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Home My WebLink About95-03634 JA Y R. BAKER PllIlntlff : IN TilE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO q .;..J{, IV &~i f-""'- FELICIA BAKER Defendllnt ORD~R 0.' CO\JRT AND NOW, 'i" I" , .; ,1995, upon conslderlltion of the attached Complaint, It is hereby directed thlltth'e pllrties lInd their respective counsel appear before -1-\. ..., ) '-.,...,1 I (. ,the Concllllltor,lIt ',"I (I (", , ,'.I, J. I on the II LA dllyof 1I1. .J I. t . 1995, lit I I., o'clock ....t...m., for a Pre- Hellring Custody Conference. "At such conference, lIn effort will be made to resolve the issues in dispute; or if this CRnnot be accomplished, to define and narrow the Issues to be hellrd by the Court, and to enter into II temporlll)' order. All children age five or older ~ " I a.tt also be present lit the conference. FlIilure to appear at the conference may provide grounds for entry of a temporal)' or permanent order. FOR THE COURT: /) ,/ By: ./.".,/ -() (/I..".I.,;:J Custody Conciliator .. t .":AI, /.t.:P/,/ 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 BY THE COURT: J. JUI Iii 2 SG fH '95 1'1'. Ii 'l f~ \ fl,', : , ' I 7, It/.tff &,,1. (W. )nt;rf4l~ a~ ):/ttk /-/1/.6- 71~tt /lfaJJ.t/ ~ c/#/ 7-11I'~ tbpy Imi.JlI ~ f!f~It&~ . JA Y R. BAKER Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. FELICIA BAKER Defendant : NO Q,>- 3<. N ClL;~' Tt._ : CIVIL ACfION . CUSTODY COMPLAINT FOR CUSTOIIT J. Plaintiff Is Jay R. Baker, residing at 152 Faith Circle, Carlisle, Cumberland County, Pennsylvania, 17013, 2. Defendant is Felicia Baker, present address Is unknown but I. believed to be residing at 19 Fieldstone Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Plaintiff seeks custody of the following children: Jayson K. Baker, born December 22, 1986 and Courtney A, Baker, born January 21, 1991, current address I. believed to be 19 Fieldstone Drive, Mechanlcsburg, Pennsylvania, 17055, 4. Jayson K. Baker and Courtney A. Baker were born In wedlock. 5. Jayson K. Baker and Courtney A. Bake are believed to be presently In tbe custody of Felicia Baker, who currently Is residing at 19 Fieldstone Drive, Mechanlcsburg, Pennsylvania, 17055 6. During the past five yeai'll, the children have resided wilh the following pel'llons and at tile following addresses: &ME ADDRESS DATES April of 1989 to April of 1994 April of 1994 to July 4, 1995 Jay R. & Felicia Baker 386 Pin Oak Lane Carlisle PA 17013 152 Faith Circle Carlisle PA 17013 Jay R. & Felicia Baker 1lAlUlllnlll'JOIIN 7. The molher of Ihe children Is Felicia Baker, believed 10 be currently residing at 19 Fieldstone Drive, Mechanlcsburg, Pennsylvania. She Is married. 8. The father of the children Is Jay R. Baker, currently residing at 152 Faith Circle, Carlisle, Pennsylvania. He Is married. 9. The relaUonshlp of Ihe PlalnUff to the children is that of natural father. The Plalnliff does nol currenlly reside with any olher person. 10. The relalionshlp of Defendant 10 the children is that of natural mother, The Defendanl currenlly resides wilh the following persons: Name RelaUonshlp friend son daughter Ann Dart Jayson K. Baker Courtney A. Baker II. PlalnUff has not participated as a party or wilness, or In another capacity, In other litigation concerning Ihe custody of the child in Ihls or another court. 12. Plaintiff has no InformaUon of a custody proceeding concerning the child pending In a court of this Commonwealth. 13. Plalnliff does nol know of a person not a party to the proceedings who has physical custody of the child or who claims to have cuslody or vlsilatlon rights with respect 10 the child. 3 . IIAKI!R.C:\JI\'JOIlN 14. The best Interest and permanent welfare of the children wll\ be selVed by granting the rellef requested. 15. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiff requests the Court to grant primary custody of Jayson K. and Courtney A. Baker to Plaintiff with such partial custodyMsltatlon to Defendant 81 appears to be in the best interest of the child. Respectfully submitted, HETRICK, ZALESKI & PIERCE, P.C. 10 S. Market Square, Suite 500 Post Office Box 1265 Harrisburg, P A 171 08-1265 Telephone: (717) 236-9581 Attorney for Plaintiff 4 . . I,^KI',1l111fo1111llN ~ I verify that the atatements made In this Complaint are true and correct, I undentand that false statements herein are made subject to the penalties of 18 Pa. C.S.A, Section 4904 relating to unsworn falsification to authorities. ~Jf (JI.,., JAY ,B. R 1/ i " Date: ~i c" ..." /., i) I ~ s i '_ , '..' > h J!.;'''., ~ ~ 1~' -1'#1 '~ ~..: . '.'.-j h !:r ~ ] '"-..J Cb R.: ~ ... .. .t. ~ \>>I III .. ~ ~ ~ ~ f ~ HI:Tfl'CK ZAlf-SKI 6 Plf-nct I',c. AlllllHit 'to, All AW 10 5nutlt MAllkl1 SWIM" PU!>I OIlIlL 11m JilfHi '-'..hnl\IIUllII, Jl.NN\\'I\lANIA 111(J1I126fl J lJl 11171 t!1.... lIt;Jt, I , I'IQ!j )'trj . . . " ,b_ " V JAY H. IlAKEH/ I IN 'rilE COUR'r OF c.'OMMOO PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I CIVIL ACTION - LAW vs, I I NO, 95-3634 civil Term I FELICIA BAKER, I Defendant I CUSTODY amm OFaxJRT AND NOW, this 25th day of September, 1995, the Conciliator, being advised that the parties have resolved the custody issues by agreement, relinquishes jurisdiction in this case. ft. bI -:.. ,. ... <<'"..r.' w tt a ~ :JLI /' i) \gg~ ~'" JAY R. OAKER, I IN TilE COURT OF COOMON PLEAS OF Plaintiff I CUMOERI.AND COUNTY, PENNSYLVANIA I CIVIL ACTION - I,AW vs. I I NO. 95-31\34 CivU Term I FELICIA BAKER, I Defendant I CUSTODY au>I!R OF CWRT AND NON, this 25th day of September, 1995, the Conciliator, being advised that the parties have resolved the custody issues by agreement, relinquishes juriSdiction in this case. ~~ Dawn S. Sun ay, Esqu r ';. "',.d'. . ..!I' ~., . lltt -; :'.~ .....,. H If tel tAl ~ til ~ , ~/ JAY R. bAKER, I IN 'l'IlE COUR'f OF CU\MCX'l I'I.I~AS 01' Plalntiff I CUMBERLAND COUNTY, PENNSYLVANIA I CIVIL AC'rION - LAW VI. I I NO. 95-3634 Civil Term I FELICIA BAKER, I Defendant I CUSTODY OODI!R or cum AND NOW, thie 25th day of September, 1995, the Conoiliator, being adviled that the partiel have resolved the custody isaues by agreement, relinquishes jurisdiction in this case, ~cv l"l f.U t'..J .....~ v: "" Ql ".U at m