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HomeMy WebLinkAbout10-1519 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CHRISTINA L. SEIBERT, Plaintiff ) n o -0 W V. No- 3 5- AARON M. MCCAUSLIN, ) Defendant ) ];; 0 COMPLAINT FOR CUSTODY 1. Plaintiff is CHRISTINA L. SEIBERT, who resides at 24 Regency Woods North, Carlisle, PA 17015. 2. Defendant is AARON M. MCCAUSLIN, who resides at 239 3Rd Street, East Berlin, PA 17316. 3. Plaintiff seeks custody of the following child: Name Age Was child born out of wedlock? Hunter G. Mccauslin 9 years Yes 4. The child is presently in the custody of Plaintiff who resides at 24 Regency Woods North, Carlisle, PA 17015. 5. During the past five years, the child has resided with the following persons and at the following addresses: From To Address With whom APR, 2007 (Still living 24 Regency Woods North Plaintiff, mother; Fisher there) Carlisle, PA 17015 Mccauslin-brother Michael Keister-mother's fiance MAY, 2005 APR, 2007 Betty Nelson Court Christina Seibert-mother Carlisle, PA 17013 Fisher Mccauslin-brother Thomas Shields Jr- mother's ex-boyfriend 179.00 rv• pf M. o -* S i// y?2 01? pt* Complaint Page 3 of 5 6. The mother of the child is currently residing at 24 Regency Woods North, Carlisle, PA 17015. She is single. 7. The father of the child is currently residing at 239 3Rd Street, East Berlin, PA 17316. He is single. 8. The relationship of Plaintiff to the child is mother. Plaintiff currently resides with the following persons: Name Hunter G. Mccauslin Michael A. Keister ltrparFisher M. Mccauslin Relationship to Plaintiff' child fiance son 9. The relationship of Defendant to the child is father. Defendant currently resides with the following persons: Name Mary Mccauslin Relationship to Defendant mother 10. 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. 11. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 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 because Child has always resided with mother. Defendant has had visitation with his son in the past up until the child came home and said his father was mean to him. He says his father smacked him across the face when the child asked his father to bring him home to his mother. Child does not want to see or speak to his father. Defendant has made numerous text messages and voice messages threatening to take the child and never bring him back. 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. Complaint Page 4 of 5 WHEREFORE, Plaintiff requests the Court to grant custody of the child to Plaintiff. , ? • 361t\J::? cviucVq-0- CHRISTINA L. SEIBERT, Plaintiff Verification I, CHRISTINA L. SEIBERT, Plaintiff, verify that the facts stated in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. Petitioner understands that false statements therein are subject to the penalties of 18 Pa. C.S.A. ' 4904 relating to unworn falsification to authorities. Date: A__ `t iD Oa?rk CHRISTINA L. SEIBERT, Plaintiff Complaint Page 5 of 5 CHRISTINA L. SEIBERT IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. AARON M. MCCAUSLIN DEFLNDANT • 2010-1519 CIVIL ACTION LAW 1N CUSTODY ORDER OF COURT AND NOw', Wednesday, March 10, 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 Coun Courthouse, Carlisle on Friday, March 26, 2010 at 8:30 AM for aPre-Hearing Custody Conference. At such conference, an effort will he 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 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/ Hubert X. Gilro 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 ho~~irs 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 A"I' 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 C ounty Bar Association 3? South Bedt~~rd Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 c;r.. ~,r ~, :~:- . 2014I~~IZ I I ~~EE~i i! ~ I ~ „, GL~~~,~; '~,~~~;,