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Home My WebLink About06-1931 DORY A, THOMPSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO, tJ/,' 1'i3/ CwJ !;.-. VS, MARCUS A. THOMPSON, Defendant CIVIL ACTION - LAW CUSTODY CUSTODY COMPLAINT 1. The Plaintiff is Dory A. Thompson, an adult individual residing at 321 Somerset Drive, Shiremanstown, Cumberland County, Pennsylvania 17011. Plaintiff resides in a single family home owned by her mother and step-father. 2, The Defendant is Marcus A. Thompson, an adult individual residing at a drug/alcohol rehabilitation facility located at 60 I Roxbury Road Shippensburg, Cumberland County, Pennsylvania 17257, The Defendant may have checked himself out of the facility prematurely and may be located at 400 High Street, Highspire, Dauphin County, Pennsylyania 17034, 3, Plaintiff and Defendant were married on June 29, 2004, 4, Plaintiff seeks sole legal custody and sole physical custody of her daughter: Madison E. Thompson (DOB 5/5/05; Age 10 months). 5, Since her birth on May 5, 2005 the toddler has always resided with the Plaintiff as her primary caregiver at the following addresses: a, 321 Somerset Drive, Shiremanstown, PA 17011 since 3/16/06, soon after the Defendant's admission to the drug/alcohol facility; and b, 5916 Linglestown Road, Harrisburg, PA 17112 (From 2/4/05 to 3/5/06), 6, The Mother of the child is Plaintiff Dory A. Thompson, 7, The Father of the child is Defendant Marcus A. Thompson, 8, The relationship of the Plaintiff to the child is that of Mother, 9, The relationship of the Defendant to the child is that of Father. 10, Plaintiff has not participated as a party or witness or in any other capacity in other litigation concerning the custody of the child in this or another court. 11, Plaintiff has no information of a custody proceeding concerning the child pending in another court of this Commonwealth, 12, Plaintiff does not know of a person not a party to the proceedings that has physical custody of the child or claims to have custody or visitation rights of the child, 13, The best interest and permanent welfare of the child will be served by granting the relief requested because: a. Father is presently enrolled as an inpatient at a drug rehabilitations center in Cumberland County, Pennsylvania; b. Father is addicted to alcohol and cocaine; c, Father is not able to care for Madison in any unsupervised setting; d, Father is unable to care for two children (Joshua Thompson, Age 6; and Kaitlyn Thompson, Age 5) from a prior relationship; e, When under the influence of alcohol or illegal drugs Father becomes violent and his behavior is erratic and often unpredictable; and f. Mother is employed full time and has the support of her mother and step-father in raising the child in a safe and healthy environment. 14, Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child haye been named as parties to this action, 15. The best interests of the child will be served by granting the requested relief. WHEREFORE, Mother seeks an Order granting her sole legal and physical custody of the child, Respectfully submitted, ven How , quire Howell Law Firm 619 Bridge Street New Cumberland, P A 17070 Supreme Court ID 62063 Attorney for Plaintiff By: Date: March 31, 2006 VERIFICATION I/we verify that the statements made in the foregoing document are true and correct. I/we understand that false statements herein are made subj ect to the penalties of 18 Pa. C.S,A. Section 4904 relating to unsworn falsification to authorities. ~'! a/J BY: ~Jrn Dory Thompson Date: li~ i ~; -. --J '-.J B ~ c~, , VJ -.J '"" ~ -:\ ;J ~ '\ " \\ \~ ""- -'"' f' ~ \~ ~L CJ -1.\ :::":3 \ 4--~ ..,::: .-" r:? -...< . ,. DORY A, THOMPSON PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, 06-1931 CIVIL ACTION LAW MARCUS A, THOMPSON IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, ApI!' 12, 2006 , upon consideration of the attached Complaint. it is hercby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. . the conciliator, at ,1\"I?J Manlove, 1901 Sta_t~~t,,91111' HiII,I';\,I7~}} on uF'ri~ay, May 12, 2006 at 8:30 AM It1r a Pre-Hearing Custody Conference, At such confcrencc, an effort will bc made to rcsolve the issues in dispute; or i r this cannot bc accomplishcd. to dellnc and narrow the issucs 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 hearin!!. FOR THE COURT. By:~,u., ,.,.Jlfelissa P. Greevy. Esq, -----\tlfI"- Custody Conciliator " The Court of Common Pleas of Cumberland County is required by law to comply with thc Americans with Disabilites Act of 1990, For information about accessible facilities and rcasonablc accommodations available to disabled individuals having business before the court. please contact our ofllce, 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 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 '1V' u"P,1J 7,}' "Y'17 1r7 vI" /? 4:1~ J;ZJ ., ~,~)n( ~ _ Ai..,:7 j: ~if v"7! tr.7t?y(~ I"f"r - d /. J:>1 ';;', /*"" -p-r;t' #Vu,J ' P :1' IlJ (h7h?1;..6 tJ?;! v ,'; ,1, ;', "i" ,.' . -' ,~. ,- .. DORY A. THOMPSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 06 - 1931 MARCUS A. THOMPSON, Defendant CIVIL ACTION - LA W CUSTODY AFFIDAVIT OF SERVICE OF CUSTODY COMPLAINT AND CONFERENCE ORDER I hereby certify that service of the Custody Complaint and Order of April 12, 2006 was made in the following manner: 1. On April 28, 2006 Constable Ed Siptroth served both documents in person on the Defendant Marcus A. Thompson at 321 Somerset Drive, Shiremanstown, P A 17011 when he visited the child at Plaintiff s home as shown on Exhibit "A". Defendant's signature acknowledging receipt of service is on Exhibit "A". 2. On April 21, 2006 both documents were mailed by U.S. Express Mail to the Defendant's residential address at 2521 White March Way, Savannah, GA 31410 as shown on Exhibit "B". 3. Service by mail was achieved on a "Thompson" as shown on Exhibit "C- I", "C-2" and "C-3" on April 22, 2006 at 1:07 PM. 4. These statements are made subject to the penalties of 18 Pa. C.S.A. S4904 relating to unsworn falsification to authorities. Respectfully submitted, BY: even owe I, squire Howell Law Firm 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 I. .,~ n ~ d -= ~ I J :f 9- i ~ ~~ .Q:3 a~ _ut o 5' i:f CO ~~ 02' ~3 en 0 0- .....(1) .....a> ~~ . @ 00' Y>(6 ~2 i 8co . ,t::.0 ::::I ...:J i coo. ~8 ~a c- :J c ~a :J ~ -0 ~ :J =1;0. o' :f 89- :JQ o~ c~ ~'~ 3:~ m~ .ut '::j co CD :s- o CD 3 o ~ r ~ ~ ~ .... t f f f It a f .. m f Ji! ~ I [ ir r f .I~IIIIIIIIII'I J . . EQ D9397&8~9 US I PO zl.' P,~~" a " Day of Delivery Postage II '. Xl D 2nd D 2ndO.l.ll.. $ .. I I l' u,ed Date of Delivery Return Receipt Fee I Date AC~ed' \ I i, Jilip Month Day $ I ~::~:=ed . y~' Scheduled Time of Delivery $COD Fee $'nsurance Fee I, DAM ONoon "PM' . I .:; f)' 'PM Mllltery Total Postage & Faes I Flat Rate)Zl or Weig 0 2nd Day 0 3rd "-. $ i I,-f L: ,'.I I ~b.. ,')'. '.; 1 'nt" Alpha Country Coda AccePtance..~m.Pi~;n~tlals I FRO,~: (PlEASE PRINT) . PHONE i"J 11 ) "1 -, ('1 -- \7l. -: -, I (::;; \-t "'tor\ \\-(,we \\ \; s, 't \A \ r (:' \..\D\.A.I~\\ LAv,/ ~\ {M I f \ Cl (J~\ \ ~ qQ S +, ~e+ I 10, -, I '\\ ') i ~ Q.,J.) C,^ J\'\ S Q( \ 1\ /1 CI \ f:\ \ ., 0 -, 0 I I I FOR PICKUP OR TRACKING v,,,, www.usps.com _ _ _ -':;:~:r C,dl 1-800-222-1811 -=$E~5~ gEXPRESS - MIJIL UNITED STJJTES POSTJJL SERVICE. . . Del/very Attempt Time Mo. Ds Delivery Attempt Time Mo. DeUv8<y D_ TIme Mo. TO: (PLEASE PRINT) PHONE ( _ I ~ ~ a. CU s "'. '\ \-\0"",, P S1) f\.)-/ I ~Sa\ W~'\E M~(lS\-\\N\\'1I' <; 1\ V f.\ l'0 \\i \\ 14. I G p.j [~lcLr@ITT~-:[jD DO I FOR INTERHAnONAL IlUnNAnoNS. WRl11! COUNTRY NAME Bnow. ' I [ .. II - ------ ----..------------.===..-- ------.-------...-.---- ---------------=.J Ub ~ostal Service 4/~A(2006 15: 33 PAGE001/001F'~ Fax Server - ,-' ~ UNITED STJJTES ~ POSTAL SERVICE Date: 04/25/2006 Fax Transmission To: Steven Howell Fax Number: 717-770-1278 Dear: Steven Howell: The following is in response to your 04/24/2006 request for delivery information on your Express Mail item number EQ09 3978 879U S. The delivery record shows that this item was delivered on 04/22/2006 at 01 :07 PM in SAVANNAH, GA 31410to T THOMPTON. The scanned image of the recipient information is provided below, S. . f R .. Delivery 6ectlon Ignatme 0 eClplen!: 1~ /,.t:<r~f. w --'--..;..>. ., :1" . - Address of Recipient: --' ~L 10 ~ ~~ .91. rm. . United States Postal Service IPS - Track & Confirm or- .r--- ,..-- Page 1 of 1 ~ Track & Confirm Search Results Label/Receipt Number: EQ09 3978 879U S Detailed Results: e Delivered, April 22, 2006, 1:07 pm, SAVANNAH, GA 31410 e Arrival at Unit, April 22, 2006, 11:23 am, SAVANNAH, GA 31404 e Enroute, April 22, 2006, 7:42 am, SAVANNAH, GA 31418 e Enroute, April 21, 2006, 7:03 pm, HARRISBURG, PA 17107 e Acceptance, April 21, 2006, 5:01 pm, CAMP HILL, PA 17011 Traet&Confirm ~ Enter LabeVReceipt Number. L ( (<Bid') ( __ to tJ$I'$.t#Jm".,..> ) NotiIicatioe OptiOR$ Track & Confirm by email Get current event information or updates for your item sent to you or others by email. rOe>) Proof of Delivery Verify who signed for your item by email, fax, or mail. C ()q>) . POSTAL INSPECTORS Preserving the Trust site map contact us government services jobs National & Premier Accounts Copyrlght@ 1999.2004 USPS. All Rights Reserved, Terms of Use Privacy Polley http://trkcnfrml.smi.usps.com/PTSlntemetWeb/InterLabelDetail.do 4/24/2006 ...IPS - Track & Confirm ,...--... \ .~ .---.. Page 1 of 1 . ' .~. Home I t!t.!Jl Track a. Confirm Search Results Label/Receipt Number: EQ09 3978 879U S Status: . Delivered TiMkl.Confirm ~ Enter Label/Receipt Number. t.. Your item was delivered at 1 :07 pm on April 22, 2006 in SAVANNAH, GA 31410. The item was signed for by T THOMPTON. (AddItJI1ItaI ~ >- ) ("."". '" urn.f:ODJ"" >- ) ( NoIificatioII O"'ons ..............,.....hO.........,.........................r_~.........".............. ,.. Track & Confirm by email Get current event information or updates for your item sent to you or others by email. ce:;-;:) Proof of Delivery Verify who signed for your item by email, fax, or mail. (60)) . POSTAL INSPECTORS Preserving the Trust site map contact us government services jobs National & Premier Accounts Copyright@ 1999-2004 USPS. All Rights Reserved. Terms of Use Privacy Policy http://trkcnfrml.smi.usps.com/PTSlntemetWeb/InterLabelInquiry .do 4/24/2006 o c S::. O::Jrr.' rr!(" ~;J' r: ~~ ~c..' ...,j - ~; L- .=< ....., = <= C7" :x ::- -< o -n ~:!J I -om ::D? 90 :r::n S.2o om ---i ~ CT\ J,:. --'... - 0:> c..:> co r I DORY A. THOMPSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-1931 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY v. MARCUS A. THOMPSON, Defendant TEMPORARY ORDER OF COURT AND NOW, this ::70 - day of May, 2006, upon consideration of the CustOdy Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Dory A. Thompson shall have legal and physical custOdy of the minor child, Madison E. Thompson, born May 5,2005. 2. Father, Marcus A. Thompson, shall have visitation with the minor child arranged by mutual agreement of the parties. 3. matter. Cumberland County Court of Common Pleas shall relain jUriSdiction of this 4. This Order is temporary in nature and may be mOdified by mutual agreement of the parties. In the event that the parties do not agree, both parties relain the right to petition the Court for modification of this Order. 5. Counsel for the Plaintiff shall serve the Defendant with the copy of this Order at all known addresses, and shall file a Retum of Service confirming delivery of the Order to the Defendant. BY THE COURT: #d J. Dist: Steven Howell, Esquire. 619 Bridge Street, New Cumberland, PA 17070 Marcus A. Thompson, 2521 White Marsh Way, Savannah, GA 31410 ~ ~ 6', 3/J-- N_ ~. -'-",' - , ~ FiLED-- C':j leE OF ~Ht:r- IDor.m'!I~),\!()_II\t'ly . .. "U " " ", ", Ivr 2006 1M Y 30 P/1 12: 5 i CUtvt:::[,:/ ._; PEt DORY A. THOM SON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 06 - 1931 MARCUS A. TH PSON, Defendant AFFID VIT OF SERVICE OF TEMPORARY ORDER CIVIL ACTION - LAW CUSTODY I hereby ce ify that service of the Temporary Order of May 30, 2006 was made in the following m r: 1. Serv ce by first class US Mail, postage prepaid using USPS Form 3817 (Ce ificate of Mailing) on the following addresses known to be used by the efendant: a. 400 High Street Highspire, P A 17034 b. 2521 White Marsh Way Savannah, GA 31410 2. Copi s of both USPS Form 3817 are attached hereto showing service on June 1,2006. 3. Thes statements are made subject to the penalties of 18 Pa. C.S.A. ~4904 relati g to unsworn falsification to authorities. Respectfully submitted, BY: . -. U.S. POSTAL SERVICE CERTIFICATE OF MAILING - aa._ "~"""IA"I"""IAI lJlAl1 nnl:~ NOT Steven Howell Attorney At Law 619 Bridge Street Ne~ Cumberland, PA 17070 P Form 38t7, January 2001 U.S. POSTAL SERVICE MAY BE U$~r PROVIDE' CERTIFICATE OF MAILING Recelv " o o o o III I~ h c::> g -E:A- -0 m: 3lc.c I t.J'1 ~ 1; n f= ~ _~-a!'l s;lCl~ ::0 2-0:1:......." -I" '::rC~ o r -I en ;, ~ ::0 rn ------,--.- o o o o ~Iil ~~ i~ != o One piece 0 iI to: e~~ kC>Lt.lJ._~" ~ '\\\O(\t.r~O 1\ tc..c as a\ w ltl T e. 1'-\ M.~ ~t lJ\,.A-1- ~t.J'1 s AvAt7I1I1-I+- &A- 51 iff D ; n f ! _*-a!'l o~ ::0 -Q%......" -I. '::rC~ o r -I en ;, ~ ::0 rn PS Form 3817, January 2001 ,"" () ~-= - ,....., = <=> er- c_ <.:::: -.'V. ---- o -n --I ~::.TJ \- -(1 fTl ...~~~~: -r- -T, (") -:,'~.; --~::" (') ;~~~r-n ?lJ -< J en o f'.) cr',\