The URL can be used to link to this page

Home My WebLink About04-3683Samantha McKee, Plaintiff Duane Morris, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04- ,~/~P~ CIVIL TERM : CIVIL ACTION - CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Samantha McKee, an adult individual whose residence is at 302 Sherwood Drive, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Duane Morris, an adult individual whose residence is 120 North Pitt Street, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of her child Bethany Morris, born December 1, 2000, currently residing at 302 Sherwood Drive, Carlisle, Cumberland County, Pennsylvania. 4. The child, Bethany Morris, is presently in the custody of Plaintiff. 5. Since the child's birth, the child has resided at the following addresses: Name Address Dates Bethany Morris 302 Sherwood Drive Birth to Present Carlisle, PA 17013 6. The relationship of the Plaintiff to the child is that of natural mother. 7. The relationship of the Defendant to the child is that of natural father, 8. The Plaintiff has not participated as a party or in any other capacity, in other litigation concerning the custody of the child in this or any other Court. 9. Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. 10. The best interest and permanent welfare of the child will be served by granting the relief requested for the following reasons: a.) Plaintiff is the primary care giver with respect to the child; II b.) Defendant is on-call to drive tow trucks at unpredictable times during nighttime (sleeptime) hours and therefore it is not in the best interest of the child to stay overnight with Defendant. 11. 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 to have any right to custody or visitation of the child other than the parties to this action. WHEREFORE, Plaintiff requests your Honorable Court to order shared legal custody and sole overnight physical custody to Plaintiff, with visitation rights to Defendant. Respectfully Submitted TURO LAW OFFICES Na~y A.~Ffescott, Esquire 2~South Pitt Street Carlisle, PA 17013 (717) 245-9688; (717) 245 21665 (Fax) Attorney ID.# 89627 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Custody Complaint are true and correct, I understand that false statements made herein are subject to the penalties of 18 Pa. C,S. ~4904 relating to unsworn falsification to authorities. Date Samantha McKee Samantha McKee, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :so. 04- 3b¥-x civm am~tu Duane Morris, Defendant : CIVIL ACTION - CUSTODY PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY OF SAID COURT: Please enter the appearance of Nancy A. Prescott, Esquire, on behalf of the Plaintiff in the above-captioned case. Date Respectfully Submitted, TURO LAW OFFICES ti, Esquire Tpro Law Offices 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 1D~89627 Attorney for Plaintiff SAMANTHA MCKEE PLAINTIFF V. DUANE MORRIS DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-3683 CIV1L ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, August 05, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear belbre Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, August 26, 2004 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an eftbrt 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 al~pear 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. FORTHE COURT, By: /s/ .Iacqueline M. Verne~, Esq. 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ;amantha McKee, Plaintiff )uane Morris, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04- 36~-~ CIVIL : CIVIL ACTION - CUSTODY PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY OF SAID COURT: Please enter the appearance of Nancy A. Prescott, Esquire, on behalf of the Plaintiff in the above-captioned case. )at6 ' Respectfully Submitteq, TURO LAW OFFICES l~ancy ~. Prescott, Esquire T~ro Law Offices 25 South Pitt Stree~ Carlisle, PA 17013 (717) 245-9688 ID~89627 Attorney for Plaintiff Samantha McKee, Plaintiff' Duane Morris, Defendant IN THE COURT OF COMMON PLEAS · CUM])ERLAND COUNTY, PENNSYLVANIA : NO. 04-3683 CIVIL TERM : CIVIL ACTION. CUSTODY MOTION FOR CONT~ AND NOW, comes the Plaintiff, Samantha IVlcKee, by and through her attorney Nancy A Prescott, Esquire who moves to continue indefinitely the Pro-Hearing Custody Conference scheduled for August 26, 2004 - 8:30 a.m. before Jacqueline M. Verney, Esq. - and states: 1.) The parties, subsequent to the Order for* a Pre-Hearing Custody Conference, have reconciled, and custody is not cum~ntly disputed. 2.) An indefinite continuance is requested because the Parties have only recently reunited, and there remains uncertainty il~ the reunification will be permanent. 3.) The Defendant, Duane Morris, is unropresented by counsel. WHEREFORE, Counsel respectfully requests an indefinite continuance in the above captioned matter. Resp, !ctfully ubmitted, i, ,-Offi&s- -- A~onrCnYeA'o Pre_scott, Esquire 'y mr Defendant Attorney I.D.# 89627 28 South Pitt Street Carlisle, PA 17013 (717)245-9688 (717)245_2165 (Fax) Samantha McKee, Plaintiff V. Duane Morris, Defendant · IN THE-' COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 04-3683 CIVIL TERM · CIVII~ ACTION - CUSTODY CERTIFICATE OF SERVICF I hereby certify that I served a true and correct copy of the Motion for Continuance upon Defendant, Duane Morris,_b~_y depositing same in the United States Mail, first class, postage pre-paid on the /~ day of (~/M~- ,2004, from Carlisle, Pennsylvania, addressed as follows: -- Mr. Duane Morris 302 Sherwood Drive Carlisle, PA 17013 TURO LAW OFFICES 28 South Pitt Street Carlisle, PA 17013 Attorney ID 89627 (717) 245-9688; FAX 717.245.2165 SAMANTHA McKEE, Plaintiff V. DUANE MORRIS, Defendant AUG,?O/2004 : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2004-3683 CIV][L TERM : : CIVIL ACTION - [,AW : : IN CUSTODY ORDER OF COURT AND NOW, this 20th day of August, 2004, being advised that the parties have resolved their differences, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THECOURT, ~ac~Jeiine M. Vemey, Esquire, Cus~ly Conciliator