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HomeMy WebLinkAbout94-04023 " , , " , 'I; .,'1 ,! " I, II \ , \ \ J I / , , i,", :1, , , i " " / / / / , , , , " I' " I " r , , ' , , ~ ~ ...~ ' ;';~ I.'~ ~ ' ~ '1 .'.. ' M :oct , " ~ '" ~~ o.~ , '.'." "- . , 0 '" , ~.:! ~, ", " I., ;, , i.' ! 21 . ~ ~ ~ ' '~ \) , , , I. ,'t, "~ ' I " , 't'., , ,., . " I " , , I , , , ',~ ---.:::::. . , " 5 ~i ~, 0 I~!~I ' ... i . I '100 .1 ~ I , 0 , .~ ~iil~ ~i I ~ . r~ ~!~ ~~!Ib ~I~ <:Il > = ~5l:l ~ . ~ < u ~ ~ ~il ~ ~ . ~ i <:Il , ,I. I, : ' , " " " , ' , . , , " , " " , " j-' -, >" . , , . . '" , , 'I ':', .. -. f'; ., . . . . . ._' . ., JUt 21 199~ I , , . ; 'I ....- .' .. . , '" Reginald Holt, ~ IN THE COURT OF COMMON Plaintiff t PLEAS CUMBERLAND COUNTY, t PENNSYLVANIA t V. t CIVIL AC'rION - CUSTODY t 6~~ Sally C. Smith t Defendant t NO. 11/- .t!{I"J3 OF 1994 ORDER OF COURT You, Sally C. Smith, defendant, have been sued in court to obtain custody of the child: Christian Maria Holt. You are ordered to appear i~ person at on at .I ,.M., for a (conference) (hearing). You are further ordered to bring with you the child: Christian Maria Holt. If you fail to appear as provided by this order or to bring the child, an order for custody, partial custody or visitation may be entered against you or the court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR LANYER AT ONCE. IF YOU DO NOT HAVE A LANYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OrrICE SET rORTH BELON TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator's Office 1 Courthouse Square Cumberland County Courthouse Carlisle, PA 17013-3387 240-62002-9356 BY THE COURT: J. .' Reginald Holt, I IN THE COURT OF COMMON Plaintiff I PLEAS CUMBERLAND COUNTY, I PENNSYLVANIA I V. I CIVIL ACTION - CUSTODY I Sally C. Smith I Defendant NO. OF 1994 COMPLAINT FOR CUSTODY 1. The Plaintiff, Reginald Holt, resides at 17 Falcon Court, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant, Sally C. Smith, resides at 549 East 118th Street, Cleveland, Cuyahoga County, Cleveland, Ohio 44108. 3. Plaintiff seeks custody of the following child: ~ Present Residepce ~ 17 Falcon Court, Mechanicsburg, PA The Child was born out of wedlock. However, the natural father was married to and has been divorced from the natural mother, Defendant, and also adopted said child. Christian Maria Holt 13 yra. The child is presently in the physical custody of Reginald Holt, who resides at 17 Falcon Court, Mechanicsburg, PA. During the past five years, the child has resided with the Defendant at the following addresses: Sally C. Smith 4401 Marisol Road, 7/1/93-7/1/94 Cleveland, OH Sally C. Smith 549 East 118th Street 7/1/90-6/30/93 Cleveland, OH 44108 Sally C. Smith Pittsburg, PA - 6/30/60 The mother, Sally C. Smith, of the child currently resides at 549 East 18th Street, Cleveland, OH 44108. She is divorced. The father of the child is Reginald Holt, currently residing at 17 Falcon Court, Mechanicsburg, PA 17055. He is married. ,'. Reginald Holt, I IN THE COURT OF COMMON Plaintiff I PLEAS CUMBERLAND COUNTY, I PENNSYTNANIA I V. I CIVIL ACTION - CUSTODY I Sally C. Smith I Defendant I NO. OF 1994 V E R I F I CAT ION I verify that the statements made and correct, I understand that false subject to the penalties of 18 Pa. C. unsworn falsification to authorities.' in this Complaint are true statements herein are made S. ~/904 relating to ) / ",/ / ,t:.' " Re nald Holt, Plaintiff " .' . . . Reginald Holt, t IN THE COURT OF COMMON Plaintiff I PLEAS CUMBERLAND COUNTY, I PENNSYLVANIA I V, I CIVIL ACTION - CUSTODY t Sally C. Smith I Defendant I NO. OF 1994 CIRTIrICATI or SERVICE I I Richard Stevens, Paralegal, do hereby certify that on this ---1 S t::L day of -tlu.1t-, 19~ placed in the United States Mail true and correct copies of ~laint for Custody to the following: Sally C. Smith 5490 East 18th Street Cleveland, OH 44108 ~~.,/~~ Ric ard Stevens Paralegal for Tony W. Penn, Esquire " I " /' < ;' I , '" I " ' ,I, , I .' ;11 ,', , , I " , " , , , , " " !, I ~ '. ~r ~ ~ ~ I ~ ~ ! I' I, ~ .... ~ ~I ~ . ~ ~ ~ 11 I ~ .~ ~ ~ ~ ~ Hi i ~~ '" ~ ~. c i 6 : ~ i . i 5 u . ~ Ii ~ /' ,. i>:i' F,:J , , ",,'i' . 'I, . , , "," .' "- '.' ' . '. AUG 10 199v"'- rAUl 28 1991rlA ~' " Reginald Holt IN THE COURT or COMMON Plaintiff PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - CUSTODY Sally C, smith Defendant NO. JY .w'.:<~ (-;.,./;;; ... or 1994 ORDER or COURT AND NOW, this day of July, 1994 after careful review of plaintiff's petition for Special Relief, it is or.dered that: Temporary physical and legal custody of the minor child Christian Maria Holt, shall be with her father Reginald Holt, By the Court: Judge li;iPl~~\L ,~ .,~ "'c..o ~'"' .~ 'u,o 1.::J/ ~ e~l.v.,;:~fJ 9/~' Reginald Holt, I IN THE COURT OF COMMON Plaintiff I PLEAS CUMBERLAND COUNTY, I PENNSYLVANIA I V. I CIVIL ACTION - CUSTODY I Sally C. Smith I Defendant I NO, '1'/ 'I" ' " / ;7,' OF 1994 .' .!.,(.'/(,' '1.,1'- IImergen.::y p.tition for Cu.tody 1. Petitioner is Reginald Holt, father of the child Christian Maria Holt and plaintiff in the above-captioned matter, petitioner currently resides at 17 Falcon Court, Mechanicsburg, pennsylvania. 2. Respondent is Sally C. Smith, mother of the child Christian Maria Holt and defendant in the above-captioned matter, respondent currently resides at 549 East 118th street, Cleveland, ohio. 3. The child Christian Maria Holt is 13 years of age and presently resides with Reginald Holt, at 17 Falcon Court, Mechanicsburg, Pennsylvania. 4. A petition for custody was filed with your Court on 21 July 1994, with a prehearing custody conference being scheduled for September 20, 1.994 at 1:00 P. M.. 5. Reginald Holt, the plaintiff herein request that this most honorable Court grant him special relief as per PA R. civ. P.1915.13 in the form of emergency temporary custody of his child, Christian Maria Holt, and in support thereof avers the following to wit: (A) Defendant Sally C. Smith lives in another state and has stated to their child Christian Maria Holt that she will do whatever is necessary to ensure that she never lives with her father, the plaintiff here in Pennsylvania. (B) Defendant has been seen surveying and stalking the plaintiff's home. (C) Defendant has threatened to take their child Christian Maria Holt back to ohio and not let the plaintiff see her again. (D) The uncertainty of the aforesaid situation has left both the plaintiff and the subject child nervous and upset. (E) The School year will start before even the pretrial preliminary hearing has been scheduled. . Reginald Hol.t, I IN THE COURT OF COMMON plaintiff I PLEAS CUMBERLAND COUNTY, I PENNSYLVANIA I V. I CIVIL ACTION - CUSTODY I sally C. Smith I Defendant I NO. OF 1994 V E R I F I CAT ION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. & 4904 relating to unsworn falsification to authorities. // ') Reginald Holt, ~ IN THE COURT OF COMMON Plaintiff : PLEAS CUMBERLAND COUNTY, : PENNSYLVANIA : V. ~ CIVIL ACTION - CUSTODY ~ Sally C. Smith Defendant NO. :,J/. '';'''..")'<. ~',' " J'''d1 OF 1994 Imergency Petition for Cu.tody 1. Petitioner is Reginald Holt, father of the child Christian Maria Holt and plaintiff in the above-captioned matter, petitioner currently resides at 17 Falcon Court, Mechanicsburg, Pennsylvania. 2. Respondent is Sally C. Smith, mother of the child C,ristian Maria Holt and defendant in the above-captioned matter, respondent currently resides at 549 East 118th street, Cleveland, Ohio. 3. The child Christian Maria Holt is 13 years of age and presently resides with Reginald Holt, at 17 Falcon Court, Mechanic~burg, Pennsylvania. 4. A petition for custody was filed with your Court on 21 July 1994, with a prehearing custody conference being scheduled for September 20, 1994 at 1:00 P. M.. 5. Reginald Holt, the plaintiff herein request that this most honorable Court grant him special relief as per PA R. Civ. P.1915.13 in the form of emergency temporary custody of his child, Christian Maria Holt, and in support thereof avers the following to wit: (A) Defendant Sally C. Smith lives in another state and has stated to their child Christian Maria Holt that she will do whatever is necessary to ensuro that she never lives with her father, the plaintiff here in pennsylvania. (B) Defendant has been seen surveying and stalking the plaintiff's home. (C) Defendant has threatened to take their child Christian Maria Holt back to Ohio and not let the plaintiff see her again. (D) The uncertainty of the aforesaid situation has left both the plaintiff and the subject child nervous and upset. (E) The School year will start before even the p~etrial preliminary hearing has been scheduled. . . . Reqinald Holt, 'I IN THE COURT OF COMMON . plaintiff 1 PLEAS CUMBERLAND COUNTY, I PENNSYLV AN IA I V. I CIVIL ACTION - CUSTODY I Sally C. Smith I Defendant 1 NO. OF 1994 V E R I F I CAT ION I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. & 4904 relatinq to unsworn falsification to authorities. (/ " ' Reginald Hol t, plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - CUSTODY Sally C. Smith Defendant NO. 1'I't't..Jj/.. / r..-", OF 1994 Emergency Petition for Cu.tody 1. Petitioner is Reginald Holt, father of the child Christian Maria Holt and plaintiff in the above-captioned matter, petitioner currently resides at 17 Falcon Court, Mechanicsburg, pennsy I vania. 2. Respondent is Sally C. Smith, mother of the child Christian Maria Holt and defendant in the above-captioned matter, respondent currently resides at 549 East 118th street, Cleveland, Ohio. 3. The child Christian Maria Holt is 13 years of age and presently resides with Reginald Holt, at 17 Falcon Court, Mechanicsburg, Pennsylvania, 4. A petition for custody was filed with your Court on 21 July 1994, with a prehearing custody conference being scheduled for September 20, 1994 at 1:00 P. M.. 5. Reginald Holt, the plaintiff herein request that this most honorable Court grant him special relief as per PA R. civ. P.1915.13 in the form of emergency temporary custody of his child, Christian Maria Holt, and in support thereof avers the following to wit: (A) Defendant Sally C. Smith lives in another state and has stated to their child Christian Maria Holt that she will do whatever is necessary to ensure that she never lives with her father, the plaintiff here in pennsylvania. (8) Defendant has been seen surveying and stalking the plaintiff's home. (C) Defendant has threatened to take their child Christian Maria Holt back to Ohio and not let the plaintiff see her again. (D) The uncertainty of the aforesaid situation has left both the plaintiff and the subject child nervous and upset. (E) The School year will start before even the pretrial preliminary hearing has been scheduled. (F) The best interest and welfare of the subject child would be served by adjudicating this matter as soon as possible. Wherefore, petitioner respectfully request this Court to grant temporary custody of Christian Maria Holt to her father Reginald Holt until permanent custody can be determined by this court ill later proceedings. A , , '. Reginald Holt, I IN THE COURT OF COMMON plaintiff I PLEAS CUMBERLAND COUNTY, I PENNSYLVANIA I V. I CIVIL AC'rION - CUSTODY I Sally C. Smith I Defendant I NO. OF 1994 V E R I F I CAT ION I verify that the statements made in this Complaint are true and cQrrect. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. & 4904 relating to unsworn falsification to authorities. t, Reginald Holt, IN THE COURT OF COMMON Plaintiff PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - CUSTODY Sally c. Smith Defendant NO. Jly', "ft' 1.3' " . '.r- .1 OF 1994 Emergency Petition for Custody 1. petit.ioner is Reginald Holt, father of the child Christian Maria Holt and plaintiff in the above-captioned matter, petitioner currently resides at 17 Falcon Court, Mechanicsburg, Pennsylvania. 2. Respondent is Sally C. Smith, mother of the child Christian Maria Holt and defendant in the above-captioned matter, respondent currently resides at 549 East 118th street, Cleveland, Ohio. 3. The child Christian Maria Holt is 13 years of age and presently resides with Reginald Holt, at 17 Falcon Court, Mechanicsburg, Pennsylvania. 4. A petition for custody was filed with your Court on 21 July 1994, with a prehearing custody conference being scheduled for September 20, 1994 at 1:00 P. M.. 5. Reginald Holt, the plaintiff herein request that this most honorable Court grant him special relief as per PA R. Civ. P.1915.13 in the form of emergency temporary custody of his child, Christian Maria Holt, and in support thereof avers the following to wit: (A) Defendant Sally C. Smith lives in another state and has stated to their child Christian Maria Holt that she will do whatever is necessary to ensure that she never lives with her father, the plaintiff here in Pennsylvania. (B) Defendant has been seen surveying and stalking the plaintiff's home. (C) Defendant has threatened to take their child Christian Maria Holt back to Ohio and not let the plaintiff see her again. (D) The uncertainty of the aforesaid situation has left both the plaintiff and the subject child nervous and upset. (E) The School year will start before even the pretrial preliminary hearing has been scheduled. V E R I F I CAT ION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C. S. & 4904 relating to unsworn falsification to authorities. ", ',ll1v" ~:i'<;j :" 1, CilthoL', [H3nJl)rln: Tho l'IJL,It:l"lll:lllp ()f PJllintlU to tho child If; th'~t of 'I'hl) Pl'li,ntiff ClIrtdltly 1":;[,,1,,,; .Ilt.h tl)(> folloVlinq /'liJj,'ltJ. [lld,ill: i<-'lll,lilll Nol iusiI Iloll. JlIst ill IJ, Lit'.~n'nCfl Reqin,11d I';. lIoll n \~.i hi ~i t.opnon Hon 5. 'rho IIIOt.hlll', PUt,:I/,)l\l.i: ftdittlonr;hlp of [Jefr!llllant t;,) tho 'J'hu [J"I,:nllilnt. I!UII'l!nt,1 y t"p lei..):; eh lid I.U that o( w j, th the fnllcl"'" In<j Nl1ll<?, fl, PlalllCi.JI. hH:i H!)l' r,irt: il..~ipdt",j dl; rl /,;dt:ty 1)1- \!1i.t.no~::,;, Ul~ .In i.lrloLli(}r cap:\ci.t'!1 In lltllcl III j'Jilt.i'JII 1'llllt:llJ:niJI',j l~h,~ cu::.;1:I)dy (Jf tho r:h i lo:! 'i.n I: hi:; 01 lillY, <111,,') ,:OUII', i'L,lnti,ff h,'}:: II" i n(,Il'wlt ion 01 II clIr;t'ldy PI'1CI'odinq (!oncr:tnill'l HilI eld,ld fl"l1din'l i.n 'I CIIIII't ,iI thl:,; C,l/II!11llnw,..,:llth. PL.lilll:iff dm>:; n,Ji' kn()\,' ,,[ .:, pOr.lillll 1'10' it par.ty to Llll! pr:oGoedingl' l'lh,' IlIlI; phy:d";11 1:<I:,tudy of 1.11,. ,:hild or claims to, hilve Clll1tody 0' vl"lti\ti~)fl 11<IIlt.,; wi l'h r:(,sfhll;t tu t.h(! chi 1<1, 7. '1'hl' bcst i.nh'tlwt ilnd 1"'~'ll1illhlnt vl"ltar" ot ttw child ./J,ll be served by gr'ilntinq th" l'oJ i", f t'C'llI"IIt.ud, 8. Each pan,nt .:hon... [J'I1'''ld:;ll rl'lht':,; to trll' chi lrl havl! not bean tcrm.lniltod and tll<! f'~II;on .,ltO hill:; phy:,;.i,cal cnBtody "f the child have beHn nHJllud a:3 rh\rti(~:.; to th.is act Lon, Al.l ot.her' [Jot'sons, named below, who ill" known to have or clilim A right to custody or visitilti,oo uf I:tl" chlld hi\vl, b,,<'n 'liven notice of tho p"lldency of t.1.i:; (l(:tion iltJd thu riqhl: tu into,nv,)ne: None, Wherefore, of the child, I'litint.! El n,quellt t.ho Cour. t tq .'Jl.dl1t him cu;:;t,ody : ) . ' ..' \' (" 'l';';ll'y'-\tl;)(;ill;;"';.;,:iI\\/{V '" -,' AU"it'no.'y tor Pia.! nt,~t I: :,~(1j"1, c..;rt~un Stt.cH~I'. , llnITi:,;I'IlI"J, [Iii 1'/tlO ('/17) 2,i,-'/I311 I, LJ. ;;I:! :':!iJI; ~ ,n-.tl)ll'l;.!,....~'\If;l~fr""~.r,,(:(,,~':l'!~'V'\''':J',..,t ,...."., , ' .", _It ,;, ~, ,jrn~\ , : ; '.. .~t11:lj~d "," "'~'. ' .....r~'f-', .. 'I\q-,- ~.".'~~I~', i '11".,.. ~_\ ; . ";".'!, ,.; .:,~~,,-,.,' ,'.,i.?i. C",' ;1 "."-,,,.-..", '-t' -..:-,.....:.~l'."IT~ "',' ."_0 ., , ,. '.. . ' " . -'r If,,,,It'~,, I ' .., '. ~:--. . 1'-1 SEP 2819~ J..~ REGINALD HOLT, IN THE COURT OF COMMON plaintiff PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs CUSTODY/VISITATION SALLY c. SMITH, Defendant NO. 94-4023 CIVIL TERM ORDER or COURT AND NOW, this 27th day of september 1994, the parties havinq not appeared for the scheduled conciliation conference, the undersigned conciliator assumes the matter has been resolved and hereby relinquishes jurisdiction of the case. If either of the parties wishes further proceedings in this action, they should petition the Court anew. FOR THE COURT, SaL~~ Custody Conciliator $er 29 e iJZ ~H 'g~ r,'., I, f.lj'i tll;t , 1t!J~'~'j' ~") 'I' :1' ';+' II Y I .. -' ',' '.~ ~ " ,\ ", "