HomeMy WebLinkAbout04-3524DEBORAH HADLEY,
Plaintiff
VS.
GERALD K. BUSH,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO.
: CIVIL ACTION - LAW
: CUSTODY
COMPLAINT FOR CUSTODY
Custodian
Deborah Hadley-Bush
Gerald K. Bush
Plaintiffis Deborah Hadley, residing at 216 High Street, Newburyport,
Massachusetts 01950.
The defendant is Gerald K. Bush, residing at 4 Hunter Lane, Camp Hill,
Cumberland County, Pennsylvania 17011.
Plaintiff seeks custody of Kyle Bush, bom May 21, 1994.
The child was not bom out of wedlock. The child is presently in the
custody of Gerald K. Bush, who has had custody of the child since
August, 2001.
For the past five years, the child has resided with the following persons at
the following addresses:
Address
4 Hunter Lane
Camp Hill, PA
Shared custody-alternate
Weekends
Gerald K. Bush
Dates
1998 - August 4, 1999
4 Hunter Lane
Camp Hill, PA
Deborah Hadley 4173 Grouse Court
Mechanicsburg, PA
Gerald Ko Bush
Deborah Hadley
Gerald K. Bush
Deborah Hadley
Deborah Hadley
Connie Reinhardt
4 Hunter Lane
Camp Hill, PA
173 Winter Street
Brockton, MA
4 Hunter Lane
Camp Hill, PA
10 16t~ Street
Newbury, MA
216 High Street
Newburyport, MA
2001-2002
sumnler vacation,
holiday weekends
2002-present
summer vacation,
holiday weekends
2002-June 2003
summer vacation,
holiday weekends
June 2003 -present
9.
10.
11.
12.
The mother of the child is Deborah Hadley who currently resides at 10
16th Street, Newbury, Plum Island, Massachusetts. She is single.
The father of the child is Gerald K. Bush, currently residing at 4 Hunter
Lane, Camp Hill, Peunsylvania. He is married.
The plaintiff currently resides with Connie Reihardt.
The defendant currently resides with Sharon Bush
Plaintiff has not participated as a party or witness, or in another capacity,
in other litigation concerning the custody of the child in this or another
court.
The plaintiff has no information of a custody proceeding concerning the
child pending in a court in this Commonwealth or in any other court.
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.
13. The best interest and permanent welfare of the child will be served by
granting the plaintiff custody of Kyle Bush because of superior
educational opportunities where plaintiffresides as well as her schedule
which permits her to spend more parental time with Kyle on a daily basis
than is now possible.
14. Each parent whose parental fights 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.
WHEREFORE, plaintiffrequests this Court to award her primary physical
custody of Kyle Bush.
Timothy J. O'Connell, l~sttn
Turner and O'Connell
4415 North Front Street
Harrisburg, PA 17110
(717) 232-4551
Verification
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.A. Section 4904 relating to unswom falsification to authorities.
Date: Deborah Hadley ~
DEBORAH HADLEY,
Plaintiff
VS.
GERALD K. BUSH,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-3524 Civil Teem
: CIVIL ACTION - LAW'
: CUSTODY
PRAECIPE
TO THE PROTHONOTARY:
Please mark the above captioned action discontinued.
Date: July 27, 2004
Timoth~J. O'Connell, Esquire
TURNER AND O'CONNELL
4415 North Front Street
Harrisburg, PA 17110
(717) 2324551
Attorney for plaintiff