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Home My WebLink About95-01235 RUTH HENSLEY Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN CUSTODY v. LYNN F. CAIN Defendant : NO, 95-lJ-~IVIL TERM COMPLAINT FOR CUSTODY AND NOW, the defendant, Ruth Hensley, by her attorneys, the Family Law Clinic, sets forth the following cause of action: 1. The plaintiff is Ruth Hensley, residing at 48 E. Main St, Second Floor, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The defendant is Lynn F. Cain, whose mailing address is clo Ellen Wimpee, 575 Wildwood Park, Battletown, Kentucky, 40104. 3. Plaintiff seeks custody of the following child. ~ Present Residence AB Aaron Paul Cain 48 E. Main St., Mechanicsburg, PA 17055 DOB 2/19/92 The child was born out of wedlock, The child is presently in the custody of Ruth Hensley, who resides at 48 E. Main Street, 2nd Floor, Mechanicsburg, Cumberland County, Pennsylvania 17055. During the past five years, the child has resided with the following persons and at the following addresses: Persons Addresses IhUa Ruth M, Hensley, Lynn Cain Mackport, IN 2/19/92 - 5/92 Ruth M. Hensley. Lynn Cain Old State Rd, Brandenburg, KY 5/92 - 10/92 Ruth M. Hensley, her parents Etters, PA 10/92 - 1/93 Ruth M, Hensley 319 3rd St., W. Fairview, PA 1/93 - 6/93 Ruth M. Hensley 1910 Old Trail Rd" Etters, PA 6/93 - 11193 Ruth M. Hensley, Dennis Wilson, 48 E. Main St, 2nd Floor Dennis Wilson, Jr, Mechanicsburg, PA 11193 - The mothcr of the child is Ruth M. Hensley, currently residing at 48 E. Main St., 2nd Floor, Mechanicsburg, Cumberland County, Pennsylvania 17055. She is single. The father of thc child is Lynn F, Cain, whose mailing address is c/o Ellen Wimpee, 575 Wildwood Park, Battletown, Kentucky, 40104. He is single. 4. The relationship of the defendant to the child is that of father. It is not known whether the defendant resides with other persons. 5, The relationship of plaintiff to the child is that of mother. The plaintiff currently lives with Aaron Paul Cain, Dennis Wilson, and Dennis Wilson, Jr.. 6. Plaintiff has not participated as a party or witness, or in another capacity. in other litigation concerning the custody of the child in this or another court. Plaintiff has no information 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. 7. The best intcrest and permanent welfare of the child will be served by granting the COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: SS. I verify that the statements made in this Custody Complaint art ,"Ill 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. Section 4904, relating to unsworn falsification authorities. Date 1l~!l8- q" ~W-LJI' I-k It ~bh RUTH HENSLEY 0 ,., ':'l.." ..':)i~ ::,~ :::;,;''';'. ~f::l:';<. ...<.t~:':1 (1 "':':.1:;. -~ ~........- ... T'-O~Ci ~'?Utt'l ....1.:_-. ;r.,... ~"" :.1;' -<.... ::w:: ~ "" IX' W &: ... ~ - ~ RUTH HENSLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. LYNN F. CAIN, Defendant. : CIVIL ACTION - LAW : IN CUSTODY IJ35 : NO. 95- CIVIL TERM PETITION TO PROCEED IN FORMA PAUPERIS' Ruth Hensley, plaintiff in the above titled action, respectfully requests this Honorable Court to grant her leave pursuant to Pa.R.C.P. 240 to proceed in forma pauperis to the extent that she be relieved of all costs attendant to this action. Date 3-o-1S- ~~~ f-1~~~ THOMAS M. PLACE ROBERT E. RAINS LINDA E. FISHER Supervising Attorney THOMAS L. PEELER Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW IN : CUSTODY \~35 : NO. 95- CIVIL TERM - . . . RUTH HENSLEY, Plaintiff v. LYNN F. CAIN, Defendant. AFFIDA VIT SUPPORTING PETITION I<'OR LEA VE TO PROCEED INFORMA PAUPERIS 1. I am the Plaintiff in the above matter and because of my financial condition am unable to pay the fees and cost~ of pr()secuting or defending tbe action or proceeding. 2, I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: Ruth Hensley Address: 48 E. Main Street, Second Floor, Mechanicsburg, PA 17055 Social Security No,: 201-54-1612 (b) Employment Not presently employed Date of last employmcnt: March, 1994 Salary or wages per month: $6.60/hour Type of work: office temporary (c) Other income within lhe pa~t twelve months Business 01' Jlrofe~sio!1; ilia Other sclf.cmploymcnt: n/1 IntcreM: nI a Dividcnds: nla Pension and annuities: n/a Social security bel1cfjt~: nla Support payments: $292,00 (she has only received $375.00 total in the last year = $30.oo/mo.) . Disability payments: nla Unemploymclll compensation and supplemental benefits: nla Workman's compensation: 11I.1 Public Assistance: $316.00 Other: food stamps $206.00 TOTAL INCOME: $552.00 per month .- (d) Other contributions to household support Name: nla (e) Property owned Cash: nla Checking account: nla Savings account: nla Certificates of deposit: nla Real estate (including home): nla Motor vehicle: nla Other: nla (t) Debts and obligations Mortgage: n/a Rent: nla Loans: nla Other: phone/electric bills $90.oo/mo., child's clothing/activities $180.oo/mo., traffic fines $20.oo/mo" clothing/misc. $30.oo/mo., food $206.00 = TOTAL EXPENSES = $526,00, (g) Persons dependent upon you for support Name: Children, if any: Name: DOB: Aaron Paul Cain 2/19/92 Dennis Wilson, Jr, 1/16/95 Other persons:nla 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit 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. .' Date~ . a&- CIS ~~PL RUTH HENSLEY -rr Plaintiff RUTH HENSLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY LYNN F. CAIN. Defendant : NO. 95- CIVIL TERM b.~~RNEY'S AFFIDAVIT SUPPORTING PETITION FLEA VE TO PROCEED IN FORMA PAUPERIS I, Michele L. Belluzzi, of the Family Law Clinic, attorney for the party petitioning to proceed in forma pauperis, certify that I believe petitioner is unable to pay the costs of instituting this action and that I am providing free legal service to petitioner. Plaintiff/Petitioner's Affidavit showing inability to pay the costs of litigation is attached Date ,?--IJ -r::) hereto. L~d-e ~ ~ THOMAS M. PLACE ROBERT E. RAINS LINDA E. FISHER Supervising Attorney THOMAS L. PEELER Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 c "~.,,, ~."i'~.,., ~ ~~;7ir~'.: (;., ~~, ':', 01 ~~::~~ - br..."....,.. O <<.:-.'...........' . 3'- .,-0_ rJ, z~~.%",a V .. .,...~,?'I s-:,:~ -.... -<..., = ... ,., CI:) w ..<: - -." ::Ie tft , , f' I. RtrrH HENSLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA I v. : CIVIL ACTION - LAW : IN CUSTODY LYNN CAIN, Defendant : NO. 95-1235 CIVIL TERM CERTIFICATE OF SERVICE I, Michele L. Belluzzi, Family Law Clinic, hereby certify that I have served a true and correct copy of Court Order and Conciliation Conference Summary Report on Lynn Cain, first class mail, postage prepaid, this 1st day of May, 1995, ichele L. Belluzzi Student Attorney residing at clo Ellen Wimpee, 575 Wildwood Park, Battlelown, KY, 40104, by Uniled Slates :c .. -< .... ~. co UM ~- ~ ._.~ .' ..~ ~- - ~