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HomeMy WebLinkAbout94-01895 .C ~ ~. / ( JI. ( J .J \~ I \01 ~! ~ ............ '# \ ...'('. , .. . - :.~~.':~",:'1u'. I,.... P(,fJ t''''''7 : T e:-ffrt-v Il - -11"1<\111 dl! , . I"W t", IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : . . . . v . Dew,A ~. ~~-\c:t'"\ ; NO. 01,/- ~S- ,.."I ~e~~~~~~ : B,,( ~w" L, /1v.J;. ORDER OF COURT AND NOW, Ilcg~~~ f6', ICf{1H upon consideration of the attached complaint, it is hereby directed that the part es and their cespe~tive counsel appear before ~ b r - &. If" t , the conciliator, at '-l 0..... h......~,. on the~dayof....1V ,19, ,at .' P79.fVJ, m~a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute1 or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a t~~{~ry order. All children age five or older ~l lalso be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. . . CUSTODY/VISITATION .-:... FOR THE COURT, 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. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 ~ ~rR 21 II 18 ~~ 1M , tile! of' ','OI4';an r.\J~.'~ .I,~O ,;, ,;!IT~ \-\.H~').n o..i'.\ ( fl.p l1-,,_'1I\ . vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW ~ NO. CJIf- IBCjs CIVIL~_ JEFFREY A. MARTIN Petitioner DAVID H. HUSTON and BARBARA, L. HUSTON Respondent . . : VISITATION ORDER OF COURT AND NOW, this 13 ri-l day of )jfa-r { '--- , 19~on consideration of the attached application , leave is granted to the petitioner to proceed in forma pauperis to the extent that he is relieved of all costs in this action. ipt J!--- I JUN 2 2 1994Cl,,\ JEFFREY A. MARTIN, Plaintiff : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA . . v :NO. 94-1895 - CIVIL - 1994 . . DAVID H. HUSTON AND BARBARA L. HUSTON, Defendants . . . . :CIVIL ACTION - CUSTODY COURT ORDBR off AND NOW, this;:)O day of I!y~",- , 1994, the Conciliator having appeared for the Conf~nce on June 9, 1994, and no parties having appeared for either the Plaintiff or the Defendant, the Conciliator relinquishes jurisdiction. Another Conciliation Conference will be scheduled upon petition of either party. ;/)?Ill cc: Jeffrey A. Hartin C be-hd .I.... r:; /2. Z/'11 0,. " ... ~~ (~q\ vI J JEFFREY A. MARTIN Petitioner vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, : PENNSYLVANIA CIVIL ACTION - LAW ~~ NO. .!]....- I afj!j CIVIL ~_ DAVID H. HUSTON and BARBARA L. HUSTON Respondents VISITATION PETITION FOR VISITATION TO THE HONORABLE JUDGES OF SAID COURT: Petitioner, JEFFREY A. MARTIN, Pro se, respectfully represents the following: 1.. Petitioner, JEFFREY A. MARTIN, is an adult presently incarcerated at the State Correctional Institute at CAMP HILL, PA. His expected date of release is lj, 0 c f 90{ . 2. Previous to his incarceration, petitioner's last address was 175 E. North Street, Carlisle, Cumberland County, Pennsylvania, 17013 . 3. Respondent, David H. Huston and Barbara L. Huston are adults residing at 2107 Douglas Drive, Carlisle, Cumberland, County, Pennsylvania, 17013. ~. The petitioner is a natural parent of the following minor child: Jeffrey Allen Martin born .s c.~ q (elR,., ~~ The minor child has currently resided with David H. Huston and Barbara L. Huston for .) Ye~ ('<; ... -__A _ 6. The minor child has resided in the following places for the following approximate times: ~ Jeffrey Allen Martin Address/Dates 2107 Douglas Drive, Carlisle, Pa. (.:>. 'fe....s) 7. Petitioner has not participated as a party, witness or in any other capacity in any other litigation concerning custody or visitation of the above-named minor child in this or any other court. B. Petitioner knows of no other person, not a party to this proceeding who has physical custody of said children. 9. Petitioner has consistently made attempts to remain in contact with said children. 10. Petitioner has repeatedly requested that respondents allow said children to visit him at SCI Camp Hill. 11. Petitioner has made arrangements with Mary Anne Martin, the children's grandmother, to transport said minor child to and from SCI Camp Hill at no cost to respondents. 12. Petitioner believes and avers that Mary Anne Martin is a responsible adult and will use all due care, including the use of seatbelts in transporting said minor child. 13. Petitioner believes and avers that Mary Anne Martin will accompany and supervise said minor child at all times before and after the visit with petitioner, while at the State Correctional Institute at Camp Hill, Pa. 14. Petitioner has placed the names of Mary Anne Martin and Respectfully submitted, . . ~,~.. . - said minor child on the list of people authorized to visit him at SCI Camp Hill. ~~ The last visit petitioner had with said minor child was 10 J"'" '11../ 16. Petitioner believes and avers that the welfare and best interests of said minor child will be served by regular visits with petitioner, despite the latter's incarceration. 17. Petitioner believes and avers that the State Correctional Institute at Camp Hill, Pa. recognizes the importance of continuing family relationships during incarceration. This recognition is demonstrated by provision of facilities for family visits such as picnic tables, playground equipment and a family visiting room. WHEREFORE, Petitioner prays your Honorable Court to establish a reasonable visitation schedule under which petitioner and said minor child will have visitation. ~.verify that the statements made in this complaint are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date 3' 50 . '1~ / #;/10 ~~j~~ 6; - >- ~ "'~ ::lC ..>- ~'": ~~,~-f 0 '2'% Co:;; ;' :I- ::: o~>:i 1ft . en n;:'2:J> '~ ":):;:= . ' ,.'~ ~ ...: ~'"- .1.: ;..: 0 l'Jt~Jz - 1.' ~:lt.J ... 1,-::1::-" F ... ......:::>> -=z: 0<> . . . . .- ". '. , JEFFREY A. MARTIN Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ~ NO. qlf--I i'1S CIVIL-1+_ vs. DAVID H. HUSTON and BARBARA L. HUSTON Respondent . . . . VISITATION PETITION TO PROCEED IN FORMA PAUPERIS JEFFREY A. MARTIN, petitioner in the above-titled action, on this 30 , 19~~, respectfully t1.," c.~ day of requests this Honorable Court to grant JEFFREY A. MARTIN leave pursuant to Pa. R.C.P. 1920.62 to proceed in forma pauperis to the extent that JEFFREY A. MARTIN be relieved of all costs attendant to this action. ~~~~ ~ oro se .' .- ... -,. . JEFFREY A. MARTIN Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . . vs. CIVIL ACTION - LAW NO. CIVIL 19___ DAVID H. HUSTON and BARBARA, L. HUSTON Respondents VISITATION AFFIDAVIT SUPPORTING PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS TO THE HONORABLE JUDGES OF SAID COURT: The petitioner, JEFFREY A. MARTIN, residing at the State Correctional Institution at CAMP HILL, Cumberland County, Pennsylvania, upon his oath deposes and says: 1. I am the named plaintiff in the above-titled civil cause of action and the defendants are DAVID H. HUSTON and BARBARA L. HUSTON. 2. This affidavit is made to inform the court as to my status of indigency and to induce the court to grant me leave to proceed in this cause as an indigent. 3. In making this affidavit, I am aware that perjury is a felony and that punishment is a fine of not more than $3,000 or imprisonment for not more than seven years or both. 4. I am unable to obtain funds from anyone, including my family, by way of compensation for counsel, filing fees, or any other costs of this action and represent that the following statements are true to the best of my information and belief. 5. I have approximately $0.00 in my prison account. 6. I do not own real estate, personal property, or any other assets. I am not owed any amounts of money by any other person. , .' (J ~ Il. vf/I.AJo-f...:.. t7 ) Pro se ..- ..- -: ' '.. . 7. I am presently unemployed because I am incarcerated. lB). My social security number is :2n~ -"'/A-bJfl';- . 9. I have no means of income outside my minimum prison earnings. 10. I am not the owner of an automobile. WHEREFORE, petitioner prays that this Honorable Court grant petitioner leave to proceed in forma pauperis in the above-titled action with fee or cost to the petitioner. I verify that the statements made in this petition are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date !J - l" - q~ ~ en - -=- >->- ~.... t- ~.t W(."II.. _. (,):z c.'';J''. ~OUoc1 l.,:?:e~ -, -~- I '." "'f' ..:),,,:_...J~ .:;~~Z , ~~g:J~ ...~% ....=> 0'" ::c <I: o :z' 0") "" .... -= . - .. , "