HomeMy WebLinkAbout01-0589Colin Jeffrey LeVert
Plaintiff
Vo
Christine A. Hodge
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. S 200L- ~pq ~ T~_
CIVIL ACTION - LAW
CUSTODY ACTION
PA
CUSTODY COMPLAINT
The plaintiff is Colin Jeffrey LeVert
611 Reily Street Harrisburg PA 17105
(717) 257-4445 ; (717) 257-4440
at
PA
and at work is
, Dauphin
(home phone) (work phone)
2. The defendant is Christine A. Hodge
148 North West Street Carlisle PA 17013
His phone number at home is
N/A
residing
County,
residing
,Cumberland County,
N/A
3. Plaintiff seeks custody of the following
child/ten:
Name
Lamar Parrish Hodge
Present Residence Date of Birth
148 North West Street Carlisle PA 17013 09/06/84
The child/ten are presently in the
Richard Hodge who resides at
1356 Grand View Court Carlisle PA 17013
The child/ren were born in/~ of wedlock.
custody of
, PA.
5. During the past five years,
resided with the following persons and at
addresses:
the child/ren have
the following
Helena Davis (Deceased)
Addresses
154 West North St.
151 North St.
Dates
10/84 - 5/00
Janina Yvette Hodge
The mother of the child/ren is ,
currently residing at Atlan/a GA PA.
She is ~/married.
6. The relationship of plaintiff to the child/ren is
that of Mother/~.
following persons: N/A
Name
The Plaintiff currently resides with the
RelationshiD
that
7. The relationship of defendant to the child/ren is
Grand
of Father/~. The defendant currently resides with the
following persons:
N/A
Relationship
Male Companion
8. Plaintiff has not participated as a party or
witness, or in another capacity, in other litigation concerning
the custody of the child/ren in this or another court.
Plaintiff has no information of a custody proceeding
concerning the child/ren 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 child/ren or claims
to have custody or visitation rights with respect to the
child/ren.
If any of the above are not true, cross it out and
explain: The Defendant is the Grandmother Great Grandmother who had
physical custody passed away in May 2000 current custody of child is unknown
9. The best interest and permanent'welfare of the
child/ren will be served by granting the relief requested because
Paternal Father is presently the only Parent residing in State (PA)
The child needs Supervision Its to the child best welfare he reside w/ his
Father (Parent)
10. Each parent whose parental rights to the child/ren
have not been terminated and that person who has physical custody
of the child/ten have been named as parties to this action.
WHEREFORE, pursuant to the Custody Act, 23 Pa.
C.S. Section 5301, e__t seq., Plaintiff requests the court to grant
me ~OJ~/visitation of the child/ren.
I verify that the statements made in this Complaint are
true and correct. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. §4901 re~at~n~ to
unsworn falsification to authorit~s.
January 24, 2001 ef LeVert
Date Plaintiff, Pro Se
(717) 257-4445 257-4440
Phone Number
Colin Jeffrey LeVert
Plaintiff
Christine A. HodRe
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY ~ PENNSYLVANIA
: NO. S 2001 ~ ~ -
CIVIL ACTION - LAW
CUSTODY ACTION
ORDER GRANTING LEAVE TO PROCEED IN FORMA PAUPERIS
~ NOW, this 24 day of 3anuary
, 2001 , upon presentation and consideration of the
within petition and attached Certification, we 9rant the relief
prayed for, and grant Petitioner leave to proceed with this case
in forma pauperis, without the need to pay any costs connected
therewith, all of which is pursuant to Pa.R.C.P. No. 240.
BY T~ COURT:
,J.
Colin Jeffrey LeVert : IN THE COURT OF, COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PEI'~SYLV32~IIA
v. : NO. S 200
Christine A, Hodgo : CIVIL ACTION - MW
Defendant : CUSTODY ACTION
PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS
TO THE HONORABLE JUDGES OF SAID COURT:
Pursuant to Pa. R.C.P. No. 240, I hereby certify that I
am without financial resources to pay the costs associated with
my custody case, and therefore believe that I am entitled to
proceed in forma pauperis. In support of my petition, I have
attached to it a certification of indigency and incorporate it
herein by reference, a certification which fully and truthfully
describes my overall financial condition at the present time.
W~REFORE, the undersigned asks leave of court to
proceed in forma pauperis, without the need to pay any costs in
connection with the instant custody/visitation action.
R~ectfully submitted/ { __
Colin Jeffrey LeVert
January 24, 2001
Date
Petitioner, Pro Se
Colin Jeffrey LeVert
Plaintiff
Christine A. Hodge
Defondant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 200_
CIVIL ACTION - LAW
CUSTODY ACTION
CERTIFICATE OF II~DIGENCY
1. I am the (p~) (defendant) in the above
matter and because of my financial condition am unable to pay the
fees and costs of prosecuting or defending the action or
proceeding.
2, I am unable
my family and associates,
3, I represent
to obtain funds from anyone, including
to pay the costs of litigation.
that the information below relating to
my ability to pay the fees and costs
(a) Name:
Address:
(b)
is true and correct:
Colin Jeffrey LeVert
611Reily Street (Bethesda Mission)
HarrlsburR PA 17105
Social Security Number: 378-66-5034
Employment
If you are presently employed, state
Employer: N/A
Address:
Salary or wages per month:
(c)
Type of work: Accountant
If you are presently unemployed, state
Date of last employment :
4/00
Salary or wages per month: N/A
Other income within the past twelve months
Business or profession: N/A
Other self-employment: N/A
Interests: N/A
Dividends: N/A
Pensions and annuities: N/A
Social Security benefits: N/A
Support payments: N/A
Disability payments: N/A
Unemployment compensation and supplemental
benefits: PBC 78 WBR 193A
Workman's compensation: N/A
Public Assistance: N/A
Food Stamps per month (average)
Other: $130 per month March 2001
(d) Other contributions to your household support
(Wife) (Husband) Name: N/A
If your (wife) (husband) is employed, state
Employer: N/A
Salary or wages per month: N/A
(e)
Type of work: N/A
Contributions from children:
Contributions from parents: N/A
Other contributions: N/A
Property owned
Cash: $0.00
Checking account:
Savings account: 378665034 PSECU
Certificates of deposit: N/A
Real estate (including home):
Motor vehicle: Make
Stocks;
Other:
Cost $
bonds:
N/A
N/A Year
Amount Owed $
N/A
(f) Debts and obligations
Mortgage: N/A
Rent: N/A
Loans: N/A
Clothing: N/A
Electricity: N/A
Gas: N/A
Telephone: N/A
Transportation:
Food: N/A
- average per month
$24.00 PAT PASSES
Non-food household goods:
N/A
Other: N/A
Persons dependent upon you for support
(Wife) (Husband) Name:
Children, if any:
Name: Lamar Parrish Hodge Age:
16
Other persons:
Name: N/A
Relationship:
4. I understand that I have a continuing obligation to
inform the court of improvement in my
financial circumstances which would permit me
to pay the costs incurred herein.
5. I verify that the statements made in this affidavit
are true and correct. I understand that false statements herein
are being made subject to the penalties of 18 Pa. C.S.~4904,
/
relating to unsworn falsification to authorities. / /
January 24, 2001 -C'61in Jeff~Le
Date Petitioner
COLIN JEFFREY LEVERT
PLAINTIFF
V.
CHRISTINE A. HODGE
DEFENDANT
1N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-589 CIVIL ACTION LAW
IN CUSTODY
ORDER OFCOURT
AND NOW, this 14TH day of February ,2001, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliat
at 4th Floor, Cumberland County Courthouse, Carlisle on the 15th day of March ,2001, at 10:30 a.m.
for a Pre-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. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
FORTHECOURT,
By: /s/
Hubert X. Gilroy, E~I~N
Custody Conciliatog \'~
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
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
COLIN JEFFREY LEVERT
Plaintiff
CHRISTINE A. HODGE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 01-589 CIVIL TERM
ORDER OF COURT
AND NOW, this 1st day of February, 2001, upon consideration of Plaintiff's request
to proceed in forma pauperis, Plaintiff is granted leave to file the custody complaint in the
above matter without payment of the usual filing fee.
Colin J. LeVert
611 Reily Street
Harrisburg, PA 17105
Plaintiff, Pro Se
Christine A. Hodge
148 North West Street
Carlisle, PA 17013
Defendant, Pro Se
BY THE COURT,
Wesley (3~)~.
:re
COLIN J. LEVERT,
Plaintiff
V
CHRISTINE A. HODGE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2001 - 589 CIVIL
1N CUSTODY
COURT ORDER
AND NOW, this 1~ day of May, 2001, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
The minor dill& Lamar Parrish Hodge, bom September 6, 1984, shall remain in the
physical custody of Richard Hodge pending circumstances as set forth below.
Upon the Father, Colin J. Levert, obtaining a primary residence in Carlisle, physical
custody of the minor child, Lamar Parfish Hodge, shall be transferred to the Father,
Colin J. Levert.
The Mother, Janine Hodge, the maternal uncle, Richard Hodge and the maternal
grandmother, Christine Hodge, shall continue to enjoy periods of temporary custody
of the minor child as the parties agree.
CC:
In the event circumstances change and any party desires to modify this order, that
party may contact the Conciliator directly, at which time the Conciliator will proceed
with scheduling another Custody Conciliation Confere~/~ this case.
Julie Miller ,
Dickinson School of Law Family Law Clinic
Colin J. Levert
1918 Green Street, Apt. 3
Harrisburg, PA 17l 10
Janine Hodge
3331 Sims Street
Hapeville, GA 30354-1469
Richard Hodge
1356 Grandview Court
Carlisle, PA 17013
COLIN J. LEVERT,
Plaintiff
V
CHRISTINE A. HODGE,
Defendant
1N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:
CiVIL ACTION - LAW
:
: NO. 2001 -589 CIVIL
: 1N CUSTODY
Prior Judge:
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the following report:
The pertinent information pertaining to the child who is the subject of this litigation is as
follows:
Lamar Parrish Hodge, bom September 6, 1984.
A Conciliation Conference was held on May 4, 2001, with the following individuals in
attendance:
The Father, Colin J. Levert, who appeared without counsel; and the maternal grandmother,
Christine A. Hodge, who appeared with Julie Miller of the Dickinson School of Law Family
Law Clinic. The natural Mother, Janine Hodge, lives in Georgia and has minimal contact
with the child. The child is currently living with Richard Hodge who is the maternal uncle.
The parties all agree that the child at this point wants to live with his Father once his Father
relocates from Harrisburg to Carlisle.
The Conciliator recommends the entry of an order in the form as attached to accomplish that
desire.
DATE
COLIN J. LEVERT,
Plaintiff
CHRISTINE A. HODGE,
Defendant
1N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:
CIVIL ACTION - LAW
:
: NO. 2001 -589 CIVIL
: IN CUSTODY
COURT ORDER
AND NOW, this ~Q ~)~day of March, 2001, the Conciliator has determined that another
Conciliation Conference is required and that additional parties need to be notified of this
Conference. Accordingly, a second Conciliation Conference is scheduled on Friday, May 4, 2001 at
9:30 a.m. in connection with the case of Lamar Parrish Hodge, bom September 6, 1984. The
following parties are invited to attend:
Mr. Colin J. LeVert
611 Reily Street
Harrisburg, PA 17105
Christine A. Hodge
148 North West Street
Carlisle, PA 17013
Richard Hodge
1356 Grandview Court
Carlisle, PA 17013
Janine Hodge
3331 Sims Street
Hapeville, GA 30354-1469
CC;
~Stephen Boell
Dickinson School of Law
Family Law Clinic
BY THE COURT,
Hubert X. Gilroy, Esquire
Custody Conciliator ~,D0~