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HomeMy WebLinkAbout10-1388 Amanda G. Henderson Address 1608 Locust Street New Cumberland, PA Dates 12-24-08 to present 6. The mother of the child is currently residing at her parents' home at 1608 Locust Street, New Cumberland, PA. She is single. +17q' o0 Pp eW &8(01 e.138 051 RYAN P. BALL, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ID - ISM 0.1m l Tar % CIVIL ACTION - LAW CUSTODY AMANDA G. HENDERSON, Defendant n - COMPLAINT FOR CUSTODY C:J `r7 rr _ , 1. Plaintiff is Ryan P. Ball, residing at 801 Elkwood Drive, New Cumberland, - rl 17, PA 17070 Cumberland County . , 2. Defendant is Amanda G. Henderson, residing at 1608 Locust Street, New Cumberland, PA 17070. 3. 4 Plaintiff seeks custody of the following child: Name Present Address Date-of-Birth Quinn Wayne Henderson 1608 Locust Street New Cumberland, PA 12-24-08 The child was born out of wedlock. The child is presently in the custody of Mother, residing at 1608 Locust Street, New Cumberland, PA 17070. 5. During the past five (5) years, the child has resided with the following persons the following address(es): Name 7. The father of the child is currently residing at 801 Elkwood Drive, New Cumberland, PA. He is single. 8. The relationship of Plaintiff to the child is that of natural Father. Plaintiff currently resides with the following person(s): Name Angela Kelly Relationship Mother 9. The relationship of Defendant to the child is that of natural Mother. Defendant currently resides with the following person(s): Name Relationship Daniel Henderson Father Barbara Henderson Mother Emily Henderson Sister Quinn Henderson Son 10. Plaintiff has not participated as a parry or a witness, or in any other capacity in other litigation concerning the custody of the child in this or any other Court. 11. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 12. 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. 13. The best interest and permanent welfare of the child will be served by granting the relief requested as follows: .r a. Plaintiff Father has been actively involved in his son's life through prenatal care and during his birth and has had regular consistent periods of partial custody since his birth; and b. Plaintiff Father loves the minor child and wishes to have more periods of partial physical custody with the child, and c. It is in the best interest and permanent welfare of the child that he have additional periods of physical custody with the child. d. Mother repeatedly threatens to deny Father contact with the child and has denied contact and it is in the child's best interest and permanent welfare to have regular contact with his Father. 14. 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. WHEREFORE, Plaintiff requests the Court to grant him shared legal and shared physical custody of the minor child, Quinn Wayne Henderson. Respectfully submitted, HARRISON CLOU Date: Joanne"Iarrison Clough, ] Attorney ID No.: 36461 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Ryan P. Ball VERIFICATION I, Ryan P. Ball hereby verify and state that the facts set forth in the foregoing pleading are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn verification to authorities. DATE: ? ' l 3 -10 - i &?& Ryan P. Ball RYAN P. BALL IN THE COURT OF COMMON PLEAS OF Pi.AINTIFF CUMBERLAND COUNTY, PE:NNSYLVAN[A V. AMANDA G. HENDERSON DEFF•,NDANT ZO10-1388 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, __ ,Tuesday, March 02, 2010 __, upon consideration of the attached Complaint, if 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, Apr~1.05, 2010 at 10:30 AM for aPre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issuc;s 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 ~~nay 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/ 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 oftice. All arrangements m~~ist 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. 1F YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTFI BELOW TU FIND OUT WI~IERE YOU CAN GET LEGAL E-IELP. Cumberland County Bar Association 3? South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 r?F ?HE ~Q rQ~7TARY Z~~a M~~ -s ah ra s2 PEN~~;SY~y;~lv1A