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Home My WebLink About06-2002 II SUZANNE K. WOODALL, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006 - ;;"60~ CIVIL TERM ROBERT L. WOODALL, II, Defendant. IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Suzanne K. Woodall, an adult individual, currently residing at 327 West Ridge Street, Carlisle, Cumberland County, Pennsylvania, 17013-4011. 2. Defendant is Robert L. Woodall, II, an adult individual, currently residing at 21 Mulberry Drive, Carlisle, Cumberland County, Pennsylvania, 17013. I 1\ I, I I I I I ! " , 3. Plaintiff seeks primary custody of the following children: Name Present Residence Date of Birth Isaiah R. L. Woodall 327 West Ridge Street Carlisle, Pennsylvania, 17013-4011 May 3, 1998 Briahna K. Woodall 327 West Ridge Street Carlisle, Pennsylvania, 17013-4011 May 7,2000 Jeremy D. Woodall 327 West Ridge Street Carlisle, Pennsylvania, 17013-4011 January 17, 2003 The children were not born out of wedlock. The children are presently in the custody of Plaintiff, who resides at 327 West Ridge Street, Carlisle, Cumberland County, Pennsylvania, 17013-4011. During the past five years, the children have resided with the following persons at the following addresses: Persons Residences Dates Suzanne K. Woodall 327 West Ridge Street Carlisle, Pennsylvania 17013-4011 November, 2005 to present Suzanne K. Woodall Robert L. Woodall, II 20 East Street, #7 Carlisle, Pennsylvania 17013-4011 Birth to November, 2005 The natural mother of the children is Suzanne K. Woodall, currently residing 327 West Ridge Street, Carlisle, Cumberland County, Pennsylvania, 17013-4011. She is married. I II I I The natural father of the children is Robert L. Woodall, II, whose mailing address is 21 Mulberry Drive, Carlisle, Cumberland County, Pennsylvania, 17013. He is married. II II II II Ii I! I' ,I ., 'I I: I' I! 'I I I I 4. The relationship of Plaintiff to the children is that of natural mother. Plaintiff currently resides with the following persons: Names Relationshio Isaiah R. L. Woodall Son Briahna K. Woodall Daughter Jeremy D. Woodall Son 5. The relationship of Defendant to the children is that of natural father. Defendant currently resides with the following persons: Names Relationshio Mr. Woodall Father Mrs. Woodall Mother 6. 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. I, 7. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have 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 children will be given notice of the pendency of this action and the right to intervene: None. WHEREFORE, Plaintiff requests your Honorable Court to grant her primary physical custody of the children and give Defendant partial custody at such times as is convenient for the Defendant and the parties. Respectfully submitted, I' il " I' I O'BRIEN, BARIC & SCHERER 1!-4a~ Michael A. Scherer, Esquire I.D. # 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 DATE: April 7, 2006 mas\Oomestic\Woodall\custody.camp ,- - ~ i I' II SUZANNE K. WOODALL, I I Plaintiff, V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006 - CIVIL TERM ROBERT L. WOODALL, II, Defendant. IN CUSTODY YERIFICA TION I verify that the statements made in the foregoing Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A.~4904, relating to unsworn falsification to authorities. S;~~t L~~ , zanne K. Woodall DATE: APril.3 , 2006 ~: 0:'':> ("-J P 0:) u: r- I \:-1 r:-~,~ r= ~~ II ~...:, (:} c.::) ,) (~...i C) oL ~ y c.J r" ~\f) ~ C'- --.J. ~ Q r::: ~~~~ _~-=a- 4\=. _ --a U ~~G-~ SUZANNE K. WOODALL PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 06-2002 CIVIL ACTION LAW ROBERT L. WOODALL, II DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, April 13,2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberlaud Couuty Courthouse, Carlisle on Thursday,. May 11,2006 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort wiIl 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. AIl 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 herehy 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: _~ lacqueline M. Verney, Esq. Custody Conciliator ~ The Court of Common Pleas of Cumberland County is required by law to comply with tlie Americans with Disabilites Act of 1990. For infol111ation about accessible facilities and reasonable accommodations available to disabled individuals baving 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 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 trf' c4Y'/f1?f1 ,f,z!? --0':' }~p;?~ tH) '70- of'-,/7 _ ': --It:":, .9 ,:29?rtft1J ,nn-+' J / j if? :;, F7/ ' -r u:~ .M- ,X'.d }?'7-?-:r>' J;.p ~ /ty1m/ ~09 p9 -Jr?- <<-17 ., "', .~' 'I I , ~ ",1 . '.' .._,~ . -:-~:D M.AY 1 9, 2006 IdY; V' : IN THE COURT OF COMM01" . VI' : CUMBERLAND COUNTY, PENNSYLVANIA ) SUZANNE K. WOODALL, Plaintiff V. : NO. 06-2002 CIVIL ACTION - LAW ROBERT L. WOODALL, II, Defendant IN CUSTODY ORDER OF COURT AND NOW, this 110 ~ day of (it"l ' 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Suzanne K. Woodall and the Father, Robert L. Woodall, II, shall have shared legal custody of Isaiah R. L. Woodall, born May 3, 1998, Briahna K. Woodall, born May 7, 2000 and Jeremy D. Woodall, born January 17,2003. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. 2. Mother shall have primary physical custody of the children. 3. Father shall have periods of partial physical custody as follows: A. Alternating weekends, beginning May 19,2006 from Friday at 6:00 p.m. to Sunday at 2:00 p.m. B. Such other times as the parties agree. 4. While the children are in Father's physical custody, they shall spend overnights either at paternal grandparents' house or paternal aunt and uncle's house. 5. Mother shall have physical custody of the children on Mother's Day; Father shall have physical custody of the children on Father's Day, both as agreed by the parties. 6. Holidays shall be shared as agreed by the parties. 7. Transportation shall be as agreed by the parties. 8. The parties shall have liberal telephone contact with the children. j -. . 9. Each party shall be entitled to one full week of physical custody in the summer provided they give the other party 30 days prior notice and provide a telephone number and address where the may be reached. 10. Neither party may partake in alcoholic beverages to the point of intoxication or illegal drugs immediately prior to or during their periods of physical custody. 11. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BYTH J. cc' Lchael A. Scherer, Esquire, Counsel for Mother ~bert L. W ooda11, II, pro se 'y/iNV1IlASNN3d ,wI 'J('~r . ... "''''-''~no . Ii f t ,,,' i":-_';"~!lr ! 1\,,--' '.' ...,); f t I 0 :Z Wd 91 A VW 900Z AtNIONOH10Od 3Hl :10 30!::!:lO-{J31I:l