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Home My WebLink About05-3731 DANELLE R. WELKER IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V ANlA Plaintiff v. NO.: 05'3131 CIVIL TERM JOEY EDWARD WILLLIAMS CIVIL ACTION - LAW Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Danelle R. Welker, who currently resides at 314 North Middlesex Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Joey Edward Williams, who currently resides at 205 F. Stockton Way, Greensboro, NC 27406. 3. The Plaintiff seeks sole legal custody of the following child: Name: Tyler Renee Williams Date of Birth: J anuaty 3, 2000 Address: 314 North Middlesex Road, Carlisle, Cwnberland County, Pennsylvania 17013. 4. The child was born out of wedlock. The child is presently in the custody of Danelle R. Welker, who resides at 314 North Middlesex Road, Carlisle, Cwnberland County, Pennsylvania 17013 5. During the child's lifetime, she has resided with the following persons and at the following addresses: Name Danelle Welker Address 1414 Bradley Drive, Carlisle, P A 314 Middlesex Road, Carlisle, PA Date Birth - 5/2003 Danelle Welker, Donald & Deborah Welker OS/2003 to present The mother of the child is Danelle R. Welker, who resides at 314 North Middlesex Road, Carlisle, Cumberland County, Pennsylvania 17013. 6. Mother of the child, Danelle R. Welker, is not married. 7. The father of the child is Joey Edward Wilfums, who currently resides at 205 F. Stockton Way, Greensboro, NC 27406. 8. Father of the child, Joey Edward Williams, is not married. 9. The relationship of Plaintiff to the child is that of Mother. 10. The relationship of Defendant to the child is that of Father. 11. The 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 any other court. 12. The Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 13. The 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. 14. The best interest and permanent welfare of the child will be served by granting the relief requested for reasons including the following: a. The Mother has been the primary caregiver of the minor child since her birth. She has: 1. Planned and prepared meals; 11. Bathed, groomed and dressed the child; 111. Purchased, cleaned and cared for the child's clothing; IV. Arranged medical care, including trips to physicians; v. Arranged alternative daycare; VI. Put the child to bed nighrly, attended the child in the middle of the night, and awakened the child in the morning. b. The child has a psychological bond with the Mother. c. Mother is able to provide a stable envirorunent for the child. 15. Each parent whose parental rights to the child have not been terminated has been named as parties to this action. WHEREFORE, the Plaintiff requests that this Court grant sole legal custody and primary physical custody of the child to the Plaintiff/Mother and partial custody at such times as the parties can agree. Respectfully submitted, ABOM & KUTULAKIS, L.L.P. DATE. Dl ~DS . ~lJ/JL-LJ, 1~~~laJL~. '__~ Kara W. Haggerty -err ID No. 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff DANEllE ~ WELKER : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO.: CIVIL TERM JOEY EDWARD WIllLIAMS CIVIL ACTION - LAW Defendant IN CUSTODY VERIFICATION I, Danelle R. Welker, verify that the statements made in this Custody Complaint are true 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.e.S. ~ 4904 relating to unsworn falsification to authorities. Date r; J/8Io'5 UCt1J2.W;( C))p).. Danelle R. Welker DANELLE R. WELKER IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO.: CIVIL TERM JOEY EDWARD WILLLIAMS CIVIL ACTION - LAW Defendant IN CUSTODY CERTIFICATE OF SERVICE ..j.t,- ...--rj llM.--. AND NOW, this 2/) day of L L cr- 2005, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Custody Complaint, upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Joey Edward Williams 205 F. Stockton Way Greensboro, NC 27406 Respectfully submitted, ADOM & KUTULAKIS, L.L.P. Kara W. Haggerty ID No. 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff C1 r-> ....:::" ;,t c_, -I;IJ -.-. L. h C;; - , - ''-' - '" .:t,:::.. ~ VI 0 c;;--- ~ r<:; <><;> ("n ~ C"..) -... ~ ~ ~ --+-. DANELLE R. WELKER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 05-3731 CIVIL ACTION LAW JOEY EDWARD WILLIAMS DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, July 27, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumherland County Courthouse, Carlisle on Thursday, September 01, 2005 , the conciliator, 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 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. Tbe court bereby directs tbe parties to furnisb any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to tbe conciliator 48 bours prior to scbeduled bearing. FOR THE COURT. By: Isl Hubert X Gilrov, Esq. Custody Conciliator :Y 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 A TTORNEY 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~ M; 5tJ-!;C'-L w/' ~.tI- -,-r . ~ Nr!L _ .~1.- ~1'1'9 5~be-'- ~ !tPC?~ \\":.\\; IV-' ,\1 .~(' ~.~\," r.l""\\\\ ~ " 0" ;1 '(.,0 .)0 ft.\ .() -", . ,. ,\ .,yu. - ,'i",J ..... , .:<\\j('~:i~() . ,,\\JS\)",< \.\\'('\)...1 l"v"- --::;)\:?,...... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA DANELLE R. WELKER, No. 05-3731 Plaintiff v. IN CUSTODY JOEY EDWARD WILLIAMS, Defendant PRAECIPE TO ENTER APPEARA.NCE To the Prothonotary: Please enter my appearance on behalf of Joey Edward WiUiams, Defendant in the above- captioned matter. Respectfully submitted, Dated: August t.t(", 2005 T & ASSOCIATES, P.C. ean M. Shultz, Esquire Attorney J.D. No. 9094 11 Roadway Dri ve, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 Attorney for Defendant o ~;"; <;;:; fJ.. 'JP c:: {..,") (~, o "".--; c Q, -' -c..-.-\ ft"r:;, -(~~li ~~,\ --''',," '0 '.:.<c - ~,- -.. '-P. r-..o r-..o 17 DANELLE R. WELKER IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO.: CIVIL TERM JOEY EDWARD WILLLIAMS CIVIL ACTION - LAW Defendant IN CUSTODY CUSTODY STIPULATION AND NOW, comes Danelle R. Welker, (hereinafter "mother"), by and through her attorney, Kara W. Haggerty of Abom & Kutulakis, L.L.P., and Joey Edward Williams (hereinafter "father"), who hereby agree as follows: WHEREAS, the parties are the natural parents of one minor child: Tyler Renee Williams, DOB: 01103/2000; WHEREAS, the parties desire to enter into an agreement as to the custody of the above said child and to the visitation rights of the non-custodial parent; NOW, THEREFORE, intending to be legally bound hereby, the parties agree as follows: I. The mother shall have sole legal custody of the subject minor child. 2. The mother shall have primary physical custody of the subject minor child. 3. The father shall have partial physical custody of the subject minor child as follows: a. For a period of two (2) weeks over the Thanksgiving holiday; b. For a period of two (2) weeks over the Fourth of July holiday; and c. At such other times as the parties can agree. :i~l :,.', n ," r-' =' c..:.-') cf' ~ o ""'" , ~- --c' ::;;:: o "Tl ..... :3:-n n.lp -O~ -~1-2 ~r """l t ~ --;"1.::;': ').'-.'--, ;'-.1'1'\ ) ::-\ '-!? (Jl ~-;1 .- DANELLE R. WELKER I 0 ~ r--"~"~'''' Y" ~"".. ~""""c,,-", \ . .""'.::.......~_J ._...., ..."". 'v -<'''''',..." i/ \ i~OV. II 7 .!OIS J IllY ="'~/'J===== IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL \'ANIA ~ Plaintiff v. : NO.: 05-3731 CIVIL TERM JOEY EDWARD WILLLIAMS CIVIL ACTION - LA W Defendant IN CUSTODY ORDER OF COURT AND NOW this ".. day of /..J~ , 2005, the attaehed Custody Stipulation is hereby made an Order of Court. BY THE COURT, J. Distribution: ~'a W. Haggerty, Esquire 7an M. Shultz, Esquire ~ Lt. :C ~\d 5- [.I}H S\\\\l " r" [.y., . L",. , co' '1. ~o ,,:O'\(,1-\')'i ~.U(1,i:'J,_,n.,..l0 ..... :l,')1jJO-O:PB