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HomeMy WebLinkAbout02-1379Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 RICHARD E. MURPHY, Plaintiff Vo DENISE P. MURPHY, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - CUSTODY : CUSTODY COMPLAINT 1. The Plaintiff is Richard E. Murphy (hereinafter referred to as "Father"), who currently resides at 1908 High Street, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. The Defendant is Denise P. Murphy (hereinafter referred to as "Mother"), who currently resides at 543 Spring House Road, Camp Hill, Cumberland County, Pennsylvania 17011. Ryan C. Murphy Travis W. Murphy Plaintiff seeks shared legal and physical custody of the following children: PRESENT RESIDENCE 543 Spring House Road Camp Hill, PA 17011 6/28/88 8/18/91 4. The children are presently in the custody of the Mother who resides at 543 Spring House Road, Camp Hill, Cumberland County, Pennsylvania, 17011. 5. During the past five years the children have resided with the following persons at the following addresses: 1996 to 10/15/01 1015/01 to present 543 Spring House Road Camp Hill, PA 17011 543 Spring House Road Camp Hill, PA 17011 NAMFS OF pER,~-)NS IN HOUSIZHOLD Mother, Father, children Mother, children The parties are presently married but separated. 6. The Mother of the children is Denise P. Murphy, currently residing at 543 Spring House Road, Camp Hill, Cumberland County, Pennsylvania 17011. 7. The Father of the children is Richard E. Murphy, currently residing at 1908 High Street, Camp Hill, Cumberland County, Pennsylvania 17011. o currently resides with the following persons: No one The relationship of the Plaintiff to that of the children is that of Father. The Plaintiff resides with the following persons: NAME Ryan C. Murphy Travis W. Murphy The relationship of the Defendant to the children is Mother. The Defendant currently Son Son 10. Plaintiff has no information of a custody proceeding concerning the children pending in any court of this Commonwealth. 11. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 12. The best interest and permanent welfare of the children will be served by granting Father shared legal and physical custody of the children. Father has always been involved in the children's lives as an active caregiver and a source of stability. He is fit and able to care for the children. 13. Since the time of separation in October, 2001, Father has been attempting to develop a fixed schedule of custody with the children. This has been to no avail. Father would like to share legal and physical custody of his sons. Father is able to provide a stable loving environment for his sons. Father has a strong relationship with his sons. 14. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children has been named as parties to this action. WHEREFORE, the Plaintiff requests the Court to grant shared legal and physical custody of the children. DATE:~/~,~ ,2002 Respectfully submitted, ~van, ~squire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 RICHARD E. MURPHY, Plaintiff DENISE P. MURPHY, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - CUSTODY : : NO. I, RICHARD E. MURPHY, hereby certify that the facts set forth in the foregoing CUSTODY COMPLAINT are tree and correct to the best of my knowledge, information and belief. I understo~nd that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unswom falsification to authorities. Dated: .~/~'-'~ ,2002 RICHARD E. MURPHY PLAIN'rIFF V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : : 02-1379 CIVIL ACTION LAW DENISE P. MURPHY DEFENDANT : IN CUSTODY AND NOW, Thursday, March 28, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. GreeW, Esq. , the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Tuesday, April 30, 2002 at 8:30 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 be present at the conference. Failure to appear at the conference may provide grounds for entry ora 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/ Melissa P. Greevy. Esq. 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 heating. 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 jU OOZ RICHARD E. MURPHY, Plaintiff V, DENISE S. MURPHY, Defendant iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1379 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this 24th day of June, 2002, upon the request from counsel for the parties to reconvene the Custody Conciliation Conference, it is hereby directed that the parties and their respective counsel appear before Melissa Peel Greevy, Esquire, the Conciliator, at 301 Market Street, Lemoyne, Pennsylvania 17043 on the 6th day of August, 2002 at 8:30 a.m. for a Custody Conciliation 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 a temporary order. 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~~. Melissa Peel G-reevy, Es~juir Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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. Dist: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 Barbara Sumple-Sullivan, Esq., 549 Bridge Street, New Cumberland, PA 17070 Donald T. Kissinger, Esq., 130 Walnut Street, Harrisburg, PA 17101 :159964 RICHARD E. MURPHY, Plaintiff V. DENISE P. MURPHY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1379 CIVIL TERM 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 CURRENTLY IN THE CUSTODY OF Ryan C. Murphy Travis W. Murphy June 28, 1988 August 18, 1991 Mother Mother 2. A Custody Conciliation Conference was held on April 30, 2002 pursuant to Father's Petition filed on March 20, 2002. In attendance at the conference were the Father, Richard E. Murphy and his counsel, Barbara Sumple-Sullivan, Esquire; the Mother, Denise P. Murphy and her counsel, Donald T. Kissinger, Esquire. At the conclusion of a rather lengthy conciliation conference, counsel requested the opportunity to continue discussions to resolve this issue outside the conference setting. Those discussions continued. Progress was monitored by the conciliator through telephone conferences with counsel. Subsequently, the parties reached an agreement in the form of Stipulation and Order is attached. The custody conciliation conference will reconvene on August 6, 2002 at 8:30 at the office of the conciliator, Melissa Peel Greevy, Esquire, 301 Market Street, Lemoyne, PA 17043. At that time, the parties intend to discuss the schedule for the school year upcoming. Date t_...--' ~el~sa Peel Greevy, Esquire t~ustody Conciliator : 160073 RICHARD E. MURPHY, Plaintiff DENISE P. MURPHY, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - CUSTODY : NO. 02-1379 ORDER ADOPTING STIPULATION OF PARTIES AND NOW, to wit, this ~e4[ day of ~. ,2002, upon consideration of the foregoing Stipulation for Custody and on motion of Barbara Sumple-Sullivan, Esquire, counsel for Plaintiff, Richard E. Murphy, and Donald T. Kissinger, Esquire, counsel for Defendant, Denise P. Murphy, it is hereby ordered, adjudged and decreed that the terms, conditions and provisions of the foregoi,g Stipu,~tion for Custody dated,~,~.~, ~ 6/ ,2002 is ~dopted as an Order of Court as if set forth herein at length.