HomeMy WebLinkAbout91-1359
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,WENDY MARIE GRIMES,
I Plaintiff
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IIEMMANUELV~HRISTY' JR.,
II Defendant
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Ilwhose residence is at 547 North Bedford Street, Carlisle,
II Cumberland County , Pennsylvania.
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lindividual currently residing at Headquarters Company, U.S. Army
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i!Garrison, Box 8, Carlisle Barracks, Cumberland County,
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!IPennSYIVania.
Ii 3. Plaintiff seeks custody of her child, Evan Dominque
I!ChristY-GrimeS currently residing at 547 North Bedford Street,
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Ilcarlisle, Cumberland County, Pennsylvania and whose date of birth
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[lis February 14, 1991.
'i 4. The child is presently in the custody of
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IjPlainitff, who resides at 547 North Bedford Street, Carlisle,
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ICumberland County, Pennsylvania.
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION
13st1
NO.
CUSTODY
LAW
CIVIL 1991
COMPLAINT FOR CUSTODY
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Plantiff is Wendy Marie Grimes, an adult individual
Defendant is
Emmanuel
Christy,
Jr. ,
an
adult
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5. Since the
child's
birth, the child has resided with
following:
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Name
Address
Date
l'wendY Grimes
Tom Grimes
I Bonnie Grimes
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547 North Bedford Street
Carlisle, PA 17013
2/14/91 -
Present
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The relationship of the Plaintiff to the child is
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Ithat of natural mother. The Plaintiff currently resides with the
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ifollowing persons:
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II Tom Grimes
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Bonnie Grimes
II Evan Dominque Christy-Grimes
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[[that of natural father. The Defendant currently resides alone.
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Ilany other capacity, in other litigation concerning the custody of
lithe child in this or any other court.
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IlconcernJ.ng the child pending in a court of this Commonwealth.
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il 10. Plaintiff does not know of any person not a party to
ilthese proceedings who has physical custody of the child or
ilclaims to have custody or visitation rights with respect to the
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!!Child.
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Ilhave not been terminated and the person who has physical custody
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Name
Relationship
Father
Mother
Son
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The relationship of the Defendant to the child is
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The Plaintiff has not participated
as a party or in
Plaintiff has no information of a custody proceeding
Each parent whose parental rights to the child
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!of the child have been named as parties to this action. No
other persons are known to have or claim to have any right to
!,custodY or visitation of the child other than the parties to
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I 12. The best interest and permanent welfare of the
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Ichild will be served by granting the relief requested because:
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II (a) During the life of the child, Plaintiff has
!!provided primary care, custody and control for the child.
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I provided the primary physical, mental and emotional guidance and
Ithe primary physical, mental and emotional care for the child.
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ila time and place for a hearing at which time Plaintiff requests
lithe court to grant her custody of her child, Evan Dominque
II Christy-Grimes .
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(b)
During the lifetime of the child, Plaintiff has
WHEREFORE, Plaintiff requests your Honorable Court to set
mitted,
ON TURO, ESQUIRE
2 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 245-9688
Attorney for Plaintiff
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VERIFICATION
I VERIFY that the statements made in the foregoing
ii Complaint are true and correct to the best of my knowledge,
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iiinformation and belief.
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rlherein made are subject to the penalties of 18 Pa.C.S.A. Section
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,14904.
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I understand that false statements
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WENDY MARIE GRIMES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 135 q
CIVIL (qql
EMMANUEL CHRISTY, JR.,
Defendant
CIVIL ACTION - LAW
CUSTODY/VISITATION
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ii AND NOW, this /1 fA day of /i /IU . L
Ilconsideration of the attached complaint, it is hereby directed
Ilthat the parties and their respective counsel appear before
I!Ll~.Y. CJJ2.cr r~'l;-' the conciliator, at the Cumberland
II County Courthouse, 4th floor on the J. nd day of ml'l Y ,
111991, at II: JIJ A .m. for a Pre-hearing Custody Conference. At
I'isuch conference, an effort will be made to resolve the issues
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Ilin dispute; or if this cannot be accomplished, to define and
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!Inarrow the issues to be heard by the court, and to enter into a
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litemporary order.
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I[present at the conference. Failure to appear at the conference
I[may provide grounds for entry of a temporary or permanent order.
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ORDER OF COURT
1991,
upon
All children age five or older shall also be
THE COURT,
u~ rUckJ
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.
OFFICE OF THE COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE, 4TH FLOOR
CARLISLE, PA 17013
(717) 240-6200
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WENDY MARIE GRIMES,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
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:NO. 1359 - CIVIL - 1991
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EMMANUEL E. CHRISTY, JR.,
Defendant
:CIVIL ACTION - LAW
: CUSTODY/VISITATION
AND NOW, this
report of the
follows:
ORDER
?~ day of May, 1991,
Custody Conciliator, it
upon review of the attached
is ordered and directed as
A. Wendy M. Grimes shall have legal custody of Evan Dominque
Christy-Grimes born February 14, 1991.
B. In light of the fact that there is currently a paternity
action filed against Emmanuel E. Christy, Jr., the Defendant in
the above action, and Mr. Christy has not admitted paternity, Mr.
Christy does not seek any custody or visitation rights at this
time. In the event that it is determined that the Defendant is
the Father either by Defendant's admission or through court order,
Defendant may at that time petition this Court to have this
custody order modified, with the understanding that Defendant's
failure to seek custody or visitation with the minor child at the
initial custody conciliation conference will not prejudice his
position in the future.
C. Plaintiff's attorney shall provide a copy of this order to the
Defendant.
BY THE COURT:
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cc: Ron Turo, Esquire
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WENDY MARIE GRIMES,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
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:NO. 1359 - CIVIL - 1991
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EMMANUEL E. CHRISTY, JR.,
Defendant
:CIVIL ACTION - LAW
: CUSTODY/VISITATION
JUDGE PREVIOUSLY ASSIGNED: None
CONCILIATOR CONFERENCE SUHHARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8(b), 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:
Evan Dominque Christy-Grimes born February 14, 1991
and currently in the custody of Mother.
2. A Conciliation Conference was held on May 2, 1991 and the
following individuals were present:
Natural Mother Wendy M. Grimes with her counsel Ron
Turo and Father Emmanuel E. Christy, Jr. who was
unrepresented.
3. The parties agreed to the entry of an order as set forth in
the attached form.
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Hubert X. Gilroy, Es ire
Custody Conciliator
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