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Home My WebLink About01-3461 JUN 11 200~ rfl I , s '. DONALD McCAUSEL YN Pia intiff/Petitioner v. IN THE COURT OF COMMON 1:11.. PeS ( CUMBERLAI"JD COUNTY, PEN/'I; 'LV! NO: 01- 34(..,1 ~:.ru -T~ LEISA WYATT, Defendant/Respondent CIVIL ACTION. FAMIl.Y DIVISi (I CUSTODY ORDER OF COURT AND NOW, this cr fL day of ~\) l, , 2001, after con:3id,~ra' i :>f I Plairtiff's Petition for Custody, it is hereby ordered and deemed that Plaintiff, Dona: kC: is granted joint legal and primary physical custody of the minor child, Aaron Christo::: p McCauselyn, subject to liberal periods of temporary custody in the Defendant, as agi': c t I between the partes. IT IS FURTHEn ORDERED, Defendant, Leisa Wyatt, is granted joint It!.. I al I primary physical custody of the minor child, AndreV\ Jeul Mc8auselyn, sJbject tc lit" i P( I temporary custody in the Defendant, as agreed to between the puties. BY THE COURT: ~il-. ~ '. DONA.LD McCAUSLIN Plai ntifflPetitioner v. IN THE COURT OF COMMON FJI..' AS DF CUMBERLAND COUN"TY, PENI'I~ 'LV!!' . NO: DI- 3'1"1 ~ I.t.- LEISA WYATT, Defendant/Respondent CIVIL ACTION - FAMILY DI1/ISI [1 CUSTO DY PETITION FOR CUSTODY AND NOW, comes Plaintiff DONALD McCAUS IN, and by his attorne)', Jji Ii Dolgos, respectfully represents as follows: COUNT I. CUSTODY OF AARON CHRI STOPHER McCAUSLIN 1. Plaintiff, DONALD McCAUSLIN, is an cldult individual SJ.ll Luri~!" SIOl~ 14458 Holly Pike, Cariisle, Cumberland County, Pennsylvania, 17013. 2. Defendant, LEISA WYATT, is an adult individual .sill iuri~i, resid! r a1 - Old Forge Road, New Cumberland, Cumberland Courty, Pennsylvania. 3. Plaintiff and defendant have been bonafide residents of this Cc: ime L for at least six (6) months immediately previous to tre filing of this Petition. 4. Plaintiff requests an award of joint legal custody and primary I: )/SI',. custody of the minor child, Aaron Christopher McCauslin, born March 26, 11~ln 5. The child is presently in the physical custody of the plaintiff. 6. The mother of the child is Leisa Wyatt, defendant in the instcl i leti: 7. The father of the child is Donald McCciuslin, plaintiff in the im",: c :'i 8. The minor child, Aaron Christopher M:Causlin, has resded a e f( !. addresses with the following persons: a. From his birth on March 26,1988 un1i11993, said minor chile as .- with both plaintiff and defendant and with Andrew JU':l1 McCauslin, born Augu: 9 :- b. Since mid 1993 until mid 1994, said minor child has ',: Ice: defendant and Andrew Juel McCauslin. c. Mid 1994 until 1996 with defendant and Andrew Juel f,/ Ca I; Florida. d. Mid 1996 until fall of 1998 with defendant and Andre"~ Jel McCauslin in Tennessee. e. Fall of 1998 with defendant ar d her husband, Chad Wlt a \- Andrew Juel McCauslin in Pennsylvania. f. December 1998 until April 2000 with plaintiff and hi~ \'. e 1\ ( McCauselyn at 1445B Holly Pike, Carlisle, Cumberland County, Pennsylvani :i, 70 g. April 2000 with defendant and her husband, Chad WyC3! an I Andrew Juel McCauslin at 856 Old Forge Road, New Cumberland, Cumberlalll: 20Lllc Pennsylvania. h. Summer of 2000 until present with plaintiff ancl his VI'!1: ~"li( (. McCauslin at 1445B Holly Pike, Carlisle, Cumberlanc County, Pennsylvania, 1 ).'.~. 9. Plaintiff and defendant were parties te, a previous custody acli: re j from a PFA in Cumberland County in 1992, at no. 2lJ Civil 1992, this actio' , is dismissed on February 12, 1996. 10. No person(s) not a party to this transclction are known to the~: irt: have had physical custody or claims to custody or vi~ itation with regard to th.: jalC child. '. 11. The best interest and permanent welfare of the said child wil I' se \ granting legal custody and primary physical custody to plaintiff, with liberal) iod j temporary custody to defendant, as agreed to betweE!n the parties, because ::, lUn " benefits to the child which would result from this ongoing stable relati ::>nshil:" ::i t " and love that would be provided to him. 1 ~~. Each parent whose parental rights to ':he child have 110t been t: rrq j and the person who has physical custody of the child have been named as (:,I!' es I) action. WHEREFORE, Plaintiff requests this Honorable Court to enter an Orcl,: I ~;,a I. joint legal and primary physical custody of the minor child, Aaron Cnristophn ~cC: i to plaintiff, subject to liberal periods of temporary custody in the defendant, c' agl: i between the parties. COUNT II. CUSTODY OF ANDRE'" JUEL McCAUSUN 13. Paragraphs 1 through 3 above are incorporated herein and n 8 a I' . hereof as if set forth in full. 14. Plaintiff requests an award of joint legal custody and primary r; ySI", custody of the minor child, Andrew Juel McCauslin, torn August 9, 1989 be r ce .' defendant in this matter. 15. The child is presently in tre physical custody of the plaintiff. 16. The mother of the child is Leisa Wyatt, defendant in the instclt lcti: 17. The father of the child is Donald McCcluslin, plaintiff in the im "c: 18. The minor child, Andrew Juel McCaus in, has resided at the fo wlr; addresses with the following persons: a. From his birth on August 9, 1989 until 1993, said mill ch resided with both plaintiff and defendant and with Aa ron Christopher 1'/lcCaL:;1 ,b I March 26, 1988. b. Since mid 1993 until mid 1994-, said minor child has ': ICE: defendant and Aaron Christopher McCauslin. c. Mid 1994 until 1996 with defendant and Aaron Chris:c i ler McCauslin in Florida. d. Mid 1996 until fall of 1998 with defendant and Aamn Crist: McCauslin in Tennessee. e. Fall of 1998 with defendant ard her husband, Chad W~,t a L Aaron Christopher McCauslin in Pennsylvania. f. December 1998 until April 2000 with plaintiff and hi~ ,\ E ~ McCauselyn at 14458 Holly Pike, Carlisle, Cumberland County, Penn5ylvani:l, 70 Aaron Christopher McCauslin. g. April 2000 with defendant and her husband, Chad Wya I en I . Christopher McCauslin. h. Summer of 2000 until present with plaintiff and his wd, t'l1ic \ McCauslin at 14458 Holly Pike, Carlisle, Cumberlanc County, Pennsy!vania,] ):..~. 19. Plaintiff and defendant were parties tc. a previous custody act i:: re j from a PFA in Cumberland County in 1992, at no. 21:> Civil 1992, this actio'! , ::s dismissed on February 12, 1996. 20. No person(s) not a party to this transclction are known to the~. i:~t: have had physical custody or claims to custody or vi~ itation with regard to tho ialC child. 21. The best interest and permanent welfare of the said child wil I. 5e \ granting legal custody and primary physical custody to defendant, with libet:l len)~ temporary custody to plaintiff, as agreed to between the parties, because of I-I YJ2!: benefits to the child which would result from this ongoing stable relatJnshir:; d t 1: and love that would be provided to him. 22. Each parent whose parental rights to ':he child have not been t: ml! 1. and the person who has physical custody of the child have been named as 1=.:11' esu action. WHEREFORE, Plaintiff requests this Honorable Court to enter an Orcll: I ;:a \.. joint legal and primary physical custody of the minor child, Andrew ju,=1 McCi 3: r defendant, subject to liberal periods of temporary cu,tody in the plaintiff. a~, ,I ree: between the parties. Respectfully submitted, Date: ~f/P S ,C/()Ol " By: C)JA~~"f1fr7fC() ~{h F. Dolgos,-E;qJ~, --. Attorney 10 68738 P.O. Box 60809 Harrisburg, PA 17106-0: '9 (717) 541.9660 Attorney for Pl3intif1' '. VERIFICATION I verify that the statements made in this Petition for Custody are tru:~ :, ld ( ~); 2~t I understand that false statements herein are made subject to the penalties Ji .8 ['3. S. ~4901 relating to unsworn falsifications to authoritie~,. Dated :'\7j.<J {. :2 ZOO, U" ! j 'J1Q~ {- Donald McCausl' ,~1 /( /' v. IN THE COURT OF COMMON PL':AS or CUMBERLAND COUNTY, PENI~~, fLV,~J~;A. NO: 0/_ 3'-1<" ~ -'.L- CIVIL ACTION. FAMilY DIVISIO j CUSTODY DONALD McCAUSLIN Plaintiff LEISA WYATT, Defendant JOINDER FOR CUSTODY AND NOW, comes Defendant, LEISA WYATT, and respectfully represents as fed )W~ 1. The address of defendant is 856 Old Forge Road, New Cumb,~1 . nd. Cumberland County, Pennsylvania. 2. Defendant is the mother of the minor :hildren, Aaron Christopr' McCauslin and Andrew Juel McCauslin. 3. Plaintiff is the father of the minor children, Aaron Christopher ' :<~( l ! and I\ndrew Juel McCauslin. 4. Defendant has reviewed plaintiff's Petition for joint legal custody ancl [: -:12 'j physical custody of the said minor children and joins in plaintiff's request tt1a1 prim" ph: custody of Aaron Christopher McCauslin be with the plaintiff, sub.!ect to periods of I" al temporary custody in the defendant as agreed to between th~ parties. 5. Defendant further joins in plaintiff's request tl1at she be granted Joint ~al 1: primary physical custody of Andrew Juel McCauslin subject to periods of liber:!1 tempc.a ') custody in plaintiff as agreed to between the parties. 6. Plaintiff and defendant agree that such custody arrangement is in the L 35t J":rES~ of th,~ minor child. . WHEREFORE, Defendant LEISA WYATT, joins with plaintiff in reques1 r' thi; Honorable Court grant the plaintiff he rete joint legal and primary physical CL~; ,dy ,:f minor child Aaron Christopher McCauslin, and joint legal and primary physica, :us'odyof Andrew Juel McCauslin be granted to defendant, sutject to periods of temj:Y: ry cu s:::;dy as agreed to between the parties. Dated: b - --s -()/ /~(L1~~) 6. ~ LEISA VJYATT (' . DONALD McCAUSEL YN, Plai ntiff/Petitioner v. IN THE COURT OF COMMON 1:11.. AS I J CUMBERLAND COUNTY, PENI'I: 'LVt NO: 0 I~ 3lj(, ( ~ ",;...-- LEISA WYATT, Defenda nt/Respondent CIVIL ACTION. FAMIl.Y DIVISI U I ENTRY OF APPEARANCE To the Prothonotary: Please enter my appearance on behalf of Plai ltiff, DONALD McCAUS::. ''I, above custody matter. Respectfully submitted By: , -.4JW . .' ~~1CrC==--- Ith F. Dolgos, Esqu 0' torney ID 68738 P.O. Box 60809 Harrisburg, PA 17106-0: .j (717) 541-9660 Attorney for PI:=! i ntifl' JUN 2 5 2001 'ff OONALD McCAUSELYN, Plaintiff . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND caJNTY, PENNSYLVANIA . . . . vs. : NO. 01-3461 CIVIL TERM . . : CIVIL ACTION - LAW LEISA WYATI', . . Defendant : IN CUSTODY aIDER OF caJRT AND R:Ii, this 22nd day of June, 2001, the Conciliator, being advised by Plaintiff1s counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction in this case. The CUstody Conciliation Conference scheduled for July 3, 2001 is canceled. FOR THE COURT, L r, r-. SfP () 3 tOOt' 5 Donald McCauslin IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. Leisa Wyatt 01-3461 CIVIL ACTION-FAMILY DIVISION CUSTODY Defendent ORDER OF COURT AND NOW, this -_5li. day of --~~-""-~-U--, 2002, after consideration of the Plaintiff's Petition for Custody, it is hereby ordered and decreed that Plaintiff, Donald McCauslin is granted joint legal and primary physical custody of the minor child, Andrew Juel McCauslin, subject to liberal periods of temporary custody to the Defendant, as agreed to between the parties. Donald McCauslin is therr of temporary custody, as agreed to between the parties. C~fl~t 1::(j: Deft PLR ~. bo\~os BY THE COURT f_vf!t.~f !. ; ~ . ~ Donald McCauslin IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. 01-3461 CIVIL ACTION LAW Leisa Wyatt Defendant IN CUSTODY PETITION TO MODIFY CUSTODY ORDER Come now Donald McCauslin, Plaintiff and Leisa Wyatt, Defendant to petition the court to modify custody of Andrew Juel McCauslin to grant joint legal and primary physical custody of the minor child Andrew McCauslin to Plaintiff, Donald McCauslin~ subject to liberal periods of temporay custody to the Defendant as agreed to between the parties. WHEREFORE, said plaintiff Donald McCauslin,and defendant Leisa Wyatt;request that the Court enter an order granting joint legaliand primary physical custody of the minor child/Andrew Juel McCauslin to the plaintiff and liberal periods of temporary custody ISo ~h~ Defindanas agreed to between the parties. 1121tLJ;bJi(~L&~ DONALD M~USLIN Plaintiff ~A'~~TT ~J~I-_ ..- Defendant STATE OF PENNSYLVANIA ss: COUNTY OF CUMBERLAND Before me, a Notary Public in and for said County personally appeared Donald McCauslin, who acknowledged execution of the foregoing to be his voluntary act ird verified the truth thereof. { pZ ~~y of and State, the deed and ~~~~S~O~~.hand and Notarial Seal this NOTARIAL SEAL . ROBERT F. SUMBURY, Notary PublIC Mechanicsburg, Cumberland County -- My commission Fy"irRS N~vember1. 2005 My Commission Expires , . STATE OF TENNESSEE ss: COUNTY OF CUMBERLAND Before me, a Notary Public in and for said County and State, personally appeared Leisa Wyatt, who acknowledged the execution of the foregoing to be her voluntary act and deed and verified the truth thereof. WITNESS my hand and Notarial Seal this _l~- day of ~~~__, 2002. ~~;:~~~:;~2~~:~:- - t .~ _L~dzlj__ Nota~ Public Residing in Cumberland County, Tennessee I . . VERIFICATION I, Donald McCauslin, certify that the statements made in the foregoing PETITION TO MODIFY CUSTODY AND STIPULATION OF THE PARTIES, are true and correct to the best of my knowledge and belief. I understand that false statements herein are made subject to the penal': es of 18 Pa. C.S.A, C, 4904, relating to unsworn falsification to authorities. Dated: 8/2&/D2- ~....~---,--_. ' ~ ~ -,.:::::- b -. '- ~ ~ ~ -c: 0 V\ -.l\) () 0 0 r--...') -(1 ~ ~ :P" .-' -:> ~::: ~ -c W \..1'"") CQ <;:> ~ :,s. t..) tr. '- .~' (--') C) ... 0 r-"'; ::>1\ ~ ~ , . 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