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Home My WebLink About02-0956: IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION IN CUSTODY : NOTICE TO DEFEND TO THE RESPONDENTS NAMED HEREIN: 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 Petition 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 notice for any money claimed in the Petition or for any other claim or relief requested by the Plaintiffs. 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. Cumberland County Bar Association Two Liberty Avenue Carlisle, PA 17013 (717)249-3166 Le han demandado a usted enla corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partie de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objectones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, las corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. VS. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION IN CUSTODY : :No. 0~' c?6-G . COMPLAINT IN CUSTODY o Theplaintiffis '~Y~iel~',~t~,STt~,residingat ~_ r] ~ ~.3C 5V ' The defend~t is ~rq ~roma~ ,residingat; 7 ~ ~a~Je ~k~0~.~b~9~ , ~ f~. l~g57 Plaintiff seekS, ~a~ial custody), (visitation) of the following child(ren): N~E P~SENT ~D~SS AGE The child(ren) (~)(was not) bom out of wedlock. The child(ren) is presently in the custody of ~_ l'-dt ,~o ~a~ who resides at ~ ? z-. ~.~9~ $/. ~,e;~¢.~ ?~, 17;5'z During the past five years, the child(ren) has resided with the following persons at the following addresses: LIST OF PERSONS ADDRESSES .~0 '3. ~d~, DATES /o- ~ - ~ oo~ 2- io - I The mother of the child(ren) is'7'~l~ ~ ~'t t~ o rna r~ She is~(married)(divorced). The father of the child(ren) is '~ i~_, ~ [ ~ r~t,5 7c~' ri . currently residing at He is s~(married)(divorced). , currently residing at c~ ? ,r220/. 31771 / The Plaintiff currently The relationship of the Plaintiffto the child(ren) is: resides with : fY~ 03~' ~r~ NAME RELATIONSHIP The relationship of the Defendant to the child(ren)is: if)'/0 Ch ~' ~ currently resides with: ,5'~ [ ~C' The Defendant NAME RELATIONSHIP o Plaintiff (has) participated as a party or witness, or in another capacity, in other litigation concerning the custody of this minor child(ren) in this or another court. (if so)The court, term and number, and its relationship to this action is: Plaintiff (has)Q information of a custody proceeding concerning the child(ren) pending in a court of this Commonwealth. (if so)The court, term and number and its relationship to this action is: Plaintiff (knows not kno of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation fights with respect to the child. The name and address of such a person is: The best interest and permanent welfare of the child will be served by granting the relief requested Each parent whose parental fights 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 fight 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 ~E~FO~, Plaintiffrequests this cou~ to grant~(tempora~ ~ustody)(visit&tion) of the child(ren) to the Plaintiff. Respectfully submitted, d Date Attachment- for line # 7 Do to the reckless and endangering behavior of the mother, I Daniel Edward Edmisten, plead that the court acknowledge my request and grant me full custody of my child (Madison Stroman Edmisten). Over the past 2.5 years Tara Stroman has demonstrated that she is not a reliable or a sufficient mother/caretaker of Madison. She has attempted suicide numerous times and has abandoned the residence leaving Madison in the care of the father (Daniel) without phoning home or other relatives for days at a time. The mother suffers bom a Bi-Polar condition and refuses to adhere to the prescnl~e medication and consulting sessions by here Psychiatrist. She continues to abuses drugs and alcohol that has lead to a disruptive, irrespons~l¢ behavior. Due to those circumstances, Tara has lost her employment and is capable of taking her life and those around her. Ifthe court, acknowledges my plea, I assure you that she will he in a loving stable environment with Christian values. I have the support of my family and will make certain that Madison and I are well taken care of. Sincerely, , Daniel Edward Edmisten DANIEL EDMISTEN : PLAINTIFF ' : V. : 02-956 TARA STROMAH DEFENDANT : 1N CUSTODY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW AND NOW, Friday, March 08, 2002 , 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 Friday, April 05, 2002 at 9:30 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 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 he 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 fnrnish 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: Is/ Hubert X. Gilrov. Esa. 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 court. 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 VS. In the Court of Common Pleas of Cumberland County, Pennsylvania No. ~,T' ~56' ~'~/'~/g/ Civil. 19. Prothonotary Term, 19 __ PRAECIPE 19 , Atty.