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HomeMy WebLinkAbout01-5241JACOB MICHAEL HALL, Plaintiff CHRISTINA G. SWAVOLA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Ot- CIVIL ACTION - LAW CUSTODY COMPLAINT FOR CUSTODY The Plaintiff is Jacob Michael Hall, who currently resides at 625 keSenteir Lane, the following addresses: Jacob M. Hall and Christina 625 Le Senteir Lane, May 28, G. Swavola Harrisburg, PA 17112 7. The relationship of Plaintiff to the child is that of natural father. 8. The relationship of Defendant to the child is that of natural mother. 9. Plaintiff has not participated as a party or wimess, or in another capacity, in other litigation concerning the custody of the child in this or another court. 10. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 1999- August 17, 2001 Harrisburg, PA 17112. 2. The Defendant is Christina G. Swavola, who currently resides at 5 Addams Street, Apt. 3, Enola, Pennsylvania 17025. 3. Plaintiff seeks custody of the minor child, Jacob Michael-Ray Hall, Jr., bom May 28, 1999, who currently resides at 5 Addams Street, Apt. 3, Enola, Pennsylvania 17025. 4. The child was bom out of wedlock. 5. The child is presently in the custody of the Defendant, Christina G. Swavola. 6. During the child's lifet'nne the child has resided with the following persons and at 11. 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 rights with respect to the child. 12. The Plaintiff/Father seeks primary custody for the following reasons: a. Mother is an unfit parent. b. Father has provided a stable home life for the child since the child's birth. 13. Each parent whose parental rights to the child have not been terminated and the person who Nas physical custody of the child have been named as parties to this action. WltEREFORE, the Plaintiff, Jacob Hall, respectfully requests this Court to grant primary physical and legal custody of the child to the Plaintiff. Respectfully submitted, Austin F. Grogan, ~ff~squire// -- Attorney for Plaintiff 24 North 32® Street Camp Hill, PA 17011 (717) 737-1956 ID # 59020 VERIFICATION I, Jacob M. Hall, verify that the statements made in the foregoing Custody Complaint are tree 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. § 4904, relating to unswom falsification to authorities. Jac~. Hall O~ 0 Om: r~ 0 0 JACOB MICHAEL HALL PLAINTIFF V. CHRISTINA G. SWAVOLA DEFENDANT 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-5241 CIVIL ACTION LAW IN CUSTODY ORDER OFCOURT AND NOW, Monday, September 10, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, October 18, 2001 at 9:30 a.m. 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 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 erdsfing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilroy. 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 OCT 8 200i JACOB M. HALL, Plaintiff V CHRISTINA G. SWAVOLA, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01 -5241 CIVIL IN CUSTODY COURT ORDER AND NOW, this ~-6 ~ day of October, 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: This Court Order replaces the prior custody order entered by the Dauphin County Court at Docket No. 2001 - 3819. The Father, Jacob Michael Hall, and the Mother, Christina G. Swavola, shall enjoy shared legal custody of Jacob Michael-Ray Hall, Jr., bom May 28, 1999. 3. The Mother shall enjoy primary physical custody of the minor child. The Father shall enjoy periods of temporary physical custody with the minor child as follows: On altemating weekends f}om Friday at 5:00 p.m. until Monday morning at 9:00 a.m. B. Every Wednesday night t?om 5:00 p.m. until Thursday morning at 9:00 a.m. C. At such other times as agreed upon by the parties. Exchange of custody shall take place at the East Pennsboro Police Department unless agreed otherwise by the parties. The parties shall work between themselves to ensure a shared custody arrangement for holidays. For the Christmas holiday, the parties agree the Father shall have custody of the minor child on Christmas Eve through Christmas Day at Noon, with the Mother having custody of the minor child from Christmas Day at Noon until December 26th at Noon. The parties shall submit themselves to a counseling session arranged by Father under circumstances where the costs of the session are paid for by Father or some social service agency. The sole purpose of these counseling sessions shall be for the parties to address custody/communication issues. This order is entered pursuant to an agreement reached by the parties at a custody conciliation conference. In the event either party desires to modify this order, that party may petition the court to have the case again scheduled with the custody conciliator. CCi David Lopez, Esquire Austin F. Grogan, Esquire BY THE COURT, JACOB M. HALL, Plaintiff V CHRISTINA G. SWAVOLA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01 - 5241 CIVIL IN CUSTODY Prior Judge: CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CWIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the child/children who is/are the subject of this litigation is as follows: Jacob Michael-Ray Hall, Jr., bom May 28, 1999. A Conciliation Conference was held on October 18, 2001, with the following individuals in attendance: The Father, Jacob M. Hall, with his counsel, Austin F. Grogan, Esquire; and the Mother, Christina G. Swavola, with her counsel, David Lopez, Esquire. 3. The parties agree to the entry of an order in the form as attached. DATE Hubert X. ire Custody Cor~iliator