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Home My WebLink About06-2755 v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06- .r1 ~h- Cw:.I ,. u.- CIVIL ACTION - LAW ANDREW SCOTT JUNK, Plaintiff TAMMY LOUISE JUNK, Defendant IN CUSTODY PLAINTIFF'S COMPLAINT FOR CUSTODY 1. Plaintiffis Andrew S. Junk (hereinafter, "Father"), an adult individual currently residing at 155 Beetem Hollow Road, Newville, Cumberland County, Permsylvania. 2, Defendant is Tammy L. Junk (hereinafter, ''Mother'), an adult individual currently residing at 157 Beetem Hollow Road, Newville, Cumberland County, Permsylvania. 3. Father seeks custody of the children, Rachel Savanna Junk, who was born November 16, 1997, and Zachary Scott Junk, who was born September 1, 2002. The children were born in wedlock. 4. Since the children's births, the children have resided with the following persons at the following addresses for the following periods of time: Since the children's births, they have resided at 155 Beetem Hollow Road, Newville, with both parties. 5. On May 14,2006, Motherremoved the children and their belongings from the marital residence to her relative's house nearby and refuses to allow Father to see the children. 6. Mother had kept the parties' son from daycare in an attempt to keep Father from the child. 7, For these reasons, Father requests an expedited Conciliation Conference. 8. The relationship oftheP1aintiffto the children is that of Father. He is married and living separately. The Plaintiff currently resides with the following: Rachel S. Junk Zachary S, Junk Relationship Daughter Son Name 9. The relationship of the Defendant to the children is that ofMother. She is married and living separately. The Defendant currently resides with the following: Name Rachel S. Junk Zachary S. Junk Relationship Daughter Son 10. The parties have not participated in previous litigation concerning the custody of the children in this court or any court. 11. The Plaintiffhas no information of a custody proceeding concerning the children pending in any other court. 12. The best interest and permanent welfare of the children will be served by granting custody to Plaintiff because: he can best provide a stable and nurturing environment for his children. 13. Plaintiff does not know of any person not a party to these proceedings who claims to have custody or visitation rights with respect to the children. WHEREFORE, Plaintiff requests your Honorable Court to set a time and place for a hearing at which Plaintiffrequests the Court to grant Plaintiff the Custody Order. Pending said hearing, Plaintiff requests temporary custody and an expedited Conciliation Conference. MARTSQN DEARDORFF WILLIAMS & OTTO I By Jennifi L. Spears, Esquire Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff Date: May 15, 2006 VERIFICATION The foregoing Complaint for Custody is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. 1 have read the Complaint and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities, which provides that if! make knowingly false averments, I may be subject to criminal penalties. a.~ Andrew Scott J F \FILES\DA T AFILE\General\Current\ 12088.1.custcom ~ ~ ~ 0 ,..., ~ c g ::;::, "" < ::;II: ~e -. ~ -(1\J.:~ \I~'\"\'-' ~ -..l _",1' -..l ,/:: \.. ..",h':l - :nl::( (('\ <JI !".. ~ ,:/ cc:\Q Ol ('~:. ~ ~ ,,- -0 ~:c -11 ,-' - 06 \) ':E" ' .... \:-' -., .- z ';'2~ O(rl - '-P. "'"' V 3 N ~ 0" :t ANDREW SCOTT JUNK PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. 06-2755 CIVIL ACTION LAW TAMMY LOUISE JUNK DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, May 19, 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 Courthouse, Carlisle on Thursday, June 22, 2006 at 10:30 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 hearin2. FOR THE COURT. By: Isl Jacqueline M. Vemev, 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 infonnation 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 >- ~ I-" UJQ (.) 4~ lC~", ''-~r:':: (r ~ DeL Ll.J :=! lU l.L.:r: t- L1- o N M 2':: z ::::..<( ::,)-:;; :_:):< :J:::i ."F .~_ ;-~-~~'5 r":':=;;:' !]m Do... ~ :J o "'T"" 0:: N N >- <.( :c \,.0 = = "'" ~~ ~ ~f( ~ . ") 'J SHERIFF'S RETURN - REGULAR CASE NO: 2006-02755 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JUNK ANDREW SCOTT VS JUNK TAMMY LOUISE DOUGLAS RUZANSKI , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - CUSTODY was served upon SPEARS TAMMY LOUISE the at WALMART , at 0937:00 HOURS, on the 17th day of May 60 NOBLE BLVD , 2006 DEFENDANT CARLISLE, PA 17013 by handing to TAMMY LOUISE JUNK a true and attested copy of COMPLAINT - CUSTODY together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge So Answers: rJ'/~ 6JD IP 18.00 4.40 .39 10.00 .00 32.79 .r~~ R. Thomas Kline '1 '-- -r 05/18/2006 MDW&O Sworn and Subscribed to before By: me this day of A.D. Prothonotary