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Home My WebLink About06-0879 .. v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ~ No. 0(,.- J'7 q ~ 'Tv--- BOBBI JO LIGHTNER, Plaintiff ROGER WALTER POND, JR., Defendant CIVIL ACTION - LAW CUSTODY COMPLAINT IN CUSTODY AND NOW, the Plaintiff, BOBBI 10 LIGHTNER, by and through her attorney, Jeanne B. Costopoulos, Esquire, makes the following Complaint in Custody: 1. The Plaintiff, Bobbi Jo Lightner (hereinafter referred to as Mother), is an adult individual who currently resides at 113 Tower Circle, Carlisle, Cumberland County, Pennsylvania, 17013. 2. The Defendant, Roger Walter Pond, Jr. (hereinafter referred to as Father), is an adult individual who is believed to reside at 107 Tower Circle, Carlisle, Pennsylvania, 17013. 3. Mother seeks primary physical custody of the following child: Name Present Residence Age Chase M. Pond 113 Tower Circle Carlisle, PA 17013 13 months DOB 12/30/2004 4. The child named above is presently in the custody of Mother, currently residing at 113 Tower Circle, Carlisle, Pennsylvania, 17013. 5. Since birth, the child has resided with the following persons at the following addresses: Name Address Dates Bobbi Jo Lightner (Mother) Janet Blosser (maternal grandmother) 113 Tower Circle birth to present Carlisle, PA 17013 0'" 6. The biological mother of the child is Bobbi Jo Lightner, Plaintiff, 113 Tower Circle, Carlisle, Pennsylvania, 17013. The biological father of the child is Roger Walter Pond, Jr., Defendant, currently residing at 107 Tower Circle, Carlisle, Pennsylvania, 17013. 7. Mother has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 8. Mother does not know of a person not a party to the proceedings who has physical custody of the child or claims to have physical custody or visitation rights with respect to the child. 9. The best interests and permanent welfare of the child will be served by granting primary physical custody of the child to Mother subject to specific periods of partial custody with Father. 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. No other persons are known to have or claim a right to custody or visitation of the child to be given notice of the pendency of this action and the right to intervene. WHEREFORE, PlaintifflMother respectfully requests that she be granted primary physical custody of her son, Chase M. Pond, born December 20, 2004. Dated: -z.f J Ic'-dd 6 Respectfully submitted, ~, ----~' ,/ , ----------- feanne B. Costopoulos, Esquire ATTORNEY FOR PLAINTIFF 3803 Gettysburg Road Camp Hill, PA 17011 Telephone: (7]7) 920-2500 PA Supreme Ct. ID No. 68735 ,. BOBBI JO LIGHTNER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. ROGER WALTER POND, JR., Defendant CIVIL ACTION - LAW CUSTODY VERIFICATION I, Bobbi Jo Lightner, Plaintiff, hereby verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904, relating to unsworn falsification to authorities. Date: ~/ r:)/a-p Signature: MH~C~ Bobbi Jo iglitn ~ ......... ~ --C ~ :c-, ') ~ ~ - C) ~ ~ ~ % ,;::,;~ 'd.\dJ -<:1 f"T' GJ ::.:1 1"- ' ("..., I..~_J L;, , 808Bl 10 LIGHTNER PLAINTIFF IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, 06-879 CIVIL ACTION LA W ROGER WALTER POND, JR. DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, ___~--'Iuesday, February...l'., 200~.~,~. ' upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilruy, Esq, , the conciliator, at 4th Fluur, CUlnbe,,~,lan,<!..f.u_II~.l2: C~II,:t~~u.se,<:~r!isle. on ___Friday, Ma':cltll.. 211116_~_~~ at 8:30 _AM for a Pre-Hcaring Custody Conference. At such confercncc, an effort will be made to resolve tbe issues in dispute: or if this cannot be accomplished. to deHne and narrow the issues to be heard by the court. and to enter into a temporary order. All children agc five or older may also be prescnt at the confcrcnce. Failure to appear at the conference 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/ _~Huber! X Gilrov, EsCJ.. ---,44ft Custody Conciliator r 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 COUll, please contact our ofllee. All arrangements must be made at least 72 houl's prior to any hearing or business bej()fe the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR A TTORNEY AT ONCE. IF YOU DO NOT HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TilE OFFlCE 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 yT/~;I~~~J 'J}IM _ fr ff ~ "'7',,1., '7/ j('e r?,~/Pf'~_MJ.n? _7/lrC 'oi \ .:' U) (' .-"J ,._.J \,., ' ~ (."1 \ \ / "c', ',J "'\ .~...... i'cN '" BOBBI JO LIGHTNER, Plaintiff v. ROGER W ALTER POND, JR., Defendant TO THE PROTHONOTARY: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 06-879 : CIVIL ACTION - LAW : CUSTODY PRAECIPE TO DISCONTINUE Please mark the above-referenced custody action discontinued and dismissed and cancel the custody conference scheduled on April 27, 2006 at 9:30 a.m. ~ ~ Jeanne B. Costopoulos, Esquire ATTORNEY FOR PLAINTWF 3803 Gettysburg Road Camp Hill, PA 17011 Phone: (717) 920-2500 PA Supreme Ct. ID No. 68735 DATE: vk;O~ , BY: ,: BOBBI 10 LIGHTNER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 06-879 ROGER W ALTER POND, JR" Defendant CIVIL ACTION - LAW CUSTODY CERTIFICATE OF SERVICE I, Jeanne B. Costopoulos, Esquire, hereby certij'y that this day I served a copy of the foregoing document upon the person(s), and in the manner, indicated below, which service satisfies the requirements of the P A Rules of Civil Procedure, by depositing a copy of the same with the United States Post Office at Camp Hill, Pennsylvania, through first class mail, prepaid, and addressed as follows: Roger Walter Pond, Jr. 107 Tower Circle Carlisle, PA 17013 Hubert X. Gilroy, Esquire 4 North Hanover Street Carlisle, P A 17013 BY: ~ ---, , Jeanne B. Costopoulos, Esquire :1803 Gettysburg Road Camp Hill, P A 17011 Phone: (717) 920-2500 PA Supreme Ct. ID No. 68735 DATED: ~ <-' ,-::.::> ..-:> ~'.~ -" _wI - C) --ri .-1 ~j'-- ,-,", ;:;- , BOBBI JO LIGHTNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CML ACTION - LAW ROGER WALTHER POND, JR., Defendant NO. 2006-879 IN CUSTODY COURT ORDER AND NOW, this ~ day of May, 2006, The Conciliator being advised that the Plaintiff has withdrawn the above action, the Conciliator relinquishes jurisdiction. ~ Hubert X. Gilroy, &quire Custody Conciliator (') C'~ .-.-, C.;:;. t:-~ w.... o ., .--1 ffi:?J , -:::1:_i-; , , -,:01 !~~,~ :r~"', -y,.' ~, /". '':r6 '__J ":; :'.0 -< C) U1 -.;