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Home My WebLink About10-1011• FILED-O T-:' H11t"XAqy 20 10 FEB -8 FiN 3: 23 LAW OFFICES OF DILS & DILS DIANE M. DILS, ESQUIRE Attorney I.D. No. 71873 1400 North Second Street Harrisburg, PA 17102 Telephone No. (717) 232-9724 Attorney for Plaintiff, Amanda Greene cull ? AMANDA GREENE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. :NO. 10 - 1011 O'ivit term RICHARD GREENE : CIVIL ACTION - LAW Defendant :CUSTODY COMPLAINT FOR SHARED LEGAL AND PRIMARY PHYSICAL CUSTODY AND NOW, this day of February, 2010, comes the Plaintiff, Amanda Greene, by her attorney, Diane M. Dils, Esquire, and respectfully avers the following: 1. The Plaintiff is Amanda Greene, an adult individual currently residing at 712 Quaker Circle, Apartment 6, Lewisberry, York County, Pennsylvania 17339. 2. The Defendant is Richard Greene, an adult individual currently residing at 1374 Old Willow Mill Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. $1 `iq . OO Pp Airy 1 Cky 35 3(o M* 3. The Plaintiff and Defendant were married on June 24, 2007. 4. Plaintiff and Defendant are the natural parents of one child; namely, Richard Bryant Greene, born November 14, 2007 in Camp Hill, Pennsylvania. 5. The minor child has resided with the Plaintiff, Amanda Greene, at the above address since approximately October, 2009; however, the minor child resided at 66 Sunset Drive, in Mechanicsburg, Pennsylvania from his date of birth until October 1, 2009. It is suggested that Cumberland County is the home County and maintains jurisdiction of this custody matter. 6. Plaintiff believes the best interest of her son will be served by granting shared legal custody between the parties and primary physical custody of the minor child, Richard Bryant Greene, in the Plaintiff. 7. The Plaintiff has not participated as a party or witness in any capacity in other litigation concerning the custody of the minor child in this or any other Court. 8. The Plaintiff has no information of the custody proceedings concerning the child pending in a Court of this Commonwealth or any other state. 9. The parties had signed an Agreement in December, 2009 wherein the minor child would visit with the father three days a week in the home of father's parents with no overnight visitations. 2 10. Approximately one week ago was the first time father visited with his son without overnights. 11. Father became aware that mother had moved on with her life over the last few days, became irate and unreasonable and told mother that he was taking the child. 12. Mother is fearful that father will take the child and not return him to her. 13. The 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. WHEREFORE, the Plaintiff, Amanda Greene, respectfully prays your Honorable Court to grant her primary physical custody of her son with shared legal custody between the parties. Respe lly?ubmitted, B , lane M. s, Esquire 1400 North Second Street Date First Floor, Front Harrisburg, PA 17102 (717) 232-9724 I.D. No. 71873 3 VERIFICATION COMPLAINT FOR SHARED LEGAL I verify that the statements made in this AND PRIMARY PHYSICAL CUSTODY are true and correct. 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. AMANDA GREENE Date: February 3, 2010 AMANDA GREENE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 2010-1011 CIVIL ACTION LAW RICHARD GREENE FN CUSTODY DFFF:NDANT ORDF,R OF COURT AND NOW, Frid~, February 12, 2010 __ _, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. ,the conciliator, at 39 West Main Street, Mechanicsbur , PA 1.7055 on Thursday, March 18, 2010___ at 10:30_AM _._. for a Prc 1-Tearing 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 P,rormds 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/ ___ Dawn S. Sunda Es . Custody Conciliator "fhe Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information aboti-t accessible facilities and reaso~7able 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 FORTF-1 BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 170 ] 3 Telephone (717) 249-3166 F~l~[)--L;-r~Uc 2~f~ FEB 15 °~ 12~ t+ I .uv~l~~ ~ -/G -ice ~v~ H+~w~e' ~ ~,~~ c.a% 5 AMANDA GREENS vs. RICHARD GREENS IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA 2010-1011 CIVIL ACTION LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of ~GC GL S ~ 2010, upon consideration of the attached ustody Conciliation Report, i ordered and directed as follows: 1. The prior Order of this Court dated March 30, 2010 shall continue in effect as modified by this Order. 2. The parties shall participate in a course of therapeutic family counseling with a professional selected by agreement. The purpose of the counseling shall be to assist the parties in addressing family issues and in developing sufficient communication and cooperation to enable them to effectively co- parent their Child. The costs of the counseling shall be shared equally between the parties. The parties shall select the counselor and contact the counselor's office within two weeks of the date of the custody conciliation conference to schedule the initial sessions. 3. Paragraph 2D of the March 30, 2010 Order shall be modified as follows: The Father shall have custody of the Child every week from Tuesday at 3:30 p.m. through Thursday at 9:00 p.m. 4. This Order is entered pursuant to an agreement of the parties at 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. BY THE COURT, A bert H. Masland J. (7 ~^a t: ~ .` ~' cc: Mark F. Bayley, Esquire -Counsel for Father -~,,'` ~ ~ 7 Diane M. Dils, Esquire -Counsel for Mother ~i' ='" ~`' c~ ~, , ~ ~=} ~ ~. _ ~, - '64 c-. AMANDA GREENE Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2010-1011 CIVIL ACTION LAW IN CUSTODY vs. RICHARD GREENE Defendant Prior Judge: Albert H. Masland CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Richard Bryant Greene November 14, 2007 Mother 2. A custody conciliation conference was held on July 29, 2010, with the following individuals in attendance: the Mother, Amanda Greene, with her counsel, Diane M. Dils, Esquire, and the Father, Richard Greene, with his counsel, Mark F. Bayley, Esquire. 3. The parties agreed to entry of an Order in the form as attached. ~~ 30 . a v i v Date Dawn S. Sunday, Esquire Custody Conciliator