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Home My WebLink About95-01501 ~ - o \() - I \.(') 0- . ,'f''''' QUETRlNA L. SIMS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY : 150 : NO. 95- - civIL TERM I1Ai( ~ 4 1995 .)""-,, HENRY E. BRADLEY, Defendant ORDER OF COURT AND NOW, this =11 stay of M"rch ,1995, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before, O I - . . 5 I (V1r-r/,C-\n j c.d,!"') t\""'I\ <; .S~"''''1{,1he conciliator, at 3'1 Lv . M'"'' ,eulltbcrlllRd Coutlty-€6uflhouse, on tha\,l"day of flpr. I , 1995, at 1'l?l1m., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Either party may bring the child(ren) who is the subject of this custody action to the conference, but the child/children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. AMERICANS WITH DISABlLITffiS ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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 hearing or business before the court. You must attend the scheduled conference or hearing. FOR THE COURT: By:' U.c.c<t1_4Ldt l7ri~_ f"s 'I Custody Conciliator -fCl.rJ4' / 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 "IF~ II Ii H ,jlJ '85 ".' " 't'r " y L-/ ,'/ 'is' (;1) ('1:; f;r.?J!:; 6, ~1"1 ~.v 1-1 /1 ~?5- l't:.iul 1'I.l~Jb ;1. '~;; ,/ 1/ ~('., " ,. 'I "If . '/ (I1JlJ'<-I.,Jk/ tt XJ. ..:U(-'~1 QUETRlNA L. SIMS Plaintiff ; IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY HENRY E. BRADLEY Defcndant . : NO. 95-1501 1995 CIVIL TERM NOTICE TO DEFEND AND CLAIM RIGHTS You havc been sued in court. If you wish to dcfend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose moncy o.r property or other rights important to you, including custody or visitation of your children.. 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 Carlislc. Pennsylvania 17013 (717)240-6200 , I, i I, ! : QUETRINA L. SIMS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :! v. : CIVIL ACTION - LAW : IN CUSTODY HENRY E. BRADLEY, Defendant \50 I : NO. 95- 1995 CIVIL TERM COMPLAINT FOR CUSTODY AND NOW, the Plaintiff, Quetrina L. Sims, by her attorneys, the Family Law Clinic, sets forth the following cause of action: 1. The plaintiff is Quetrina L. Sims, residing at 2203 C Cedar Run Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The defendant is Henry E. Bradley, residing at 1840 Bamberger Road, Harrisburg, Dauphin County, Pennsylvania 17110. 3. Plaintiff seeks custody of the following child. ~ Prcscnt Rcsldcncc ~ Cherish LaCoy Sims-Bradley 2203 C Cedar Run Drive Camp Hill, PA 17011 7 yrs. (d.o.b. 8/8/87) The child was born out of wedlock. The child is presently in the custody of Quetrina L. Sims, who resides at 2203 C Cedar Run Drive, Camp Hill, Cumberland County, Pennsylvania 17011. During the past live years, the child has resided with the following persons and at the following addresses: custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best intercst and permanent welfare of the child will bc scrved by granting the rclief requcstcd becausc: a) Plaintiff has been primary caretaker of thc child since birth; b) Plaintiff provides thc child with a home with adequate moral, cmotional tlnd physical surroundings as required to mcet thc child's nceds; c) Plaintiff is willing to accept custody of the child; d) Plaintiff continues to exercise parental duties and enjoys the love and affection of the child; e) Defendant has not indicated to plaintiff an interest in accepting custody of the child. 8. 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. WHEREFORE, plaintiff requcsts the court to grant her sole legal and primary physical custody of the child. n Date J'/+0S ex Com a t IJctiLndJ Dana E. McDade Student Attorney ~J~te,~ THOMAS M. PLACE ROBERT E. RAINS LINDA E. FISHER Supervising Attorney THOMAS L. PEELER Staff Attorney FAMILY LAW CLINIC 45 North Pilt Street Carlisle, PA 17013 717/243-2968 , . i .i I , COMMONWEALTH OF PENNSYLVANIA: ,i COUNTY OF CUMBERLAND: SS. I verify that the statements made in this Custody 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. Section 4904, relating to unsworn falsification authorities. Date 0 / t21J - '1,- ! i -'J 1L X. ~ (J or> ~\~ () 0 ~") ~ c;n .' '1 l{) () .:J = In It (J) ..~ ~ :W;'_: ~') '-.,.. , 0 :r U) r> 10 I.. -. N :r- eo (1! '" <:::> . rJ1. :l1 1:' '" oJ .,L m c) ".... .:! "" " =-= LM en ;,....... " = ..", -'1' ::r \.1- l.~ ~' , en .... "" :c {H'i I ~~ ~ ~~m 0&. II": ~~~8 n ". Jl ~:B '" " r:t ~ ,- :tl "' ~ .. ~ ,. - . ":5~ = ~ - ~ ,'" 5 I Vi ~ 'j Ii II, IQ(, -:; .=": ~~8~ ~ <: . - <: (.l . I ~ ~ ~ '~ ~ ~~ .tfIf e ~ = , r ~" :!lH Ul~ ~~ g:: .c .Q ~~~~ ~ s ~..a ::; . ::: ";';' '" ii ~ ~ (;() '41 n_ I . .... I . ~ ~~ rLI ! ~~ . ,; '.' . . , ., ~. JUN . 5 1~~1~ i I ~ ... QUETRINA L. SIMS, . IN THE COURT OF COMMON PLEAS OF . Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . . vs. . NO. 95-1501 CIVIL TERM . . . HENRY E. BRADLEY, . CIVIL ACTION . Defendant IN CUSTODY aIDER OF CXXIRT AND tOI, this ~ tt, day of 'J \oJ ., eo the attached Custody Conciliation Report, it as follows: , 199~, upon consideration of is hereby ordered and directed 1. The Mother, Quetrina L. Sims, shall have sole legal and primary physical custody of the minor Child, Cherish LaCey Sims-Bradley, born August B, 19B7. 2. The Father, Henry E. Bradley, shall have partial physical custody of the Child only by mutual agreement of the parties. 3. If either party wishes to amend the terms of this Order, that party may petition the Court to have this case again scheduled Idth the Custody Conciliator for a COnference. BY THE COURT, cc: Nicholas Craig/Thomas M. Place, Esquire Henry E. Bradley Q...,r.,.~., ~L "lqJf{S'. \) ..b. 6' . J. .4/1.'1;<" " '{)1l', ,.\1 (', ': -""','1 .!..; NOh-,';'" ,'...-,-1 J;'i.'J-; ,I .'-!.:.ty',7;; ~ . C . 'I, SG, lid 60 J l . ' iO C 8/fflr