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HomeMy WebLinkAbout09-7977 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA JENEEA M. DUNLAP, Civil Action At Law---Custody Plaintiff, Case No. pQ O v Z L VS. GEORGE E. PERRY, Defendant, COMPLAINT FOR CUSTODY 1. The plaintiff is Jeneea M. Dunlap, who currently resides at 500 Geneva Drive, Apt. B-6, Mechanicsburg, 17055 in the County of Cumberland Commonwealth of Pennsylvania. 2. The defendant is George E. Perry, whose address is currently unknown. 3. Plaintiff seeks custody of the following children: Name Address dob Age Khalil J. Perry same address as Mothers' 2/3/2006 3 Years 4. The child was born outside of wedlock. 5. The child is currently in the custody of Jeneea M. Dunlap, the biological mother, whose current address is 500 Geneva Drive, Apt. B-6 Mechanicsburg, PA. 17055. 6. Since, the childs' birth he has resided with the mother. 7. The biological mother of the child is Jeneea M. Dunlap, whose current address is 500 Geneva Drive, Apt. B-6 Mechanicsburg, PA. 17055. 8. The mother is separated from the father, and remains unmarried to the same. 9. The father of the child is George E. Perry, whose current address is unknown. 10. The father is separated from the Mother and remains unmarried to the same. 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 Khalil J. Perry Biological Son 12. The plaintiff has not participated as a party or witness, or in another capacity, in any 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 Children pending in a Court of this Commonwealth. 14. Plaintiff does not know of a person not a party to the proceedings who has Physical Custody of the child or claims to have custody or visitation rights with respect to the child. 15. The best interest and permanent welfare of the children will be served by Granting the relief requested for the reasons as hereinafter recited: (a) The mother has been the primary caretaker and caregiver to the child and has resided with his mother since birth where she has had a sense of stability and predictability and within which his physical and emotional needs were being fulfilled. (b) The defendant father has unilaterally, defiantly, and blatantly, refused to provide to mother his current physical address and has done so despite having had the child in his custody. (c) The father, has caused mother much distress to the extent that on those limited occasions when father has had custody of the child, he the child, has returned from the fathers' custody smelling of marijuana which the mother has herself witnessed 1 01 the father indulging in several years ago and which she believes he continues to partake of in the presence of the child. (d) The father, has prevented the mother from knowing of his physical address while during those periods when he has had custody of the minor child and has refused to answer any telephone calls from mother precipitated by her desire to discern of the childs' physical whereabouts. (e) The mother suspects that the father lacks suitable living accommodations to properly safeguard the childs' physical and emotional well being. The child has informed the mother that subsequent to his overnight with his father that he did not have his own bed and had to sleep with his father and his step-sister in the same room and bed. (f) Plaintiff, believes and therefore avers that she can continue to provide a predictable and stable lifestyle for which, the child has become accustomed and one that will continue to be in the best interest of the child during his formative years and throughout his life. WHEREFORE, Plaintiff, Jeneea Dunlap, respectfully requests for the aforementioned reasons, that the court grant and award her primary physical custody of the minor child Khalil J. Perry GREGORY S. HAZLETT GraCorv/S. HaAW,, Wuire i7'W Main St? M anicsburg, PA. 17055 Phone: (717) 790-5500 Attorney for Plaintiff 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: rf J eea M. Dunlap, Plai tiff 4 FILID' ^..P' 7F r- U !' X17 w T 2039 ttlov 16 Fri ?, ?/4s. so ?cL flay i Y 2?- a3 2 lm-3 JENEEA M. DUNLAP IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-7977 CIVIL ACTION LAW GEORGE E. PERRY IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, November 20, 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 _ Monday, December 14, 2009_ at 10:30 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/ faequeline M. Verney, Es _ 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 ry Flip: _LE 20G9 NOV 23 PH 12:55 Irv,- ; ? . l JUL 12 2010 JENEEA M. DUNLAP, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : N0.2009-7977 CIVIL ACTION -LAW GEORGE E. PERRY, Defendant : IN CUSTODY -v i;- ~- ~ ~- -,, "T l ~ :.c - ORDER OF COURT '''' `- ~ ' `~;` AND NOW, this 9th of July, 2010, having no contact with the parties for more than ninety days to reschedule a Conciliation Conference, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, ~L~ ~ acq line M. Verney, Esquire, C tody Conciliator