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Home My WebLink About01-2996Weston Green, Jr., : IN THE COURT OF COMMON PLEAS OF Plaintiff : : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 01- ~9q/- CIVILTERM Kristy Green, : Defendant : CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff.is Weston Green, Jr., residing at 155 East North Street, Carlisle, Cumberland County, Pennsylvania. 2. The defendant is Kristy Green, residing at 161 Fry~own Road, Carlisle,Cumberland County, Pennsylvania. 3. The plaintiffseeks custody ofthe following child: Name Present Residence Kayleigh Green 161 Frytown Road March 20, 2001- Date of Birth Carlisle, PA The child was not born out ofwedlock. The child is presently in the custody of Kristy Green, who resides at 161 Frytown Road, Carlisle, Pennsylvania. During the child's lifetime, she has resided with the following persons and at the following addresses: .Name Address Date Weston Green, .Ir. 155 East North Street 3/20/01 to 5/10/01 Kristy Green Carlisle, PA 17013 Kristy Green 161 Frytown Road 5/10/01 to present Marilyn Jumper Carlisle, PA 17013 Calvin .lumper The mother of the child is Kristy Green, currently residing at 161 Frytown Road, Carlisle, Pennsylvania. She is married. The father of the child is Weston Green, Jr., currently residing at 155 East North Street, Carlisle, Pennsylvania. He is married. 4. The relationship of the plaintiffto the child is that of father. The plaintiff currently is residing at 155 East North Street, Carlisle, PA. 5. The relationship ofthe defendant to the child is that of mother. The defendant currently resides with the following persons: .Name Relationship Marilyn Jumper Mother Calvin Jumper Father Kayleigh Green Child 6. The 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. 7. The plaintiffhas no information ora custody proceeding concerning the child pending in a court of this Commonwealth. 8. The plaintiffdoes not know ora 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. 9. The best interest and permanent welfare of the child will be served by granting the relief requested for reasons including, but not limited to, the following: a. Plaintiff(Father) has lived with the child since her birth, and has provided and can continue to provide for the child's physical, emotional and financial needs including a stable environment. b. The child has been with the father since her birth and she has bonded with him, and Defendant (Mother) has not acted in the child's best interest by removing her from her father, denying him reasonable contact with her, and limiting him to sporadic, supervised visits. c. The father has concerns for the child if she remains primarily in the mother's care for reasons including, but not limited to, the following: 1. The mother has a history of mental instability which has resulted in periods of extended hospitalization at least twice. 2. The mother has impulse control issues which could adversely effect the child. For example, ten days before the child's birth the mother became angry at the father and punched her arm through a window resulting in her receiving approximately sixteen (16) stitches. 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. WHEREFORE, the plaintiffrequests that this Court grant him physical and legal custody of the child and any other relief which is just and proper. Respectfully submitted, ... f'JoXan Carey t~/ Attorney for Plaintiff MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 VERIFICATION The above-named Plaintiff, Weston Green, Jr., verifies that the statements made in the above Complaint 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: 5'-la- c~ .~._.,,~.._~,~,~.~_?. Weston Green, Jr., Plaintiff WESTON GREEN, JR., : Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA KRISTY GREEN, : NO. 01-~ CIVIL TERM Defendant : pRAECIPE TO PROC~.~r~ IN FOP. MA PAUPERIS To the Prothonotary: Kindly allow, Weston Green, Jr., Plaintiff, to proceed in forma ~. I, Joan Carey, attorney for the party proceeding in forma I~,~-~, certify that I believe the pm'ty is unable to pay the costs and that I am providing free le.~l services to the party. The p~ty's affidavit showing inability to pay the costs of litigation is at~ached hereto. carey // Attorney for Plaintiff ~ MIDPENN LEOAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 WESTON GREEN, JR., : Plaintiff : IN THE COURT OF COMMON PLEAS OF : : CUMBERLAND COUNTY, PENNSYLVANIA V. : : KRISTY GREEN, : NO. 01- CIVIL TERM Defendant : AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROC~.~-r) IN FORMA PAUPERIS 1. I am the Plaintiff in the above mailer and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and (a) Name: Weston Gree~. Jr. Address: 155 E. North St. Carlisle. PA 17013 Co) Social Security Number: If you are presently employed, stale Employer: N/A Address: Salary or wages per month: TyI~ of work: If you are presently unemployed, state Date of last employment: 4/01 Salary or wages per month: $1700 Type of work: Freauenc? a~,_~i~,~ ~n~in~er (c) Other income within the past twelve months Business or profession: Other self-employment: N/A Interest: N/A Dividends: N/A Pension and annuities: N/A Social Security benefits: N/A Support payments: N/A Disability payments: H/A Unemployment compensation and supplemental benefits: $1063/month Workman's compensation: N/A Public Assistance: Other: (d) Other contributions to household support (Wife)(Husband) Name: If your (husband) (wife) is employed, state Employer: Salary or wages per month: Type of work: Contributions from children: (e) Property owned Cash: $250.00 Checking Account: $0.00 Savings Account: $450.00 Certificates of Deposit: N/A Real Estate (including home): N/A Motor vehicle: Mak~[..~.l~~ Year 1991 Cost $3(:d)(} Amount owed $0 Make~__ Year 2000 Cost $21000 Amount owed $16500 Stocks; bonds: Other: (f) Debts and obligations Mortgage: Rent: $465 Loans: $71.00/m~nth fsehool loans~: car loan $340 Monthly Expenses: ~Iroceries $150: Telex_ hone $40: Electric $100: Gas for vehicle $140: Cellular _nhrm~ $30: Credit card ~t,~h, $140 Cest~ (g) Persons dependent upon you for support (Wife) (Husband) Name: Children, if any: Name: Kayleioh Green Age: 2 months 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unswom falsification to authorities. Weston Green, Jr., Plaintiff WESTON GREEN, JR. : IN THE COURT OF COMMON PLEAS OF PLAINTIFF -' CUMBERLAND COUNTY, PENNSYLVANIA V. KRISTY GREEN : 01-2996 CIVIL ACTION LAW DEFENDANT IN CUSTODY AND NOW, Thursday, May 24, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear beforeJaequeline M. Verney, Igsq. . the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, June 20, 2001 at 1:30 p.m. 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 cfa temporary or permanent order. The eourt hereby directs the parties to furnish any and all existing Protection from Abuse orders, Speeiul Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Is~ Jacqueline M. Verney. Esq. ~ Custody Coociliator 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 ATrORNEY 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 Liberb' Avenue Carlisle. Pennsylvania 17013 Telephone (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Kathy .~. Gorman, : No. 2001-3096 Plaintiff : : Civil Action - Law VS. : In Divorce Jerry L. Gorman, : Defendant : AFFIDAVIT OF SERVICE H. Anthony Adams, Esquire being duly sworn according to law deposes and states that an amended complaint in divorce was mailed to .~erry L. Gorman, of P.O. Box 362, St. Thomas, Pennsylvania, 17252, certified mail, return receipt requested on May 30, 2001 and was accepted on delivery by 3erry L. Gorman on .~une 2, 2001 as shown by the attached receipt. H. Anthony Adams, ~'~ui~ Attorney for Plaintiff' 128 E. King Street Shippensburg, PA 17257 (717)-532-3270 Sworn to and subscribed this ~8th day of 3une, 2001. My Commission Expires!. / UG ZOOt WESTON GREEN, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : V. : NO. 2001-2996 CIVIL TERM ; KRISTY GREEN, : CIVIL ACTION - LAW Defendant : : IN CUSTODY ORDER OF COURT AND NOW, this 23r~ day of August, 2001, the Conciliator being notified that the parties have reconciled and are presently living together with the child, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, ~acqu~ine M. Vemey, Esquire, Custody~on~iliator