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Home My WebLink About06-5338 Cynthia L. Good, pro se 512 Sample Bridge Road Enola, P A 17025 CYNTHIA L. GOOD, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 0 ~ - lJ-' :J j 'if C-4.,J -- I ..l-- MICAH E. GOOD, Defendant CIVIL ACTION- CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, Cynthia L. Gocd , pro se, and files this COMPLAINT FOR CUSTODY, and in support thereof, avers the folhwing: 1. Plaintiff is Cynthia L. Good, with a -.:urrent mailing address of 512 Sample Bridge Road, Enola, Cumberland County, Commor vealth of Pennsylvania, 17025. 2. Defendant is Micah E. Good, wif 1 a current mailing address of 1433 Peace Drive, Belleville, Illinois, 62220. 3. Plaintiff seeks custody of the parties' minor children Name Katelyn Good Present Residence Age 5 512 Sample Bridge Road Enola, P A 17025 Abby Good same 3 The children were not born out of wedlock. The children are presently in the custody of the Plaintiff. During the past five years, the children have resided with the following persons at the following addresses: Name Address Date 512 Sample Bridge Road 2006 present Enola, P A 17025 Plain tiff & maternal grandparents Plaintiff & Defendant 1433 Peace Drive 2004-2006 Belleville, IL 62220 Plaintiff & Defendant 2507-B Ocean Court 2000-2004 Aberdeen Proving Grounds, MD 21005 The mother of the children is the Plaintiff, Cynthia L. Good, with a current mailing address of 512 Sample Bridge Road, Enola, Cumberland County, Commonwealth of Pennsylvania, 17025. The father of the children is the Defendant, Micah E. Good, with a current mailing address of 1433 Peace Drive, Belleville, Illinois, 62220. The parties remain married to each other; however, it is anticipated that a Complaint in Divorce may be forthcoming from the Defendant. 4. The relationship of the Plaintiff to the children is that of biological mother, who resides with her parents, the subject children's grandparents, Leslie and Diane Weller. 5. The relationship of the Defendant to the children is that of biological father. It is unknown if the Defendant resides with anyone as of this filing. 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 person not a party to the proceeding who has physical custody of the child or 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 Plaintiff the relief requested because: a. Plaintiff is the natural, biological mother of the children and has played a major role in the children's lives as their primary caregiver since the children's birth. b. Plaintiff has established a close bond with the children which should be maintained and nurtured in a loving and emotionally secure environment, fostered within recognized and comfortable surroundings. c. Plaintiff desires to exercise proper and reasonable parental duties and to enjoy the love and affection of the children in an emotionally secure environment. The children, while entitled to establish and nurture a . relationship with their natural mother, require more stability than the Defendant can be reasonably expected to offer. d. The children should be permitted to enjoy the continued care, love, affection and emotional support which can be provided by the natural mother in a loving and secure environment. e. The children, both females, would benefit greatly from custody with their natural mother who has been the primary caretaker of the children since their birth. f. The Defendant, presently in the United States military, is subject to duty transfer at any time by the government and is called upon to complete temporary duty assignments at the convenience of the government. 8. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the children has been named as parties to this action. WHEREFORE, Plaintiff respectfully requests this Honorable Court to grant primary physical custody of the children. '"\ DATE: J.tp f- I d-', 2006 Ww?{ J .~IJ d CyntHia L. Good, pro se 512 Sample Bridge Road Enola, P A 17025 Tel: 717-697-5256 . < \ ' . . CYNTHIA L. GOOD, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. MICAH E. GOOD, Defendant CIVIL ACTION- CUSTODY VERIFICATION STATEMENT 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. Cons. Stat. Ann. 9 4904, relating to unsworn falsification to authorities. Datei:=-~}-r ('2- ,2006 ,\ 1 ~ (ir~U1X' 'd: ' .' Cc{ Cy thia L. Good, Plaintiff \ -- ~ \J " '" \..N "- ~ '-. ~ ~~ ~ ~~ \ \~ ~ \~ '" ~ ~ " C.>o: "-'->. C.-" .-\ :1";~ i' > -- N ----- ---~- .. ' CYNTHIA L. GOOD PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 06-5338 CIVIL ACTION LAW MICAH E. GOOD DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, September 14, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Gret!'1'!Esq. , the conciliator, at MDJ Manlove, 1901 State St., Camp Hill, PA 17011 on Friday, October 20, 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 hearinl!. FOR THE COURT. By: Isl Melissa P. Greevy, Esq. ---IJ--l:A-- Custody Conciliator f' . . 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 A TTORNEY 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 ~h' -7 ~ ~ X' 7:-''''' ~~ ~_->>;? . ~~ ~ .2 ~~.J -;op ::v-->> t3 ... · " .',) 1 ;,1 S I 'S', ; 't .. Cr ~. "_"J CYNTHIA L. GOOD, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 0&... S 3 3 r MICAH E. GOOD, Defendant CIVIL ACTION- CUSTODY AFFIDAVIT OF SERVICE I, Diane Weller, an adult resident of Cumberland County, hereby certify that I have personally served a true and correct copy of the Complaint in Custody as per the Pa.R.Civ.P. 1930.4, docketed in the Cumberland County Court of Common Pleas at the above number, upon the Defendant. The place of service was 514 ~LE 6~1X.,.1: J(Oh~\ E IJQLA I a 17 () <0 The date and time of Service was 9 / I ~ I 0 (, J J .' c:J 0 P fY\ . I { Date: g //5-1 I ( 2006 ~:I112@Jr/ Diane Weller COMMONWEALTH OF PENNSYLVANIA COUNTY OF C\.\...~\()ex\o.s~ SS. On this, the \~ day of~ 2006, before me, a Notary Public, the undersigned officer, personally appeared DIANE WELLER, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. COMM ~rnOF~~~~ Notarial Seal 'l\u.nmy J. Misty_an, Notary Public ~T~., Cumberland County My COmmission Expires June 28, 2lJ07 Member, Pennsylvania Association of Notaries :~. .:t :: ~ '.-;~.:J C:i ~ .'- ,,) CYNTHIA L. GOOD V. MICAH E. GOOD IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006 - 5338 CIVIL TERM ORDER OF COURT AND NOW, this 17TH day of NOVEMBER, 2006, it appearing that a custody action is pending in the state of Illinois, before the Honorable Stephen Rice and it further appearing that mother and the children resided with father in Illinois for two (2) years before moving to Pennsylvania in August 2006, proceedings in this matter are stayed pending Judge Rice's determination of whether Illinois has jurisdiction under the Uniform Child Custody Jurisdiction Act. (23 P.S. ~ 5421, 750 ILCS 36/201). ~ssa Greevy, Esquire ~hael Sheldon, Esquire Jffl Laux, Esquire P.O. Box 1473 O'Fallon, Illinois 62269 ~hard Coffee, Esquire 333 Salem Place, Suite 100 Fairview Heights, Illinois 62220 :sld Edward E. 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