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HomeMy WebLinkAbout09-6773IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA LAUREN R. ADAMS, Civil Action At Law---Custody Plaintiff, Case No. 6Q VS. JOSEPH W. MCCONNELL., . Defendant, COMPLAINT FOR CUSTODY 1. The plaintiff, Lauren R. Adams, is an adult individual, sui juris, currently resides at 1119 North Pitt Street, Carlisle, 17013 in the County of Cumberland, Commonwealth of Pennsylvania, 2. The defendant is Joseph W. McConnell and adult individual, sui juris who is currently residing at 2 Pearl St. Harrisburg, 17019 in the County of Dauphin, Commonwealth of Pennsylvania, 3. Plaintiff seeks custody of the following child: Name Address DOB Age Brydon M. McConnell. same as mother's 4/29/2009 6 months 4. The child was born outside the bonds of matrimony. 5. The child is in the custody of the plaintiff, mother and residing at 1119 North Pitt St. Carlisle, PA. 17013 6. Since April 29th, 2009 the child has resided with the Mother exclusively at 1119 N. Pitt St. Carlisle, PA. 17013. 8. The mother is separated from the father and currently remains unmarried to the same. 9. The father of the child is Joseph W. McConnell, who is currently residing at 2 Pearl St. Harrisburg, PA. 17019 in the County of Dauphin, Commonwealth of Pennsylvania, 10. The father is separated and remains unmarried to the mother. 11. The relationship of the plaintiff to the child is that of a biological Mother. The Plaintiff currently resides with the following persons: Name Relationship Brydon M. McConnell Biological Son 12. The plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 13. The plaintiff has no other information of a custody proceeding concerning the child Pending in a Court or any other court in the commonwealth. 14. The best interest and permanent welfare of the child will be served by Granting the relief requested because: (a) The mother has and can continue to provide a stable, predictable and permanent environment for the child within which the child will enjoy a sense of stability. (b) The plaintiff mother, has been, and continues to be the primary provider and caregiver of the child since the childs' birth on April 29th, 2009. (c) The father frequently indulges in marijuana and has been inebriated while the child was in his presence. (d) The father has declined mothers' invitations to visit his son at her home and has demonstrated little interest in maintaining contact with the child since his birth. (e) The father does not have a stable residence and co-habitats with fourteen (14) other individuals in a single residence that lacks the space to separately accommodate an infant child. (f) The mother has and continues to provide all necessities relative to the childs' emotional, physical, and psychological needs and provides a stable, predictable, and consistent home environment wherein the child feels a sense of comfort and permanency. (g) Plaintiff, believes and therefore avers that she can continue to provide a predictable and stable lifestyle which will be in the best interest of the child during his formative years and throughout his life. WHEREFORE, Plaintiff, Lauren R. Adams, respectfully requests for the aforementioned reasons, that the court grant and award her primary physical custody of the child Brydon M. McConnell. Dated: / I / GREGORY S. HAZLETT VERIFICATION 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 Date• t? 4V auren W.Ams, laintif JU Phone: (717) 790-5500 +t? SflC ?. f..;^ ,IOTA l? 2009 OCT 1 2 f ti)l 10: 4 2 G a! Crl.? 76 ?yzaia z, -LL K-= :7 a3tgs8 LAUREN R. ADAMS IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-6773 CIVIL ACTION LAW JOSEPH W. MCCONNELL IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, October 16, 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 Friday, November 20, 2009 at 2:30 PM 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/ John. 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 ?F THE "L TARP 2009 OCT 20 Pilo 2: 2 -j" ;.,ate. AV'