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HomeMy WebLinkAbout87-0032PAMELA LANDRUM, : PETITIONER : for herself and on behalf: of her children : TISHA LANDRUM AND DANIEL : LANDRUM : QUILLA RAY LANDRUM, : RESPONDENT : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW 434 CIVIL 1986 32 CIVIL 1987 ORDER OF COURT AND NOW, this %~ day of April, 1987, upon relation by Stanley E. Schneider, Ed.D., who was appointed by this Court on February 10, 1987, to conduct an evaluation in the above captioned case, that an additional four (4) weeks will be needed in order to complete said evaluation, it is ordered that the next hearing now scheduled for Thursday, April 16, 1987, at 1:30 o'clock, p.m., is continued and re-set for Monday, June 1, 1987, at 1:30 o'clock p.m., in Courtroom No. 2, Cumberland County Courthouse, Carlisle, Pennsylvania. All other provisions of this Court's order of February 5, 1987,~.emain in full force and effect pending this next sched~ed_hearing~ Edgar B. Bayley ~'~ J. Kevin J. Frederick, Esquire For Petitioner Edward S. Finkelstein, Esquire For Respondent Stanley Schneider, Ed.D. PAMELA LANDRUM, : PETITIONER : for herself and on behalf: of her minor children, TISHA LANDRUM & DANIEL LANDRUM, Ve QUILLA RAY LANDRUM, RESPONDENT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW 434 CIVIL 1986/ 32 CIVIL 1987 AND NOW, this ORDER OF COURT day of February, 1987, upon relation of counsel that the parties are unable to agree on a particular qualified clinical psychologist for the purposes of conducting an evaluation pursuant to this Court's order of February 5, 1987, it is ordered that the psychologist who shall conduct the evaluation pursuant to the terms of that prior order is Stanley E. Schneider, Psychologist, located in the Medical Arts Building, Camp Hill, Pennsylvania. Kevin J. Frederick, Esquire For Petitioner Edward S. Finkelstein, Esquire For Respondent The par~~e to proceed ythe Cou}rt/ ~ accordingly. Jo :bll PAMELA LANDRUM, : PETITIONER : for herself and on behalf of : her children : : TISHA LANDRUM & DANIEL LANDRUM: : V. : : QUILLA RAY LANDRUM, : RESPONDENT : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 434 CIVIL 1986 NO. 32 CIVIL 1987 PROTECTION FROM ABUSE AND CONFIRMATION OF CUSTODY ORDER OF COURT AND NOW, this 5th day of February, 1987, at 1:30 P.M., the hearing on the custody case and sentencing on the finding of contempt on the protection from abuse case is set for 1:30 P.M., Thursday, April 16, 1987. 2. A temporary Order of Exclusion in the marital residence in Mechanicsburg is entered against the husband, effective this Saturday, February 9, 1987, at 5:00 P.M., and to remain in full force and effect until the next hearing is held in this case which is now scheduled for April 16, 1987. During this period of time the husband is excluded from said marital residence.. 3. Temporary physical custody of the parties' two children, Tisha and Daniel, shall be with the mother, pending the next scheduled hearing. 4. Pending the next scheduled hearing, the parties shall have shared legal custody, as the term "legal custody" is defined, as contrasted from physical custody. By that I mean each of you shall consult with each other regarding matters~ concerning your No. 434 Civil 1986 No. 32 Civil 1987 Page 2 legal custody regarding your children except in emergency situations. 5. The children shall not be moved out of Pennsylvania pending the next hearing in this case. 6. Pending the next hearing in this case, the wife may live with the two children in the marital residence, but no one else may live and reside in that residence with her pending that hearing. 7. Pending the next hearing, the father shall have temporary physical custody of his children on the following schedule: starting next Sunday, February 8, 1987 from 8:00 A.M. to 7:30 P.M.; on the following weekend from 7:00 P.M. on Friday evenings through Sunday at 3:00 PoM. This alternate weekend schedule shall continue on those two different types of schedules until the next hearing. In addition, the husband shall have the two children every Tuesday evening from 5:30 P.M. through 7:30 P.M. At all times when the husband arrives to pick up the children and bring the childrn back he shall be accompanied by another adult person, and the husband may not ~hvsically enter the residence during this period of time from which he is excluded therefrom. No. 434 civil 1986 No. 32 civil 1987 Page 3 8. Pending the next hearing, the parties shall cooperate to secure the services of a qualified clinical psychologist for the purpose of evaluating their respective situations regarding custody of the two children. The father shall pay for these services. If the parties are unable to agree upon whom that clinical psychologist shall be, counsel should immediately notfiy this Court, and I will appoint a clinical psychologist to conduct said psychological revie~ /By the COurt~ E~gar B. ~ayley, J. Kevin J. Frederick, Esquire For Petitioner Edward S. Finkelstein, Esquire For Respondent : sod QUILLA RAY LANDRUM, JR., Petitioner VS. PAMELA LANDRUM, Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 32 CIVIL 1987 : : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 1st day of June, 1987, this case having been called for a hearing, it is ordered that this Court's prior Order of February 5, 1987, is vacated. 1. The mother, Pamela Landrum, and the father, Quilla Ray Landrum, shall have shared legal custody of their two children, Tisha Landrum and Daniel Landrum, as that term is statutorily defined. 2. The mother shall have primary physical custody of the two children. The father shall have temporary physical custody on the following schedule: (a) Every other weekend from 5:30 P.M. through Sunday evening at 7:30 P.M when school is in schedule, and until 8:30 P.M. when the children are not in school the next day; (b) every Tuesday evening from 5:30 P.M. through 7:30 P.M. when school is in schedule or to 8:30 P.M. when there is no school the next day; (c) for a two (2) week continuous period each summer with at least thirty (30) days advance written notice to the Page 2 of 3 No. 32 civil 19 87 mother, consistent with the schedules of both of the parties. This two-week period of temporary custody in 1987 shall be from Friday evening, July 17 at 5:30 P.M. through Sunday evening, August 2, at 8:00 P.M~; (d) from 3:00 P.M. each Christmas Day through 8:30 P.M. each December 29th. This Christmas schedule shall result in the mother always having the children on Christmas Eve through 3:00 P.M. on Christmas Day; (~e} on the alternate holidays of July 4th, Labor Day, Thanksgiving, Easter and Memorial Day, with the father"s first alternate holiday being on July 4th, 1987. On the year in which he has the children on Thanksgiving, this period of temporary physical custody shall extend through Friday~ the day after, at 8:30 P.M. On the year he does not have the children on Thanksgiving~ he shall always have them on the next Friday evening through Sunday evening. These periods of holidays temporary physical custody shall be from 9:00 A.M. through 7:30 P.M. when school is in schedule, and 8:30 P.M. if the next day is not a school day. 3. The father shall have the children on each Father's Day. The mother shall have the children on each Mother's Day. This special arrangement for Father's Day and Mother's Day shall supersede the regularly scheduled alternate periods of temporary physcial custody~ Page 3 of 3 No. 32 Civil 1987 4. The children shall always have phone access with the parent with whom they are not with at any given time. 5. Unless further contested upon petition, the father shall pay for the services of Stanley Schneider, Ed.D., who was appointed by this Court and who conducted an evaluation for the benefit of the Court and both of the parties. As a means of assisting the father in this payment, it is ordered that the parties shall file a joint 1986 federal income tax return and that the mother shall assist the father by providing the necessary information on her earnings and any applicable deductions. When this return is prepared and filed, a separate calculation shall be made as to the amount of money the mother would have received as a refund if she had filed a separate 1986 tax return. Upon receipt of a joint check from the federal government for a refund on this return, the mother shall endorse same to husband, at which time husband shall pay to her the amount she would have received had she filed a 1986 return in the category of marr~ s~arat~ly'yl~ ~~~i/~~BYEdgartheB.C~'~Ba Kevin J. Frederick, Esquire For ReSpondent Edward S. Finkelstein, Esquire For Petitioner ;sod N TIlE COURT OF COMMON PLEAS BERLAND COUN~TY, PENNSYLVANI · 32 Civ~-I 1987 iIL ACTION' i LAW ,UILLA RAY LANDRUM, Petitioner LANDRUM, Respondent AFFIDAVIT OF SERVICE EDWARD S. FINKELSTEIN COUNSELLOR AT LAW SEVEN HUNDRED GREEN STREET HARRISBURG, PENNSYLVANIA 17102 (717) 233-1667 QUILLA RAY LANDRUM, JR., Petitioner Ve PAMELA LANDRUM, Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 32 Civil 1987 CIVIL ACTION - LAW IN CUSTODY NOTICE TO PLEAD TO: QUILLA RAY LANDRUM, Petitioner, and his attorney, EDWARD S. FINKELSTEIN: YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED ANSWER WITH NEW MATTER WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST YOU. McNEE~LACE & ~~ ,~0vin/R~Z~F r ~de~ k 0 P~e S]~-~eet P. O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorneys for Respondent QUILLA RAY LANDRUM, JR., Petitioner Vo PAMELA LANDRUM, Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 32 Civil 1987 CIVIL ACTION - LAW IN CUSTODY ANSWER AND NEW MATTER AND NOW, comes the Respondent, by her attorneys, McNees, Wallace & Nurick, and files the within Answer and New Matter: 1. Admitted 2. Denied. The Respondent Pamela Landrum resides at 1653 Main Street, Lisburn, Cumberland County, Pennsylvania (hereinafter "Lisburn residence"), however, due to the physical and emotional abuse of the Respondent by the Petitioner, the Respondent is temporarily living at an undisclosed shelter (hereinafter "Shelter"), the location of which will be furnished upon request. 3. Denied. Tisha Landrum is seven (7) years of age. The present address of both children is the Lisburn residence, however, due to the physical and emotional abuse of the Respondent by the Petitioner and the Respondent's concern over - 2 - the impact on the children through exposure to the abuse, the Respondent removed the children from their residence and they are temporarily living at the Shelter with the Respondent. It is admitted that the children resided with the Petitioner and Respondent at the addresses averred from February, 1979 to August, 1985. The children did reside with the Petitioner and Respondent at the Lisburn residence from May, 1985 to December 21, 1986, however, from approximately February 18, 1986 to May 18, 1986, the Petitioner was excluded from the Lisburn residence by order of court obtained pursuant to a Protection From Abuse Petition, order dated February 18, 1986, Docket No. 434 Civil 1986, Court of Common Pleas of Cumberland County, Pennsylvania. Further, the residence of the children from December 21, 1986 was and continues to the present time to be the Lisburn residence. On December 21,1986, due to the physical and emotional abuse of the Respondent by the Petitioner and the Respondent's concern over the impact on the children through exposure to the abuse, the Respondent removed the children from their residence and obtained temporary living quarters at Spring Meadow Farm, School House Lane, Lewisberry, Pennsylvania. On January 3, 1987, the Respondent obtained temporary living quarters for herself and the children at the - 3 - Shelter. The children visited with the Petitioner overnight on December 22-23 and 30-31, 1986. With respect to the residence of the mother of the children, the Respondent hereby incorporates her answer to Paragraph 2 of the Petition as though the same were fully set forth herein at length. The remaining averments of Paragraph 3 are admitted. 4. Denied as stated. Petitioner Quilla Ray Landrum is the father of the children but shares the Lisburn residence with the Respondent and the children who are temporarily living at the Shelter. 5. Admitted. 6. Denied as stated. The Petitioner has participated in previous litigation concerning custody of the children and that litigation was styled Pamela Landrum v. Quilla Ray Landrum, Case No. 434 Civil 1986, in the Court of Common Pleas of Cumberland County, Pennsylvania, Civil Action - Law, Protection From Abuse and Confirmation of Custody. 7. Denied. It is specifically denied that it is in the best interests and permanent welfare of the children to grant custody to the petitioner. To the contrary, the best interests and permanent welfare of the children would be served by con- firming custody of the children in the Respondent. It is - 4 - further denied that the Respondent threatened to remove the children to the State of Missouri. 8. Admitted. WHEREFORE, the Respondent respectfully requests that this Honorable Court deny the Petitioner's request for relief and to confirm custody in the Respondent. NEW MATTER Counterclaim for Custody 9. Respondent Pamela Landrum resides at 1653 Main Street, Lisburn, Cumberland County, Pennsylvania, however, due to the physical and emotional abuse of the Respondent by the Petitioner, the Respondent is temporarily living at the Shelter. 10. Petitioner is Quilla Ray Landrum, Jr., residing at 1653 Main Street, Lisburn, Cumberland County, Pennsylvania. 11. Respondent seeks custody of the following children: Name Present Residence Age Tisha Landrum 1653 Main Street 7 Lisburn, PA Daniel Landrum 1653 Main Street 5 Lisburn, PA The above children were not born out of wedlock. - 5 - Tisha and Daniel Landrum are presently in the custody of the Respondent, Pamela Landrum who is temporarily living at the Shelter. During the past five years, Tisha and Daniel Landrum have resided with the following persons at the following addresses: Persons Pamela Landrum Pamela Landrum Pamela Landrum and Quilla Ray Landrum Pamela Landrum and Quilla Ray Landrum Pamela Landrum and Quilla Ray Landrum Addresses Shelter Spring Meadow Farm Schoolhouse Lane Lewisberry, PA 1653 Main Street Lisburn, PA 13239 Myrna Lane Houston, TX Aqueduct Road Houston, TX Dates 1/3/87 to Present 12/21/86 to 1/2/87 5/85 to 12/21/86 8/83 to 5/85 2/79 to 8/83 The mother of the two children is Pamela Landrum, who is temporarily living at the Shelter but whose residence is 1653 Main Street, Lisburn, Pennsylvania. She is married. The father of the two children is Quilla Ray Landrum cur- rently residing at 1653 Main Street, Lisburn, Pennsylvania. He is married. - 6 - 12. children is that of mother. with the following persons: Name The relationship of Pamela Landrum to the two The Respondent currently resides Relationship Tisha Landrum Daughter Daniel Landrum Son 13. The relationship of Petitioner Quilla Ray Landrum to the children is that of father. The Petitioner currently resides alone. 14. The Respondent has participated as a party in other litigation concerning the custody of the two children in this Court and that litigation was styled Pamela Landrum v. Quilla Ray Landrum, Case No. 434 Civil 1986, in the Court of Common Pleas of Cumberland County, Pennsylvania, Civil Action - Law, Protection From Abuse and Confirmation of Custody. Respondent does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 15. The best interests and permanent welfare of the two children will be served by granting the relief requested because: - 7 - (a) Respondent Pamela Landrum has been the primary caretaker of the children throughout their lives; (b) It is the express wish and desire of Tisha Landrum and Daniel Landrum to be in the custody and care of their mother, Pamela Landrum; (c) Respondent, Pamela Landrum, is better able to provide the love, care and guidance that is needed by the children; (d) Respondent can and will provide the better, more stable, home environment with better living conditions for the children. (e) The Respondent has demonstrated by his abuse of the Petitioner that he is an inappropriate role model for the children. (f) The Respondent has demonstrated by his verbal abuse of the children that he is an unfit parent. 16. Each parent whose parental rights to the children have not been terminated and persons who have physical custody of the children have been named as parties to this action. No other persons are known to have or claim to have any right to custody or visitation of the children. - 8 - WHEREFORE, Petitioner requests the Court to grant custody to Respondent, Pamela Landrum, of the two children of the parties, Tisha and Daniel Landrum. McNEES, ~ALLACE & NURICK '~ in J~//~ r~ r i~ 100 Pir~ Street P. O. Box 1166 Harrisburg, PA 17108 (717) 232-8000 Attorneys for Respondent - 9 - VERIFICATION I verify that the statements made in this Answer and New Matter are true and correct. I understand that false statements are made subject to the penalties of 13 Pa. C. S. S4904, relating to unsworn falsification to authorities. Dated: January 24, 1987 - 10 - CERTIFICATE OF SERVICE A~ND NOW, on this 27th day of January, 1987, I hereby certify that I have served a true and correct copy of the within Answer and New Matter upon the attorney of record for the petitioner by mailing the same to such attorney on this date by regular first class United States mail, postage prepaid. Attorney for Respondent QUI LLA RAY LANDRUM, Peri tioner PAMELA LANDRUM, Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 32 Civil 1987 CIVIL ACTION - LAW I N CUSTODY AFFIDAVIT OF SER~JlCE COMMONWEALTH OF PENNSYLVANIA: : SS.: COUNTY OF DAUPHIN: I, LEE WIGGINS, being duly sworn according to law, doth depose and say that I served the Order signed by Judge 8ayley and Petition for Custody in the above captioned matter upon the Defendant, Pamela Landrum, at the Women in Crisis Center, Bull Frog Valley Road, Hershey, Dauphin County, Penns>'lvania, on this at 5:31 P.M. 8th day of Januar::,.', 1987 Sworn to and subscribed before me, this ~P~-- da>' of January., 1987. Notary Public My Commission Expires: /0//7/~¢~ PAMELA LANDRUM, PETITIONER for herself and on behalf of her children, TISHA LANDRU~ & DANIEL LANDRUM: · V. QUILLA RAY LANDRUM, RESPONDENT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION _ LAW NO. 434 CIVIL 1986 NO. 32 CIVIL 1987 PROTECTION FROM ABUSE AND CONFIRMATION OF CUSTODY ORDER OF~ AND NOW, this 5th day of February, 1987, at 11:20 A.M., I find as a fact that the respondent has violated the terms and conditions of this Court,s Order of February 18, 1986. There- fore, I find him in contempt of Court. The respondent is ordered to appear for sentencing at 1:30 P.M. on April 16, 1987. This Court,s Order of February 18, 1986, Placing the husband Under a Protection from Abuse Order, is extended for one year forward from this date, February 5, 1987, with the exception of paragraph (4) Kevin j. F~ederick, Esquire For Petitioner lve to SUpport. Edward S. Finkelstein Esquire For Respondent ' . :sod PAMELA LANDRUM, PETITIONER for herself and on behalf of her minor children, TISHA LANDRUM & DANIEL LANDRUM: QUILLA RAY LANDRUM, : RESPONDENT : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 434 CIVIL 1986 NO. 32 CIVIL 1987 PROTECTION FROM ABUSE AND CONFIRMATION OF CUSTODY ORDER OF COURT AND NOW, this 5th day of February, 1987, at 9:30 A.M., the cases filed at Numbers 32 Civil 1987 and 434 Civil 1986 are consolidated. Edgar ~ ~ ~. ~ Kevin j. Frederick, Esquire For Petitioner Edward S. Finkelstein, Esquire For Respondent :sod QUILLA RAY LANDRUM, JR., Plmintiff PAMELA LANDRUM, Defendant IN RE. CUSTODY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 32 CIVIL 1987~ NO. 3876 CIVIL 1990 AND NON, this 28th day of February, 1991, following a hearing on the within custody case, the following order is entered. 1. This court's prior order dated June 1, 1987, at 32 Civil 1987, is vacated and replaced with this order. 2. This court's prior order dated November 21, 1990, at 3876 Civil 1990, is vacated. 3. The mother, Pamela Landrum, shall have primary Physical custody of Tisha Landrum, born November 14, 1979, and Daniel Landrum, born April 7, 1981. 4. The father, Quilla Ray Landrum, Jr., shall have te~Dporary Physical custody of the two children on the following schedule. (a) every other weekend from 5'30 p.m. Friday through Sunday evening at 8'00 P.m. 8'00 p,m. (b) every Tuesday evening from 5'30 p,m. through ¢c) for two separate periods of three continuous weeks through the summer school vacation period of the children each year. These weeks shall be chosen by the father with written notice to the mother at least two weeks before the beginning of the school vacation period. The two periods shall be separated by not less than two weeks~ and the last period shall end at least one full week before the Start of the next school year. During the school vacation period when the father does not have the children, his periods of temporary Physical custody shall be the same as in the non-school vacation period. (d) from $'00 P.m, each Christmas Day through 8'00 P,m, each December 29th. This Christmas schedule shall result in the mother always having the children on Christmas Eve through $'00 P,m~ on Christmas Day, (e) on the alternate holidays of July ~th, Labor Dayj Thanksgivingj Easter and Memorial Day. On the year in which the father has the children on Thanksgiving, this period of temporary Physical custody shall extend through Friday, the day after, at 8'00 P.m. On the year he does not have the children on Thanksgivingj he shall always have them on the next Friday evening through Sunday evening, (f) the father shall have the children on each FatherJs Day. The mother shall have the children on each Mother's Day. These Periods shall SUpersede the regular schedule in this order. 5, The mother may change the place of the children,s schooling after the completion of the current school year. 6. As long as the mother is living in her current residencej Trisha shall be allowed to occupy the bedroom that the maternal grandmother is now using once the maternal grandmother returns to her own home. ?. The mother shall always send adequate clothing along with the children for them to use during any periods of temporary Physical custody with the father. 8. The father shall provide all transportation for his Periods of temporary Physical Deborah Hammaker ./~s-t~, however, either he or may Pick , Edward S, Finkelstein, Esquire For the Plaintiff Mark T. Sillikerj Esquire For the Defendant 'prs QUI[LA RAY' [ANDRUM, JR., Petitioner V. PAMELA LANDRUM, Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. ~,~ ~ / 9~q CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT You, Pamela Landrum, Respondent, have been sued in Court to obtain custody of the children: Tisha Landrum and Daniel Landrum. You are ordered to appear in person at Cumberland County Court Ho~se, Carlisle, Pennsylvania, in Courtroom No. -~ on/~~_~.~ ..~*-~ , 1987, at ~ t~ z~.M for a Hearing f ' . You are further ordered to bring with you the children, Tisha Landrum and Daniel Landrum. If you fail to appear as provided by this Order, an Order for custody may be entered against you or the Court may issue a warrant for your arrest. Furthermore, the children shall not be removed from Pennsylvania pending further Order of this Court. Date: 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. THE COURT OF C0]~ON PLEAS 0] ',UM_BERLAND COUNTY, PENNSYLVAN QUILLA RAY LANDRUM, JR., Petitioner Vo PAMELA LANDRUM, Respondent PETITION FOR CUSTODY EDWARD $. FINKELSTEIN COUNSELLOR AT LAW SEVEN HUNDRED GREEN STREET HARRISBURG, PENNSYLVANIA 17102 (717) 233-1667 QUILLA RAY LANDRUM, JR., Petitioner PAMELA LANDRUM, Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY PETITION FOR CUSTODY AND NOW, comes the Petitioner, by his attorney, Edward S. Finkelstein, Esquire, and avers as follows: 1. The Petitioner is Quilla Ray Landrum, Jr. residing at 1653 Main Street, Lisburn, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Respondent is Pamela Landrum residing at Spring Meadow Farm, School House Lane, Lewisberry, York County, Pennsylvania. 3. Petitioner seeks custody of the following children: Name: Tisha Landrum, age: 6 years old Daniel Landrum, age: 5 years old Present address of both children: Spring Meadow Farm, School House Lane, Lewisbury, York County, Pennsylvania. The children are presently in the custody of Pamela Landrum who resides at Spring Meadow Farm, School House Lane, Lewisberry, York County, Pennsylvania. During the past five (5) years, the children resided with the following persons at the following addresses: Aquaduct Road Houston, Texas 13239 Myrna Lane Houston, Texas 1653 Main Street Mechanisburg, PA Spring Meadow Farm School House Lane kewisberry, PA 1653 ~Main Street Mechanicsburg, PA Spring Meadow Farm School House Lane Lewisberry, PA 1653 Main Street Mechanicsburg, PA Spring Meadow Farm School House Lane l.ewisberry, PA From 2/99 to 8/83 Petitioner and Respondent From 8/83 to 5/85 Petitioner and Respondent From 5/85 to 12/21/86 Petitioner (excluding a period of time in February and March, 1986) and Respondent From 12/21/86 to 12/22/86 Respondent From 12/22/86 to 12/23/86 Petitioner From 12/23/86 to 12/30/86 Respondent From 12/30/86 to 12/31/86 Petitioner From 12/31/86 to present Respondent Yhe mother of the children is Pamela Landrum currently residing at Spring Meadow Farm, School House Lane, Lewisberry, York County, Pennsylvania. She is married to the Petitioner, the father of the children. She currently has custody of the children. The father of the children is Quilla Ray Landrum, Jr. currently residing at 1653 Main Street, Lisburn, Mechanicsburg, Cumberland County, Pennsylvania. He is currently married to the Respondent~ the mother of the children. of father. The Petitioner currently resides alone. The relationship of Petitioner to the children is that that of mother. persons: The relationship of the Respondent to the children is The Respondent currently resides with the following Tisha Landrum, daughter Daniel Landrum, son 6. Petitioner has participated as a party in other litigation concerning the custody of the children. This litigation being Case No. A34 Civil 1986 in the Court of Common Pleas of Cumberland County, Pennsylvania, Civil Action - Law, In Child Custody in which he was named Respondent of the action. Petitioner has no information of any other custody proceedi~g concerning the children pending in a court of this Commonwealth. Petitioner does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. ?. The best interest and permanent welfare of the children will be served by granting the relief requested because it is in the children's best interest to live with their father and Respondent~s situation is unstable and she is threatening to remove the children to the State of Missouri where her parents reside. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as party to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim NONE NONE NONE WHEREFORE, the Petitioner prays your Honorable Court to schedule a prompt hearing to determine custody and visitation of the children and to issue an order restraining Respondent from removing the children from Pennsylvania until this matter is heard by the Court. LAW OFFICES EDWARD S. FINKELSTEIN Edward S. Finkelstein, Esquire Attorney for Petitioner 700 Green Street Harrisburg, PA 17102 717-233-1667 Supreme Court No.: 06869 VERIFICATION I, QUILLA RAY LANDRUM, JR. verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Plaintiff