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Home My WebLink About06-4685 . .. ASHLEY-MARIE JUNKINS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 61.-I./IJS Civil Tenn AHMAD GILES, : ACTION IN CUSTODY Defendant CUSTODY COMPLAINT 1. Plaintiff is Ashley-Marie Junkins, who currently resides at 45 W. Baltimore St., Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Ahmad Giles, who currently resides at 247 E. Princess St., York, York County, Pennsylvania, 17403. 3. Plaintiff is the mother of the following child and seeks a custody order regarding the following child: NAME DOB ADDRESS Ahmauri Giles 1/30/06 45 W. Baltimore St. Carlisle, Pa. 17013 child. Mother and Father are not married. Mother currently has primary physical custody of the . During the past five years, the children have resided with the following persons and at the following addresses: NAME ADDRESSES DATES Ashley-Marie Junkins 45 W. Baltimore St. Carlisle, Pa. 17013 Shawnta Boyer (maternal grandmother) Keith Boyer (maternal grandfather) Mariah Boyer (aunt, age 14) Brianna Boyer (aunt, age 13) Brian Boyer (step-uncle, age 17) July 18, 2006 - present , " Ashley-Marie Junkins Ahmad Giles 141 N. West St. Carlisle, Pa. 17013 1/30/06 - 7/18/06 . The mother of the child is Ashley-Marie Junkins. She currently resides at 45 W. Baltimore St., Carlsle, Pa. 17013. She is not married. The father the child is Ahmad Giles. He currently resides at 247 East Princess St., York, Pennsylvania, 17403. He is not married. 4. The relationship of plaintiff to the children is that of mother. The Plaintiff currently resides with the child, her parents, Shawnta Boyer and Keith Boyer, as well as Mariah Boyer (14), Brianna Boyer (13) and Brian Boyer (17). 5. The relationship of defendant to the child is that of Father. The persons that the Defendant currently resides with are his sister. 6. Plaintiff-has not participated as a party or 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 party to the proceedings who has physical custody of the child or anyone who claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: The oarties seoarated on July 18. 2006. Since that time Mother has maintained primary custodv of the child: Mother has also been the orimary caretaker of the child since birth. there is no custodv Order. Since the date of separation. Mother and Father have had diswzreements rel/arding the custody arranl/ements and Father has threatened Mother with regards to custodv. It would be in the best interest of the child to confirm that Mother has primary custody of the child in a Court Order because this would orovide stability and security for the child. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. , " ~ WHEREFORE, Plaintiff requests the court to enter a custody order regarding the child. Date:~\,-\ \ 0 ~ Respectfully submitted, ~ Adams, Esquire . No. 79465 South Pitt Street Carlisle, Pa. 17013 (717) 245.8508 ATTORNEY FORPLArnTWF , , . . '. VERIFICATION I verify that the statements made in this Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: 8//4) zcdo C--' '- .,.., ...'......., nh (v0) iff , \ ~ g ~ ~ ~ ~ - 5: ~ ~::t! ""('(J.~ ...... r-nr,. )...J -7 ,...' t;"> -or;; ....~ .,' , z~ - -'J';S '0 %, ~."~~.~- (Jl r..) - ~C" :~..,.. ?:: _ -1"\ ~ ~,f~) '-'" go ~ 9 _om - U J;>C S r- .. ~ ~ ~ - t w 1- . ASHLEY.MARIE JUNKINS PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 06-4685 CIVIL ACTION LAW AHMAD GILES DEFENDANT IN CUSTODY , ORDER OF COURT AND NOW, Monday. AUllust 21, 2006 , upon consideration of the allached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thnrsday. September 21, 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 pennanent 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 hearinl!. FOR THE COURT. By: Isl Hubert X. Gilroy, Esq. ..(if' 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 Ollr office. All arrangements must be made at least 72 hOllrs prior to any hearing or business before the court. You must allend 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 . ~ ~~ ":"~ ~ :)7./.", . ~ :? ~ ~~ 70/.1' ~~;2~~.~'A?/'b -,} C'''f qi IiINV/1 '. '.. :.':;\>:'..='..'^'n::> . 1"'.-- -"-""11'~ I "''Ice 1\J.J"\i.1. _ I S :01 IW 1- d3S 9flOl ",,'. 'l',id 3Hl :10 AU\;flOI.'I\;rc,::- r.'T1I:l o -rr"..1J\r.....bl_ :J,-/I_,,,"_ !J ASHLEY -MARIE JUNKINS, Plaintiff SEP 2 6 2006 fflt IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW AHMAD GILES, Defendant NO. 06-4685 IN CUSTODY COURT ORDER "\~ AND NOW, this 1.. ~ day of September, 2006, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. The mother, Ashley-Marie Junkins, shall enjoy legal and physical custody of Ahmaurie Giles, born January 30, 2006. 2. The father, Ahmad Giles, shall enjoy periods of temporary physical custody with the minor child pursuant to a schedule arranged between the father and the mother. Mother is encouraged to give the father liberal periods of temporary custody subject to a schedule they agree upon. 3. If the father desires to modify this Order, father may petition the Court to have this case again scheduled for a Conciliation Conference. If father retains an attorney, that attorney may contact the Conciliator directly to schedule another Conference. 4. The above Order is entered with the understanding that the father was not in attendance at the Conciliation Conference. In the event another Conciliation Conference is held or the Court conducts a hearing in this case, father may assert any and all claims relative to custody in this matter. BY THE COURT, cc~ Adams, Esquire ~mad Giles ~ Judge )JJ\("!C^'--: /" r'-;>~_:~:-::1:,t~n8 2 Z :8 Hlj E- .l.:JO 900l AtJ'ilO>'<./i-,-Udd 3Hl ::10 38U:;O-{EllIJ -- ASHLEY-MARIE JUNKINS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v CIVIL ACTION - LAW AHMAD GILES, Defendant NO. 06-4685 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Ahmauri Giles, born January 30, 2006. 2. A Conciliation Conference was held on September 21, 2006, with the following individuals in attendance: The mother, Ashley-Marie Junkins, with her counsel, Jane Adams, Esquire, and the father, Ahmad Giles, did not appear. Jane Adams indicated she sent two notices certified mail but he did not pick them up. The father did, however, contact Attorney Adams office a few days before the hearing and acknowledged that he was aware of the Custody Conciliation Conference. 3. Mother relates that the parties have been separated since July and that she has had primary custody of the minor child. She indicates that father has had various times of temporary custody of the minor child. 4. Based upon the above, the Conciliator recommends an Order in the form as attached. f:- ;JS; I V DATE ASHLEY MARIE JUNKINS IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. G 2006-4685 CIVIL ACTION LAW -3 ex r*i c- c rn--. AHMAD GILES v. IN CUSTODY DEFENDANT CC) ZZ rr p -' -+er?' M V J ORDER OF COURT AND NOW, Friday, June 29, 2012 upon consideration of the attached Com plaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, July 11, 2012 at 9:30 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. 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: /s/ Hubert X. Gilroy, Es q. 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 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 HAVE 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 J a 6lZ9l/L "ot ASHLEY-MARIE JUNKINS, Plaintiff vs. AHMAD GILES, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2006 - 4685 Civil Term IN CUSTODY Defendant ORDER OF COURT ~~ A, AND NOW, this ~~ day of N d ~I , 2012, having reviewed the agreement between the parties signed and dated the 16T" day of November, 2012, it is hereby ORDERED and DECREED that the attached stipulation shall be entered and incorporated into this Order of Court. By the Court: ~~ cc: / Jane Adams, Esquire, for Plaintiff / Ahmad Giles, Defendant fop, ~s ,~,,.Y~ol ~ ~ f~~/, = . ,ern o ~~~~ ZS' -C ~ ,.--, ~ C"" '~ ~ >~ ~ y ~_ ~~! y~ ~, v ,, ,_ .~ --~~~ ~`~ ,...,~ ASHLF,Y MARIE JUNKINS, Plaintiff vs. AHMAD GILES Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2006-4685 IN CUSTODY ORDER AND NOW, this l~ day of November, 2012, the Conciliator being advised the parties have reached an agreement and a Custody Stipulation has been signed and filed with the Court, the Conciliator relinquishes jurisdiction. Hubert X. GiJ~f~oy, Esquire Custody C ciliator