durden, born January 27, 2006. No prior Court Orders have been issued regarding said child. 6. The Plaintiff desires that the parties have shared legal custody of the minor child, Jayden D. Durden. 7. The Plaintiff desires that she have primary physical custody of the minor child, Jayden D. Durden with periods of temporary custody to the Defendant as the parties can agree is in the best interest of the minor child, Jayden D. Durden. 8. The best interests and permanent welfare of the minor child requires that the Court grant the Plaintiff's request as set forth above. WHEREFORE, the Plaintiff, Amanda M. Wannyn, respectfully requests that she be awarded primary physical custody and shared legal custody of Jayden D. Durden, with periods of temporary custody to the Defendant, Raymond D. Durden, Sr., as provided herein. Respectfully submitted, IRWIN Mc GHT, P.C. By: Mar s A. McKnig t, , Esquire Attorney for Pl 60 West Pom et Street Carlisle, Pennsy 7013-3222 (717) 249-2353 Supreme Court I. D. No. 25476 Date: May 12, 2009 EXHIBIT "A" MAR 1 7 2006 AMANDA M. WANNYN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-817 CIVIL ACTION - LAW RAYMOND D. DURDEN, SR., . Defendant : IN CUSTODY ORDER OF COURT AND NOW, this day of , 2006, upon consideration of the attached Custody Concil' tion Report, it is ordered and directed as follows: 1. The Mother, Amanda M. Wannyn and the Father, Raymond D. Durden, Sr., shall have shared legal custody of Angel M. Durden, born January 27, 2006. Each parent shall have an equal right, to be exercised jointly with the other parent, 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. Mother shall have primary physical custody of the child. 3. Father shall have periods of partial physical custody every weekend from Saturday from 2:00 p.m. to Sunday at 6:00 p.m. and such other times as the parties agree. 4. Holidays shall be shared as agreed by the parties. 5. Transportation shall be as agreed by the parties. 6. 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 COURT, 4 y ? J. cc: Marcus A. McKnight, III, Esquire, Counsel for Mother Raymond D. Durden, Sr., pro se 40 West Green Street Apartment B Mechanicsburg, PA 17055 I&VItniza MAR 23 2006 III( W f N' 4? {??c SIG T AMANDA M. WANNYN, Plaintiff V. RAYMOND D. DURDEN, SR., Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-817 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 Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Angel M. Durden January 27, 2006 Mother 2. A Conciliation Conference was held in this matter on March 16, 2006, with the following in attendance: The Mother, Amanda J. Wannyn, with her counsel, Marcus A. McKnight, III, Esquire, and the Father, Raymond D. Durden, Sr., pro se. 3. The parties agreed to an Order in the form as attached. 3 -o Date jacq line M. Verney, Esquire Custody Conciliator VERIFICATION The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. I have read the statements made in this document and they are true 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. AMANDA M. WANNYN Date: May 12, 2009 FIL%-' F OF THE ?'?Tw,'NOTAPY 2009 MAY 12 PPS 2: 4 5 r P iV& f LVA A /w /oy ,CE(,{l °?o? S G3/ AMANDA M. WANNYN IN THE COURT OF COMMON PLEAS OF: PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. RAYMOND D. DURDEN, SR. DEFENDANT 2009-2992 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Wednesday, May 13, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, June 11, 2009 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. 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/ [acgueEne M. Vern ey, Es T4 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 Y HLEF)-g t ;°I 0O THc i' 2009 MAY 14 PH 0: 30 uA R).. V,. tt 6 61 1. JUN 1 2,2009t4 AMANDA M. WANNYN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-2992 CIVIL ACTION - LAW RAYMOND D. DURDEN, SR., . Defendant : IN CUSTODY ORDER OF COURT AND NOW, this __a?(day of -.7, , 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Amanda M. Wannyn and the Father, Raymond D. Durden, Sr., shall have shared legal custody of Jayden D. Durden, born March 20, 2007. Each parent shall have an equal right, to be exercised jointly with the other parent, 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. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 2. Mother shall have primary physical custody of the child. 3. Father shall have periods of partial physical custody every weekend from Saturday from 2:00 p.m. to Sunday at 6:00 p.m. and such other times as the parties agree. 4. Holidays shall be shared as agreed by the parties. 5. Transportation shall be as agreed by the parties. 6. 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. ccus A. McKnight, III, Esquire, Counsel for Mother /Raymond D. Durden, Sr., pro se 40 West Green Street Apartment B Mechanicsburg, PA 17055 IT t??.S rn.Zl? BY THE COURT, AMANDA M. WANNYN, Plaintiff V. RAYMOND D. DURDEN, SR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-2992 CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., J. 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 Child who is the subject of this litigation is as follows: NAME Jayden D. Durden DATE OF BIRTH CURRENTLY IN CUSTODY OF March 20, 2007 Mother 2. A Conciliation Conference was held in this matter on June 11, 2009, with the following in attendance: The Mother, Amanda M. Wannyn, with her counsel, Marcus A. McKnight, III, Esquire, and the Father, Raymond D. Durden, Sr., pro se. 3. The Honorable J. Wesley Oler, Jr. previously entered an Order of Court at docket number 06-817 dated March 21, 2006 concerning an older child of the parties. 4. The parties agreed to an Order in the form as attached. Date cq line M. Verney, Esquire Custody Conciliator OF THE F 2009 Ju 18 PH 4 08 ,ll . ," r