HomeMy WebLinkAbout01-5314Law Offices ofHazlett & Oesterling
20 South Market Street
Mechanicsburg, PA 17055
(717)-790-0490
IN THE COURT OF COMMON PLEAS FOR THE NINTH JUDICIAL
DISTRICT, CUMBERLAND COUNTY, PENNSYLVANIA
TERRY E. WOLF
Plaintiff,
LUCY W. WOLF
Defendant
NO.
Civil Action - Custody
COMPLAINT FOR CUSTODY
1. The Plaintiff is Terry E. Wolf, an adult individual, sui juris, who resides at 283 Frost Road,
City of Gardners, County of Cumberland, Commonwealth of Pennsylvania, 17324.
2. The Defendant is Lucy W. Wolf, an adult individual, sui juris, who temporarily resides at 283
Frost Road, City of Gardners, County of Cumberland, Commonwealth of Pennsylvania, 17324.
3. Plaintiff seeks custody of the following children:
Name Present Residence Age
Victoria C. Wolf 283 Frost Road, Gardners, PA 17324 11 y/o 0-9-90)
Crystal M. Wolf 283 Frost Road, Gardners, PA 17324 9 y/o (10-25-91)
4. The children were born in wedlock.
5. The children are presently in the custody of Plaintiff.
6. During the past five years, the children have resided with the following persons and at the
following addresses:
Person
Terry E. and Lucy W. Wolf
Address
283 Frost Road, Gardners, Pa
Dates
1998 to
present
Terry E. and Lucy W. Wolf 928 Goodyear Road, Gardners, Pa 1989-1998
Name
Lucy W. Wolf
Victoria Wolf
Crystal Wolf
Name
Terry E. Wolf
Victoria Wolf
Crystal Woff
7. The mother of the child is Lucy W. Wolf.
8. She is mamed.
9. The father of the child is Terry E. Wolf.
10. He is married.
11. The relationship of plaintiff to the child is that of biological father.
12. The plaintiff currently resides with the following persons:
Relationship
Wife
Daughter
Daughter
13. The relationship of defendant to the child is that of biological mother.
14. The defendant currently resides with the following persons:
Relationship
Husband
Daughter
Daughter
15. Plaintiffhas not participated as a party or wimess, or in another capacity, in other
litigation concerning the custody of the child in this or another court.
16. Plaintiff has no information of a custody proceeding concerning the child pending in
a court of this Commonwealth.
17. Plaintiffdoes 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.
18. The best interest and permanent welfare of the child will be
served by granting the relief requested because:
a. Plaintiff has been the custodian and caregiver of the children
since birth.
Plaintiff has maintained a relationship with the children that has
provided for the physical, intellectual, emotional and spiritual well being
of the children.
Plaintiff has maintained the children's contacts with extended family and
friends.
Plaintiff has legal fight to continued residence in the marital residence to
which the children are familiar and comfortable with.
Plaintiff avers that defendant is engaged in an extramarital affair and that
she has threatened to remove the children from the marital residence thus
causing great disruption to their lives.
19. Each parent whose parental rights to the child have not been terminated and the person
who has physical custody of the child have been named as parties to this action. All other persons, named
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 fight to intervene:
Name Address Basis of Claim
NONE
WHEREFORE, plaintiff, Terry E. Wolf, requests the court to grant him custody of the children.
Respectfully Submitted,
HAZLETT ~lt,,LING
/ ~Lee E. 6ester~l~'eg,, E~ ~ ....
~ Attorney I.D.# 71320
/ 20 South Market Street
/ Mechanicsburg, PA 17055
(717) 790-0490
Attomey for Plaintiff, Terry E. Wolf
VERIFICATION
I verify that upon personal knowledge or information and belief that the statements made in this
Complaint are true and correct. I understand that false state~ments herein are made subject to the penalties
of la ea.C.S. § 4904, relating to unsworn fals~cation to authol~ities. /
Terry E. ~Volfg~laintiff //
Date:
TERRY E. WOLF : IN THE COLrRT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
PLAINTIFF : 01-5314 CIVIL ACTION LAW
V.
LUCY W. WOLF
: IN CUSTODY
DEFENDANT
AND NOW, Tuesday, September 18, 2001 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Meehanicsbur§, PA 17055 on Wednesday, October 17, 2001 at 11:30 A.M
for a Pre-Heating 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.
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: /si
Dawn S. Sunday. Esq.
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 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 corot. You must
attend the scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY 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
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
TERRY E. WOLF,
VS.
LUCY W. WOLF,
Plaintiff
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-5314 C1VIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 17th day of October, 2001, the Conciliator, being advised by Plaintiff's
counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes
jurisdiction. The Custody Conciliation Conference scheduled for today, October 17, 2001 is canceled.
FOR THE COURT,
Custody Conciliator