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Home My WebLink About10-0406ALED-CIFi ,CC ?F THE FRU t.?rT STACY B. WOLF, ESQUIRE 2010 JAN 19 PM 1: 5 n ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 ±; ?1T/ 1 2414436 ? C?: {,-D' N ATTORNEY FOR PLAINTIFF TAMAZINE T. BROOKS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW SEAN M. BROOKS, : NO. 2010 - 5/04. CIVIL TERM Defendant : IN CUSTODY COMPLAINT FOR CUSTODY NOW comes the Plaintiff, Tamazine T. Brooks, by her attorney, Stacy B. Wolf, Esquire, and respectfully represents as follows: 1.) Plaintiff is Tamazine T. Brooks, (hereinafter "Mother"), an adult individual residing at 4807 East Trindle Road, Apt. 2, Mechanicsburg, Pennsylvania 17050. 2.) Defendant is Sean M. Brooks, (hereinafter "Father', an adult individual whose last known address is c/o Dennis & Cathy Brooks, 110 Renee Place, Staten Island, New York 10314. 3.) Plaintiff seeks an order establishing custody of the following child: Name Present Residence Age Izabella V. Brooks 4807 East Trindle Road, Apt. 2 3 years Mechanicsburg, PA 17050 D.O.B. 8/23/2006 4.) Plaintiff and defendant are the natural parents of the child. 5.) The child is presently in the custody of Plaintiff and has been since her birth. 6.) The child was born during the marriage of the parties. eke .zLS? ,?'?' a34. yA3 7.) Since the child's birth, the child has resided with the following persons at the following addresses: Persons : Address: Dates: Plaintiff 4807 East Trindle Road, Apt. 2 5/2009- present Mechanicsburg, Pennsylvania 17050 Plaintiff 78 White Dogwood Drive 7/2008 -5/2009 Etters, PA 17319 Plaintiff 171 West Vine Street, Apt. B 8/1/2007-7/2008 Shiremanstown, PA 17011 Plaintiff/Defendant 107 November Drive 2/2007-8/1/2007 Apartment 2 Camp Hill, PA 17011 Plaintiff/Defendant 2110 Logan Street 12/2006-2/2007 Camp Hill, PA 17011 Plaintiff/Defendant 10 21St Street 10/2006-12/2006 Camp Hill, PA 17011 Plaintiff/Defendant 2102 Market Street Birth-10/2006 Apartment 2 Camp Hill, PA 17011 8.) 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. 9.) Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 10.) 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. 11.) Mother has been the sole caregiver of the child since her birth. 12.) The best interests and permanent welfare of the child will be served by granting the relief requested herein. WHEREFORE, for the reasons set forth herein, plaintiff, Tamazine T. Brooks, respectfully requests that the Court enter an order granting primary physical custody and sole legal custody of the child to the plaintiff, along with any additional relief that the Court deems appropriate and just. Respectfully submitted, 2010 STACY OLF, ES Attorney r Plaintiff 10 West High Street Carlisle, Pennsylvania 17013 (717) 241-4436 Supreme Court I.D. No. 88732 VERIFICATION I do hereby verify that I am the plaintiff in the foregoing action and that the facts set forth in this complaint are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. 2009 Tamazine T. oks STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF TAMAZINE T. BROOKS, Plaintiff V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW SEAN M. BROOKS, : NO. 2010 - CIVIL TERM Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Stacy B. Wolf, Esquire, have served a true and correct copy of Complaint for Custody upon the following person and in the matter indicated: SERVICE BY U.S. MAIL: Sean M. Brooks c/o Dennis & Cathy Brooks 110 Renee Place Staten Island, NY 10314 WOLF & WOLF January4, 2010 STACY B. LF, ESQUIRE Attorney f r laintiff lj 10 West H h Street Carlisle, Pennsylvania 17013 (717) 241-4436 Supreme Court I.D. No. 88732 TAMAZINE T. BROOKS IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2010-406 CIVIL ACTION LAW SEAN M. BROOKS IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, January 22, 2010 _, 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 Monday, March 01, 2010 _ at 9:00 _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 ofa 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/ ohn . Man an r. 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 J {, s r r? FEB 2 ? zulU 6, 1 TAMAZINE T. BROOKS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 10-406 CIVIL ACTION LAW SEAN M. BROOKS, IN CUSTODY Defendant ORDER OF COURT AND NOW this -).< A day of February 2010, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. Legal Custody: The Mother, Tamazine T. Brooks, shall have sole legal custody of Izabella V. Brooks, born 08/23/2006. 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 subject to Father's physical custody/visitation as the parties mutually agree. 3. The Father shall have telephone contact with the Child as agreed to by Mother. 4. Holidays: The parents shall arrange the holiday schedule as mutually agreed upon. 5. 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. 6. During any periods of custody or visitation, the parties shall not possess or use illegal 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. 7. This Order shall not preclude Father from asserting his custodial rights when/if Father deems it appropriate by filing a Petition for Modification. 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. I 10Z Zvi 0 Di bution: Wolf, Esquire ,,-Se Brooks, 110 Renee Place, Staten Island, New York 10314 ohn J. Mangan, Esquire eoPr ?Y1`dtu TAMAZINE T. BROOKS, Plaintiff V. SEAN M. BROOKS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 10-406 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: The pertinent information pertaining to the Child who is the subject of this litigation is as follows: Name Date of Birth Currents in the Custody of Izabella V. Brooks 08/23/2006 Primary Mother 2. A Conciliation Conference was held with regard to this matter on February 24, 2010 with the following individuals in attendance: The Mother, Tamazine Brooks, with her counsel, Stacy Wolf, Esq. The Father, Sean Brooks, did not appear. 3. The undersigned recommends the entry of an Order in the form as attached. Date Jo J. gan, Esquire C tod Conciliator