HomeMy WebLinkAbout94-00106
"
.
.
Petition of the Court of Common Pleal, cumberland
County,Pennlylval\ia,
"~,,for l.egal CUltody of Jamel Thomas O'Connor Jr.
Jamel Thomall 0' Connor Sr. I Plaint! ff 'n~ - 1 L17~
Wanpen Boon.in: Defendant
Jamel ThomBl 0 I Connor Jr, was born AprU 4th, 1992 in
Phuket, Thailand, and i. a United State. citizen Ipending
the lalt 16 month. at hi. home at 419 Allendale Way, Camp
Hill, Pennlylvania with both the Plaintiff and the
Defendant,
The Defendant abandoned the child on December 20th, 1993
leaving in the middle of the night. The Defendant I I
whereabout I are unknown. The Defendant hae not tried to
make contact with the Plaintiff or the child.
The Plaintiff, born October 2nd, 1946, Social Security
number 184-36-6159, ia the natural father. The Plaintiff
il a life long relident of Camp HU1, Pennlylvania, and hal
owned his home for the lalt nineteen yean, The Plaintiff il
retired from the rederal Government, and ownl leveral
rental propertiel in the area. The Plaintiff i. a member of
the St, Therel. 'I Catholic Church where Jamel Jr. was
The child ha. not been involved in any previous cUltody
lawsuH. There i. no knowledge of any other current custody
law.uH.
I
Ii
\
1,
,
.
baptiled. The Plaintiff has a daughter, Maureen, to a
prevlQul marriage who is Ufteen years old and Uvea in Camp
Hlll. James Jr, and Maureen are vary close. The P1aint1ff
carrie. health ~nsurance on James Jr" and ha. Dr, Jonel
AIIQciates in Camp Hill al his doctor,
The Defendant, born October 28th, 1970, is the natural
mother, The Defendant i. II. citilen of Thailand, and doe.
not have a green card.
Jame. Jr., Social Security number 166-74-5750, il
c:uuently attending day care at Uni ted Methodist Church in
Camp Hill several days a week whlle the PlaintUf i. taking
care of him the other day., James Jr, is a well adjulted,
happy, and intelligent boy for twenty months old.
We pray that the Court awards legal custody of Jamel Thom.s
O'Connor Jr. to hia father, Jam.. Thoma. O'Connor Sr.
,~ 'll, '..,
;;r--,
~ I, (() ~
~ I)'
,
~ :a , , .
~I~ ....
,,) ..
f: .' , " ~ "i\-
11,1.,_ ';)
I.'."" ". .() ~,
~ I, f ~ t.i . ~ Ii)
I, I;," " (j ~ ;,.I.!
. .f.' ~
~ .:.:, ,~ l,-j ~ '0
.'
.- U, ,,' .. ~
~'I I 0- "
Jq
, ' lo)l
.,i'
.
. '
JAMES T. O'CONNOR, SR,
Pldntiff
IN THB COURT or COMMQN
PLBAS OF CUMBERLAND
COUNTY, PBNNSYLVANIA
NO. 106 CIVIL 1994
VI.
WAN PEN BOONSIN,
Defendant CUSTODY
JUDGE PREVIOUBLY ABBIGN~Dl None
OOHilllJJMQI.J;!)f!f..!llM.!;Il.Jl!ll!l!DY RBPORT-
IN IICCORDANCB WITH CUMBBRl,AND COUNTY RULB OF CIVIL PROCBDURB 1915.3-8 (b), the
undersigned custody Conciliator submits the following reportl
1. The pertinent information concerning the child who in the subject of thia
litigation is as followSl
NM1!l.
lliTIIDA1'E
4 April 1992
CURRENTLY IN
~8TODY OF
Plaintiff/Father
James T, O'Connor, Jr,
3, A Conciliation Conference was held on 2 February 1994.
3, The Plaintiff/Fathor appeared at the conforence without counsel, He atated
that the mother had left the family home several months before and he did not know
where she was living, He apparently has not heard from her whatsoever for more than
two months, As a result, he had not effected service upon her,
I 4, Because the father needs a custody order to stablize the situation, as well aa
to obtain medical and other care for the child, he requesta an order be entered,
Attached is an order that wB 1 "rant him custody of the child while preserving the
Mother'a rights to have the order modified if and when she reappears and makes such a
I requeat, I explained to the father in a letter (a copy of which is attached to this
I report) that it would be his responsibility to serve a copy of the order upon the
I Mother as soon as she reappeared,
II
2
'''-'NU.... J.. ANP."
OIOlnl ft, VAUQIJf, "'
NlelKU', ... nAND.
". 1"1" Dlun..
ANJ)I'.H, VAl/OliN &: IIANOH
AT'I'OJiNHYH AT J.AW
rUin NUJfTII 'rWlu.rrn HTIfICl';I'
I', 0. nux IUU
LIl)'OYNIl, J'JlNNH1f!.vANIA 11<1.111
t.~".llII.
""I "1.11M1
,..
'"'' "I'I~I
4 ftbruary 1994
Hr. Th~a' T. O'Connor, Ir.
419 Allendale Way
Casp Hill, PA 17011
Dear Hr. O'CoDDorl
I write to follow-up on the Matter. we di.cu..ed at the cu.tody conference
in MY office on 2 February 1994.
Becau.e you bave not been able to make service of your complaint upon the
cbild's Moth.r, she ba. no notice of the proceeding., As a re.ult, tbe court's
order, altbougb it giv.. you custody of your child, cannot b. viewed a.
deterMining ber right. in the matter. 8imply put, the court cannot deterMine
b.r rigbt. witbout giving her an opportunity to pre.ent ber .ide of tbe .tory.
You will rec.ive an order in the mail, directly fr~ the court, witbin tb.
ne~t two we.k.. Tbat order will b. valid and will grant you cu.tody of your
cbild. If and wben the motber reapp.ar., bowever, it ia your duty to ..rye a
copy of tbat order, and your original p.tition, upon her, You c.n do tbat in
.ny way tbat you ar. able to prove tbat ab. receiv.d a copy l.ucb a. by
certified .ail or by baving anotb.r adult band her a copy in tbe pre.enca of
on. or Mor. witn.....). It will be your responsibility to do that.
Bincnely,
ANDBI, VAUGHN' BANGI
.amuel L. And..
lk
'I
Amllnll Ihu Rcell,." und "rlleeedlnllN enrulled In the enurl Ilf Cnmmlln I'leaN In and fllr lhu
cllunty Ilf ~rland . '__ III lhe l'nmmllnweahh Ilf ",nnNylvalllu
N 94-IQ" Civll -", >1M ' , I I Ilh f II I '
III Il, _" ________ crill,.... ,~_ IN enn a ne, e Il nw nil,
('OI'Y 0/' ~lete Apooarllnce
_ ()()CKF.T F.NTR Y
James Thomas OIConnor, Sr.
419 Al1endlll(l Way, C/ITlp Hill, PA 17011
va.
WlInpen Iloonsin
CQlJtSI
Complaint for CUstody Pd Plff $45,50 1/7/94
Janual~ 7, 1994, Complaint - custody
January 7, 1994, order of Court SlIllllel r" Andes -CUStody Conciliator
February 8, 1994, CondliatQr Conference SlI11nary Report and order by
Harold E. Sheely, Judge.
I,
i 'I'
h,
--
,
"~'.--
'tM .....-----
......-....-
.....
I' I
, "
I"
, ;. it
, I
, ,\,
, "
, 1 I"
'I \1
"
,
, c' ,
',I
J J I' a ~ j
hi - . j
- i J
' e J l:l \,/
. ~
.. ~
~ ! s ] ~ ~
t1 0 ,~ ll.
J ~ ! ~ ~
j ~
g :it 8
.... . . 1
I ~ 11'I 0
'3. ~ ....
1- ei 1 ~ ~ ~ I
7-
... "'"
. ,;
,
, '
.