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HomeMy WebLinkAbout10-1423THOMAS D. GOULD, ESQUIRE 2 EAST MAIN STREET SHIREMANSTOWN, PA 17011 (717) 731-1461 ROBERT K. WELCH, JR., Plaintiff V. CHERYL F. WELCH, Defendant ( 2010 FEB 26 PH 4: 22 r? rs+vly IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10- 14a3 CIVIL TERM CIVIL ACTION - LAW CUSTODY ACTION CUSTODY COMPLAINT TO THE HONORABLE JUDGES OF SAID COURT: 1. The Plaintiff is Robert K. Welch, Jr. residing at 3517 Beech Run Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Defendant is Cheryl F. Welch who resides at 5964 Mashie Circle, North Port, Florida 34287. 3. Plaintiff seeks joint legal custody and partial physical custody of the following children: NAME PRESENT RESIDENCE DOB Zoe R. Welch 5964 Mashie Circle 04/01/2003 North Port, FL Broderick R. Welch 5964 Mashie Circle 03/07/2006 North Port, FL The children were born in wedlock. The children are presently in the physical custody of Cheryl F. Welch who resides at 5964 Mashie Circle, North Port, FL. $179.00 Pa nom (? (L11F 30(vrJ ? as8??9 The children have resided with the following persons and at the following addresses: Person Address Date Mother 5964 Mashie Circle 01/10 - present North Port, FL Mother & father 3517 Beech Run Lane 05/06 - 01/10 Mechanicsburg, PA Mother & father 2609 Seip Avenue 01/03 - 05/06 Easton, PA The mother of the children is Cheryl F. Welch who currently resides at 5964 Mashie Circle, North Port, Florida 34287. She is married. The father of the children is Robert K. Welch, Jr. who currently resides at 3517 Beech Run Lane, Mechanicsburg, Pennsylvania 17050. He is married. 4. The relationship of Plaintiff to the children is that of Father. The Plaintiff currently resides alone. 5. The relationship of Defendant to the children is that of mother. The Defendant currently resides with the following persons: Name RelationshiiD Joseph Ferrari Father Joan Ferrari Mother Zoe R. Welch Daughter Broderick R. Welch Son 6. Neither party has participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 2 Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: A. Plaintiff can properly care for his children. B. Plaintiff can provide a loving home. C. Plaintiff wants to be a significant part of his children's life. D. Plaintiff will encourage the children to have mutual respect for each parent and place their interests before his own. 8. Each parent whose parental rights to the children has not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff requests this Honorable Court to grant him joint legal custody and partial physical custody of his children, at times determined to be in the children's best interest. Respectfully submitted, 'Z.,.0, D- 4. Thomas D. Gould, Esquire ID #36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 3 . VERIFICATION I, Robert K. Welch, Jr., hereby certify that the foregoing CUSTODY COMPLAINT is true and correct to the best of my knowledge, 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. DATED: Z 26 _ l" -W"l Robert K. W lch, Jr. Plaintiff 4 ROBERT K. WELCH, JR. IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 2010-1423 CIVIL ACTION LAW CHERYL F. WELCH IN CUSTODY DEFENDANT ORDER OF COl1RT AND NOW, Tuesday, March 02, 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 Mam„Street,. Mechanicsburg, PA 17055 on Monday, April 05, 2010 at 10 30 AM for a Prc-Hearing Custody Conference. At such con'ferencc, an effort will be made to resolve the iss~~ies in dispute; or if this cannot be accomplished, to de'Yinc 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 enh~y 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 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 FURTI-I BELOW TO FIND OUT WHERE YOU CAN GET LEGAL I-{ELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 2010h~R _3 Ah 10: ~ i ~YLY 3 3 ~~ ~~ .~~~ ~ ~ ~~~~ ROBERT K. WELCH, JR., Plaintiff v. CHERYL F. WELCH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA N0. 2010-1423 CIVIL TERM CIVIL ACTION -LAW IN CUSTODY PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of the Defendant, CHERYL F. WELCH, in the above referenced custody matter. Respectfully Submitted, Mary a s, Esquire Saidis, Flower & Lindsay Attorney ID #84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Dated: ~~ ~ ~ ~ 1 ~ C N 'TtE~: ~~7 1 r ~-, ~ ' ,Ti . ~_ ~_ •_. ?, a.. ~ .~ ~ ~ ,, ,,. ~ g ,T~ ~ _~ Y _ <. _ ~ =`~" ~- ~ ~-; w ± SAIDIS, FLOWER Sz LINDSAY ~~.~w 26 West High Street Carlisle, PA