HomeMy WebLinkAbout04-4233THEREA RICHARDS,
Plaintiff
JASON PAUL COOPER
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. Oq' Z/,Z$3
CIVIL ACTION - LAW
CUSTODY
COMPLAINT FOR CUSTODY
1. Plaintiff is Theresa Richards, residing at 130 Waterford, Camp Hill, Pennsylvania 17011.
2. Defendant is Jason Paul Cooper, residing at C/o of Coleen Strain 220 East Court,
Wilmington, Delaware.
Plaimiff seeks custody of the following child:
Nallle
Justin Tyler Cooper
Present Address
130 Waterford
Camp Hill, PA 17011
Date-of-Birth
March 4, 1998
4. The child was bom out of wedlock. The child is presently in the custody of Theresa
Richards, residing at 130 Waterford, Camp Hill, PA.
5. During the past five (5) years, the child has resided with the following persons the
following addresses:
Name
Theresa Richards
Jason Paul Cooper
Coleen Strain
Michael Strain
Betty Kelly
Theresa Richards
Jason Paul Cooper
Theresa Richards
Barbara Henderson (Aunt)
Address
220 East Court
Wilmington, DE
5 Colony Blvd.
Wilmington, DE
Kenmark Drive
Neward, DE
Date
Dec. 2000 - Dec. 2001
Dec2001 - May 2002
May 2002-April 2003
Theresa Richards 1130 Waterford April 2003 - Present
Gary Huether, Jr. Camp Hill, PA
single.
7.
The mother of the child is currently residing at 130 Waterford, Camp Hill, PA. She is
The father of the child is currently residing at 220 East Court, Wilmington, DE.
He is single.
with the following person(s):
Name
The relationship of Plaintiffto the children is that of Mother. Plaintiffcurrently resides
Relationshil~
Gary Heuther, Jr. Significant Other
The relationship of Defendant to the children is that of Father. Defendant currently
resides with the following person(s):.
Name
10.
Relationship
Coleen Strain Mother
Plaintiff has not participated as a party or a wimess, or in any other capacity in other
litigation concerning the custody of the child in this or any other Court.
11. Plaintiff has no information of a custody proceeding concerning the child pending in a
court of this Commonwealth.
12. 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 fights with respect to the child.
13. The best interest and permanent welfare of the child will be served by granting the relief
requested.
14. Each parent whose parental fights to the child has not been terminated and the person
who has physical custody of the child has been named as parties to this action.
WHEREFORE, Plaintiffis seeking to affirm the sole legal custody and primary physical
custody of the child, with fights of partial custody to Father as the parties agree.
Respectfully submitted,
Reager & Adler, PC
2331 Market Street
Camp Hill, PA 17011
(717) 763-1383
Attorney for Plaintiff Theresa Richards
VERIFICATION
I, Theresa Richards, verify that the statements made in the foregoing document are true
and correct to the best of my knowledge, information and belief.
I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904, relating to unswom falsification to authorities.
Date:
THERESA RICHARDS
THERESA RICHARDS
PLAINTIFF
JASON PAUL COOPER
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
04-4233 CIVIL ACT/ON LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Thursda~y, September 02, 2004 _, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear betbre Hubert X. Gilro ~ Es~q:~, the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, October 07, 2004
at 10:30 AM
for a Pre-Hearing Custody Conference. At such conference, m~ et~brt 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 are five or older may also be vresent at the conference. Failure to avpear 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: ~si tIt~ert J(. Gil~y.~__~ mhc
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 O ......
NE, GO ~10 OR IELEPHONE 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
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