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HomeMy WebLinkAbout02-3583RICHARD MACINTYRE PLAINTIFF JESSICA BUSHNELL WOOD DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-3583 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, August 01, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , thc conciliator, at 39 West Main Street, Meehanicsburg, PA 17055 on Thursday, August 22, 2002 at 8:30 AM for a Pm-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot bc accomplished, to define and narrow thc issues to bc heard by thc court, and to enter into a temporary order. All children age five or older may also bc present at thc 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: /s/ Dawn S. Sunday. Esq. '~-~ Custody Conciliator 0 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 heating 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 Richard Maclntyre, Plaintiff Vo Jessica Bushnell Wood, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : ! NO.~-3~-?~ CIVIL TERM : CIVIL ACTION - CUSTODY : COMPLAINT FOR CUSTODY And PETITION FOR SCHEDULING OF PLOWMAN HEARING 1. Plaintiff is Richard Maclntyre, an adult individual whose residence is at 502 North College Street, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Jessica Bushnell Wood, an adult individual whose last known residence is at 502 North College Street, Carlisle, Cumberland County, Pennsylvania. 3. The relationship of the Plaintiff to the children is that of natural father. 4. The relationship of the Defendant to the children is that of natural mother. 5. Father seeks legal custody and primary physical custody of his children Richard Kenneth Maclntyre and Riley David Maclntyre, born June 17, 2002. 6. Said children were residing at 502 North College Street, Carlisle, Cumberland County, Pennsylvania with both Father and Mother until on or about June 25, 2002. 7. On or about June 25, 2002, Mother removed the children from the home against the will of the Father. 8. Mother refuses to tell the Father where the children are currently located. 9. Mother provided a phone number to the Father, where she could allegedly be reached. When Father tried to reach Mother at this phone number, he learned it was disconnected. 10. Father has reason to believe that Mother may have relocated or is attempting to relocate outside the Commonwealth of Pennsylvania, and most likely in the Commonwealth of Virginia. 11. The children are presently in the custody of Mother. 12. Since the children's births, they have continuously resided at 502 North College Street, Carlisle, Pennsylvania. 13. The Father has not Participated as a party or in any other capacity, in other litigation concerning the custody of the children in this or any other Court. 14. Father has no information of a custody proceeding concerning the childrer pending in a Court of this Commonwealth. 15. The best interest and permanent welfare of the children will be best served by granting the Father primary physical custody the children. 16. 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. No other persons are known to have or claim to have any right to custody or visitation of the child other than the parties to this action. 17. Father seeks an expedited proceeding under Plowman v. Plowman, 409 Pa. Super 143, 597 A.2d 71 (1991). WHEREFORE, Plaintiff requests your Honorable Court to grant him primary physical custody of his children. Respectfully Submitted TURO LAW OFFICES grane~, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Custody Complaint 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. Date Rici~ard Maclntyre Richard Maclntyre, Plaintiff Jessica Bushnell Wood, Defendant · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 00-02-3583 CIVIL TERM · CIVIL ACTION - CUSTODY AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT I served a true and correct copy of a Custody Complaint filed in the above captioned case upon Jessica Bushnell Wood, by personal hand of Carol L. Cingranelli, on July 28, 2002 at 11:45 AM; place of service: Jessica Bushnell Wood 502 North College Street Carlisle, PA 17013 I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF, I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Dat~ / ' TURO LAW OFFICES Carol L. Cingranelli, EsqUire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff ,m 32002 RICHARD MAC INTYRE, Plaintiff VS. JESSICA BUSHNELL WOOD, Defendant :IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3583 CIVIL ACTION LAW : IN CUSTODY ORDER OF COURT AND NOW, this 20th day of August, 2002, the Conciliator, being advised by Plaintiff that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction. The Custody Conciliation Conference scheduled for August 22, 2002 is canceled. FOR THE COURT, Da~// Custody Conciliator