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Home My WebLink About10-0841T1 .r 4, _ jt 1Y JESSICA CRESPO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law No. t0 841 0wi1Tt°rK WARREN BENNETT, Defendant COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, Jessica Crespo, by and through her counsel, Michael J. Whare, Esquire and avers as follows: 1. Plaintiff is Jessica Crespo, who currently resides at 307 B North Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Warren Bennett, who currently resides at 8 Robert Lane, Carlisle, Cumberland County, Pennsylvania 17013. : IN CUSTODY 2013 FEB -2 ; t l 12". ; 3. Plaintiff seeks primary physical custody of Name Primary Residence DOB Adrian Bennett The child was born out of wedlock. 307 B North Pitt Street Carlisle, PA 17013 07/17/04 1'T?t-00 Pp A7Tf (o(o(o k'" 37 i t o 0 The child is presently in the custody of Jessica Crespo, mother, who resides at 307 B North Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. Since birth, the child has resided with the following persons at the following addresses: Name Addresses Dates Mother 307 B North Pitt St birth-present Carlisle, PA 17013 The mother of the child is Jessica. Crespo, who resides at 307 B North Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. She is not married. The father of the child is Warren Bennett, who resides at 8 Robert Lane, Carlisle, Cumberland County, Pennsylvania 17013. He is not married. 4. The relationship of the Plaintiff to the child is that of natural mother. The Plaintiff currently resides with the following persons: Name Adrian Bennett Relationship Son 5. The relationship of the Defendant to the child is that of natural father. The Defendant currently resides with the following persons: Name Eve Bennett Warren Bennett, Sr Relationship Mother Father 6. 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. 7. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 8. 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. 9. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: N s Address Basis of Claim None 10. The best interest and permanent welfare of the child will be served by granting the relief requested because: a) Plaintiff has undertaken and performed the primary physical responsibilities for the child. b) Plaintiff is best able to provide the care and nurture which the child needs for healthy development. c) A Court Order of custody and structured visitation is desired so that Plaintiff and child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion. WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant her Complaint for primary physical custody of the child. Respectfully submitted, I'll Date: 00?? Michael J. Whpfe, Esquire 37 East Pomfret Street Carlisle, PA 17013 Supreme Ct. Id No. 89028 Attorney for Plaintiff JESSICA CRESPO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law WARREN BENNETT, Defendant : No. : IN CUSTODY 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 unworn falsification to authorities. Date: aU? - -011--)--.-,1'.'2 C) Jessi respo, Plaintiff JESSICA CRESPO IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. WARREN BENNETT [)EFENDANT • 2010-841 CIVIL ACTION LAW W CUSTODY 012UER OF COt112T AND NOW, ____ _ Thursday, February 04, 2010 ,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 Thursday, March 04, 2010 at 8:30 AM for aPre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot he 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 temporar~~ 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 hearini;. FOR T'HE COUR"I', By: /s/ Hubert X. Gilroy 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 FORTI{ BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland C ounty Bar Association 33 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 OF 20lfl FEB -t~ PM !2: 3 ~ CUM r..;~a~~u t,~~.,lf'VE'Y PEI`~I~`S~LG~~~1lA . , MAR o ~ zo~u~, ~ JESSICA CRESPO, Plaintiff vs. WARREN BENNETT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2010-841 IN CUSTODY COURT ORDER c w `= °rJ c-n - ~ ~ , ~ r, n ~- ,; ~ rn --~ s, `= , rah -~•_ ~ `"~ ~ :. ~ , ; I : i i ~ I - ~ `-i ~ ~ w c~ -. "~ NOW, this ~ day of March, 2010, upon consideration of the attached Custod Y Conciliation Report, it is ordered and directed that the following TEMPORARY Order is issued: 1. The mother, Jessica Crespo, and the father, Warren Bennett, shall enjoy shared legal custody of Adrian Bennett, born July 17, 2004. 2. The Mother shall enjoy primary physical custody of the minor child. 3. The Father shall enjoy periods of temporary physical custody as follows: A. On alternating weekends from Friday at 5:00 p.m. until Sunday until 6:00 p.m.; B. On the week following Father's weekend custody, Father shall also have custody of the child on Tuesday and Wednesday evenings from 3:30 p.m. until 6:30 p.m.; C. On the week following the weekend when Mother has custody, Father shall have custody of the minor child from 3:30 p.m. until 6:30 p.m. on Monday and Wednesday; D. At such other times as agreed upon by the parties. 4. This Order is a TEMPORARY Order issued based upon an agreement of the parties at the custody conciliation conference. The parties shall attend a second custody conciliation conference on Thursday, May 6, 2010, at 9:30 a.m. At that time and in the event the parties are unable to reach an agreement, the Conciliator shall schedule this matter for a hearing before the Court. At said hearing, either party may advance a different custody arrangement and the schedule set forth above shall not bind either party at said hearing. 5. It is noted that the Mother will have custody the week of March 28`~ through Easter on April 4`h . However, Mother shall provide Father with make-up time for the evenings he will miss during that week and, additionally, if Mother must leave early on Sunday for the trip out of town, she will provide Father with additional time to make up for that Sunday. BY THE COURT, Judge cc: ~chael J. Whare, Esquire ,•1'~Ir. Warren Bennett JESSICA CRESPO, Plaintiff vs. WARREN BENNETT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2010-841 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 pertinent information pertaining to the child who is the subject of this litigation is as follows: Adrian Bennett, born July 17, 2004 2. A Conciliation Conference was held on March 4, 2010, with the following individuals in attendance: the mother, Jessica Crespo, who appeared with her counsel, Michael Whare, and the father, Warren Bennett, who appeared without counsel. 3. The parties agree to the attached TEMPORARY Order. Date: March ~ , 2010 Q Hubert X. Gilroy, Esquir Custody Conciliator JESSICA CRESPO, Plaintiff vs. WARREN BENNETT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2010-841 IN CUSTODY ORDER r? ' ? ::$ G7 AND NOW, this day of December, 2012, the Conciliator being advised the parties are working things out between themselves and no longer desire to have a Custody Conciliation Conference, the Conciliator relinquishes jurisdiction. cl-'? " Hubert X. Gilroy, Es ire Custody Conciliato