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VI C C Cj .....'. -- i" 'R ,v. ~ ~ r- -~ r' 1- ..!. v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO,Q5.733cIVIL TERM CIVIL ACTION - LAW Scarf M. THRUSH, Plaintiff LEHOMA J. WORTHINGTON, Defendant IN CUSTODY NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you, 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. Court Administrator - Fourth Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 Telephone (717) 240-6200 James J. Kayer, Esquire Attorney for Plaintiff Liberty Loft 4 E. Liberty Avenue Carlisle, PA 17013 (717) 243-7922 '. SCOTT M, THRUSH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO, ,/'), 73 j CIVIL TERM CIVIL ACTION - LAW LEHOMA J. WORTHINGTON, Defendant IN CUSTODY EMERGENCY PETITION FOR CUSTODY COMES NOW, Plaintiff, Scott M. Thrush, by and through his attorney, James J. Kayer, Esquire and avers as follows: 1. Plaintiff is Scott M. Thrush, an adult individual, residing at 972 W. Old York Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Lehorna J. Worthington, an adult individual, whose current address is 22 N, Hanover Street, Apt. 4, Carlisle, Cumberland County, Pennsylvania 17013, 3. Plaintiff seeks custody of the following children: Name Present Residence Age Alisha R, Thrush, born June 17, 1993. The child was not born in wedlock. The child is presently in the custody of mother, Lehoma J. Worthington, who resides at 22 N. Hanover Street, Apt. 4, Carlisle, Pennsylvania 17013. During the past five years, the child has resided with the following person(s) at the below addressees): From February 1, 1995 to the present: Mother, Lehoma J, Worthington at 22 N, Hanover Street, Apt. 4, Carlisle, PA 17013. From AugUl>1, 1994 until January 31, 1995 with Mother, l..ehollld J, Wonhington, Father, Scott M, TIlrush, and paternal gnmdparents, Paul and Eleanor TIlrush at 972 W. Old York Road, Carlisle, Pa, 17013, From June, 1994 until August, 1994 with Mother, l..ehoma J. Wonhington and Father, Scott M, TIlrush at Lot 14, Betty Nelson Coun, Carlisle, PA 17013, From Binh until June, ]994 with Mother, l..ehoma J. Wonhington, Father Scott M, TIlrush and paterna] 1; ! ! grnndparents, Paul and Eleanor TIlrush, at 972 W. Old York Road, Carlis]e, PA 17013, 4. The mother of the child is l..ehoma J, Wonhington, currently residing at 22 N. Hanover Slreet, Api, 4, Carlisle, Pennsylvania 17013, She is single. 5. The father of the child is Scott M. Thrush, currently residing at 972 W. Old York Road, Carlisle, Pennsylvania 17013. He is single. 6. The relationship of Plaintiff to the child is that of father. TIle Plaintiff currently resides with the following person(s): Name Relationship Paul Thrush Father E]eanor Thrush Mother 7. The relationship of the defendant to the child is that of mother. The Defendant currently resides with child and the following person(s): Name Re]ationship Miles Wonhington Father 8. Plaintiff has not panicipated as a pany or witness, or in wlother capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no infonnation of a custody proceeding concerning the child pending in a court of this Commonwealth, 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. 9. TIle best interests and pennanent welfare of the child will be served by gmnting tempomry primary physical custody of the child to the Plaintiff as the Defendant is a night risk. Defendant has wamed Plaintiff on seveml occasions that should he undertake any action to pursue his custody rights, that she would take the child with her to live in Florida with her relatives that currently reside there, Additionally, on February 1,1995, Defendant removed the child from the parties' residence under cover of darkness in order to avoid a confrontation with the Plaintiff. Gnmting Plaintiff tempomry custody of the child until a Hearing on the merits in this matter will be in the best interest and pennanent welfare of the child as it will ensure that the child will not be removed from this jurisdiction pending further action by this Court, 10. Each parent whose parental rights to the child has not been tenninated and the person who has physical custody of the child have been named as parties to this action, All other persons, names 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: Name Address Basis of Claim None WHEREFORE, Plaintiff requests the court to gnmt custody of the child to Plaintiff. VERIFICATION OF PLEADINGS The foregoing Petition is based upon infonnation which has been gathered by my counsel and myself in the preparation of this action. TIle language of the Petition may in part be the language of my counsel and not my own, I have read the ~1atements made in this Petition and to the extent that it is based upon infonnation which I have given to my counsel, it is true and correct to the best of my knowledge, infonnation and belief. To the extent that the contents of the stalements are that of counsel, I have relied upon counsel in making this Verification. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities, ..f en-a '0' ;;fv'(/<-1~' Date: ..., 11/) / r:<r MAR' 1 1995 J..J v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95.733 CIVIL TERM CIVIL ACfION . LAW SCOIf M. THRUSH, Plaintiff AND NOW, this 2"" day of tv'. "'<..A , 1995 it is decreed that the I I , j, " ! LEHOMA J. WORTHINGTON, Defendant IN CUSTODY ORDER OF COURT Stipulation and Agreement for Custody and Panial Custody that has been executed by the parties named above shall be made an Order of this Coun. TIle Coun of Common Pleas of Cumberland County shall maintain jurisdiction in this matter. i I I f f I ! i