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Home My WebLink About04-6154ANDREA N. NELSON, Plaimiff go SYLVESTER M. MCADOO, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION-LAW : CUSTODY / : NO. CIVIL TERM COMPLAINT FOR CUSTODY The plaintiff, Andrea Nelson, by her attorneys, the Family Law Clinic, sets forth the following action: 1. The plaintiff is Andrea N. Nelson, residing at 1387 Grandview Court, Carlisle, Cumberland County, PA 17013. 2. The defendant is Sylvester M. McAdoo, residing at 2436 Derry Street, o Name Jelani Nelson Harrisburg, Dauphin County, PA 17111. Plaintiff seeks custody of the following child: Present Residence 1387 Grandview Court Carlisle, PA 17013 The Child was bom out of wedlock. Date of Birth 8/31/98 The Child is presently in the custody of Andrea N. Nelson, who resides at 1387 Grandview Court, Carlisle, PA 17013. During the past six years, the Child has resided with the following persons and at the following addresses: Persons Andrea Nelson Address 279 E. Pomfret Street Carlisle, PA 17013 Dates August 1998-September 1999 Andrea Nelson October 1999-September 2000 158 ½ E. North Street Carlisle, PA 17013 Andrea Nelson 102 W. High Street Carlisle, PA 17013 September 2000-February 2001 Andrea Nelson 1397 Grandview Court Carlisle, PA 17013 February 2001-October 2003 Andrea Nelson Khaliese McReynolds 1387 Grandview Court Carlisle, PA 17013 October 2003-Present 4. The Plaintiff, mother of the Child, hereinafter "Mother," currently resides at 1387 Grandview Court, Carlisle, PA 17013. She is single. 5. The, Defendant, father of the Child, hereinafter "Father," currently resides at 2436 Derry Street, Harrisburg, PA 17111. He is single. 6. The relationship of the plaintiff to the Child is that of mother. Mother resides with the following persons: Name Khaliese McReynolds Relationshio Daughter 7. The relationship of the defendant to the child is that of father. Father currently resides with the following persons: Name Relationshio Unknown 8. Mother 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. Mother has no information of a custody proceeding concerning the Child pending in a court of this Commonwealth or any other state. Mother does not know of a person not a party to the proceedings who has physical custody of the Children or claims to have custody or visitation rights with respect to the Children. 9. The best interest and permanent welfare of the Child will be served by granting the relief requested because: (a) Plaintiff has been the primary caretaker of the Child since birth; (b) Plaintiff provides the Child with a home with the necessary moral, emotional, and physical surroundings to meet their needs; (c) Plaintiff continues to exercise parental duties on behalf of the Child and enjoys the love and affection of the Child; (d) Plaintiff is willing to grant the Father periods of partial custody to facilitate the development of a strong parent/child relationship with both parents. 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, Mother requests the Court grant primary physical custody of Child, Jelani Nelson, to Mother, with Father having periods of partial physical, custody. / ~ Date: ~/~' 0~1 ~OOq e~?fer ~/mi J tro-vich C~'rtified Legal Intern THOMAS M. I~LACE ROBER~ E. ~AINS LUCY JOXI"INSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 VERIFICATION I verify that the statements made in this Custody Complaint are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: ~.~ · (t~ / ~ ~~k~, ~ Andrea N. Nelson, Plaintiff ANDREA NELSON, Plaintiff SYLVESTER MCADO0, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE · NO. 2004- ' CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Andrea Nelson, Plaintiff, to proceed in forma pauperis. I, Jennifer Smitrovich, Certified Legal Intern for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Certified Legal Intern ucy ~n-Walsh~ /., Anne M~cDonald-Fo~ Thomas Place Robert Rains Supervising Attomeys The Family Law Clinic 45 N. Pitt Street Carlisle, PA 17013 (717) 243-2968 ANDREA N. NELSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION-LAW : CUSTODY SYLVESTER M. MCADOO, Defendant : NO. 04-6154 CIVIL TERM CERTIFICATE OF SERVICE I hereby certity that I served a true and correct copy of the Custody Complaint on Sylvester McAdoo, residing at 2436 Derry Street, Harrisburg, P A 17111, by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Sylvester McAdoo on the fourth day of January 2005 as evidenced by his signature on the attached return receiP1, I /l/{ Dated:(1~ II) blooS- ~fuPsm~c" f u Certified Legal Intern F AMIL Y LAW CLINIC 45 N. Pitt Street Carlisle, P A 17013 (717) 243-2968 . ~omp'~te items 1, 2, and 3. Also complete Item 4 If Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailplece, or on the front if space permits. 1, Article Addressed to: 5\/ \veJk y Me MOl! {) '--(3lc U 1"'0\ cA- t\e,-Y(\~b\)YJ ~ )1\\\ 7, , 0 ,.,; ;:?/f/,. /~.. . Agent /,,. t~ Add~see 'ntOO Name) C. Date of Delivery -I/-c) S-' D. Is delivery dd/19SS different from Item 1? 0 Yes If YES, enter doli very address below: 0 No 3. Service Type ~ertified Mail 0 Express Mail o Registered ..:a:..s..eturn Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted DelivE'ry? (Extra Fee) )itye. 2. 7003 3110 0004 5774 2655 PS Form 3811 . August 2001 Domestic Return Receipt 1 02595-02-M-1 035 -~ fi, r-',"i ,--or -" u') ..-!' ,IAN 1 4 2005 ANDREA NELSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2004-6154 CIVIL TERM SYLVESTER McADOO, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this --2:l1L- day of :l2J1 ,2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Andrea Nelson shall have sole legal and physical custody of Jelani Nelson, born August 31,1998. 2. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modifY the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, c~nnifer Smitrovich, certified legal intern, . Lucy Johnston-Walsh, Esquire, Family Law Clinic, counsel for Mother ~lvester McAdoo, pro se 2436 Derry Street Harrisburg, P A 17111 ViNVf\IASNf{3d A1Nn():".,~ (}:-.)'_r~\::J\:Jt~nJ 02 :! I \>IV 52 ~JVr ~nnl }J:l\ilONOH1D2d :1H1 :lO 3~!1,:HO-o3l1:l ANDREA NELSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : 2004-6154 CIVIL TERM SYLVESTER McADOO, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY 1N CUSTODY OF Jelani Nelson August 31, 1998 Mother 2. A Conciliation Conference was held in this matter on January 13,2005, with the following individuals in attendance: The Mother, Andrea Nelson, with her counsel, Jennifer Smitrovich, certified legal intern, Lucy Johnston Walsh, Esquire, Family Law Clinic and Father, Sylvester McAdoo, pro se. 3. The parties agreed to an Order in the form as attached. / - I 3 -0 ~ Date 9~~( ~,L ac elme M. Verney, EsqUlre Custody Conciliator ~ (j