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Home My WebLink About05-5856 Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05 ~)lc)7.. CIVIL TERM CIVIL ACTION - LAW : IN CUSTODY RANDALL L. CLARK, Plaintiff v. TERRY D. CLARK, COMPLAINT FOR CUSTODY OF MINOR CHILD AND NOW, comes Plaintiff Randall L. Clark, by his attorneys, Snelbaker, & Brenneman, P. C., and avers the following: I. Plaintiff is Randall L. Clark residing at 128 Holly Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 2. Defendant is Terry D. Clark residing at IIA Hemlock Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff seeks a custody order for the following minor child: NAME PRESENT RESIDENCE AGE Taylor Rose Clark llA Hemlock Drive Mechanicsburg, Pennsylvania 17055 7 (D.O.B. 10/6/97) The child was born in wedlock. Taylor is presently in the custody of Terry D. Clark who resides at llA Hemlock Drive, Mechanicsburg, Pennsylvania 17055. 4. During the last five (5) years, the child has resided with the following person at the following address: PERSONS ADDRESS DATES 1. Terry D. Clark and Randall L. Clark 3543 Rolo Court Mechanicsburg, Pennsylvania March 1998 to April 2003 LAW OFFICES SNELBAKER & BRENNEMAN, P.C. 2. Terry D. Clark 3543 Rolo Court and I1A Hemlock Drive, Mechanicsburg, Pennsylvania April 2003 to Present . The father ofthe child is Randall L. Clark currently residing at 128 Holly Drive, Mechanicsburg, Pennsylvania 17055. 5. The relationship of Plaintiff to the child is that of father. The Plaintiff currently resides with the following persons: NAME RELATIONSHIP Wanda Lesh Scott Lesh Steven Lesh Girlfriend Girlfriend's son (age 19) Girlfriend's son (age 17). 6. The relationship of Defendant to the child is that of mother. The Defendant currently resides with the following persons: None other than Taylor. 7. Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning custody of the child in this or another 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 proceeding who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 8. The best interest and permanent welfare ofthe child will be served by granting shared equal physical custody to Plaintiff because Plaintiff has been a caretaker ofthe child since her birth and can provide a clean, safe and emotionally stable home and environment for the child. 9. Each parent whose parental rights to the child have not been terminated and the erson who has physical custody of the child have been named as parties to this action. LAW OFFICES II other persons, named below, who are known to have or claim a right to custody or SNELBAKER & BRENNEMAN, P,c. 2 , LAW OFFICES SNELBAKER & BRENNEMAN, P.C. visitation ofthe child will be given notice of the pendency of this action and the right to intervene: None. WHEREFORE, Plaintiff requests this Court to grant Plaintiff primary physical custody of Taylor Rose Clark. SNELBAKER & BRENNEMAN, P. C. ~11/V~ By: Keith O. Brenneman, Esquire 44 West Main Street Mechanicsburg, P A 17055-0318 (717) 697-8528 Attorneys for Plaintiff Randall L. Clark Date: November 7, 2005 3 . LAW OFFICES SNELBAKER & BRENNEMAN, P,C. VERIFICATION I verifY that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904 elating to unsworn falsification to authorities. ~ltiJ Randall 1. Clark Date: f (- 1-05 CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have, on the below date, caused a true and correct copy of the foregoing Custody Complaint to be served upon the person and in the manner indicated below: FIRST CLASS MAIL, POSTAGE PREPAID. ADDRESSED AS FOLLOWS: Linda A. Clotfelter, Esquire 5021 East Trindle Road Suite 100 Mechanicsburg, P A 17050 Terry D. Clark llA Hemlock Drive Mechanicsburg, PAl 7055 SNELBAKER & BRENNEMAN, P.C. By: Keith O. Brenneman, Esquire 44 W. Main Street P. O. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Randall L. Clark Date: November 10, 2005 LAW OFFICES SNELBAKER & BRENNEMAN, P.c. ,~ . '\ :J ~. <Q~ ~ . I:) <y1 ~ "- '. J'. \\ ~. ;'~ \.~ '~, 1'\ " \. ')-' '\.. . ~ 10 ~' ~ ~~ It ~ ~ ".< '''' ~~~:~ -CJ"' C) ~'n ::::l ;-C';l :t! ,. ~-f,~~ )~: :~., ~., (''''-, '-~);Tl c;} .,1) --< c. ':'? c.) r'':i RANDALL L. CLARK PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, pENNSYL VANIA v. 05-5856 CIVIL ACTION LAW TERRY D. CLARK IN CUSTODY DEFENDA~T ORDER OF COURT A'\D NOW. Tuesday, November 15, 2005 , 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 Fridav, December 23, 2005 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 detine and narrow the issues to be heard by the court. and to enter into a temporary order. All children age live or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or penn anent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By:~. Hubert X Gilroy, Esq. v.l^ 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 infonl1ation about accessible facilities and reasonable accommodations available to disabled individuals having business before the coul1. please contact our oflice. 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 ",OT HA VE AN ATTORNEY OR CANNOT AFFORD OI\:E, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FI'\D OUT WHERE YOU CA"i GET LEGAL HELP. Cumberland County Bar Association 32 South BedfiJrd Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 . ~ ~ J/- ~ ,-rd ""l ~9J LlII h~ ,.-b:o r)'~" -ru, ,0LiI/ '1ff7~V" ~ .....-- /@; P'7 ,<1 Lill ~ 11" 1- I''f/ ' ",~;-C) S \ ,(: \!A L \ r,C\H Sui}2 .., LAW OFFICES SNELBAKER & BRENNEMAN, P.C. RANDALL L. CLARK, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 05-5856 CIVIL TERM TERRY D. CLARK, Defendant : CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: Please withdraw the above-captioned Custody Complaint filed by the Plaintiff and note the matter discontinued and ended on your docket and indices. SNELBAKER & BRENNEMAN, P. C. I~ Date: January 31, 2006 BY: Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg, P A 17055 (717) 697-8528 Attorneys for Plaintiff Randall L. Clark .. LAW OFFICES SNELBAKER & BRENNEMAN, P.C, CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have, on the below date, caused a !rue and correct copy of the foregoing Praecipe to be served upon the persons and in the manner indicated below: FIRST CLASS MAIL POSTAGE PREP AlD. ADDRESSED AS FOLLOWS: Date: January 31, 2006 Linda A. Clotfelter, Esquire 5021 East Trindle Road Suite 100 Mechanicsburg. P A 17050 SNELBAKER & BRENNEMAN, P.C. /1 UvvL---- By: Keith O. Brenneman, Esquire 44 W. Main Street P. O. Box 318 Mechanicsburg, P A 17055 (717) 697-8528 Attorneys for Plaintiff Randall L. Clark o (''" "" ....~ ,:., c.~ ~" ::,; ~ --l ::t::n rnp_ -."8 -~Jl. '~t~ ,;~-. I'll ~ >- "J .< , , <- :,:;'" _0" ~ w --.J ---- RANDALL L. CLARK, Plaintiff IN THE COURT OF COMMON PLEAS OF i CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW TERRY D. CLARK, Defendant NO. 05-5856 IN CUSTODY COURT ORDER {} AND NOW, this & day of February, 2006, the Conciliator being advised that the parties have reached an agreement, the Conciliator relinquishes jurisdiction. Cl/rJ .'.' C", " 'I I" 'J [11 " 10 '7 ,.d t:J..: JCJI.. ^b";/~LC,; ''\ :J'J