The URL can be used to link to this page

Home My WebLink About06-0341 MICHAEL A. WILLLlAMS, * IN THE COURT OF COMMON PLEAS Plaintiff * CUMBERLANDCOUNTY,PENNSYLV ANIA * * Cio~L ~I->[ vs. * NO. Ols. - .3l.f1 * * SHAYLA R. BARTON, * CIVIL ACTION - LAW Defendant * IN CUSTODY COMPLAINT FOR CUSTODY AND COMES NOW, MICHAEL A. WILLIAMS, by and through his attorney, Bradley A. Winnick, Esquire, of Wiley, Lenox, Colgan & Marzzacco, P.C., and files the instant Complaint for Custody, and in support thereof, avers as follows: 1. The Plaintiff is Michael A. Williams, who currently resides at 403 Woodland Drive, Dillsburg, York County, Pennsylvania 17019. 2. The Defendant is Shayla R. Barton, who currently resides at 611 Mallard Road, Apartment B3, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff seeks shared legal and physical custody of the following child: Brenden A. Williams, born on December 17, 2004. The child was born out of wedlock. The child is presently in the physical custody of Defendant. 4. Since birth the child has resided with the following persons and at the following addresses: .I!aW Address Persons A. Birth to January 3, 2006 611 Mallard Road Apartment B3 Camp Hill, P A Mother, Father and Jayden Barton B. January 3, 2006 to present 611 Mallard Road Apartment B3 Camp Hill, PA 17011 Mother and Jayden Barton The mother of the child is Shayla R. Barton, currently residing at 611 Mallard Road, Apartment B3, Camp Hill, Cumberland County, Pennsylvania. The father of the child is Michael A. Williams, currently residing at 403 Woodland Drive, Dillsburg, York County, Pennsylvania.. 5. The relationship of Plaintiff to the child is that off ather. Plaintiff currently resides with his parents, Thomas and Barbara Williams, and his brother, Kyle Williams. 6. The relationship of Defendant to the child is that of mother. Defendant currently resides with her children, Brenden Williams and Jayden Barton. 7. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 8. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or who claims to have custody or visitation rights with respect to the child. 9. The best interest and permanent welfare ofthe child will be served by granting Plaintiff shared legal and physical custody of the child. 10. 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. MICHAEL A. WILLIAMS PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 06-341 CIVIL ACTION LA W SHA YLA R. BARTON IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, _.---'Thursday, January,26, 2006___, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at MDJ Ma~loYe.'s,}9-"!.State. St,Cam.l'..':'.i!h.!'~.!?llI! on Thursday, March 09, 2006 at _9:3Q.-AM for a Pre-Hearing Custody Conference. At soch conference, an effort will be made to resolve the issues in dispute: or if this cannot be accomplished. to detlne 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 mav provide grounds for entry of a temporary or permanent order. The court hereby dirccts the parties to furnish any and all existing Protection from Ahuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Melissa P. Greevy, Esq. Custody Conciliator .,,1 V The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with DisahiIites Act of 1990. For information about acccssible 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 con ference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VE 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 (7 I 7) 249-3166 ~ ff'/ :z /fw, t'W/ ~ 7 ~ ' 1/- ,y -7J -J(" j P ~2-"'I'l/ , ' " ~ W"_ ~L, "7(/ "7(?/ ;:Z-~d r:z ~ ~07 'p?} ':/c7 ~7(?/ > >:0 ::i !::~ c_;;; fr,;T -..'1' -. ..,1 ..:C'.... WHEREFORE, Plaintiff respectfully requests This Honorable Court to award shared legal and physical custody to both parties. Respectfully submitted, WILEY, LENOX, COLGAN & MARZZACCO By: j. Bradle ID# 3 130 W. Church Street Dillsburg, PA 17019 (717) 432-9666 Dated: 1/1) /0 '-" VERIFICATION I, Michael A. Williams, verify that the statements made in this 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. CS. ~4904, relating to unsworn falsification to authorities. Date: / -/1 -()(.iI /J1~u/d / MItHAEL A. WILLIAMS Plaintiff xJ P ~ \:\: ~ - ....::t 90 ...() ...0 lJ'I ....... -- )J b ~ D ~~ !? "f- -....(, ,..,', (...- - . c> :~, !""'" (_.- MICHAEL A. WILLIAMS, * IN THE COURT OF COMMON PLEAS Plaintiff * CUMBERLAND COUNTY,PENNSYLV ANIA * * vs. * NO. OW - 3 L/ I ~YI I Term * * SUA YLA R. BARTON, * CIVIL ACTION - LAW Defendant * IN CUSTODY RETURN OF SERVICE On the ~t!-J} day of February, 2006, I, David Rudy, Process Server, served SHA YLA R. BARTON, with the Complaint for Custody and Order of Court dated January 26, 2006 scheduling a Pre-Hearing Conference for March 9, 2006 6'1 HI't-NI:iINl.. 0,rl.f:..(!.TV'..j (o St-f.J4.VLA 6Ai.-'TDV lit) ( S FeDlJ, ST fl '01 & /71fl-/ (time of service). (manner of service) at , at tll.<;- :f..m. I verii)' that the statements in this return of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 94904 relating to unsworn falsification to authorities. Date: ;2~Ol-o (, t% -go),))) I'E.- SilR.O'fii2- '3lfo RIJf.. $I ST~u.rOAJ ~ /7//3 <.'1 \.D ,..,~ = <;::';) """ n ~'1 :::f 1~1 ;22 ~9(IJ i.JC, .;c:") .- -,-, -; _.'n -,/ ,~'" ..,., rr, co I -..J 3:' i"i' . . :>. '",-, :~< ... .-"....~.,' ,- l\._,,::.,'IC-iJ 1 ',~ ~ v MICHAEL A. WilLIAMS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-341 CIVil TERM v. CIVil ACTION - LAW SHAYLA R. BARTON, IN CUSTODY Defendant ORDER TO RELINQUISH JURISDICTION AND NOW, this 15th day of March, 2006, counsel for the Plaintiff, having filed a Praecipe to Withdraw Custody Count on March 8, 2006 in this action, the Conciliator hereby relinquishes jurisdiction of the above captioned matter. FOR THE COUQ ~(~e~Grn~;~J Custody Conciliator :270806 ']"":"',"1' 0'1" '.3d ' .~, Vi \ U \0,.); "'1 \j i! 1\1("',-''-'\ .,,-,~ 1'. ~";-..,...,,,('V", '\,.l.l-il ~~) ~.' ~ ',- ;"~ .'''::' ,'ji::!V~! h..J S I :11 Ud 91 ~V~J 900Z AliV10NJ",;DtJd 3Hl dO 3'Jl:UO-CJ3ll:J