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Home My WebLink About10-3781IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA ANTHONY HODGE, CIVIL ACTION Plaintiff v. l0"3~8~ DANIELLE THOMAS, CUSTODY Defendant COMPLAINT FOR CUSTODY cc~ a ~_~ ~~ ~ £_ ;_ ~ c~~. ~ ~ ~ ~ ~~, -.~ ~: ~: _ ` ~; c ~ ~ ~: 4 ,z, } ~~ 1. The plaintiff is Anthony Hodge who currently resides at 225 West Ridge Street, Carlisle, Pennsylvania, which is in Cumberland County, Pennsylvania. 2. The defendant is Danielle Thomas who currently resides in Spring Garden Street, Carlisle, Pennsylvania which is in Cumberland County, Pennsylvania. 3. The plaintiff is seeking custody of the following children: Name Residence Aye C'myiah Nycole Thomas Hodge. 225 West Ridge Street 2 Carlisle, PA (DOB 1/16/08) The child was born out of wedlock. ~~ ~~~~ ~Cl'i4-lr During the past five years, the child has resided with the following persons and at the following addresses: (,List all Persons) (List all Addresses) (Dates) Anthony Hodge, 225 West Ridge Street 5/9/2010 Alice Arder, Tren Arder Carlisle, PA 17013 to present and Rayana Hodge Anthony Hodge, 102 East Willow Street birth Alice Arder, Tren Arder Carlisle, PA 17013 to 5/9/2010 and Rayana Hodge The mother of the child is Danielle Thomas. She is not married. The father of the child is Anthony Hodge. He is not married. 4. The relationship of plaintiff to the child is that of father. The plaintiff currently resides with the following persons other than children: Alice Arder (plaintiff s mother), Tren Arder (plaintiff's step-father) and Rayana Hodge (plaintiff's niece, age 5) 5. The relationship of defendant to the child is that of mother. The defendant currently resides with the following persons other than the child: Trumaine Thomas (defendant's mother), Fergie Thomas (defendant's brother) and Tish Thomas and Dominique Thomas (defendant's sisters) 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 child 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 or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: Plaintiff has had primary custody of the child since her birth and is willing and able to perform the primary parental responsibilities for the child. Plaintiff is in the best position to provide the care and nurture which the children need for healthy development. Defendant has demonstrated that she is not in a possession to provide for the child's basic needs. 8. 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. WI-~REFORE, plaintiff requests the court to grant him custody of the minor child. S ri D. Coover, Esquire ttorney ID 92385 44 S. Hanover Street Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA ANTHONY HODGE, CIVIL ACTION Plaintiff v. DANIELLE THOMAS, CUSTODY Defendant VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: Anth r~ Hodge -JUL ~'D ZU~~~ ANTHONY HODGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW ~'- _ ~=.:~ Q .`---~ DANIELLE THOMAS, NO. 2010-3781 _ ~ ~_, , Defendant IN CUSTODY 4 ~ r... ~ `. COURT ORDER ; ' o ;- `~ f~ NOW, this ~~ day of Gv l , 2010, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The father, Anthony Hodge, and the mother, Danielle Thomas, shall enjoy shared legal custody and shared physical custody of C'myiah Nycole Thomas Hodge ,born January 16, 2008 2. Physical custody shall be handled on a week on/week off arrangement. The parties shall exchange custody on each Friday at 5:00 p.m. unless agreed otherwise by the parties. The father shall deliver custody of the minor child to the mother on Friday, July 30, at 5:00 p.m. at 307B North Pitt Street Carlisle, PA. Mother shall correspondingly deliver custody of the minor child to father on the following Friday at 5:00 p.m. at 318 Muench Street Harrisburg, PA. 3. The parties shall meet again for a custody conciliation conference on Thursday, October 7, 2010, at 8:30 a.m. In the event mother retains legal counsel prior to the scheduling of the second custody conciliation conference, mother's attorney shall contact father's attorney and the custody conciliator to determine if this matter should go to another conciliation conference or if it should be directed immediately for the scheduling of a hearing. _;~ ,~ ,-~ ;t f 4. Neither party shall consume or be under the influence of alcohol or illegal drugs when they have custody of the minor child. BY THE COURT, A bert H. Masland, Judge cc: "S ri D. Coover, Esquire '~ Ms. Danielle Thomas ~~~~5' rh~tlSr~ ~ ~./ ~v ANTHONY HODGE, Plaintiff vs. DANIELLE THOMAS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2010-3781 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL 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: C'myiah Nycole Thomas Hodge, born January 16, 2008 2. A Conciliation Conference was held on July 28, 2010, with the following individuals in attendance: The father, Anthony Hodge, with his counsel, Sheri D. Coover, Esquire, and the mother, Danielle Thomas, who appeared without counsel. 3. The parties present dramatically different versions on what the status quo on custody has been over the past two years. The mother has sought legal counsel but has been unable to obtain counsel at this point. The Conciliator believes that perhaps there will be opportunity to get this case resolved once mother has counsel and the Conciliator feels that a temporary order would add some stability to the situation and give the parties an opportunity to settle down and, possibly, work out an agreement. 4. The Conciliator recommends an Order in the form as attached. Date: July ~U , 2010 ~/'(fi Hubert X. ' roy, Esquire Custody C nciliator .. oar ~ 3 zoo ANTHONY HODGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA "' o vs. CIVIL ACTION -LAW c !, ~ ~ ~'' ma' '" DANIELLE THOMAS, f N0.2010-3781 ~ ~.~ --~ r %~ Defendant IN CUSTODY D to o , PRIOR JUDGE: Albert H. Masland z C~ 7ts• '~~ ~t p~i~ ~n ~~ ~ ~ orn ,~a r.~ COURT ORDER ~ „~ N „~ ~ a of Qctober 2010 u on consideration of the attached Custody 1-l NOW, this y p Conciliation Report, it is ordered and directed as follows: 1. Another Custody Conciliation Conference is scheduled on Thursday, January b, 2011, at 8:30 a.m. At this conference, it is aticipated that mother will have had an opportunity to retain legal counsel in connection with this case so that the matter may proceed to a hearing or, in the alternative, the parties may negotiate a resolution. 2. Pending further of this Court, this Court's Order of July 30, 2010, shall remain in place and custody shall be on a 50/50 shared basis. In the event the parties aze unable to agree upon a holiday schedule on their own, the following holiday schedule shall apply: A. For Thanksgiving of 2010, the day shall be split into two time frames, the first frame from 9:00 a.m. unti13:00 p.m. and the second frame from 3:00 p.m. unti19:00 p.m. The mother shall have the first frame in 2010, and the father shall have the second frame with the parties alternating thereafter. S B. For Christmas 2010, the Christmas holiday shall be divided into two segments; Segment A shall be from December 24 at noon until December 25 at noon and the Segment B shall be from December 25 at noon until December 25 at noon. The Mother shall have Segment A and the father shall have Segment B in 2010 with the parties alternating thereafter. BY THE COURT, Albert H. Masland, Judge cc: / Sri D. Coover, Esquire GMs. Danielle Thomas ~' ~' Jryl~-t to esl~v ~~ OCT 13 [u~G ANTHONY HODGE, Plaintiff vs. DANIELLE THOMAS, Defendant PRIOR JUDGE: Albert H. Masland 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.2010-3781 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: C'myiah Nycole Thomas Hodge, born January 16, 2008 2. A Conciliation Conference was held on October 7, 2010, with the following individuals in attendance: The father, Anthony Hodge, with his counsel, Sheri D. Coover, Esquire, and the mother, Danielle Thomas, who appeared without counsel. 3. The parties appeared before the Conciliator in July and reached an agreement on a 50/50 custody. Father now appears and suggests he wants primary custody and is requesting a hearing. Mother is also not satisfied with the custodial situation but is reluctant to go to a hearing because she lacks legal counsel at this point despite what she suggests have been efforts to obtain an attorney. She does not qualify for legal services, but she does not have the financial resources to hire an attorney at this point. 4. The Conciliator recommends an Order in the form as attached. Date: October ~, 2010 inns 10 M11 ANTHONY HODGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANI A CIVIL ACTION - LAW VS. DANIELLE THOMAS, .ter NO. 2010-3781 Defendant IN CUSTODY --- - PRIOR JUDGE: Albert H. Masland ?. Tj D COURT ORDER NOW, this zV day of January, 2011, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. This court's order of October 14, 2010, and the order of July 30, 2010, shall remain in place. 2. Should either party desire to modify the existing custody orders, that party may petition the court to have the case again scheduled with the custody conciliator for a conference. BY THE COURT, Albert H. Masland, udge cc: 'Sheri D. Coover, Esquire '," Ms. Danielle Thomas 00,04 C"I tPrs I t''tl D th 5 ANTHONY HODGE, Plaintiff VS. DANIELLE THOMAS, Defendant PRIOR JUDGE: Albert H. Masland IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2010-3781 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: C'myiah Nycole Thomas Hodge, born January 16, 2008 2. A Conciliation Conference was held on January 6, 2011, with the following individuals in attendance: The mother, Danielle Thomas, who appeared without counsel, and Sheri D. Coover, Esquire, who appeared for the father. The father was not in attendance and his attorney did not have any information on his whereabouts at this point. 3. The mother related that the parties are working out custody and that she is dealing primarily with the father's relatives for exchange of custody. The Conciliator recommends that the existing order remain in place with the opportunity for either party to petition the court to have the case heard again if there are problems. Date: January q 5 2011 /71-J-4 Hubert X. G' oy, Esquire Custody C ciliator