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HomeMy WebLinkAbout10-2387IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER LYNN, CIVIL ACTION Plaintiff ,. 11'T I -. RANDALL LEE LYNN, CUSTODY `== v Defendant COMPLAINT FOR CUSTODY 1. The plaintiff is Jennifer Lynn who currently resides at 1342 Kiner Boulevard, Carlisle, Pennsylvania 17015. 2.' The defendant is Randall Lee Lynn who currently resides at 16 S. High Street, Mechanicsburg, Pennsylvania 17055. 3. The plaintiff is seeking custody of the following children: Name Residence Age Jason Albert Lynn 1342 Kiner Boulevard Carlisle, Pennsylvania 14 DOB 10-12-1995 Samantha Marie Lynn 1342 Kiner Boulevard 7 Carlisle, Pennsylvania DOB 3-7-2003 During the past five years, the children have resided with the following persons and at the following addresses: (List all Persons) (List all Addresses) (Dates) Jennifer Lynn 1342 Kiner Boulevard 3/2010 Carlisle, Pennsylvania to present Jennifer Lynn and Randall 1342 Kiner Boulevard 1999 to Lee Lynn Carlisle, Pennsylvania 3/2010 The mother of the children is Jennifer Lynn. She is married, but separated. The father of the children is Randall Lee Lynn. He is married, but separated. 4. The relationship of plaintiff to the children is that of mother. The plaintiff currently resides with the following persons other than children: Christopher Lynn (parties' 18 year old son). 5. The relationship of defendant to the child is that of father. The defendant currently resides with the following persons other than the children: His mother. 6. Plaintiff has not participated as a party or witness or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. 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: Plaintiff has continuously performed parental responsibilities for the children and is willing and able to continue to act in the best interest of the children. Plaintiff has a strong relationship with the children. Plaintiff is in the best position to have primary custody of the children. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, plaintiff requests the court to grant her custody of the minor children. Sh9ki D. Coover, Fsquire .AAorney ID 92385 44 S. Hagover Street Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER LYNN, CIVIL ACTION Plaintiff V. RANDALL LEE LYNN, CUSTODY Defendant VERIFICATION I, Jennifer Lynn, hereby certify that I have reviewed the foregoing CUSTODY COMPLAINT and the averments contained therein are true and correct to the best of my knowledge, information and belief. I understand that I could be subject to the penalties of perjury for any false statements contained therein, both civilly and criminally, under Pennsylvania and federal law. "011L'1? JJennifep/Lynn/ -q-/v Date JENNIFER LYNN PLAINTIFF V. RANDALL LEE LYNN DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2010-2387 CIVIL ACTION LAW IN CUSTODY ORllEIt OF COURT AND NOW, Wednesday, April 14, 2010 _, upon consideration of the attached Complaint, it is hereby directed that pa--ties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carl-sle on Tuesday, May 04, 2010 at 10:30 AM for a Prc-Hearing 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 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 T'HE COURT, By: /s/ ac ueline M. Verne Es . Custody Conciliator ~T'he Court of Common Pleas of Clunberland 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 bl-siness 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 A"I"TORNF.:Y AT ONCE. 1F YOU DO NOT F~iAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR "TELEPHONE `fHE OFFICE SET FORTI-i BEL,OW TO FIND OUT WFIERE YOU CAN CiET LEGAL I-IELP. ~~~. C, umberland County Bar Association 3'? South Bedford Street _ '`- -`-~~' VV'~~ ~~ _. '~ ~ ~~ Carlisle, Pennsylvania 17013 ~~~ ~"'• ~;~ (~,,~ -~O ~ Telephone (7 l 7) 249-3166 ~'` _e., ~~~ ~~ _~ :~ ~~ ;t -; .~,L