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HomeMy WebLinkAbout87-0024 SHARON L. SCHWALM Plaintiff DAVID ALLEN SEIFF, A MINOR, AND RONALD L. WINTERS, JR. AND JANE A. WINTERS, HIS NATURAL GUARDIANS, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ~ CIVIL I~ CUSTODY ORDER OF COURT AND NOW, this day of ~F&,~.~ , consideration of the Complaint in Custody, the ordered to appear for a hearing concerning Christopher Allan Seiff, in Courtroom No. ~ , the Cumberland County Courthouse, Carlisle, Pennsylvania 17013, on ~-~ l~ , 198~, at ~:~ o'clock ~ . M., at which time all parties shall have an opportunity to offer evidence in this case. 198 ~ , upon defendants, is the custody of fourth floor of By the Court, SHARON L. SCHWALM, Plaintiff DAVID ALLEN SEIFF, A MINOR, AND RONALD L. WINTERS, JR. AND JANE A. WINTERS, HIS NATURAL GUARDIANS, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ~ CIVIL ! ~q CUSTODY NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse Carlisle, Pennsylvania 17013 (717) 249-1133 SHARON L. SCHWALM Plaintiff DAVID ALLEN SEIFF, A MINOR, AND IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RONALD L. WINTERS, JR. AND JANE A. WINTERS, HIS NATURAL GUARDIANS, Defendants CIVIL CUSTODY 19~7 COMPLAINT AND NOW, this ~'day of ,~,~-~, 1987, comes the plaintiff, Sharon L. Schwalm, and by her attorney, Marcus A. McKnight, III, makes the following complaint against the defendants, as follows: The plaintiff is Sharon L. resides at 12 Marilyn Drive, Carlisle, Pennsylvania 17013. 2. The defendants are David Allen Seiff, a minor, age Schwalm, an adult individual who 16, residing with his parents, defendants Ronald L. Winters, Jr. and Jane A. Winters, at 155 Amy Drive, Carlisle, Pennsylvania 17013. 3. The plaintiff Sharon L. Schwalm, the maternal grandmother of Christopher Allan Seiff, born June 13, 1986, age 6 months. The mother is her daughter, Jennifer Denise Schwalm, age 16, a minor who resides with her. 4. The minor child has resided continously with the plaintiff since birth, at 12 Marilyn Drive, Carlisle, Pennsylvania 17013. That attending the child. the minor defendant, David Allen Seiff is still Carlisle High School, as well as the minor mother of e That the plaintiff has consistently cared for and provided for the minor child. 7. That the best interests of Christopher Allan Seiff would be served by awarding physical and legal custody to the plaintiff with regular periods of visitation with the minor natural parents of the child. WHEREFORE, the plaintiff prays that this Honorable Court would award custody of said minor child as set forth above. IRWIN, IRWIN & McKNIGHT Marc~s' A."McK~ight',~IIl~~-/ Atto~rney for Plainti~ff, Sharon L. Schwalm 60 West Pomfret Street Carlisle, Pennsylvania (717) 249-2353 I verify that the statements made in this complaint are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. 4904 relating to unsworn falsification to authorities. SHARON L. SCHWALM, Plaintiff Vo : IN THE COURT OF COMMON PLEAS OF .' : CUMBERLAND COUNTY, PENNSYLVANIA .- DAVID ALLEN SEIFF, : A MINOR, AND : RONALD L. WINTERS, JR., AND : JANE A. WINTERS, HIS : NATURAL GUARDIANS, : Defendants : CIVIL ACTION - LAW 24 CIVIL 1987 CUSTODY ORDER OF COURT AND NOW, this & ~ day of March, 1987, upon consideration of the custody complaint and the evidence presented it is hereby ordered as follows: e Jane A. visits. Primary and Physical custody of the child, Christopher Allan Seiff, born June 13, 1986, shall be in the plaintiff, Sharon L. Schwalm, the maternal grandmother of said child. Visitation of said child by the natural father, David Allen Seiff shall be at times and places as the parties agree is in the best interests of Christopher Allan Seiff. The father's visitation of said child shall be limited to times and places in which his guardians, Ronald L. Winters, Jr. and Winters are present to supervise said By the Court, ./.~in' A'. 'He~: Jud'ge CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, hereby certify that I served true and correct copies of the Custody Complaint and Order of Court upon the Defendants by United States certified mail, postage prepaid, in Carlisle, Pennsylvania as follows: Date: DAVID ALLEN SEIFF 155 Amy Drive Carlisle, Pennsylvania 17013 RONALD L. WINTERS, JR. and JANE A. WINTERS 155 Amy Drive Carlisle, Pennsylvania 17013 January 9, 1987 Mlcus A. ~McKni~ht,~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 24 CIVIL 1987 CUSTODY SHARON L. SCHWALM Petitioner DAVID ALLEN SEIFF, Respondent AGREEMENT AND STIPULATION IRWIN, IRWIN & McKNIGHT WEST POMFRET PROFESSIONAL BUILDING 60 WEST POMFRET STREET CARLISLE~ PENNSYLVANIA 17013~3222 S I, OZ I, Vd '3-1Sl'l'dVO ~100-1.:11-LLP' '3SNOH. L~INOO MOIV'8_LSINI~.J..~NOO 3H..L 40 301-140 8q3H q~aq Iq9 NVO IlO/k ~d3HM ~NO aNl~ O/MOq38 FU~OJ IqS 301~0 3H~ 3NOHd33q I ~0 O± 09 '3NO ~dOJ~V/ONNVO JO ~3AMV3 V 3AVI.-I ION oa flOA -Ii ':IONO _LV M3AMV'-I ~lflOA 01 M=lclVd SIH.L 3NV/alNOFIS flOA eql ~ XlduJoo ol MCI ~ peJ!nbeJ s!/quno0 PUelJeqLunO jo seam UOLUUJO0 Jo 1J~YO mil ~JNOO 3FLL A~] s! ~. ~U!eldu~o peqo~ eqljo .uopp__~p!~ uodn g661~%~ jo ~p ~- 9ih& MON aNY J..~:INOO :10 M'::la'8o xaolsno NI ' I/~FI I l~O ~;- ,/~ 'ON ' MV1 - NOI1O¥ 1V~O ' VINVAq,,kSNN=Id .)d..NNOO aNV-'IB=IBIAIrlO ' --I0 SV31d N~O .=10 I~INOO 3RL NI ' luepuodse~l IAFIV~OS 'a M'=I-,IINN'=II'' JeuoE~. d :1-113S ¥ a~va DAVID A. SEIFF Petitioner VS. JENNIFER D. SCHWALM Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 87-24 CIVIL TERM IN CUSTODY PETITIONER'S COMPLAINT FOR CUSTODY 1. Petitioner is David A. Seiff, an adult individual, currently residing at 31 Edgewood Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. Respondent is Jennifer D. Schwalm, an adult individual, currently residing at 1185 Bower Road, Shermansdale, Perry County, Pennsylvania. 3. Petitioner seeks custody of the following child: Christopher A. Seiff, age 12, born June 13, 1986. The child was born out of wedlock. The child is presently in the custody of the Father, Daviid A. Seiff. The Respondent Mother recently placed custody of the child with the father and prior to that had left the child with her former boyfriend effective February 27, 1998. Since leaving the child in February she has had virtually no contact with the child During the past five years, or since the child's birth, he has resided with the following persons at the following addresses: (a) from June 17, 1998 to the present with the Father and Kathleen Seiff and Brandon Seiff at 31 Edgewood Drive, Mechanicsburg, PA. (b) from 1993 to June, 1998 with Respondent and Michael Buchenauer and Tyler Buchenauer at 31 Pine Hill Rd., Carlisle, PA. The natural mother of the child is the Respondent. 4. The relationship of the Respondent to the child is that of natural mother. The Respondent currently resides alone. 5. The relationship of the Petitioner to child is that of natural father. 6. The parties have participated as a party in other litigation concerning the custody of the child in this Court. Petitioner does know of a person, not a party to the current proceedings, who may claim to have visitation rights with respect to the child. This person is Sharon L. Scwalm and she will be notified of this proceeding. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: (a) The Father has been the primary caretaker of the child since the end of the school year. The Mother has effectively abandoned the child effective February 1998. (b) The Mother has stated to the father on July 26, 1998 that he could have custody of the child and that she had no interest in seeing her child if the father would agree not to seek support from her. She stated that she would give up her rights to the child if the father sought support. 8. 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 below, 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 right to intervene. NAME ADDRESS BASIS OF CLAIM Sharon L. Schwalm Maternal Grandmother WHEREFORE, Plaintiff requests your Honorable Court to: A) grant custody of the child to the Father B) set an emergency hearing in order to establish where the child will begin the school year until such time as there can be a full hearing in this matter; C) grant such other relief as is just and in the best interest of the child. Respectfully submitted, Date: Robert L. O'Brien, Esquire O'BRIEN, BARIC & SCHERER 17 West South Street Carlisle, PA 17013 (717) 249-6873 I verify that the statements made in the foregoing Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. DAVID A. SEIFF SEP g 1998 DAVID SEIFF, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V CIVIL ACTION - LAW JENNIFER D. SCHWALM, Defendant NO. 87 - 24 CIVIL IN CUSTODY COURT ORDER AND NOW, this ~ ~'Wday of September, 1998, thc Conciliator being advised that thc panics have reached an agreement, the Conciliator relinquishes jurisdiction. In thc event the parties arc unable to finalize their agreement, either party may petition to have the case again scheduled with thc Custody Conciliator. ~squim Cust~nciliator DAVID A SEIFF Pelitioner V. JENNIFER D. SCHVVALM Resp(:nd IN THE COURT OF COIVlMON PLEAS OF : CUMBERLAND COUNT~, PENNSYLVANIA : CML ACTION - LAW : NO. 87 - 24 CML TERM : IN CUSTODY ORDER OF COURT .AND NOWTHIS L\ dayof~'.~ .2000, q~cons~oftheatta:h~~int, iris Hearing Custody ~. At such ~, an elfot will be made to resolve lhe i$_~_~s in dispute; or iflhis ca'r~ be accaT~ished, to define and narrow tf~ issues to be heard by the cout, and to enter into a t~ or(:~. Ail children age five or older may also be present at lhe ~. FailLre to appea' at the ca3faa3ce may provide grou-~ for er~ of a t~ or ~ order. BY THE COURt, Cu ( y c, The Court of Common Pleas of Cumbedand Co.r~ is required by law to comply wilh the ~ with Disabilities Act of 1990. For inforn'ation about accessible facilities and ~ oFx:e. Ali ara3gements must be made at least 72 hours pdor to any headng or business ~ the YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OF CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Currt:edand ~ Bar Assodati~ 2 Libedy Avenue Cadisle, PA 17013 (717) 249-3166 WHEREFORE, Plaintiff requests your Honorable Court to: A) grant custody of the child to the Father Respectfully submitted, Date: Robert L. O'Brien, Esquire O'BRIEN, BARIC & SCHERER 17 West South Street Carlisle, PA 17013 (717) 249-6873 I verify that the statements made in the foregoing Complaint for Custody are true and correct. This verification is made by Robert L. O'Brien, Esquire and is based upon the custody Complaint filed in 1998, information confirming that the circumstances remain the same as of that filing and that a Conciliation conference is necessary to conclude this matter with an apPropriate court order. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Robert L. O'Brien, Esquire DAVID A. SEIFF V. Petitioner JENNIFER D. SCHVVALM R~ IN THE COURT OF COIVIVION PLEAS OF CUMBERLAND COUNT~, PENNSYLVANIA CML ACTION - LAW NO. 87-24 CML TERM · IN CUSTODY ORDER OF COURT Failure ~o aR2ea' at lhe (x:nfemr~ may provide ~ for entry of a t~ or ~ ordec. BY THE COURt, BY/~-/ ~.~..~., ~ .~~ 'f'he C°urt of Con'n'~ Pleas of CL,rft:eda-~d Ccu~ is required by law to ca.r~ with the ~ with Disabilities Act of 1990. For irfom3atim about accessible facilities and reasonable olfx:e. AIl ~angements rnust ~ ~ ~ ~ 72 ~ ~to ~ ~ or ~i~ ~ ~ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OF CANNOT AFFORD ONE, ~ TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE, PA 17013 (717)240-.6200 DAVID A. SEIFF Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Vs. JENNIFER D. SCHWALM ' Respondent CIVIL ACTION - LAW NO. 87-24 CIVIL TERM IN CUSTODY PETITIONER'S COMPLAINT FOR CUSTODY 1. Petitioner is David A. Seiff, an adult individual, currently residing at 31 Edgewood Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. Respondent is Jennifer D. Schwalm, an adult individual, currently residing at 1185 Bower Road, Shermansdale, Perry County, Pennsylvania. 3. Petitioner seeks custody of the following child: Christopher A. Seiff, age 12, born June 13, 1986. The child was born out of wedlock. The child is presently in the custody of the Father, Daviid A. Seiff. The Respondent Mother recently placed custody of the child with the father and prior to that had left the child with her former boyfriend effective February 27, 1998. Since leaving the child in February she has had virtually no contact with the child During the past five years, or since the child's birth, he has resided with the following persons at the following addresses: (a) from June 17, 1998 to the present with the Father and Kathleen Seiff and Brandon Seiff at 31 Edgewood Drive, Mechanics'burg, PA. (b) from 1993 to June, 1998 with Respondent and Michael Buchenauer and Tyler Buchenauer at 31 Pine Hill Rd., Carlisle, PA. The natural mother of the child is the Respondent. 4. The relationship of the Respondent to the child is that of natural mother. The Respondent currently resides alone. 5. The relationship of the Petitioner to child is that of natural father. 6. The parties have participated as a party in other litigation concerning the custody of the child in this Court. Petitioner does know of a person, not a party to the current proceedings, who may claim to have visitation rights with respect to the child. This person is Sharon L. Scwalm and she will be notified of this proceeding. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: (a) The Father has been the primary caretaker of the child since the end of the school year. The Mother has effectively abandoned the child effective February 1998. (b) The Mother has stated to the father on July 26, 1998 that he could have custody of the child and that she had no interest in seeing her child if the father would agree not to seek support from her. She stated that she would give up her rights to the child if the father sought support. 8. 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 below, 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 right to intervene. NAME ADDRESS BASIS OF CLAIM Sharon L. Schwalm Maternal Grandmother WHEREFORE, Plaintiff requests your Honorable Court to: A) grant custody of the child to the Father B) set an emergency hearing in order to establish where the child will begin the school year until such time as there can be a full hearing in this mat[er; C) grant such other relief as is just and in the best interest of the child. Respectfully submitted, Robert L. O'Brien, Esquire O'BRIEN, BARIC & SCHERER 17 West South Street Carlisle, PA 17013 (717) 249.-6873 I verify that the statements made in the foregoing Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. DAVID A. SEIFF .APR 0 ZO00 DAVID A. SEIFF, Plaintiff V JENNIFER D. SCHWALM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 87-24 CIVIL IN CUSTODY COURT ORDER AND NOW, this '-/_~ day of ,,/~'7/~ ~'i , 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directe~ as follows: The Mother and the minor child, Christopher A. Seiff, bom June 13, 1986, shall engage in some family counseling with the focus of that counseling being to initiate further contact between the minor child and the Mother. The Mother, along with the Father, shall make arrangements for this counseling. Any costs of the counseling that are not covered by the Father's insurance shall be paid by Mother subject to Father's voluntary contributions towards those costs. The Father shall ensure that the minor child participates in the counseling. The aim of the counseling is to allow the Mother to initiate some type of meaningful visitation with her son. In the event the counseling continues for a period of time and the Father feels the counseling requirement needs to be modified, Father's attorney may contact the Conciliator to have this matter again addressed. Pending further order of this court, this Court orders as follows with respect to custody of the minor child: A. All prior custody orders are vacated. The Father, David A. Sheiff, shall enjoy legal and physical custody of Christopher A. Seiff, bom June 13, 1986. The Mother, Jennifer D. Schwalm, shall enjoy periods of temporary physical custody with the minor child at such times and under such circumstances as agreed upon by the parties. CC: 'Robert L. O'Brien, Esquire Jennifer D. Schwalm 1 Maryland Drive Carlisle, PA 17013 BY THE COURT, / DAVID A. SEIFF, Plaintiff V JENNIFER D. SCHWALM, Defendant Prior Judge: · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · CIVIL ACTION - LAW · NO. 87-24 CIVIL · IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE. 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the child who is the subject of this litigation is as follows: Christopher A. Seiff, bom June 13, 1986. A Conciliation Conference was held on March 28, 2000, with the following individuals in attendance: The Father, David A. Seiff, with his counsel, Robert L. O'Brien, Esquire; and the Mother, Jennifer D. Schwalm, who appeared without counsel The parties agree to the entry of an order in the form as attached. DAVID A. SEIFF, Plaintiff V JENNIFER D. SCHWALM, Defendant IN THE COURT OF. COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 87 - 24 CIVIL IN CUSTODY COURT ORDER AND NOW, this [~ ~f~t day of December, 2000, the Conciliator being advised that the parties have reached an agreement, the Conciliator relinquishes jurisdiction. BY THE COURT, ;. G~oy, Esquire Custody/96nciliator I verify that the statements made in the foregoing Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. DAVID A. SEIFF APR 0 ZO00 DAVID A. SEIFF, Plaintiff V JENNIFER D. SCHWALM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 87-24 CIVIL IN CUSTODY COURT ORDER AND NOW, this '-I' day of ~/~ ~,'i , 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and direct~ as follows: The Mother and the minor child, Christopher A. Seiff, bom June 13, 1986, shall engage in some family counseling with the focus of that counseling being to initiate further contact between the minor child and the Mother. The Mother, along with the Father, shall make arrangements for this counseling. Any costs of the counseling that are not covered by the Father's insurance shall be paid by Mother subject to Father's voluntary contributions towards those costs. The Father shall ensure that the minor child participates in the counseling. The aim of the counseling is to allow the Mother to initiate some type of meaningful visitation with her son. In the event the counseling continues for a period of time and the Father feels the counseling requirement needs to be modified, Father's attorney may contact the Conciliator to have this matter again addressed. Pending further order of this court, this Court orders as follows with respect to custody of the minor child: A. All prior custody orders are vacated. The Father, David A. Sheiff, shall enjoy legal and physical custody of Christopher A. Seiff, bom June 13, 1986. The Mother, Jennifer D. Schwalm, shall enjoy periods of temporary physical custody with the minor child at such times and under such circumstances as agreed upon by the parties. 'Robert L. O'Brien, Esquire Jennifer D. Schwalm 1 Maryland Drive Carlisle, PA 17013 BY THE COURT, DAVID A. SEIFF Petitioner VS. JENNIFER D. SCHWALM Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 87-24 CIVIL TERM IN CUSTODY PETITIONER'S COMPLAINT FOR CUSTODY 1. Petitioner is David A. Seiff, an adult individual, currently residing at 31 Edgewood Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. Respondent is Jennifer D. Schwalm, an adult individual, currently residing at 1 Marilyn Drive, Carlisle PA 17013. 3. Petitioner seeks custody of the following child: Christopher A. Seiff, age 12, born June 13, 1986. The child was born out of wedlock. The child is presently in the custody of the Father, Daviid A. Seiff. The Respondent Mother placed custody of the child with the father and prior to that had left the child with her former boyfriend effective February 27, 1998. During the past five years, or since the child's birth, he has resided with the following persons at the following addresses: (a) from June 17, 1998 to the present with the Father and Kathleen Seiff and Brandon Seiff at 31 Edgewood Drive, Mechanicsburg, PA. (b) from 1993 to June, 1998 with Respondent and Michael Buchenauer and Tyler Buchenauer at 31 Pine Hill Rd., Carlisle, PA. The natural mother of the child is the Respondent. 4. The relationship of the Respondent to the child is that of natural mother. The Respondent currently resides alone. 5. The relationship of the Petitioner to child is that of natural father. 6. The parties have participated as a party in other litigation concerning the custody of the child in this Court. Petitioner does not know of a person, not a party to the current proceedings, who may claim to have visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: (a) The Father has been the primary caretaker of the child since June, 1998. The Mother has had very little contact with the child. (b) The parties had a prior conciliation scheduled and postponed it, however no new order recognizing the Father's primary custody has been entered. 8. 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 below, 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 right to intervene. NAME ADDRESS BASIS OF CLAIM