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Home My WebLink About05-2544 v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. Of: - J54LI Clu~C-T VL~ CIVIL ACTION - LAW IN CUSTODY LISA A. EDWARDS, Plaintiff BRIAN K, EDWARDS, Defendant COMPLAINT FOR CUSTODY AND NOW COMES Plaintiff, Lisa A. Edwards, by and through her attorneys, Debra D. Cantor, Esquire, and McNees Wallace & Nurick LLC, and files the following Custody Complaint. 1. Plaintiff, Lisa A. Edwards, is an adult individual who currently resides at 456 Stonehedge Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2, Defendant, Brian K. Edwards, is an adult individual who currently resides at 111 Round Ridge Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff seeks custody of the following children: NAME PRESENT RESIDENCE D.O.8. Ashley L, Edwards 111 Round Ridge Road Mechanicsburg, PA 17055 August 21, 1989 456 Stone hedge Lane Mechanicsburg, PA 17055 Megan N. Edwards 111 Round Ridge Road Mechanicsburg, PA 17055 December 13, 1994 456 Stonehedge Lane Mechanicsburg, PA 17055 4, The children were not born out of wedlock, -3- 5. The children are presently in the custody of Brian K. Edwards at 111 Round Ridge Road, Mechanicsburg, Cumberland County, Pennsylvania and Lisa A, Edwards at 456 Stonehedge Lane, Mechanicsburg, Cumberland County, Pennsylvania. 6, During the past five years, the children have resided with the following persons and at the following addresses. NAME Brian K, Edwards Lisa A. Edwards Brian K. Edwards Lisa A. Edwards Brian K. Edwards Lisa A. Edwards Lisa A. Edwards ADDRESS 2245 Wagon Wheel Drive Easton, PA 18040 111 Round Ridge Road Mechanicsburg, PA 17055 111 Round Ridge Road Mechanicsburg, PA 17055 1150 Camp Hill Bypass Camp Hill, PA 17011 456 Stonehedge Lane Mechanicsburg, PA 17055 DATES 1994 to July 2000 July 2000 to September 2004 July 2000 to present September 2004 to January 2005 January 2005 to the present 7. The mother of the children is Plaintiff, Lisa A. Edwards, currently residing at 456 Stonehedge Lane, Mechanicsburg, Cumberland County, Pennsylvania. 8. The father of the children is Defendant, Brian K. Edwards, currently residing at 111 Round Ridge Road, Mechanicsburg, Cumberland County, Pennsylvania. 9. The relationship of Plaintiff to the children is that of mother. The Plaintiff currently resides with the following persons: -4- NAME RELATIONSHIP Ashley L. Edwards Megan N. Edwards Daughter Daughter 10. The relationship of Defendant to the children is that of father. The Defendant currently resides with the following persons: NAME RELATIONSHIP Ashley L. Edwards Megan N. Edwards Daughter Daughter 11. Plaintiff has participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. The Court term and number and its relationship to this action is: Brian K. Edwards, Plaintiff, v. Lisa A. Edwards, Defendant, No. 04-4077 Civil. The Divorce Complaint included a count for custody. No Custody Order has been entered in this action. 12, Plaintiff has information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state, The Court term and number and its relationship to this action is: Brian K. Edwards, Plaintiff, v. Lisa A. Edwards, Defendant, No, 04-4077 Civil. The Divorce Complaint included a count for custody, No Custody Order has been entered in this action. 13. Plaintiff 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. -5- 14. The best interest and permanent welfare of the children will be served by granting the relief requested because: a. Plaintiff has a close, loving relationship with the children; b. Plaintiff can provide a stable home environment for the children; and c. Defendant has demonstrated instability and lack of proper consideration for the best interests of the children by, for example, being abusive to Plaintiff in the presence of the children. 15. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff requests the court to grant shared physical and legal custody of the children to Plaintiff. McNEES WALLACE & NURICK LLC By llliAo.. f;). C1dc~ /lbP Debra D. Cantor, Esq~ire I. D. #66378 100 Pine Street P,O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorneys for Plaintiff Dated: May , to , 2005 -6- VERIFICATION I verify that the statements made in this Complaint are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S4904, relating to unsworn falsification to authorities. '/ ?J . :~,' C ::t~ ~ A. Edw,'" - N~ ~ t ~ ...... -- - C/( -- () r w ...c -.() -J t, tv Q, N) F- i- (; ...', C':' ,'--' c.-.rl o -n ..... T rn ,- -' -" :}:: N .r ....,J LISA A, EDWARDS PLAlNTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, 05-2544 CIVIL ACTION LAW BRIAN K, EDWARDS DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, May 20, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. at DJ Manlove's,l'lQI State St., Camp Hill, PA 17011 on Fridav, July 01, 2005 , thc conciliator, at II :00 AM -..,.."'....-----..,- for a Pre-Hearing Custody Conference, At such confercncc, an effort will be made to rcsoIve thc issucs 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 contercncc may provide grounds for entry of a temporary or permanent order. The court hcreby directs the plITties to furnish any and all existing Protection from Abuse orders, SpecilJl Relief orders, and Custody orders to tbe conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: --E/._. Melissa P. Gr~Esq'_---ctffL- Custody Conciliator f" The Court of Commou 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 HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FlND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249.3166 ~P--./t:' 1!1 ~};JvtJ ~7 c """"",/'1"- _ :r F '(/ ,- ? /t} (7C S' _ .- 71- /P~ l?7)#lI, )Z;.;;eY ~ rzl ~ /V:>1' h:9;/rfJ JiJ-~5 E, '; !,~ -1 ': ~,: ,\ " .,j - ,~. - LISA A. EDWARDS : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff v. : NO. 05-2544 CIVIL TERM BRIAN K. EDWARDS, : CIVIL ACTION - LAW : IN CUSTODY Defendant PRAECIPE TO THE PROTHONOTARY: Please withdraw the Custody Complaint in the above-captioned matter without prejudice. McNEES WALLACE & NURICK LLC By raD. 1. D.#66 100 Pine Street P.O. Box 1166 Harrisburg, P A 17108-1166 (717) 232-8000 Attorneys for Plaintiff Dated: September 20, 2005 CERTIFICATE OF SERVICE Tbe undersigned hereby certifies that on this date a true and correct copy of the foregoing document was served by first-class mail upon the following: Brian K. Edwards 111 Round Ridge Road Mechanicsburg, P A 17055 Dated: September 22, 2005 (') c;;: "TJi":C ;,";\f .., '2:(: 02'" 2:: .:-~( . -~f~: z :::2 ~ C/l r<1 -0 N C) "" :;;: Q. ~:n f;:; ~9 Co .-~j -T't :L4"' ('20 6rn ,,'I <:;; :.Q. Cf! c.n -