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HomeMy WebLinkAbout10-2828JANE ADAMS ATTORNEY AT LAW Attorney I.D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 esgadams@gmail.com ----------------------------------------------- CHESTER H. TAYLOR and ELAINE J.TAYLOR, Plaintiffs vs. TOMICA M. JOHNSON, and JEROME S. GUISE, Defendants 2at0 PZ 26 FM 2: 02 L ,,;t.ajlV 1 ! IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. /0- 30 ? Civil Term IN CUSTODY CIVIL ACTION - LAW CUSTODY COMPLAINT 1. Plaintiffs are Chester H. Taylor and Elaine J. Taylor, (hereinafter referred to as "Grandparents"), who currently reside at 22 Cobblestone Drive, Carlisle, Cumberland County, Pennsylvania, 17015. 2. Defendants are Tomica M. Johnson, (hereinafter referred to as "Mother"), whose address is 405 N. Baltimore Ave., Apt. #3, Mount Holly Springs, Cumberland County, Pennsylvania, 17065, and Jerome S. Guise, (hereinafter referred to as "Father"), whose address is 358 Sterline Run Road, Driftwood, Pennsylvania, 15832. 3. Petitioners are the grandparents of the following children, are in loco parentis to the following children, and seek a custody order regarding the following children: NAME DOB/AGE ADDRESS Kayla Nicole Guise 7/15/2006 22 Cobblestone Drive Carlisle, Pa. 17015. Wyatt Lee Guise 2/1212008 22 Cobblestone Drive Carlisle, Pa. 17015. Defendants are the natural parents of the children. Grandparents have primary physical custody of the children and are in loco parentis to the children. During the past five years, the children have resided with the following persons and at the following addresses: &zw ?5-z/5 Rlzv?661b ? NAME ADDRESSES DATES Chester H. Taylor Elaine J. Taylor 22 Cobblestone Drive Carlisle, Pa. 17015 12/31/2009 - present Tomica M. Johnson 405 N. Baltimore Ave 2006 - 12/31/2009 The mother of the children is Tomica M. Johnson. She currently resides at 405 N. Baltimore Ave., Apt #3, Mount Holly Springs, Pa. 17065. She is twenty-seven years old and she is not married. The father of the children is Jerome S. Guise. He currently resides at 358 Sterline Run Road, Driftwood, Pa. 15832. He is twenty three years old and he is not married. 4. The relationship of plaintiffs to the children is that of maternal grandparents. The plaintiffs currently reside with the children. 5. The relationship of defendants to the children is that of Natural Father and Natural Mother. 6. Plaintiffs have 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. Plaintiffs have information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. Plaintiffs do 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 child will be served by granting the relief requested because: Mother left the children in maternal rand parents care on December 31, 2009. Since that time the have been the primary care fivers for the children. The children are doin well in their care. Father has not requested or filed for custody. Grand arents are re uestin a court Order that confirms that the share in le al custody. and confirms that they have primary physical custody Such an Order would be in the best interest of the children because it would enable the rand arents to rovide for the children's medical and educational needs and would ensure stabili for the children. t 8. Each parent whose parental rights to the children has not been terminated and the person who has physical custody of the children has been named as parties to this action. WHEREFORE, Plaintiff requests the court to enter a custody order regarding the children. Respectfully submitted, Date: Y/- )?// 6 ne Adams, Esquire D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF VERIFICATION I verify that the statements made in this Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: Cv--- 1D ? - ? ??' y - Chester Taylor, PlaintiffDate: -/ lame Taylor, intiff CHESTER H. TAYLOR AND ELAINE J. IN THE COURT OF COMMON PLEAS OF TAYLOR PLAIN~rIFF CUMBERLAND COUNTY, PENNSYLVANIA v' 2010-2828 CIVIL ACTION I.~AW TOMICA M. JOHSON AND JEROME S. GUISE TN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, May O5, 2010 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, June 03, 2010 at _8:30 AM toy a Pic. I~-Tearing C ustody Conference. At such co~~~ference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to he heard by the court, and to enter i~~~to a temporary order. Failure to appear at the conference may provide gro~mds for entry of a temporary or permane~~~t 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'I'HE COURT, By: _ /s/ .~c~ueline M. Verney, E.__s ~~tJ ____ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans w-ith Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available ro 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 1-IAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPF-{ONE TETE OFF:E ~_[' FOKTH BF:L,OW TO F1ND OUT WHERE YOU CAN GF.T LEGAL HEi,P. ~=' ~' r O C~.t'~ M~`~ Cumberland County I3ar Association -::; `~ `~ I ~ 32 South Bedford Street c~.n ~Q.~(LS Carlisle, Pennsylvania 17013 ~~~ ~ -~ ~'~ Tele hone (717) 249-3166 ~"° 5 • ~-/d cc~P '~~gcec~ In 1/u- n e~.'s ~Si le . -T~ --r T a; -. t , •, i=~ __~ Jl .~ MAY ? 6 ?_010 CHESTER H. TAYLOR and ELAINE J.TAYLOR, Plaintiffs vs. TOMICA M. JOHNSON, and JEROME S. GUISE, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2010 - 2828 Civil Term IN CUSTODY CIVIL ACTION -LAW ORDER AND NOW, this ~~~,~ day of '~~ = `~ , 2010, having reviewed the attached agreement between the parties, it is hereby ORDERED and DECREED that the stipulation entered by the parties on May 20, 2010, shall be entered and incorporated into this Order of Court. cc: ~ Jane Adams, Esquire ~ Tomica M. Johnson, mother ~rome S. Guise, father sl~7~rd cn ^ `; ;- _ K~ ~ r i ~ s ~ ~ ~,-; __ ~" ~ ' - ,~, = _ ;. .~ ,{ N BY THE COURT: MAY 2 ~ 2010 CHESTER H. TAYLOR and ELAINE J. TAYLOR, Plaintiffs V. TOMICA M. JOHNSON and JEROME S. GUISE, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2010-2828 CIVIL ACTION -LAW IN CUSTODY C . ~;;, ri'"i ~ _, d ORDER OF COURT ~~` ~~ rv ``' x:~~ __ s~ --~ AND NOW, this 26th day of May, 2010, being advised that the parties have ~' reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, .~ ---~ . cqu ne M. Verney, Esquire, Custody onciliator _~ -; f"T'? -~, -,,, ,_, °~'