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HomeMy WebLinkAbout02-0668RUTH ANN R. FREDERICK, Plaintiff BOBBY E. FREDERICK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA i NO. 20o2-( CIVIL : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Ruth Ann R. Frederick, an adult individual currently residing at 35 West Main Street, Plainfield, Cumberland County, Pennsylvania 17081. 2. Defendant is Bobby E. Frederick, an adult individual currently residing at 6 St. William Drive, Newville, Cumberland County, Pennsylvania 17241. 3. The Plaintiff is the natural mother of the child, Savannah Dianne Frederick, bom November 25, 1996. 5. following addresses for the following lengths of time: The child was bom in wedlock· For the past five years, the child has resided with the following persons at the NAME Ruth Ann Frederick 35 West Main Street Plainfield, PA 6 St. William Drive Newville, PA Ruth Ann Frederick Bobby Frederick married. 7. married. DATER February 3, 2002 to Present Birth to February 3, 3002 The natural Mother of the child is the Plaintiff, who resides as foresaid. She is The natural Father of the child is the Defendant, who resides as foresaid. He is 8. The relationship of the Defendant to the child is that of natural Father. The Defendant currently resides alone. 9. The relationship of the Plaintiff to the child is that of natural Mother. The Plaintiff currently resides with the child. 10. The Plaintiff has no information of a custody proceeding concerning the child pending in any Court of this Commonwealth. 11. The best interest and permanent welfare of the child will be best served by granting the relief requested as the Plaintiff is better suited to provide a stable environment to foster the child's well being. 12. The Plaintiff does not know of any person not a party to the proceedings who claims to have custody or visitation rights with respect to the child. WHEREFORE, the Plaintiff, Ruth Ann R. Frederick, respectfully requests this Honorable Court to enter an Order scheduling the Parties for a Custody Conciliation. Date: February 6, 2002 Respectfully submitted, Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 VERIFICATION I verify that the statements made in this Complaint are tree and correct. I understand that false Statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. RIJ~I-~ANlq R. FREDERICK, Plaintiff RUTH ANN R. FREDERICK, Plaintiff BOBBY E. FREDERICK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-668 CIVIL TERM : : CIVIL ACTION - LAW : IN CUSTODY AFFIDAVIT OF SERVICE AND NOW, this 13th day of February 2002, comes Thomas S. Diehl, Esquire, Attorney for the Plaintiff, Ruth Ann R. Frederick, and states that he had cause to be mailed a certified copy of a Complaint for Custody to the Defendant, Bobby E. Frederick, by certified, restricted delivery, return-receipt requested. A copy of said receipt is attached hereto indicating service was made on February 9, 2002. Respectfully submitted, Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX =.mi · Complete items 1, 2, and 3. Also complete Item 4 if Rest]tcted Deliver/is desired. ' · Pdnt your name and address on the reverse so that we can retum the card to you. · Attach this card to the back of the mailpiece, o~ on the fl'ont if spac~ permits. 1. Article Addr~sed to: BBY E. FREDERICK ~R WILLIAM DRIVE a ..~'~'I~E, PA 17241 2..~llcle Number 7(~1 ~r~,ns~r~om~,Wce~a~v_ 2510 0009 2828 6535 PS Form 3811, March 2001 Domestic Return Receipt RUTH ANN R. FREDERICK : : PLAINTIFF V. : 02-668 BOBBY E. FREDERICK DEFENDANT : IN CUSTODY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW AND NOW, Friday, February 15, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, March 13, 2002 at 8:30 AM for a Pre-Heating 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 beard 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 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: /s/ facqueline M. Verney. 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 RUTH ANN R. FREDERICK, Plaintiff BOBBY E. FREDERICK, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-668 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY PRAECIPE TO DISMISS TO THE PROTHONOTARY: Please dismiss the above-captioned custody action that I have filed on behalf of Ruth Ann Frederick. A Custody Complaint was previously filed in this matter by the above-captioned Defendant, Bobby E. Frederick, and docketed to Civil Action 2002-651 In Custody. DATE: FEB 2 ? 2002 Respectfully submitted: ~. Diehi, Esquire Attorney for Plaintiff One West High Street, Suite 208 Post Office Box 1290 Chambersburg, Pennsylvania 17201 (717) 240-0833 cc: Jacqueline Vemey, Esquire/Conciliator Plaintiff