The URL can be used to link to this page

Home My WebLink About05-0983 Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. O~ - crf:?:, C!.;u~C--T €/2...""\, : CIVIL ACTION - LAW : CUSTODYIVISITATION MARIA RIVERA, v. DAVID MARK RADCLIFF, Defendant COMPLAINT FOR CUSTODY 1. The Plaintiff is Maria Rivera, residing at 604 Ricketts Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Defendant is David Mark Radcliff, residing at 1902 Breman Lane, Indianapolis, Indiana 46229. 3. Plaintiff seeks custody of the following child: NAME PRESENT RESIDENCE AGE 8 Jennica Marie Radcliff 604 Ricketts Road Mechanicsburg, P A 17050 The child was born out of wedlock. The child is presently in the custody of the Plaintiff, who resides at 604 Ricketts Road, Mechanicsburg, PA 17050. During the past five (5) years, the child has resided with the following persons and at the following addresses: Maria Rivera, Andres Rivera Carlisle, Pennsylvania DATE 2/00 - 4/01 4/01 - 11101 11/01- present NAME RESIDENCE Maria Rivera, Shonna Jones, and Dylan Jones Concorde, California Maria Rivera, Andres Rivera, and Alexis Rivera 604 Ricketts Road Mechanicsburg, PA 17050 The mother of the child is Plaintiff, Maria Rivera, currently residing at 604 Ricketts Road, Mechanicsburg, PA 17050. She is married. The father of the child is Defendant, David Mark Radcliff, currently residing at 1902 Breman Lane, Indianapolis, Indiana 46229. He is divorced. 4. The relationship of the Plaintiff to the child is that of Mother. The Plaintiff currently resides with the following persons: NAME RELATIONSIDP Husband Daughter Daughter Andres Rivera Alexis Rivera Jennica Marie Radcliff 5. The relationship of the Defendant to the child is that of Father. The Defendant currently resides with the following persons: NAME RELATIONSIDP Wesley Chase Radcliff Son 6. 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. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody M the child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because the child has had no contact with Defendant/Father since birth, and both the Plaintiff and Defendant have agreed to the entry of an Order granting Mother sole legal and physical custody of the child, Jennica Marie Radcliff. 8. 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 a party to this action. WHEREFORE, Plaintiff requests the Court to grant an Order giving Plaintiff/Mother sole legal and physical custody of the child. Date:'~d01l:6"> Respectfully submitted, FRIEP.~&)(ING, P.C. i I / I i/ / . i _,/ Attorney for Plaintiff kIp :mrivera\complaint VERIFICATION I, Maria Rivera, hereby acknowledge that I am the Plaintiff in the foregoing action; that I have read the foregoing Complaint for Custody; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn fa!~J'i.fatio!!to authorities. /"'~-- - '------- Dated~ '))-; .?6US-. (.J :::. r:) T'" :- ',\- \l '6 -J ~ ~ --!... - -C , 0- - - ~ <r< w ~ . \ .-~ >'~ ). ..... rG ,\\ C ,. C'.:' . From: 03/15/2005 13:04 #629 P.003/004 MARIA. RIVERA, Plaintiff v. : IN TIlE COURT OF COMMON PLEAS : CUMBERLAND COUN'IY, PENNSYLVANIA : NO. 05-983 Civil Term : IN CUSTODY DAVID MARK RADCLIFF, Defendant STlPf.lL4'lION AND NOW, come the above-named parties, thi~~y of YY1 aA.{/7 . 2005, and state as follows: WHEREAS, the parties wish to enter into an agreement relative to the legal and physical custody of the child, Jenmca Marie Radcliff (date of birth 5/5/96); and WHEREAS, both parties have been provided an opportwtity to review this Stipulation with the counsel of their choice prior to si~; and THEREFORE. in consideration of the mutual covenants, promises, and agreements as hereinafter set forth, and intending to be legally bound hereby, the parties agree as follows: A. Sole legal and physical custody of said minor child shall be with Plaintiff/Mother ,Maria Rivera. B.' Any visitation by Defendant/Father shall be only as agreed to between the parties. . F . . rom. 03/15/2005 13:04 #628 P .004/004 .. WHEREFORE, the parties intending to be legally bound thereby. and with the desire that this Stipulation be entered as an Order of Court at the request of either party. hereby set their hand and seals and on the date first written above. WITNESS: , (S~ef~ /;J~W/;?;t~ (/ kJp:mrlvera \stipulation c..:- -.0 ~-?t r" V -.. '2 4:~-\" V;.,'-' "2-~~ ::;., ('-' #-.- :.:("'1-' Y1"\i>, --,fT', _ht..,.. '-1 -; (:" ...::. > .' c.:) .. C1 (.,: - MARIA RIVERA PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 05-983 CIVIL ACTION LAW DA VlD MARK RADCLIFF DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, March 02, 2005..__, upon consideration of the attached Complaint, it is hereby directed that p<U1ies and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at DJ Manlove's, 1901 State St., Camp Hill, PA t701l on Fridav, A]lril 08, 2005 ____. 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 de tine and narrow the issues to be heard by tile 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 conterence may provide grounds tt,r 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: Isl Melissa P. Greevy, 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 int()fJl1ation 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 HA YE 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (7 I 7) 249-3166 ~~--1~~ -#P ~ ~>1/ ~0-, ~/ fr '% ~'4Ict?pp ,..;., ,r II' 7 ".'1' " I", "q v- cl'i,~SilI1Z ,. o. 50C.F 50 ["- ~ <. )0 c c " Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-983 CIVIL TERM MARIA RIVERA, v. CIVIL ACTION - LAW DAVID MARK RADCLIFF, IN CUSTODY Defendant ORDER TO RELINQUISH JURISDICTION AND NOW, this 18th day of March, 2005, the parties having reached an agreement which has been memorialized in a Stipulation to be filed with this Court, the Conciliator hereby relinquishes jurisdiction of the above captioned matter. (!y~ If ~ MAR 2 3 2005t' ... MARIA RIVERA, Plaintiff : IN THE COURT OF COMMON I1LEAS : CUMBERLAND COUNTY, PENl'I SYLVANIA v. : NO. 05-983 Civil Term DAVID MARK RADCLIFF, Defendant : IN CUSTODY ORDER OF COURT AND NOW, TO WIT, this ~..-V\, day of ,,"-,2005, it is hereby ORDERED and DECREED that the attached Stipulation for Custody, da ~d March 17, 2005, is adopted in its entirety and incorporated herein as an Order of Court. I ! BY THE COURT: .1 .h/ " , " "- '-'-:-P" /7 I II I' I ~} ..~~ ~~.c9 ,rf \j0:J ;,.- 9"~ ;;") ill':::,;.- L~ ("~~ ~..i: fi~ 9.c., CD: Wo- -'Ul !J.....- F U_ o <:0 _7 -r- ;;a: -, ,,_:t" N <Y- 0::::;:( :L: Lf":\ c::.:.> c-.:;) "'"' ~~ u