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HomeMy WebLinkAbout06-6964 DOUGLAS L. WILSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006- 49&-y CIVIL TERM ELIZABETH B. WILSON, CIVIL ACTION - LAW Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Douglas L. Wilson, an adult individual currently residing at 14513 Paxton Run Road, Shippensburg, Franklin County, Pennsylvania 17257-9118. 2. Defendant is Elizabeth B. Wilson, an adult individual currently residing at 11 Wooded Drive, Shippensburg, Cumberland County, Pennsylvania 17257-9715. 3. Plaintiff seeks shared custody of the child, Bailey M. Wilson. 4. The parties are the parents of Bailey M. Wilson, age 5, born May 29, 2001. 5. The child was not born out of wedlock. 6. The child is presently in the custody of Defendant at 11 Wooded Drive, Shippensburg, Cumberland County, Pennsylvania. 7. During the past five years, the child has resided with the following persons, at the following addresses, for the following dates: Persons Address Date Douglas L. Wilson 14513 Paxton Run Road May 29, 2001 and Shippensburg, Pennsylvania through Elizabeth B. Wilson July 17, 2006 Persons Address Date Elizabeth B. Wilson 11 Wooded Drive July 17, 2006 Larry & Linda Basler Shippensburg, Pennsylvania to Anne Basler Present 8. The mother of the child is Elizabeth B. Wilson, currently residing at 11 Wooded Drive, Shippensburg, Cumberland County, Pennsylvania. She is married to Plaintiff. 9. The father of the child is Douglas L. Wilson, currently residing at 14513 Paxton Run Road, Shippensburg, Franklin County, Pennsylvania. He is married to Defendant. 10. Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the child in this or in any other Court. 11. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or in any other state. 12. Plaintiff does not 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. 13. The best interest and permanent welfare of the child will be served by granting the relief requested because Plaintiff is the natural father of the child, Plaintiff has cared for the child since birth, Plaintiff resides in the marital residence, Plaintiff can provide for the child in all aspects, and Plaintiff loves the child and will act in her best interest. 14. 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 right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene. None. WHEREFORE, Plaintiff requests this Honorable Court to grant him shared physical custody of the child. Respectfully Submitted, O'BRIEN, BARIC & SCHERER Robert J. Wiley, squire I.D. # 203418 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Attorney for Plaintiff I . VERIFICATION I verify that the statements made in this Complaint for Custody are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Xle, ou as L. Wilson Date: December 4, 2006 Cl\ No hJ t'^t n 0 -n I TA DOUGLAS L. WILSON IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ELIZABETH B. WILSON DEFENDANT 06-6964 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, December 12, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, January 04, 2007 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: isi Jacqueline M. Verney, Esq. jk 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 FS :Z I'M z! O]o 90oz 'la- , f/. r/ ty. _! TIIJ JUN 15 2007^/ DOUGLAS L. WILSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-6964 CIVIL ACTION - LAW ELIZABETH B. WILSON, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 13th day of June, 2007, the parties, having asked for a continuance and not requested a conference for more than six months, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, A.Y acqu ine M. Verney, Esquire, Cust Conciliator a C, z CD .