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HomeMy WebLinkAbout02-1319IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TANYA L. LAUNSE Plaintiff CHARLES M. LAUNSE Defendant CIVIL ACTION NO.Oog-'J.~/CJ' of 2002 CUSTODY COMPLAINT FOR CUSTODY TO THE HONORABLE, THE JUDGES OF THE SAID COURT: 1. Plaintiff is TANYA L. LAUNSE, residing at 45 West Keller Street, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is CHARLES M. LAUNSE, residing at 3447 Capital Mall Drive, Camp Hill, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of Noah Braeden Marrie, age one year, who currently resides at 45 West Keller Street, Mechanicsburg, Cumberland County, Pennsylvania. 4. The child is presently in the custody of Plaintiff, who resides at 45 West Keller Street, Mechanicsburg, Cumberland County, Pennsylvania. 5. The mother of the child is TANYA L. LAUNSE, currently residing at 45 West Keller Street, Mechanicsburg, Pennsylvania. 6. The relationship of Plaintiff to the child is that of biological mother. 7. The relationship of Defendant to the child is that of biological father. 8. Plaintiff 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. 9. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 10. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. 11. The best interest and permanent welfare of the child will be served by granting the relief requested because the Defendant has threatened to remove the child from Plaintiff's custody. 12. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child has been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child have been given notice of the pendency of this action and of their right to intervene: NONE WHEREFORE, Plaintiff requests the court to grant her custody of the child. Attorney for Plaintiff 2423 North Third Street Harrisburg, PA 17110 Supreme Court #23705 717-238-0434 Verification I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa. Cons. Stat. § 4904 relating to unsworn falsification to authorities. TANYA L. LAUNSE PLAINTIFF V. CHARLES M. LAUNSE DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-1319 CIVIL ACTION LAW IN CUSTODY AND NOW, Monday, March 25, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechaniesburg, PA 17055 on Tuesday, April 30, 2002 at 1:00 PM 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 be 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 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: Is/ Dawn S. Sunday. Esq, ,~/ Custody Conciliator O~ 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 TANYA L. LAUNSE, Plaintiff VS. CHARLES M. LAUNSE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-1319 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this ! V'- day of r-n A y , 2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Tanya L. Launse, and the Father, Charles M. Launse, shall have shared legal custody of Noah Braeden Marrie, bom November 24, 2000. Each parent shall have an equal fight, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 2. The Mother shall have primary physical custody of the Child. 3. The Father shall have partial physical custody of the Child, with the specific dates and times to be arranged by agreement of the parties. The Mother shall cooperate in scheduling regular periods of partial custody when the Father is not working. 4. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Child comply with this provision. 5. This Order is entered pursuant to an agreement at a Custody Conciliation Conference. The patties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, cc: Gregory R. Reed, Esquire - Counsel for Mother Charles M. Launse, Father XI. NnOO TANYA L. LAUNSE, Plaintiff VS. CHARLES M. LAUNSE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-1319 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, 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 Noah Braeden Marrie November 24, 2000 Mother 2. A Conciliation Conference was held on April 30, 2002, with the following individuals in attendance: The Mother's counsel, Gregory R. Reed, Esquire, and the Father, Charles M. Launse, who is not represented by counsel in this matter. The Mother, Tanya L. Launse, did not attend the Conference. The reason for the Mother's absence was not known. attached. Date The parties agreed (the Mother through counsel) to entry of an Order in the form as ! ' Dawn S. Sunday, Esquire Cd Custody Conciliator