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HomeMy WebLinkAbout09-6767ANDREW TODD COULSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION /- LAW N O. Lo f ?e 0, v C-F" STEPHANIE M. COULSON, Defendant IN CUSTODY Carlisle, Cumberland County, Pennsylvania, with Sylvia Rambo. 1. The Plaintiff is Andrew Todd Coulson, residing at 339 Barnstable Road, 2. The Defendant is Stephanie M. Coulson, residing at 911 Sadler Court, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following children: Laura Coulson, born February 19, 1992, age 17, and Andrea Coulson, born March 29, 1996, age 13. The children were not born out of wedlock. The children are presently in the custody of Defendant who resides at 911 Sadler Court, Carlisle, Cumberland County, Pennsylvania. COMPLAINT FOR CUSTODY During the past five years, the children have resided with the following persons and at SA )IS, FWNWR & LINDSAY A 1QW*-Y5-AX-L w 26 West High Street Carlisle, PA the following addresses: Name Present Residence Dates Andrew Todd Coulson and Stephanie M. Coulson Stephanie M. Coulson 911 Sadler Court, Carlisle, PA 911 Sadler Court, Carlisle, PA 2004 until June 2008 June 2008 to present The mother of the children is Stephanie M. Coulson, currently residing at 911 Sadler Court, Carlisle, Cumberland County, Pennsylvania. She is married. The father of the children is Andrew Todd Coulson, currently residing at 339 Barnstable Road, Carlisle, Cumberland County, Pennsylvania. He is married. 4. The relationship of Plaintiff to the children is that of Father. 5. The relationship of Defendant to the children is that of Mother. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: a. The children will benefit by having a schedule of regular contact with their Father; and b. The children will benefit from substantial time with their father. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the child have been named as parties to this action WHEREFORE, Plaintiff requests the Court to grant legal and partial physical custody SAIDIS, LENDSAY ATIUM -YS-A uw 26 West High Street Carlisle, PA of the children. SAIDIS, FLOWER I SAY Carol J. Lindsa quire ID No. 44693 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiff VERIFICATION 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.S. §4904, relating to unsworn falsifications to authorities. Andrew Todd Coulson Date: I L, (11 .. o c1 SAMIS, LE'l-1D5AY ATIDVEYS•AT IAW 26 West High Street Carlisle, PA FILL)- 01+11;F 2009 OCT -9 r??i 3: 15 C ?? ?LY3a apt ti? Ir .1W r ANDREW TODD COULSON IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-6767 CIVIL ACTION LAW STEPHANIE M. COULSON IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, October 21, 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, November 13, 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 Custodv orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilroy, Esq. 11A 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 r 1LEi I - - , `plc THE =NOFARY 2009 OCT 21 PH 4 08 v VIV ANDREW TODD COULSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 09-6767 STEPHANIE M. COULSON, Defendant IN CUSTODY AFFIDAVIT OF SERVICE I, Carol J. Lindsay, Esquire, being duly sworn according to law, hereby deposes and says that on October 20, 2009, I served a true and correct copy of the Custody Complaint upon Defendant, by mailing the document to her address at 911 Sadler Court, Carlisle, PA 17013, by Certified U.S. Mail, Restricted Delivery, Return Receipt Requested, as evidenced by the attached U.S. Postal Service Form 3811, Domestic Return Receipt, the latter of which is signed by the recipient, Stephanie M. Coulson. Respectfully submitted, SAIDIS, FLOWER & LINDSAY / 'i~ 9~~Z~ ;: > r r e ,~ CaroTJ- Lindsay>'Es h=e ~--- Attorney Id. 4 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS, ~LIlVD ~ Dated:` ( ', 0 ~~.~:uW I 26 West High Street Carlisle, PA .,~ ^ Complete items 1, 2, and 3. Also complete item 4 N Restricted Delivery is desired. ^ Print your name and address on the reverse so that we can return the card to you. ^ Attach this card to the back of the mailpiece, or on the front if space permits. ~. X ^ Agent 1. Article Addressed to: ~~~1L~ /Z i L ~ CJZ.L ~ S C'Yl ~1( ~5c~c~~ er C'oL~~~ ~a~r ~,~s1P, /`~l9 ~~o ~ 3 B b j~ N~~) ~ Dffie of DelNery ` -c ~IS,H I U ~U y D. Is ivory add kern 1? ^ Yes ~ If YES, enter ~lqr ' lo w: v ©~~ ' 'Q Q : ,, V ~~' ~:. 3. Service Type Q Certified Mall Mall ^ Registered ^ Return Receipt for Merchandise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (Extra Fee) s. artk~eWumber 704 1350 ~~~3 7286 2415 (flansfesr from service PS Form 3811, Fetxwry 2004 Domestic Return Receipt iozses-a¢~~aao SAIDIS, F7~OWER ~ LINDSAY ,c'tom~xsnrtww 2G West High Street Carlisle, PA ~ ,-'tTf, r•~•Yr ~i~.~~ ~ irr .i ~:. l ~:~ ~ ~ ~ , r~'' ~~ OEC 0 8 2010 ANDREW TODD COULSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION -LAW c= n 7 -. M STEPHANIE M. COULSON, NO. 2009-6767 rrg F i F -a Defendant IN CUSTODY ?- ; r --- rn C =c -*1 > c7 O-n COURT ORDER c' w ?rn AND NOW, this day of Decembey23',*2010, upon consideration of"t'h e attach-6d Custody Conciliation Report, it is ordered and directed that this court's prior order of December 29, 2009, shall remain in place subject to the following additional provisions: The parties shall submit themselves and the minor child to a custody evaluation to be performed by a professional selected by legal counsel for the parties. Cost of this evaluation shall be paid for by the father. The parties shall cooperate with the evaluator with respect to furnishing all appropriate releases and other necessary information so that an appropriate evaluation can be completed. The parties shall also cooperator with the evaluator with respect to making the minor child and any significant others of the parties available for purposes of involvement in the evaluation. 2. Upon the conclusion of the evaluation and in the event the parties are unable to reach an agreement at that time, counsel for the parties may contact the Custody Conciliator again to schedule another custody conciliation conference. BY THE COURT, Edward E. Guido, Judge cc. Ct1 Lindsay, Esquire Sandra Meilton, Esquire ( LO`0 ta?l 3 Y y • ANDREW TODD COULSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. STEPHANIE M. COULSON, Defendant PRIOR JUDGE: Edward E. Guido CIVIL ACTION - LAW NO. 2009-6767 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 Conciliator conducted a conciliation conference with legal counsel for the parties and Mrs. Coulson on December 3, 2010. Based upon that conference, the Conciliator recommends an Order in the form as attached. Date: December , 2010 a 0-5? Hubert X. ilroy, Esquire Custod onciliator