The URL can be used to link to this page

Home My WebLink About06-0817 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA AMANDA M, W ANNYN, Plaintiff v, CIVIL ACTION - LAW RAYMOND D, DURDEN, SR., Defendant NO, 2006 -FIT CIVIL TERM IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, Amanda M. Wannyn, by her attorneys, Irwin & McKnight, and presents the following Complaint for Custody. I. The Plaintiff, Amanda M. Wannyn, is an adult individual with an address of 550 Meals Road, Gardners, Cumberland County, Pennsylvania 17324. 2. The Defendant, Raymond D. Durden, Sr., is an adult individual with an address of 40 West Green Street, Apartment B, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The parties are the natural parents of one (I) child, namely, Angel M. Durden, born January 27, 2006. 4. The Plaintiff desires that she have primary legal custody of the minor child, Angel M. Durden. 5. The Plaintiff desires that she have primary physical custody of the minor child, Angel M. Durden. 6. The best interests and permanent welfare of the minor child requires that the Court grant the Plaintiffs request as set forth above_ WHEREFORE, the Plaintiff, Amanda M. Wannyn, respectfully requests that she be awarded primary physical custody and primary legal custody of Angel M. Durden, as provided herein. Respectfully submitted, By: Date: February 9,2006 VERIFICATION The foregoing Complaint for Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. V/i11()/YJd<1 ~ ?Ub./J7/K if!", AMANDAM. WA NYN (] Date: February 9, 2006 ~ -- ---J )5 ~ -lA ~ - ~)J \) ~ \:y ~ v - ~ ~ ," ~ , . n s::\ '.:.(-) ',- '. -- :. (.) " <',) '.~4..;. - :; ,. AMANDA M. W ANNYN PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 06-817 CIVIL ACTION LA W RA YMOND D. DURDEN, SR. DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, Februa'1'.1.6, 2006 .__' upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at___4t~l'loor,S~Il1~erl..n<l<::'~~n..t! Cour!.~.~I""',-<::arlisle_ on __ Thursday, March 16,2006 at 10:30 AM for a Pre-Hearing Custody Conference. At sueh conferenee, an effort wil! be made to resolve the issues in dispute; or if this cannot bc accomplished, to define and narrow the issues to bc heard by the court, and to enter into a temporary order AI! children age five or older may also be prescnt at the conferenee. Failure to appear at the confercnce 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: /s/ facqueline M. Verney. Esq. _~ Custody Conciliator i' 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. AI! 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 (717) 249-3166 . yI ~ fir ~ ,ryd t./Q;J;Il /jf t' .. ~?:Z 1l~/ ??/t1u, -J'i "71- e ~,"Ifr 'lflY"".; /.w - F9 J# 9/ e 80 ;ii I:.. ,.' 91 83.:1 U"l' ~ )tLt. RECEIVED ty MAR 1 7 2006 AMANDAM, WANNYN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V, : NO. 2006-817 CIVIL ACTION - LAW RAYMOND D, DURDEN, SR., Defendant IN CUSTODY ORDER OF COURT AND NOW, this ~ day of (II} V l.L ,2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I. The Mother, Amanda M. Wannyn and the Father, Raymond D. Durden, Sr., shall have shared legal custody of Angel M. Durden, born January 27, 2006. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all m~or non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. 2. Mother shall have primary physical custody of the child. 3. Father shall have periods of partial physical custody every weekend from Saturday from 2:00 p.m. to Sunday at 6:00 p.m. and such other times as the parties agree. 4. Holidays shall be shared as agreed by the parties. 5. Transportation shall be as agreed by the parties. 6. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms ofthis Order shall control. BY THE COURT, ~ 0'>) n,:. 'n" .'i ...J (j I :[ II:] 17 '!"I.1 ,'!C"'J Iv{\J;i~~H.:Jt.. A}-J\ilCi<C:;-;"k;t:d 3Hl :lJ .." ," '1"'11:1 _," il"~.jl 14 _J - '-'...~_.,_ .,.,.j I. cc: Marcus A. McKnight, III, Esquire, Counsel for Mother Raymond D. Durden, Sr., pro se 40 West Green Street Apartment B Mechanicsburg, P A 17055 AMANDAM. WANNYN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V, : NO, 2006-817 CIVIL ACTION - LAW RAYMOND D. DURDEN, SR" Defendant : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 19 I 5.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Angel M. Durden January 27, 2006 Mother 2. A Conciliation Conference was held in this matter on March 16,2006, with the following in attendance: The Mother, Amanda 1. Wannyn, with her counsel, Marcus A. McKnight, III, Esquire, and the Father, Raymond D. Durden, Sr., pro se. 3. The parties agreed to an Order in the form as attached. 3 -I7-o~ Date JLL V ~ cq line M. Verney, Esquire Custody Conciliator