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HomeMy WebLinkAbout06-3259 ~ Diane S. Baker, Esquire LD. No. 53200 27 South Arlene Street P.O. Box 6443 Harrisburg, P A 17112-0443 (717) 671-9600 ALICIA LANG, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO.Ql. - .3.J.S9 : CIVIL ACTION - LAW : IN CUSTODY (!lU~ CiE/'4 BRIAN LANG, Defendant COMPLAINT FOR CUSTODY AND NOW, comes Plaintiff, Alicia Lang, by and through her attorney, Diane S. Baker, Esquire, and files this Complaint, based upon the following: 1. Plaintiff, Alicia Lang, is an adult individual residing at 2A Richland Lane, Apartment 202, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. Defendant, Brian Lang, is an adult individual residing at 129 Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania, 17043. 3. Plaintiff seeks primary custody of Brianna Eve Lang, born February 27, 2002. Plaintiff is the natural mother of the children and Defendant is the natural father of the child. The child was born in wedlock. The child is currently in the custody of Plaintiff. 2 . , Since birth, the child has resided with the following persons and at the following addresses: Plaintiff and Defendant 129 Bosler Avenue 2/27/02 - 4/18/06 Lemoyne, P A Plaintiff 2 Richland Lane 4/19/06 - Present Apartment 202 Camp Hill, P A 5. Plaintiff has not participated as a party or a witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 6. Each parent whose parental rights to the child that have not been terminated and the person who has physical custody of the child have been named as parties to this action. 7. The best interest and permanent welfare of the child will be served by granting the relief because Plaintiff can provide a safe home and a stable and loving environment for the child. 3 ... ... WHEREFORE, Plaintiff requests Your Honorable Court to grant her shared legal and primary physical custody of the minor child, Brianna Eve Lang, with Defendant having periods of partial physical custody as agreed upon by the parties. Respectfully submitted, s(Z"/oo e S. Baker, Esquire Supreme Court ID #53200 27 South Arlene Street Post Office Box 6443 Harrisburg, PA 17112-0443 (717) 671-9600 DATE: 4 , VERIFICATION I verify that the statements made in this Complaint 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. Q~:a~aKl~ ICIA LANG 5 7J. (J ;Q.. '\ -. *" -. 1-.) ,.-> 0 9 f:'':C':J ,.:? -(1 )...J C ~. .... I:;;:;.... .-\ - <- ~"'"'f\ -4 ::s ~ c:-~. \'-nr:=: .,"C-- .i;,:- -c(lt ~ \ -:>y ~ t cP ...>,Ci ~ F ..:"_:',, .." ~;,~~ ~ l: ~. -' c:? r \'" -~9. u:> . .., ALICIA LANG PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 06-3259 CIVIL ACTION LAW BRIAN LANG DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, June 13, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at MDJ Manlove, 1901 State St., Camp HiII, PA 17011 on Friday, July 07, 2006 at 2:30 PM 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 hearing. FOR THE COURT, By: Isl Melissa P. Greevy, Esq. 1)41 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 ~ b $~ ~ ?q.h!.1 - * :z. ~~JL, 1fl~ hI- ~ ~ iP 1Z ~ ~ --j71} '17-/7/-1 l \\'1,;/ i\-- II j \1 \ ,.... .. " \ q7 ", i ,'. ;.. v 'V . Gs:.\]l , ' , Diane S. Baker, Esquire I.D. No. 53200 27 Soutb Arlene Street P.O. Box 6443 Harrisburg, PA 17112-0443 (717) 671-9600 Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA ALICIA LANG, v. : NO. 06-3259-CV Defendant : CIVIL ACTION - LAW : IN CUSTODY BRIAN LANG, AFFIDAVIT OF SERVICE I, Diane S. Baker, Esquire, hereby certify that a true and correct copy of the Complaint for Custody was served on the Defendant by certified mail, restricted delivery, return receipt requested, on June 15,2006, at the Defendant's last known address of: Brian Lang 129 Bosler Avenue Lemoyne, P A 17043 The return receipt card is attached hereto as Exhibit "A". ~----., // ........-------::::x' ,,' " ) ".......,...., ~-- ;/'.. .... ..',.... .~..',..,.. ,1'-, // ~m:;. Baker, Esquire Attorney for Plaintiff /' C. .l..' ~ EXHIBIT" A" . ~ompl~te ite~s 1, 2, and 3. Also complete Item 4 If Restncted Delivery is desired. . Print your name and address on the reverse' so that we can return the card to you. . Attach this card to the back of the mail piece, or on the front if space permits. '~-;;~ /,(9 ~,er;fVi/lv<i-- Lr'/lldj/tL1 {9. (10/3 2. Article Number (rransfer from service label) PS Form 3811 , August 2001 3. ii51rvi ;:0- R C~Mail I cI Flii.llRecelpt for Merchandise .0. Fee) 4. es 7006 0100 0002 4043 1451 102595-01'M-0381 Domestic Return Receipt }/;. (- i . ;~ ~~ ~... 1'......- --.l -r"' ....) f', ) c., , Diane S. Baker, Esquire J.D. No. 53200 27 South Arlene Street P.O. Box 6443 Harrisburg, PA 17112-0443 (717) 671-9600 ALICIA LANG, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-3259 BRIAN LANG, Defendant : CIVIL ACTION - LAW : IN CUSTODY STIPULATION FOR CUSTODY AND NOW, comes the parties, ALICIA LANG, by and through her attorney, Diane S. Baker, Esquire, and BRIAN LANG, pro se, and stipulate as follows: 1. The parties are the natural parents of the minor child, Brianna E. Lang, born February 27, 2002. 2. Plaintiff/Mother Alicia Lang shall have sole legal custody of said child. Mother shall be solely responsible for all major decisions such as medical, education and religion concerning the minor child however she shall keep Defendant/Father Brian Lang advised of all significant matters concerning the child. 3. Mother shall have primary physical custody of the minor child. Father shall have periods of partial physical custody as agreed upon by the parties. Mother shall not unreasonably withhold any request by Father to spend time with the child. 4. Both parties shall provide the other parent with the address and phone number where they can be reached in the event of an emergency. Both parties shall keep the other party informed as to the whereabouts of the child including an address and phone number during vacation times with the child. S. Both parties shall be entitled to reasonable telephone and e-mail contact with the child while they are in the custody of the other parent. 6. During any period of custody or visitation the parties to this Order shall not possess or use any controlled substance, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this prohibition. 7. Both parents shall establish a no-conflict zone for their child and refrain from making derogatory comments about the other parent in the presence of the child and, to the extent possible, shall not permit third parties from making such. 8. The provisions of this Stipulation have been fully explained to Plaintiff by her attorney, Diane S. Baker, Esquire. Defendant has been advised that he has a right to counsel and has chosen to waive that right. 9. The parties agree that this Agreement shall be entered as Order of Court and the custody conference scheduled for July 7, 2006, shall be cancelled. . " IN WITNESS WHEREOF, the parties hereto have set their hands and seal the day and year first above written. Qt0-~~ ICIA LANG -Wl~ => ~^~^^^ L~ BRIAN LANG ~ . . . ", COMMONWEALTH OF PENNSYLVANIA :ss. COUNTY OF DAUPHIN .11" ~ On this, the ~ day of j J '\ , 2006, before me, a Notary Public for the Commonwealth of Pennsylvania, personally appeared ALICIA LANG known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the same for the purposes therein contained. ESS WHEREOF, I have hereunto set my hand and official seal. Notary Public COMMONWEALTH OF PENNSYLVANIA COUNTY OFC:::;416~cI :ss. /?r X' On this, the _ day of ....J~y ,2006, before me a Notary Public of the Commonwealth of Pennsylvania personally appeared BRIAN LANG known to me to be the person whose name is subscribed to the within document and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. Notary Public MATTHEW J. RUTKOWSKI, Notary Public lemoyne Boro, Cumberland County . ,Mv Commission Ex~ire:.~ne 19_,_ 2010, . .___,_. __.'" W"'__-' -~" i ,=--:i r,) f'" \- ..... ALICIA LANG, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-3259 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY v. BRIAN LANG, Defendant ORDER TO RELINQUISH JURISDICTION AND NOW, this day of July, 2006, the parties having reached an agreement which has been memorialized in a Stipulation and filed with this Court, the Conciliator hereby relinquishes jurisdiction of the above captioned matter, ~. :278700 cc; Diane S. Baker, Esquire, p, O. Box 6443, Harrisburg, PA 17112-0443 Brian Lang, 129 Bosler Avenue, Lemoyne, PA 17043 ~~ 7.11-0(. q.- !l!...,', ~'i~~J , F= !r_ e:) '>.. c: ~"f' ,--_: , (-~, , -'J '.r, .-;'-;" <-;:.;.;:., (-.... ~'-.. ' " '7 Rcr'Eilr,n '''L 1" "'~ ,.;. ' "-..., _."..J ~ \) . ....'~ ".i/~IJ 7 ALICIA LANG, Plaintiff . : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-3259 BRIAN LANG, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER AND NOW, this ,t/JIII. day of ~ ' 2006, it is hereby ORDERED that custody of the minor child, Brianna E. Lang, born February 27, 2002, shall be as follows: I. PlaintifflMother Alicia Lang shall have sole legal custody of said child. Mother shall be solely responsible for all major decisions such as medical, education and religion concerning the minor child however she shall keep Defendant/Father Brian Lang advised of all significant matters concerning the child. 2. Mother shall have primary physical custody of the minor child. Father shall have periods of partial physical custody as agreed upon by the parties. Mother shall not unreasonably withhold any request by Father to spend time with the child. 3. Both parties shall provide the other parent with the address and phone , , , number where they can be reached in the event of an emergency. Both parties shall keep the other party informed as to the whereabouts of the child including an address and phone number during vacation times with the child. 4. Both parties shall be entitled to reasonable telephone and e-mail contact with the child while they are in the custody of the other parent. 5. During any period of custody or visitation the parties to this Order shall not possess or use any controlled substance, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this prohibition. 6. Both parents shall establish a no-conflict zone for their child and refrain from making derogatory comments about the other parent in the presence of the child and, to the extent possible, shall not permit third parties from making such. J. ~ . " , , (" r" . (l I., .~.' \,} ",t... '0. 'I T1f Cw., L Ii:. :!uuG i