Loading...
HomeMy WebLinkAbout02-2571JEREMY RIDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NUMBER: ~ APRIL DICE, : Defendant : CUSTODY COMPLAINT FOR CUSTODY NOW COMES the Plaintiff, JEREMY RIDER, by his attorney, Charles E. Petrie, and respectfully represents as follows: 1. Plaintiff is JEREMY RIDER, who currently resides at 17 Arwin Drive, Hummelstown, County of Dauphin, Pennsylvania. 2. Defendant is APRIL DICE, who currently resides at 49 1/2 West High Street, Apartment 3, Carlisle, County of Cumberland, Pennsylvania. 3. Plaintiff seeks to have ri§hts of temporary physical and shared legal custody with respect to JOSHUA CLAYTON DICE, born May 18, 2001. The child was born out of wedlock. The child is presently in the custody of Defendant, APRIL DICE. Since birth, the child has resided with the followin§ persons and at the following addresses: from birth until March, 2002, with Defendant in Newville, Pennsylvania; from March, 2002, until the present with Defendant at 49 West High Street, Carlisle, Pennsylvania. The mother of the child is APRIL DICE, who currently resides at 49 ½ West High Street, Carlisle, Pennsylvania. She is not married. The father of the child is JEREMY RIDER, who currently resides at 17 Arwin Drive, Hummelstown, Pennsylvania. He is not married. 4. The relationship of the Plaintiff to the child is that of father. The Plaintiff currently resides with his parents, Raymond and Karen Rider, and with his brother, Brent. 5. The relationship of the Defendant to the child is that of mother. She currently resides with the child and with a person or persons unknown to Plaintiff. 6. The 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 in another court. The Plaintiff has no information of a custody proceeding concerning the custody of the child in this or in another court. Plaintiff does not know of a person not a party to these proceedings who has physical custody of the child or 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 confirming rights of temporary physical and shared legal custody in Plaintiff because Plaintiff has been denied access to 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 have been named as parties to this action. WHEREFORE, Plaintiff requests that Your Honorable Court enter an Order confirming rights of temporary physical and shared legal custody in Plaintiff. Respectfully submitted, CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I verify that the statements in the foregoing 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. DAT'B JEREMY RIDER PLAINTIFF V. APRIL DICE DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 02-2571 CIVIL ACTION LAW : IN CUSTODY _, ORDER OF COURT AND NOW, Tuesday, June 04, 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, at 301 Market Street, Lemoyne, PA 17043 on Monday, July 08, 2002 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 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. Greev'v. Esa. 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 AUG ] 2002 JEREMY RIDER, APRIL DICE, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2571 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER TO RELINQUISH JURISDICTION AND NOW, this 9th day of August, 2002, the counsel for parties having requested a thirty (30) day continuance on July 8, 2002, and the Conciliator having received no further request for the Custody Conciliation Conference to reconvene, hereby relinquishes jurisdiction of the above captioned matter. FOR TH E(~: Custody Conciliator :160538 JEREMY RIDER, APRIL DICE, Plaintiff VS. Defendant : In The Court of Common Pleas of : : CUMBERLAND County, Pennsylvania : : No. 02-2571 Civil Term : : Custody CUSTODY ORDER AND NOW, this J~ day of September, 2002, the following Order is entered by consent of the parties with regard to custody of the parties' child, Joshua Clayton Dice, born May_ 18, 2001: 1. Plaintiff, Jeremy Rider, hereinafter referred to as the father, and Defendant, April Dice, hereinafter referred to as the mother, shall share legal custody of the child. 2. The mother shall have primary physical custody of the child. 3. The father shall have partial custody of the child every other Saturday from 8:00 a.m. until 7:00 p.m., and at other times mutually agreed upon by the parties. The partial custody shall commence on July 20, 2002. 4. The parties shall alternate the following holidays from 10:00 a.m. until 7:00 p.m.: New Year's Day, Memorial Day, Independence Day, and Labor Day. The mother shall have Independence Day and Memorial Day in odd numbered years and New Year's Day and Labor Day in even numbered years. 5. The parties shall share the Thanksgiving Day holiday with the father having the child from 8:00 a.m. until 2:00 p.m. 6. The parties shall share the Christmas Day holiday with the father having the child from 12:00 p.m. until 8:00 p.m. on Christmas Day in even numbered years and 12:00 p.m. until 8:00 p.m. on Christmas Eve Day in odd numbered years. The holiday schedule in paragraphs four, five and six above, takes precedence over the regularly scheduled custody periods. 7. The father shall be responsible for all transportation for his periods of custody. 8. The father's visits shall be based from his parents' home. If the father plans to travel outside a radius of sixty miles of his parents' house with the child, he shall provide the mother with prior notice and a telephone number at which he can be reached. 9. In the event that for some reason Jeremy cannot see his son, his parents will have the right to see him. If neither Jeremy nor his parents are available for the father's ,scheduled Saturday visit, the father shall give the mother twenty-four hours notice so that she can secure child-care. 10. In the event of dangerous weather, the mother has discretion as to whether or not the scheduled visit will take place, and the parties will mutually agree to a make-up date. 11. The mother and father, by mutual agreement, may vary from this schedule at any time, including expanding the partial custody schedule to include overnight periods when the child becomes older and when the father secures housing with appropriate overnight accommodations for the child, but this Order shall remain in effect pending further order of court. 12. The mother and father shall notify the other immediately of medical emergencies that arise while the child is in that parent's care. 13. Neither party shall do anything which may estrange the child from the other parent, or injure the opinion of the child as to the other parent or w~.~amper the free and natural development of the child's love or respect for the. oth_/~nt. ~ .~,~ By ttl~ourt, f/ ~ Judge Charles E. Petrie, Attorney for PlaintilT 3528 Brisban Street Harrisburg, PA I 71 ! ] 8 lrvine Row Carlisle, PA 17013 9 39~d 9808£ffSZ~Z:XUJ 33IJJO 3qSI3~U3 SqdM:~I 8B:ff[ 80, 88/Z0 Z98'ON 3qIJ