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Home My WebLink About10-3459TREVOR WADE THOMAS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 20101y61 CIVIL TERM SELINA MARLENE MILLER, Defendant CUSTODY n r, r COMPLAINT FOR CUSTODY C- 1. Plaintiff is Trevor Wade Thomas, (Father). Father's residence is 28 B oadcStreet `? (Ln Shippensburg, Cumberland County, Pennsylvania 17257. 2. Defendant is Selina Marlene Miller, (Mother). Mother's address is 4566 Edenville Road, Lot 3, Chambersburg, Franklin County, Pennsylvania 17201. 3. Father seeks shared physical custody of the minor child: Name Present Residence Age Trevor Thomas Jr. 4566 Edenville Road, Lot 3 1.30.10 DOB, -3 months old Chambersburg, PA 17201 Trevor was born out of wedlock. Trevor is presently in the custody of Mother. During his lifetime, Trevor has resided with the following persons and at the following addresses: Name Address Date NICU Harrisburg Hospital Harrisburg, PA birth - 3.2. 10 Trevor Thomas 28 Broad Street 3.2.10 - 4.27.10 Harry Thomas Shippensburg, PA 17257 Lisa Thomas Selina Marlene Miller Selina Marlene Miller Adrianna Miller George Miller 4566 Edenville Road, Lot 3 4.27. 10 - present Chambersburg, PA 17201 The parties are no longer in a relationship. 4. Mother resides with the following persons: Name Adrianna Miller George Miller Jr. Relationship Maternal Grandmother Maternal Grandfather 5. Father currently resides with the following persons: Name Lisa Thomas Harry Thomas Relationship Paternal Step-grandmother Paternal Grandfather 6. Father has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of Trevor in this or another court. 7. Father has no information of a current custody proceeding concerning Trevor pending in a court of this Commonwealth. 8. Father does not know of a person not a party to the proceedings who has physical custody of Trevor or claims to have custody or visitation rights with respect to Trevor. 9. The best interest and permanent welfare of Trevor will be served by granting the relief requested for reasons including, but not limited to the following: a) Father has the ability to care for Trevor for periods of shared physical custody; and for the month that Trevor and Mother lived with him he shared equally in the day to day care of Trevor. b) Father is able to use his parents' residence to provide a safe and nurturing environment in which to exercise periods of partial physical custody. c) Father is willing and able to care for Trevor during periods of partial custody and he is committed to establishing and nurturing a healthy father/son relationship with him. d) Father is willing to work with Mother to co-parent Trevor and will communicate with Mother to best serve Trevor's interests. e) Mother is not acting in Trevor's best interest in ways including but not limited to the following: i) Mother has unilaterally decided to refuse Father the ability to see or have a relationship with Trevor when she left the residence she shared with Father since Trevor was first released from the hospital. Mother's actions have negatively impacted the developing father/son relationship Father had established with Trevor. 11. Every person with rights to custody or having actual physical custody of Trevor has been named as parties to this action. WHEREFORE, Father requests this Court to grant him the following relief: 1) Grant the parties shared legal custody of Trevor. 2) Any further relief that this Court finds to be just and proper. Respectfully submitted, Jess olst, Esquire Mid enn Legal Services 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 VERIFICATION The above-named PLAINTIFF, TREVOR WADE THOMAS, verifies that the statements made in the above COMPLAINT FOR CUSTODY are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: 2_010 sAVIOT UV? ??2(J?? TREVOR WADE THOMAS 0 TREVOR WADE THOMAS, Plaintiff V. SELINA MARLENE MILLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010- CIVIL TERM CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Trevor Wade Thomas, Plaintiff, to proceed in forma au eris. c? C-- 77-7 , 7 ,f =f C, I, Jessica Holst, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. JessiNaVlolst, Esquire MidP nn Legal Services 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 i ~_ TREVOR WADE THOMAS PLAINTIFF V. SELINA MARLENE MILLER DIFFNDANT [N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2010-3459 CIVIL ACTION LAW 1N CUSTODY ORDF.,R OF COURT AND NOW, Wednesday, June 09, 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 County Courthouse, Carlisle on Thursday, June 24, 2010 at 8:30 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 he accomplished, to define and narrow the issues to be heard by the court, and to entex into a temporary order. Failure to appear at the conference may provide Rrounds 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 4$ hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Grlro Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of [990. For information about accessible facilities and reasonable accommodations a~-ailable to disabled individuals having bl~isiness 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 AT'"fORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORT[I E3ELOVb' TO F[ND OUT WHERE YOU CAN GET LEGAL HELP. ~ •G~ , ~ 0 e.~~, ~ ~;~ ~@.O ,Cumberland County Bar Association ~ ° -r".~' ~= ~, y ~~, nn ~ ~Ntli±s 32 South I3edford Street ~~ ~ _~ ~ Carlisle, Pennsylvania 17013 ' `' `p .a . ~ O /VO~C~- ~,~ ~~ -}~p~'~'i' ; Telephone (717) 249-3166 ~ `~ ` ~~- (~. r' :c- C. Q 'U ~ 00 0 ~~, _~ ~; 4 ~ ~,.L y ,j,l `~ rrz b TREVOR WADE THOMAS IN THE COURT OF COMMON PLEAS OF I'L.,AINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. SEL[NA MARLENE MILLER DF?FF.NDANT • 2010-3459 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOVb', Wednesday, June 09, 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 Thursday, June 24, 2010 at 8:30 AM for aPre-Flearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot he' 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. Gllro Es , Custody Conciliator 7~he 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 "PHIS PAPER TO YOUR. A"T'TORNEY AT ONCE. IF YOU I)O NOT HAVE AN A"r"[~ORNEY OR CANNOT AFFORD UNE, GO TO OR TELEPHONE THE OFFICE SET FORT'I-t BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. n ~ •C{ . ~ ~ e~,,~,, ~ Ma,~ ~Q.O ,Cumberland County Bar Association ~ o -r?~:~, c fit, 1 ~~n ~ ~N't~. 32 South Bedford Street ~",~`' ,~„~, CY Carlisle, Pennsylvania 17013 `~ `' ~ ,_ ~ • ~~ ~~ -{,p~Q'~'4: Telephone (7l 7) 249-3 t 66 ~ ~ •a ~ r o iuo~hc~. ~~:. ~. ~'_' `-~ _ c_; ~ ~ i ~~ -c ~` ~, ,.y =- °~ m ~` .- ` TREVOR WADE THOMAS, Plaintiff/Petitioner vs. SELINA MARLENE MILLER, Defendant/Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2010-3459 CIVIL TERM CUSTODY PRAECIPE TO WITHDRAW COMPLAINT FOR CUSTODY To the Prothonotary: Please withdraw without prejudice the Complaint for Custody brought by Plaintiff, Trevor Wade Thomas, in the above captioned case. submitted: ~'ess 61st, Esquire MI NN LEGAL SERVICES 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 I.D. # 822 i 4 c > ~ ~. ~ . ~ ~ rj~l r;-. <...._ : -IZ~ ~_.- ~. ~ ~ ~ j i ~ ? _,- . - ~ .. , .. S y_ `.., , ... ~ _{ ~ G,.7 - r- JUL 2 3 2010 TREVOR WADE THOMAS, IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner :CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2010-3459 CIVIL TERM SELINA MARLENE MILLER, . DefendantlRespondent :CUSTODY ORDER OF COURT AND NOW, this ~~ day of ~~ 2010, upon consideration of the Praecipe to Withdraw Petition filed on behalf of Plaintiff, Trevor Wade Thomas, the Complaint for Custody is withdrawn without prejudice. Di tribution: essica Holst, Esquire 401 East Louther Street C~~arl~~isle, PA 17013 Selina Marlene Miller, pro se Defendant 4566 Edenville Road Lot 3 Chambersburg, PA 17201 ~t ~Q. S 7/a.c,/rc~ rn~i~ c~ ~ ~ _, -- --~ . .. ` r~.~ - r~. , '.. Rv the (`..,,,~ f ~ TREVOR WADE THOMAS, Plaintiff/Petitioner vs. SELINA MARLENE MILLER, Defendant/Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010-3459 CIVIL TERM CUSTODY PRAECIPE TO WITHDRAW COMPLAINT FOR CUSTODY To the Prothonotary: Please withdraw without prejudice the Complaint for Custody brought by Plaintiff, Trevor Wade Thomas, in the above captioned case. submitted: mess 61st, Esquire MI NN LEGAL SERVICES 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 I.D. # 82214 cn c~ -- _~; `~ --~ _~~ .,~ - ; c-' t~% .- c ,; , , .1,. ~ - S (,' " TREVOR WADE THOMAS, Plaintiff vs. SELINA MARLENE MILLER, Defendant ~~ ~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIh ACTION -LAW NO. 2010-3459 IN CUSTODY ORDER AND NOW, this day of July, 2010, the Conciliator being advised the parties have reconciled and that the custody petition filed in the above case will be withdrawn, the Conciliator relinquishes jurisdiction. Hubert X. roy, Esquire Custody onciliator ~ r,.> c_, y' ~ f'3 (__ . , -- re3 _~ ~ ;' ~=: e , - ~ -- ~ c~ Y '~ ~ ` .~ ) ! ~ 1..~