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Home My WebLink About02-0069 SAIDIS SHUFF, FLOWER & LINDSAY ATI'OP, I~Y~.AT*LAW 26 W. High Street C~rlisle, PA MYLES D. WORTHINGTON, Plaintiff, · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. o.,!-b ~ JILL WORTHINGTON WEST, Defendant. CIVIL, 2002 · IN CUSTODY COMPLAINT FOR PARTIAL CUSTODY 1. The Plaintiff is MYLES D. WORTHINGTON, residing at 6134 White Church Road, Shippensburg, Pennsylvania 17257. 2. The Defendant is JILL WORTHINGTON WEST, residing at 326 West Allen Street, Mechanicsburg, Pennsylvania 17055. 3. The Plaintiff seeks partial custody of the following child, MARLINA WORTHINGTON, whose present residence is 326 West Allen Street, Mechanicsburg, Pennsylvania 17055. The child was born October 9, 1997, and is currently 4 years of age. The child was not born out of wedlock. The child is presently in the custody of JILL WORTHINGTON WEST, her mother, who resides at 326 West Allen Street, Mechanicsburg, Pennsylvania 17055. During the past five years, the child has resided with the following persons and at the following addresses: From birth until February of 1999, with Plaintiff, Defendant and DAVID THRUSH, Defendant's son, at 1584 Pine Road, Carlisle, Pennsylvania; From February of 1999, with Defendant, Defendant's son, DAVID SAIDIS SHUFF, FLOWER & LINDSAY ATTORI~YS*AT*LAW 26 W. High Slreet Carlisle, PA MYLES D. WORTHINGTON, Plaintiff, VS. JILL WORTHINGTON WEST, Defendant. · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. O.,~-&5 CIVIL, 2002 IN CUSTODY COMPLAINT FOR PARTIAL CUSTODY 1. The Plaintiff is MYLES D. WORTHINGTON, residing at 6134 White Church Road, Shippensburg, Pennsylvania 17257. 2. The Defendant is JILL WORTHINGTON WEST, residing at 328 West Allen Street, Mechanicsburg, Pennsylvania 17055. 3. The Plaintiff seeks partial custody of the following child, MARLINA WORTHINGTON, whose present residence is 326 West Allen Street, Mechanicsburg, Pennsylvania 17055. The child was born October 9, 1997, and is currently 4 years of age. The child was not born out of wedlock. The child is presently in the custody of JILL WORTHINGTON WEST, her mother, who resides at 326 West Allen Street, Mechanicsburg, Pennsylvania 17055. During the past five years, the child has resided with the following persons and at the following addresses: From birth until February of 1999, with Plaintiff, Defendant and DAVID THRUSH, Defendant's son, at 1584 Pine Road, Carlisle, Pennsylvania; From February of 1999, with Defendant, Defendant's son, DAVID SAIDIS SHUFF, FLOWER & LINDSAY ATroI~YS.AT.LAW 26 W. High Street Carlisle, PA THRUSH, and the child's maternal grandparents, TIMOTHY and EDNA TATCH, at 1584 Pine Road, Carlisle, Pennsylvania; From a recent undermined date until the present, with Defendant, Defendant's son, DAVID THRUSH, and a boyfriend whose name is not known to Plaintiff, at 326 West Allen Street, Mechanicsburg, Pennsylvania 17055. The mother of the child is JILL WORTHINGTON WEST, currently residing at 326 West Allen Street, Mechanicsburg, Pennsylvania 17055. She is divorced. The father of the child is MYLES D. WORTHINGTON, currently residing at 6134 White Church Road, Shippensburg, Pennsylvania 17257. He is divorced. 4. The relationship of the Plaintiff to the child is that of biological father. The Plaintiff currently resides with the following persons: None 5. The relationship of the Defendant to the child is that of biological mother. The Defendant currently resides with the following persons: The child in question, MARLINA WORTHINGTON, Defendant's son, DAVID THRUSH, and Defendant's boyfriend, whose name is undisclosed. 6. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation concerning the custody of the child in this or another jurisdiction. 7. The Plaintiff has no information of a custody proceeding concerning the child pending in a court of the Commonwealth or any other state. 8. The Plaintiff does not know of a person not a party to the }roceedings who has physical custody of the child or claims to have custody or visitation dghts with respect to the child. SAIDIS SHUFF, FLOWER & LINDSAY ATTORNEYS*AT.LAW 26 W. High Street Carlisle, PA 9. The best interest and permanent welfare of the child will be served by granting the relief requested because it is in the best interests of the child to maintain a relationship with her biological father. 10. 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. No other persons are known to have or claim a right to custody or visitation of the child. WHEREFORE, the Plaintiff requests this Court to grant partial custody of the to the Plaintiff. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Plaintiff Date~}~'~ !,Y~mes D. F~'ower, Jr./' / "'~ 26 West High Street Carlisle, PA 17013 (717) 243-6222 I.D. No. 27742 VERIFICATION I, MYLES D. WORTHINGTON, the undersigned, hereby verify that the statements made herein 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. / Myles D. Worthington Date: /- /-')/'~ 0 ~ SAIDIS SHUFF, FLOWER & LINDSAY A~roRNEYS.AT*LAW 26 W. High Street Carlisle, PA MYLES D. WORTHINGTON : PLAINTIZ-F : V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-69 CIVIL ACTION LAW JILL WORTHINGTON WEST DEFENDANT : IN CUSTODY ORDER OF COURT AND NOW, Friday, January 25, 2002 , 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 Friday, February 08, 2002 at 8:30 AM 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. 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. Gilro~. Esa. Custody Conciliator 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 ~.f VtNV^'I~SNN"-J~ APR 0 4 200 MYLES D. WORTHINGTON, Plaintiff V JILL WORTHINGTON WEST, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 069 CIVIL ACTION - LAW IN CUSTODY COURT ORDER AND NOW, this ~ day of April, 2002, the conciliator being advised that the parties have reached an agreement to the effect where the custody action will be withdrawn without prejudice to refile in the future, the conciliator relinquishes jurisdiction in this case. BY THE COURT, ~. Gi~ir'oy, Es ,re cc: Bradley L. Girffie, Esquire James D. Flower, Jr., Esquire V1NV^~$NN~d Ab¥iONOi4iO~j iH.[ JO