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Home My WebLink About06-4895 II LINDSEY BRICKER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ~NO. O&-4f?15' ~},;,( +(n".. vs. JASON FOLK, Defendant : CIVIL ACTION-LAW : CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you, and a decree of divorce, or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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, PA 17013 (717) 249-3166 II LINDSEY BRICKER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA ; NO. C1--41'9~ dO\'L~~ : CIVIL ACTION-LAW : CUSTODY vs. JASON FOLK, Defendant COMPLAINT FOR CUSTODY AND NOW, the Plaintiff, by and through her attorneys, the Law Offices of Patrick F. Lauer, Jr., LLC, files a Complaint for Custody against Defendant, and in support thereto, avers the following: 1. Plaintiff is Lindsey Bricker, Mother, who currently resides at 1110 Cocklin Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant is Jason Folk, Father, who currently resides at 755 Long's Gap Road, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following child: Name: Present Address: Age: Brianna Folk 1110 Cocklin Street 5, d.o.b. 08/15/01 4. The child was born out of wedlock. 5. The child is presently in the custody of Lindsey Bricker, Mother, residing at 1110 Cocklin Street, Mechanicsburg, Pennsylvania. 6. During the past five years, the child has resided with the following persons and at the following addresses: II Persons: Addresses: Dates: Lindsey Bricker, Mother Chad Link 1110 Cocklin Street Mechanicsburg, P A Feb. 2006-present Jason Folk, Father Mechanicsburg, P A Feb.2003-Feb.2006 Lindsey Bricker, Mother Jason Folk, Father Carol Bricker, maternal Grandmother 1 Sherwood Drive Mechanicsburg, P A Sept. 200l-Feb. 2003 7. The Mother of the child is Lindsey Bricker, who resides at the address referenced in Paragraph One above. 8. She is married to Defendant, Jason Folk. 9. The natural father of the child is Jason Folk, who resides at the address references in Paragraph Two above. 10. He is married to Plaintiff, Lindsey Bricker. 11. The relationship of Plaintiff to the children is that of natural Mother. Plaintiff currently resides with the following persons: Name: Relationship: Lindsey Bricker Chad Link Mother Mother's boyfriend 12. Plaintiff has not participated as a party or witness, or in another capacity in other litigation concerning the custody of the children in this or another court. 13. 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. II 14. The best interests and permanent welfare of the child will be served by granting the relief requested because: (a) the Plaintiff is able to provide a stable home for the child; (b) the Plaintiff is economically able to care for the child; (c ) the Plaintiff has been the caretaker of the child since birth. WHEREFORE, Plaintiff respectfully requests, this Honorable Court enter an Order granting her primary physical custody and shared legal custody. Respectfully submitted, Date:t1'- ,) d- -a () ., ana M. Pugh, s . e Law Office ofPatri F. Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 170 II ID# 200952 Tel. (717) 763-1800 i LINDSEY BRICKER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. JASON FOLK, Defendant : CIVIL ACTION-LAW : CUSTODY VERIFICATION I verifY that the statements made in this Complaint for Custody 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: ~dcx:ru. Signature~lfi~/:il M~ fa-c) Lindsey cker ~~iV ~ .... ~ - ~ .-.. ~ .....1 \.).> -- ~ ~ () ~~ -on', Ci; ~ '~ if~-; j s::: ":::.; ,~ 0,--.-,.' 5S~~ .'" ~ ~ ...." = c" 0-' ". c-=: G') N c...l E: -"'" - - ~ :r!.,., rn~ :9,V ?\ (-~ ~~ l'~ l,;C) ".rn ::?t ~ .J;::" '" LINDSEY BRICKER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 06-4895 CIVIL ACTION LAW JASON FOLK DEFENDANT IN CUSTODY ORDER OF COURT AND NOW. Friday, August 25, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. at 39 West Main Street, Mechanicsburg, PA 17055 on Friday, September 22, 2006 , the conciliator, at 10:00 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 bours prior to scheduled hearinl!. FOR THE COURT. By: Isl Dawn S. Sunda Es 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 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 ~~?- ~ ~ 'J7oN . Iff ~ ~ ~ VIp n?'tJf fJP $- ~-.tI.? -r; ?i-!- P \!"I""'-L) "" ,- ,;."d\ \;:):\:l<::-Jd . JJ.Ni,. ,,-, n:" "^~',,^'''''r'\ ._ ,_ ' ',o" '" ~:~ :'41 t..,) 2 S :01 ~lV \ - dJS quGl J.,ti'9'lONCHiUbd 31-11 :10 3:JU:lv.Q311:l 3EP 2 5 i006 /YIy 'Y LINDSEY BRICKER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 06-4895 CIVIL ACTION LA W JASON FOLK Defendant IN CUSTODY ORDER OF COURT AND NOW, this 2') cl. day of 0 :t . fad , 2006, upon consideration ofthe attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Lindsey Bricker, and the Father, Jason Folk, shall have shared legal custody of Brianna Folk, born August 15,2001. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of this paragraph, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 2. The Mother shall have primary physical custody ofthe Child. 3. The Father shall have partial physical custody of the Child on alternating weekends from Friday at 6:30 p.m. through Saturday at 8:00 p.m., beginning Friday, October 6, 2006. In addition, the Father shall have custody of the Child every Tuesday and Thursday from 6:30 p.m. through 8:30 p.m., beginning Tuesday, September 26, 2006. 4. The parties shall share having custody of the Child on Thanksgiving Day and Christmas Day, with the Father having custody from 9:00 a.m. until 3:00 p.m. and the Mother having custody for the remainder of the day beginning at 3:00 p.m. The parties shall share having custody on the remaining holidays as arranged by agreement. 5. Unless otherwise agreed, the Father shall provide all transportation for Tuesday and Thursday evening periods of custody and the parent receiving custody shall provide transportation for all other exchanges of custody. 6. Both parties shall ensure that the Child is not exposed to smoke during his or her periods of custody. 'dMnf"\ :"~I .J C? : I r 1-1 11- J "'0 qnn7 ~...' (, .. " ~,l ,', ,,_, '. .. I.i I,J V 7. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Child comply with this provIsIOn. 8. This Order is entered pursuant to an agreement of the parties at 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, cc:~son Folk, Father ~hana M. Pugh, Esquire, Counsel for Mother ~ LINDSEY BRICKER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 06-4895 CNIL ACTION LAW JASON FOLK Defendant IN CUSTODY Prior Judge: none CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Brianna Folk August 15,2001 Mother 2. A custody conciliation conference was held on September 22, 2006, with the following individuals in attendance: The Mother, Lindsey Bricker, with her counsel, Shana M. Pugh, and the Father, Jason Folk, who is not represented by counsel in this matter. 3. The parties agreed to entry of an Order in the form as attached. ~-k'~ dd, dor)& Date Di1~sq~ Custody Conciliator