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Home My WebLink About02-2396IN THE COURT OF COMMON PLEAS OF CUMBERLAND~COUNTY, PENNSYLVANIA DAVID S. BABOIAN, ) Plaintiff ) ) v. ) ) CORA J. BABOIAN, ) Defendant ) NO. CIVIL ACTION - LAW CUSTODY/VISITATION COMPLAINT FOR CUSTODY Name Present Residence Christian T. Baboian 3525 Count~side Lane 9 months Camp Hill, PA 17011 The child was adopted by the parties during marriage. The child is presently in the custody of Cora J. Baboian who resides at 3525 Countryside Lane, Camp Hill, Cumberland County, Pennsylvania 17011. 1. Plaintiff is David S. Baboian, an adult individual currently residing at 4350 Carlisle Pike, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Cora J. Baboian, an adult individual currently residing at 3525 Countryside Lane, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff seeks partial custody of the following child, bom August 19, 2001: AND NOW, comes Plaintiff, David S. Baboian, by and through his counsel, Howett, Kissinger & Conley, P.C., who hereby files the instant Complaint for Custody and in support thereof avers as follows: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DAVID S. BABOIAN, ) Plaintiff ) NO. t~ -- ~2t?/_ ) v. ) ) CORA J. BABOIAN, ) CIVIL ACTION - LAW Defendant ) CUSTODY/VISITATION COMPLAINT FOR CUSTODY ANB NOW, comes Plaintiff, David S. Baboian, by and through his counsel, Howett, Kissinger & Conley, P.C., who h~reby files the instant Complaint for Custody and in support thereof avers as follows: 1. Plaintiff is David S. Baboian, an adult individual currently residing at 4350 Carlisle Pike, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Cora J. Baboian, an adult individual currently residing at 3525 Countryside Lane, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiffseeks partial custody of the following child, bom August 19, 2001: Name Present Residence Age Christian T. Baboian 3525 Countryside Lane 9 months Camp Hill, PA 17011 The child was adopted by the parties during marriage. The child is presently in the custody of Cora J. Baboian who resides at 3525 Countryside Lane, Camp Hill, Cumberland County, Pennsylvania 17011. at the following addresses: From April 28, 2002 Adoption During the past five (5) years, child has resided with the following persons T._~o With Whom Present Plaintiff April 28, 2002 Plaintiff and Defendant Address 3525 Countryside Lane Camp Hill, PA 17011 3525 Countryside Lane Camp Hill, PA 17011 The mother of the child is Cora J. Baboian, currently residing at 3525 Countryside Lane, Camp Hill, Cumberland County, Pennsylvania 17011. She is married to Plaintiff. 6. The father of the child is David S. Baboian, currently residing at 4350 Carlisle Pike, Camp Hill, Cumberland County, Pennsylvania 17011. He is married to Defendant. 7. The relationship of Plaintiff to the child is that of Father. Plaintiff currently resides with the following persons: None 8. The relationship of Defendant to the child is that of Mother. Defendant currently resides with the following persons: Name Christian T. Baboian Relationship Son 9. 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. 10. Plaintiffhas no information of a custody proceeding concerning the child pending a court of this Commonwealth or any other state. 11. Plaintiff does not know of a person not a party to the proceedings who have physical custody of the child or claims to have custody or visitation rights with respect to the child. 12. Sole custody isolates the child from the non-custodial parent. 13. The best interests of the child require that open and meaningful access be maintained with each parent and that the child have a relationship with each parent. 14. The best interests and permanent welfare of the child will be served by granting the relief requested because the child has developed an emotional attachment to each parent and the severing of that attachment is not in the child's best interest. 15. Permitting each parent to remain involved in the life of the child enables the child to share with each parent the intimate contact necessary to strengthen a true parent child relationship. 16. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as party's to this action. WI-IEREFORE, Plaintiff respectfully requests the Court grant Plaintiff custody of the child. Date: ,P.C. 130 Walnut Street P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Plaintiff, David S. Baboian VERIFICATION I, David S. Baboian, hereby swear and affirm that the facts contained in the foregoing C6~g for Custody are tree and correct to the best of my knowledge, information and belief and are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date: 5/14/02 David S. Baboian DAVID S. BABOIAN : PLAINTIFF : : V. : 02-2396 : CORA J. BABOIAN DEFENDANT : IN CUSTODY ORDER OF COURT 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW AND NOW, Tuesday, May 21, 2002 , upon consideration of the attached 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 Friday, May 31, 2002 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. 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: /s/ Hubert X. Gilroy. 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 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 heating 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 DAVID S. BABOIAN : PLAINTIFF : : V. _. CORA J. BABOIAN DEFENDANT : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-2396 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, June 05, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator,1 at 301 Market Street, Lemoyne, PA 17043 on Tuesday, June 25, 2002 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 hearing. FOR THE COURT, By: /s/ Melissa P. Greevy. 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 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 R..Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing $ 18.00 Poundage 1.35 Advertising Law Library .50 Prothonotary 1.00 Mileage 8.28 Misc. Surcharge 20. O0 Levy 20.00 Post Pone Sale Garn/shee 69.13 Advance Costs: 150. O0 Sheriff's Costs: 69.13 80.87 Refunded to Atty on 6/17/02 G Sworn and Subscribed to before me This. ¥ ~ day o~ So Ans~ters'~- . R. Tho~ Kline, Sheriff ' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-2376 Civil COUNTY OF CLrMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PHYSICIANS FOR WOMEN'S HEALTH Plaintiff (s) From DAWN WETZEL, 4 ROBIN COURT, MECHANICSBURG, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY AT 4 ROBIN COURT, MECHANICSBURG, PA 17055. (2) You arc aiso directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamisbee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and f~om delivering any property of the defendant (s) or otherwise disposing thereof; (3) if property of the defandant(s) not levied upon an subject to at~achmant is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that be/sbe has been added as a garnishee and is enjoined as above stated. Amount Due $2,376.00 Interest Atty's Corem % Arty Paid $31.75 Plaintiff Paid Date: MAY 14, 2002 REQUESTING PARTY: Name GAlL GUIDA SOUDER~ ESQ. Address: 503 N. FRONT STREET HARRISBURG, PA 17101 Attorney for: PLAINTIFF Telephone: 717-236-6440 Supreme Court ID No. 68740 L.L..50 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonotary, Civil Division DAVID S. BABOIAN, CORA J. BABOIAN, Plaintiff Defendant -'JUl ' oo2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2396 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER TO RELINQUISH JURISDICTION AND NOW, this 25th day of July, 2002, the counsel for parties having requested a thirty (30) day continuance on June 24, 2002, and the Conciliator having received no further request for the Custody Conciliation Conference to reconvene, hereby relinquishes jurisdiction of the above captioned matter. , CUStOdy Conciliator :160407 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DAVID S. BABOIAN, ) Plaintiff ) ) v. ) ) CORA J. BABOIAN, ) Defendant ) NO. 02-2396 CIVIL TERM CIVIL ACTION - LAW CUSTODY/VISITATION PRAECIPE TO THE OFFICE OF PROTHONOTARY: Kindly withdraw the custody complaint filed by Plaintiff on Or about May 14, 2002 and discontinue the above-referenced custody action. Donald T. Kissinger, Esquir(c..) HOWETT, KISSINGER & CONLEY, P.C. 130 Walnut Street P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Plaintiff, David S. Baboian