HomeMy WebLinkAbout05-2473
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JENNY L. BROWN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
DWAYNE DUDLEY,
Defendant
NO. 2005- ,;;{LJ7J
CIVIL ACTION-LAW
IN CUSTODY
CIVIL TERM
COMPLAINT FOR CUSTODY
1. Plaintiff is Jenny L. Brown, an adult individual, currently residing at 342 East
Garfield Street, Shippensburg, Cumberland County, Pennsylvania 17257.
2. Defendant is Dwayne Dudley. an adult individual, whose mailing address is 803
Middle Drive, Chambersburg, Franklin County, Pennsylvania 17201.
3. Plaintiff seeks custody of the following child: Camdyn D.L. Dudley, born January
26, 2005.
The child was born out of wedlock.
The child is presently in the custody of Plaintiff, who resides at 342 East Garfield
Street, Shippensburg, Cumberland County. Pennsylvania.
The child has resided with the Plaintiff at 342 East Garfield Street,
Shippensburg, Cumberland County, Pennsylvania since his birth on January 26, 2005.
The natural mother of the children is Jenny L. Brown, currently residing 342 East
Garfield Street, Shippensburg. Pennsylvania.
She is not married.
The natural father of the children is Dwayne Dudley, whose mailing
address is 803 Middle Drive, Chambersburg, Pennsylvania.
He is not married.
4. The relationship of the Plaintiff to the child is that of natural mother. The
plaintiff currently resides with the following persons:
(a) Mackayla LA Brown
(b) Branson J.E. Brown
(c) Camdyn D.L. Dudley
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5. The relationship of the Defendant to the child is that of natural father.
6. Plaintiff has not participated as a party or witness, or in any other capacity in
other litigation, concerning the custody of the child in this or in any other Court.
Plaintiff has no information of a custody proceeding concerning the child pending
in a court of this Commonwealth.
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.
7. Each parent whose parental rights to the child has not been terminated and the
person who has physical custody of the child has been named as parties to this action. All
other persons, named below, who are known to have or claim a right to custody or visitation of
the child will be given notice of the pendency of this action and the right to intervene.
NAME
ADDRESS
BASIS OF CLAIM
None.
WHEREFORE, Plaintiff requests your Honorable Court to grant her primary physical
custody of the child.
Respectfully submitted.
O'BRIEN, BARIC & SCHERER
~tfYV
Mich el A. Scherer, Esquire
1.0.61974
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
mas\Oomestic\Brown,Jenny\custody.comp
I I
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JENNY L. BROWN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
DWAYNE DUDLEY,
Defendant
NO. 2005-
CIVIL ACTION-LAW
IN CUSTODY
CIVIL TERM
II
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VERIFICATION
I verify that the statements mClde in the foregoing Complaint for Custody are true and
correct. I understand that false statements herein are made subject to the penalties of 18 Pa.
C.S. S 4904, relating to unsworn falsification to authorities.
DATE: April Oi 7 . 2005
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JENNY L. BROWN
PLAINTIFF
v.
DW A YNE DUDLEY
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
05-2473 CIVIL ACTION LAW
IN CUSTODY
ORDER OF' COURT
AND NOW.
Tuesda , '!'ll}' 17,2005
__, upon consideration ofthe attached Complaint,
it is hereby directed that parties and thei respective counsel appear before Hubert X. Gilroy, Esq.
at 4th Floor, Cumberland Coun C nrthouse, Carlisle on __ Friday, June 03, 2005
, the conciliator,
at 8:30 AM
for a Pre-Hearing Custody Conference. t 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 ma also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporar or permanent order.
The court hereby directs tbe p rties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody or ers to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/
Hubert X Gilrov. E~~Y~
Custody Conciliator
The Court of Common Peas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of ] 990. For' formation about accessible facilities and reasonable accommodations
available to disabled individuals h ving business before the court, please contact our office. All arrangements
must be made at least 72 hours pri r to any hearing or business be/ore the court. You must attend the scheduled
conference or hearing.
yau SHOULD TAKE HIS PAPER TO YOUR ATTaRNEY AT ONCE. IF yaU DO' NUT
HAVE AN ATTORNEY OR CA NOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT HERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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RECEIVED JUN 13 2005 ;f
JENNY L. BROWN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
CIVIL ACTION - LAW
DWAYNE DUDLEY,
Defendant
NO. 05-2473
IN CUSTODY
COURT ORDER
AND NOW, this l.AI\ day of June, 2005, upon consideration of the attached
Custody Conciliation report, it is ordered and directed as follows:
1. The mother, Jeuny L. Brown, shall enjoy legal custody of Camdyn D.L. Dudley, born
January 26, 2005.
2. The father, Dwayne Dudley, shall enjoy periods of temporary custody with the minor
child at such times and under such circumstances as agreed upon by the parties.
3. It is noted that this Order is entered after a Custody Conciliation Conference which was
not attended by the father. Ifthe father desires to modify this Order, father may petition
the Court to have the case again heard by the Custody Conciliator. If a hearing is
scheduled at any time in this case, this Order shall at that point be deemed to have been
a temporary Order and not based upon any determination of the Court.
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2005 JUN ! 4 PN 4: 00
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JENNY L. BROWN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v
CIVIL ACTION - LAW
DWAYNE DUDLEY,
Defendant
NO. 05-2473
IN CUSTODY
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE' OF
PROCEDURE 19I5.3-8(b), the undersigned Custody Conciliator submits the following
report:
1. The pertinent information pertaining to the child who is the subject of this litigation
is as follows:
Camdyn D. L. Dudley, born January 26,2005.
2. A Conciliation Conference was held on June 3, 2005, with the following individuals in
attendance:
The mother, Jeuny L. Brown, with her counsel, Michael A. Scherer, Esquire.
The father did not attend the conference. However, Attorney Scherer indicated that
notice of conference was sent to the father regular mail, with that letter not being
returned. Also, a similar notice was sent certified mail, return receipt requested, and
that document was returned unclaimed. Additionally, mother related that she and the
father have been separated since April 1" and the father has not seen the child since
that time and mother has had custody of the child.
3. Based upon the above, the Conciliator recommends and Order in the form as
attached.
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Conciliator