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HomeMy WebLinkAbout02-2806- arrl¢ - b.-i cha kon VS. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION IN CUSTODY NO. oa- NOTICE TO DEFEND TO THE RESPONDENTS NAMED HEREIN: You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Petition and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Petition or for any other claim or relief requested by the Plaintiffs. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS 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 Two Liberty Avenue Carlisle, PA 17013 (717)249-3166 Le han demandado a usted enla corte. Si usted quierc defenderse de estas demandas cxpuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partie de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objectones a las dcmandas en contra de su persona. Sea avisado que si usted no se defiende, las corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION IN CUSTODY COMPLAINT IN CUSTODY The plaintiff is-~I&.~l~l~residing at The defendant is ~--~qlffl~ Plaintiff seek~artial custody)~ (visitation) of the following chUrl(ten): NAME PRESENT ADDRESS AGE The child(ren) (was~om out of wedlock. The child(ren) is presently in the custody of.~t21rf'l~nL [-. ~ChOF([ft2/~ho resides at 4!~ ~1~ sL. r~lc4 -P~ ~-~ 40;- During the past five years, the child(ren) has resided with the following persons at the following addresses: LIST OF PERSONS ADDRESSES DATES currently residing at She is (single)(married)(divorced). The father of the child(ren) is ~ [4]/}0 '--'~,:.~.)/q. curren, tly residing at He is (single)(married)(divorced). The relationship of the Plaintiff to the child(ren) is~lr"The Plaintiff currently resides with: NAME RELATIONSHIP ir'. I The relationship of the Defendant to the child(ren)is: ~T~tQ~r- · The Defendant currently resides with: NAME RELATIONSHIP Plaintiff (has~articipated as a party or witness, or in another capacity, in other litigation concerning the custody of this minor child(ren) in this or another court. (if so)The court, term and number, and its relationship to this action is: Plaintiff (has)~nfonnation of a custody proceeding concerning the child(ren) pending in a court of this Commonwealth. (if so)The court, term and number and its relationship to this action is: Plaintiff (knows o~ot know_,) of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. The name and address of such a person is: The best interest and permanent welfare of the child will be served by granting the relief r~quested because: S ahic horn cnviromen c QhlCh nclvflcs 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. All other persons, named below, who are known to have or claim a fight to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: NAME ADDRESS BASIS OF CLAIM WHEREFORE, Plaintiffrequests this court to grant (custody)(temporary custody)(visitation) of the child(ren) to the Plaintiff. Respectfully submitted, Date I verify that the statements made in this Complaint are true and correct. I understand that false Statements therein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. (...~l~aintif'f HARRIET L. RICHARDSON PLAINTIFF V. JAMES W. RICHARDSON, IH DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-2806 CIVIL ACTION LAW 1N CUSTODY ORDER OF COURT AND NOW, Friday, June 14, 2002 , upon consideratior it is hereby directed that parties and their respective counsel appear before Melissa 1~ at 301 Market Street, Lemoyne, PA 17043 on Monday, July for a Pre-Hearing Custody Conference. At such conference, an effort will be made tc if this cannot be accomplished, to define and narrow the issues to be heard by the cou order. All children age five or older may also be present at the conference. Failure t( provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Prote¢ Special Relief orders, and Custody orders to the conciliator 48 hours prior to sci FOR THE COURT, of the attached Complaint, · Greevy, Esq. , the conciliator, 22, 2002 at 12:30 PM resolve the issues in dispute; or rt, and to enter into a temporary . appear at the conference may tion from Abuse orders, eduled hearing. By: /si M¢lissa P. Greevv. Esa. Custody Concili'ator ' The Court of Common Pleas of Cumberland County is required by lax~ 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. 1 YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT O~qCE. IF YOU DO NOT HAVE AN ATFORNEY 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 FtLED':3FFIOE OF T.:-.:~ :IO:¢-!O,*!OTARY 02 JU~ t "/ Pi'~ 12-' 52 CUMBERLt,,".~D OOUNrfy PEi~NSYL\/>~IA HARRIET L. RICHARDSON, Plaintiff V. JAMES W. RICHARDSON, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2806 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this ':~ day of July, 2002, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. J.P,~g~J~. The parties, Harriet L. Richardson and James W. Richardson, Ill, shall have shared legal custody of the minor child, Cody J. Richardson, born June 1, 1993. 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 his health, education and religion. Pursuant to the terms of Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent· '2. ~. Mother shall have primary physical custody subject to Father's rights of partial custody which shall custody which shall be arranged as follows: A. August 3, 2002 from between 9:00 and 10:00 a.m. until between 8:00 and 9:00 p.m. B. The weekends of August 17, 2002 and August 24, 2002 from 9:00 a.m. Saturday until 8:00 p.m. Sunday. C. On alternating weekends effective September 7, 2002, from 9:00 a.m. Saturday until 8:00 p.m. Sunday· D. The alternating weekends shall be extended to commence on Fridays after school at a time when the parties agree that Cody is sufficiently acquainted with Father's girlfriend· The parties anticipate this may occur sometime in September 2002. NO. 02-2806 CIVIL TERM 3. The parties shall consult with each other about the scheduling of any activities with the child, including sports and extracurricular activities, that would impact on the other parent's custodial time. 4. ~Z~:L~QQ. Unless otherwise agreed, the parent relinquishing custody shall provide transportation. 5. li_H_oJj~. The holidays shall be shared by the parties as they may agree. 6. This order is temporary in nature. In the event that the parties find themselves in need of another Conciliation Conference, such Conference may be scheduled upon the proper petition filed with the Prothonotary's Office. Dist: BY THE COURT: Harriet L. Richardson, 416 State Street, Enola, PA 17025 James W. Richardson, III, 2056 Carlisle Road, 2nd Floor, York, PA 17404 HARRIET L. RICHARDSON, Plaintiff V. JAMES W. RICHARDSON, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2806 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPOR I 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: Cody J. Richardson June 1,1993 CURRENTLYIN THE CUSTODY OF Mother 2. The parties were seen for their first Custody Conciliation Conference on July 22, 2002. Both parties appeared pro se.  The parties reached an agreement in th rder as attached. ~ Uel~ssa Pe~l Greevy, I~squire ~ Custody Conciliator :16O847 AUG 1 ~ ~00~ ~ HARRIET L. RICHARDSON, Plaintiff V. JAMES W. RICHARDSON, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2806 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT .AND NOW, this ~,~%~,jA~ day of August, 2002, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Harriet L. Richardson and James W. Richardson, III, shall have shared legal custody of the minor child, Cody J. Richardson, born June 1, 1993. 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 his health, education and religion. Pursuant to the terms of Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. Mother shall have primary physical custody subject to Father's rights of partial custody which shall custody which shall be arranged as follows: A. August 3, 2002 from between 9:00 and 10:00 a.m. until between 8:00 and 9:00 p.m. B. The weekends of August 17, 2002 and August 24, 2002 from 9:00 a.m. Saturday until 8:00 p.m. Sunday. C. On alternating weekends effective September 7, 2002, from 9:00 a.m. Saturday until 8:00 p.m. Sunday. D. The alternating weekends shall be extended to commence on Fridays after school at a time when the parties agree that Cody is sufficiently acquainted with Father's girlfriend. The parties anticipate this may occur sometime in September 2002. NO. 02-2806 CIVIL TERM 3. The parties shall consult with each other about the scheduling of any activities with the child, including sports and extracurricular activities, that would impact on the other parent's custodial time. 4. Z/A/Z~tjD~. Unless otherwise agreed, the parent relinquishing custody shall provide transportation. 5. Holidays. The holidays shall be shared by the parties as they may agree. 6. For a period of twelve hours before and continuing throughout any period of supervised visitation or partial custody with the minor child, the parties shall consume no alcoholic beverages nor possess or use controlled substances whatsoever. The parties shall likewise ensure, to the extent possible, that the other household members and/or house guests comply with this prohibition. 7. This order is temporary in nature. In the event that the parties find themselves in need of another Conciliation Conference, such Conference may be scheduled upon the proper petition filed with the Prothonotary's Office. BY TH,~ Dist: "/Harriet L. Richardson, 416 State Street, Enola, PA 17025 ,,James W. Richardson, III, 2056 Carlisle Road, 2nd Floor, York, PA 17404 HARRIET L. RICHARDSON, Plaintiff V. JAMES W. RICHARDSON, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2806 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY 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: Cody J. Richardson June 1,1993 CURRENTLY IN THE CUSTODY OF Mother 2. The parties were seen for their first Custody Conciliation Conference on July 22, 2002. Both parties appeared pro se. 3. The parties reached an agreement in the form of an Order as attached. The Conciliator files the new Order to include a provision in Paragraph 6 agreed to by the parties at the time of the Conference which was inadvertently omitted in the prior Order submitted to the Court. Date Melis~a Peel Greevy, Esquire Custody Conciliator : 160847v2