HomeMy WebLinkAbout04-4254Christine & Richard Erickson,
Plaintiffs
Julia Erickson,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 04 -~ CIVIL TERM
IN CUSTODY
COMPLAINT FOR CUSTODY
The plaintiffs are Christine and Richard Erickson, residing at 2 Mooreland Avenue, Mt.
Holly Springs, Cumber/and County, Pennsylvania 17065.
The defendant is Julia Erickson whose address is unknown at this time.
Plaintiff seeks custody of the following child:
Name
Dariel Erickson
Malijah Erickson
Present Residence DOB
2 Mooreland Ave. 9/17/95
Mt. Holly Springs, PA 17065
2 Mooreland Ave. 2/24/98
Mt. Holly Springs, PA 17065
Age
8 yrs. 11 mos.
6 yrs. 6mos.
Dates
l 2/03 - 2/04
1/04 - 2/04
2/20/04 - 7/4/04
7/04/04 to present
List All Persons List All Addresses
Julia Erickson Safe Harbor
Richard & Christine Erickson 2 Mooreland Ave.
Mt. Holly Springs, PA
Julia Erickson 5245 Bensalem Blvd.
Bensalem, PA 19020
Richard & Christine Erickson 2 Mooreland Ave.
Mt. Holly Springs, PA
The children were bom out of wedlock
The children are presently in the custody of Christine and Richard Erickson, residing at 2
Mooreland Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania 17065.
During the past five years, the child has resided with the following persons and at the
following addresses:
The mother of the children is Julia Erickson whose address is currently unknown.
She is not married.
The father of Dariel is Darrel Brady, currently in Prison.
He is unmarried.
The father of Milajah is Marcus, currently somewhere in Jamaica.
He is unmarried.
The relationship of plaintiffs to the children is that of aunt and uncle.
The plaintiffs currently reside with the following persons.
Name Relationship
Erick J. Erickson Son
Tara M. Erickson Daughter
Jaren Jones Grandson
The relationship of defendant to the child is that of mother.
The defendant currently resides with the following persons.
Name Relationship
Unknown
Plaintiffs have not participated as a party or witness, or in another capacity, in other
litigation concerning the custody of the children in this or another court.
Plaintiffs have no information ora custody proceeding concerning the children pending in
a court of this Commonwealth.
Plaintiffs do not know of a person not a party to the proceedings who have physical
custody of the children and claims to have custody or visitation rights with respect to the
children.
The best interest and permanent welfare of the children will be served by granting the
relief request because:
Plaintiffs has undertaken and performed the primary parental responsibilities for the
children.
Plaintiffis best able to provide the care and nurture which the children need for healthy
development.
Plaintiffs continue to maintain the same family household for the children that has been
maintained since July 4, 2004. The Defendant has moved from the family residence to an
unknown address.
WHEREFORE, Plaintiffs request this Court grant Plaintiff primary physical custody
subject to structured partial custody by the Defendant.
Respectfully submitted,
ROMINGER, BAYLEY & WHARE
Michael J. Whare, Esqui4e
155 S. Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court I.D. # 89028
Attorney for Plaintiffs
Christine & Richard Erickson,
Plaintiffs
Julia Erickson,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 04 - CIVIL TERM
IN CUSTODY
VERIFICATION
MICHAEL J. WHARE, ESQUIRE, states that he is the attorney for, Christine and
Richard Erickson, Plaintiffs in this action; that he makes this affidavit as attorney because he
has sufficient knowledge or information and belief, based upon his investigation of the matters
averred or denied in the foregoing documerit; and that this statement is made subject to the
penalties of 18 Pa. C.S. Pa.C.S. §4904, relating to answorn falsification to authorities.
Date:
Michael J. Whare, Esqui~'
Attorney for Plaintiffs
CHRISTINE & RICHARD ERICKSON
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
04-4254 CIVIL ACTION LAW
JULIA ERICKSON
: IN CUSTODY
DEFENDANT
ORDER OFCOURT
AND NOW, Tuesday, August 31, 2004 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear betbre Hubert X. Gilroy, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, September 29, 2004 at 8:30 AM
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 a~e five or older ma,/also be Cresent at the conference. Failure to aCpear 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 prier to scheduled hearing.
FORTHECOURT,
By: /s/
Hubert X. Gilroy. Esq.
Custody Conciliator
mhc
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 TItlS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATI'ORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FOR'IH BELOW TO F1ND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
CHRISTINE & RICHARD ERICKSON,
Plaintiff
V
JULIA ERICKSON,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
:
: NO. 04-4254
: IN CUSTODY
COURT ORDER
AND NOW, this ~,~ day of October, 2004, the Conciliator being advised that
the parties have reached an agreement, the Conciliator relinquishes jurisdiction.
BY THE COURT,
Custody C~ciliator