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Home My WebLink About06-2272 - CAUSSIA MARIE HODGE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 06- CIVIL TERM ONDRE MA YE, Defendant CUSTODY COMPLAINT FOR CUSTODY I. Plaintiff is Caussia Marie Hodge, hereinafter referred to as Mother. Mother resides at 92 B Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Ondre Maye, hereinafter referred to Father. Father resides at 1053 Chrisler Avenue, Schenectady, Schenectady County, New York, 12303-1215. 3. Mother seeks primary physical custody ofthe minor child: Name NyAsia Hodge-Maye Present Residence 92 B Street Carlisle, P A 17013 Age 9/13/99 DOB, 6 Yz years old NyAsia was born out of wedlock 4. NyAsia is in Mother's custody. During her lifetime, NyAsia has resided with the following persons and at the following addresses: Name Address Date Caussia Hodge Miqual Hodge Shamecea Hodge Ondre Hodge 204 North Pitt Street Carlisle, P A 17013 birth - 11/99 Caussia Hodge Miqual Hodge Shamecea Hodge 204 North Pitt Street Carlisle, PA 17013 11/99 - 5/00 --- Caussia Hodge Shamecea Hodge West Street Carlisle, PA 17013 5/00 - autumn 2000 179 West North Street Carlisle, PA 17013 autumn 2000 - autumn 2001 Caussia Hodge Miqual Hodge Shamecea Hodge Ondre Maye (brief intervals of time) 228 North Pitt Street Carlisle, P A 17013 autumn 2001 - 1105 Caussia Hodge Miqual Hodge Shamecea Hodge Ondre Maye (for one month) Caussia Hodge Miqual Hodge Shamecea Hodge 92 B Street Carlisle, PA 17013 1105 - present 5. Mother currently resides with the following persons: Name Miqual Hodge Shamecea Hodge NyAsia Hodge-Maye Relationship Son Daughter Daughter with Ondre Maye 6. It is believed that Father lives primarily with the following persons: Name Fleashia Maye Unknown Male Relationship Sister Sister's Boyfriend Father is also believed to spend some time living with his cousin and her family but Mother does not know their names. 7. Mother has not participated as a party or witness, or in another capacity, in other custody litigation concerning the custody of NyAsia in this or another court. ... 8. Mother has no information of a custody proceeding concerning NyAsia pending in a court of this Commonwealth. 9. Mother does not know of a person not a party to the proceedings who has physical custody of NyAsia or claims to have custody or visitation rights with respect to NyAsia. 10. The best interest and permanent welfare of NyAsia will be served by granting the relief requested for reasons including, but not limited to the following: a. Mother is presently able to provide for NyAsia by giving her a nurturing and stable home environment and providing for her emotional, physical, medical and educational needs and she has done so since NyAsia was born. b. Since NyAsia was born, Mother has been the parent responsible for her daily needs and has done so without assistance from Father. c. Since NyAsia was born, Father has spent minimal time establishing a relationship with her because of frequent, long-term periods of incarceration for drug sales. d. NyAsia does not know Father as a parental figure and has expressed disinterest and fear if she were to be forced into a relationship with him at this time. 11. Father has not acted in NyAsia's best interests in ways including but not limited to the following: a. Throughout NyAsia's six years, Father has extensive periods of time incarcerated in New York prisons for drug sales. Since Father was absent most of NyAsia's life, there is no tangible father/daughter relationship. b. On the occasions when Father was home with Mother and NyAsia, he did not help provide for NyAsia's daily needs. Despite the fact that Father did not work, ~' Mother still had to find child care for NyAsia because Father did not want to responsibility, c, Father has repeatedly asked Mother to drop his child support obligation and continues to refuse to pay child support or offer financial help to care for NyAsia, 12. Every person with rights to custody or having actual physical custody of NyAsia has been named as parties to this action, WHEREFORE, Mother requests this Court to grant her the foJlowing relief: 1. That Mother shall have sole legal custody of NyAsia, 2, That Mother shall have primary physical custody of NyAsia. 3, That Father shall have periods of supervised visitation in Pennsylvania at times and places agreed upon by the parties, 4, That the non-custodial parent shall have reasonable telephone contact with NyAsia while she is with the other parent 5, Any other relief this Court finds just and equitable. submitted, J sICa Holst, Esquire idPenn Legal Services 40 I East Louther Street Carlisle, PAl 70 13 (717) 243-9400 .~ VERIFICATION The above-named PLAINTIFF, Caussia Marie Hodge, verifies that the statements made in the above COMPLAINT FOR CUSTODY are true and correct. plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. s4904, relating to unsworn falsification to authorities. Date: it IC{. C' C? G,E-aJ<n ~, I-~?- Caussla Marie Hodge /' CAUSSIA MARIE HODGE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 06- CIVIL TERM ONDRE MA YE, Defendant CUSTODY AFFIDA VIr OF SERVICE BY MAIL I, Jessica Holst, do hereby swear that I served Ondre Maye with a Complaint For Custody ond-! Arr; ~ , 2006 by certified mail, return receipt, restricted delivery, to the person and address below: Ondre Maye 1053 Chrisler Avenue Schenectady, NY 12303-1215 I, Jessica Holst, verify that the statements made in this Affidavit of Service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: ;21 Ap" I ;/0::)(.9 Signature: \--\ '" ~ {...l (' .1 " o CAUSSIA MARIE HODGE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 06- l. 1- "1-7- CIVIL TERM ONDRE MA YE, Defendant CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Caussia Hodge, Plaintiff, to proceed in forma pauperis. I, Jessica Holst, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. J e si a H 1st, Esquire idPenn Legal Services 40 I East Louther Street Carlisle, P A 17013 (717) 243-9400 . CAUSSIA MARIE HODGE PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 06-2272 CIVIL ACTION LAW ONDRE MA YE DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, May 03, 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, Cumberland County Courthonse, Carlisle on Tuesday, May 30, 2006 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 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: Isl Tacqueline M. Verney. Esq. Custody Conciliator .(11 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 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 '~~fp ~~4 'JcJ,{:~ .~ -7 ~ ~IL, ~'E"? ~ dL._. nn ?Cl. [" '.> 5'7 C/. W'.;2 . r . "'U!if/ T 'II' , }".l.r'WV"',' i "-"'~~'V~JnJ 10 :Z Hd (- AVH SG02 CAUSSIA MARIE HODGE, Plaintiff \ MAY 3 = 2006 : IN THE COURT OF COMMON prlEAs:OF-==:::::::::::==== : CUMBERLAND COUNTY, PENNSYLVANIA ~~~. -:~ (-" -;- --i-~<, ",:; 1 0 , .. v. : No. 2006-2272 ONDRE MAYE, Defendant : IN CUSTODY 1. The Mother, Caussia Marie Hodge, shall have sole legal custody of NyAsia Hodge-Maye, born September 13, 1999. 2. Mother shall have primary physical custody of the child. 3. Father shall have periods of supervised visits in Pennsylvania as agreed by the parties. 4. 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. BY THE COURT, J. ~ ~ 8qk ~ ~ ~ ~n ~. ~~ 0{,. ~ o ~t" -'~ ~ 01') a~ >b ' ~'" <:. Or-~ ~c)< SS :2 Hd 2- ~mr qOOl I U\./' ,', I.... . ." , , :)1 \1 JO ^o jl\.J\\'l\..j\''LLLJdG JI ::J :J~}U :\[;-O:JlI:l