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Home My WebLink About11-5384IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA c-' c o -v3 - :r -in Wr- -? 4 CD Gregory M. Rogers No. ?i-s 3Eq ° a )> n =IC =:F =CD VS. 5= o °s?7 c.n A Michelle Sopp PETITION TO PROCEED IN FORMA PAUPERIS Petitioner, Greg M. Rogers, Jr. , requests the Court to allow him/her to proceed without payment of the costs in this matter and in support of such request, has completed the attached Affidavit of Financial Status. a4ul Date Pe i FILED-OFFiCE OF THE PROTHONOTARY 2011 JUL - I AM 10: 59 CUMBERLAND COUNV PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Gregory M. Rogers No. Cl- _ 5? l f ?l vs. Michelle Sopp PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Plaintiff, Gregory M. Rogers Jr. to proceed in forma pauperis. 0) If, simultaneous with the commencement of an action or proceeding or the taking of an appeal, a party has filed a petition for leave to proceed in forma pauperis, the court prior to acting upon the petition may dismiss the action, proceeding or appeal if the allegation of poverty is untrue or if it is satisfied that the action, proceeding or appeal is frivolous. Official Note A frivolous action or proceeding has been defined as one that "lacks an arguable basis either in law or in fact." Neitzke v. Williams, 490 U. S. 319, 109 S.Ct. 1827, 104 L.Ed.2d 338 (1990). Source The provisions of this Rule 240 adopted March 25, 1983, effective April 1, 1983, 13 Pa.B. 1125; amended March 11, 1991, effective July 1, 1991, 21 Pa.13. 1274; amended November 26, 1991, effective January 1, 1992, 21 Pa.B. 5715; amended April 3, 1992, effective immediately, 22 Pa.B. 2221; amended June 3, 1994, effective September 1, 1994, 24 Pa.B. 3018; amended April 19, 1995, effective July 1, 1995, 25 Pa.B. 1767; amended April 12, 1999, effective July 1, 1999, 29 Pa.B. 2266; amended June 8, 2001, effective July 1, 2001, 31 Pa.B. 3305; amended October 22, 2009, effectively immediately, 39 Pa.B. 6426. IN THE COURT OF COMMON PLEAS DISTRICT OF PENNSYLVANIA CUMBERLAND COUNTY BRANCH CIVIL C:: -O3 zrn c z? r Gregory M. Rogers, Jr. VS. CIVIL ACTION- PARTIAL PHYSL-, CUSTODY Michelle Sopp 11 5,39V rho NO. A:fj- OF COMPLAINT FOR Partial custody / Supervised physical custody 1.)The Plaintiff is Gregory M. Rogers, residing at 2166 Mountainview Ave., State College, PA, 16801, Centre, 814-954-2585. 2.)The Defendant is Michelle Sopp, residing at 17 Marshall Dr., Camp Hill, PA, 17011, Cumberland, 717-732-1443. 3.) Plaintiff seeks partial custody / supervised physical custody of the following child(ren): Name Amya J. Sopp Present Residence Date of Birth 17 Marshall Dr. 06/13/2007 The child(ren) was born out of wedlock. The child is presently in the custody of Michelle Sopp who resides at 17 Marshall Dr., Camp Hill 17011 C.:. r-- rr7 CD Z ?y y?? During the past five years, the child has resided with the following persons and at the following addresses: (Names) (Addresses) (Dates) Greg &Jennifer Campbell 17 Marshall Dr., Camp Hill, PA birth-present Jesse Campbell 17 Marshall Dr., Camp Hill, PA birth-present Michelle Sopp 17 Marshall Dr., Camp Hill, PA birth-present The mother of the child is Michelle Sopp currently residing at 17 Marshall Dr., Camp Hill, PA, 17011, Cumberland, 717-732-1443 She is single. The father of the child is Gregory M. Rogers, currently residing at 2166 Mountainview Ave., State College, PA, 16801, Centre, 814-954-2585 He is divorced. 4.)The relationship of Plaintiff to the child is that of father. The Plaintiff currently resides with the following persons: Name Relationship DaeVonn Rogers Leslie Wofford Son Fiancee' 5.)The relationship of Defendant to the child is that of mother. The Defendant currently resides with the following persons: Name Relationship Jennifer Campbell Mother Greg Campbell Father Jesse Campbell Brother 6.)Mother has continually, and completed interfered with Father's relationship with Amya, the child. The Mother has not returned numerous phone calls, txt messages, and letters/cards. The Father has not seen the child in one years time. Pennsylvania's Sect. 23, Statute 5303, Note 572"Hostilities between parents", custody states: "In Granting legal and physical custody of minor child to mother, subject to partial custody of father, trail court adequately considered mother's interference with father's relationship with child, mother's refusal to accommodate relationship between father and child, and father's parenting skills; trial court examined mother's recalcitrance in hindering father's access to child, appropriately drafted specific custody order to preclude mother form denying father access to child, and also concluded that mother moved to Maryland for better job opportunities in her chosen profession. Plowman v. Plowman, 597 A.2d 701, 409 Pa.Super. 143, Super. 1991" 7.)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, including but not limited to: child support, protection from abuse, guardianship, dependency, delinquency, criminal, or mental health. Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth or any other state. Plaintiff knows 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. The name and address of such person is: Michelle Sopp. 8.) The best interest and permanent welfare of the child will be served by granting the relief requested because (set forth facts showing that the granting of the relief requested will be in the best interest and permanent welfare of the children): 9.) 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. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim Wherefore, Plaintiff requests the Court to grant partial of the child(ren). 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. §4904 relating to unsworn falsification to authorities. Plaintiff GREGORY M. ROGERS, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. MICHELLE SOPP, DEFENDANT 11-5384 CIVIL TERM ORDER OF COURT AND NOW, this 10 day of July, 2011, because Plaintiff failed to file an affidavit in support of his petition to proceed in forma pauperis, the court is unable to determine the ability of Plaintiff to pay the costs of litigation. Therefore, the petition to proceed in forma pauperis is DENIED. By the Court, Albert H. Masland, •' Gregory M. Rogers PO Box 145 State College, PA 16804 Michelle Sopp 17 Marshall Drive Camp Hill, PA 17011 :saa eopi't5 mje,,f -)1-7/)l A Z. c? Z te" - n r 0 ter-- , nc? ?? zo ?? x? °r n