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HomeMy WebLinkAbout02-4342IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA ROBERT C. COMBS, : Civil Action At Law---Custody Plaintiff, : Case No. (3D. - ~t~q3x VS. : ANGELA M. COMBS, : Defendant, : COMPLAINT FOR CUSTODY 1. The plaintiffis Robert C. Combs., residing at 1955 Fry Loop Avenue, Carlisle 17013, in the County of Cumberland, Commonwealth of Pennsylvania, 2. The defendant is Angela M. Combs, currently residing at 13220 East Skyview, Spokane, Washington. 3. Plaintiff seeks custody of the following child: Name Address Ryan K. Mandelbaum same as father's dob 6/18/1993 4. The child was bom ,~ outside of wedlock. 5. The child is presently in the custody of Robert C. Combs, who resides at Loop Avenue, Carlisle, PA. 17013. Age 9 1955 Fry 6. During the last nine months the child has resided with the father at 1955 Fry Loop Avenue, Carlisle, PA. 17013. 7. The biological mother of the child is Angela M. Combs, currently residing at 13220 East Skyview, Spokane, Washington. 8. The mother has been separated from the father since 1996, and is currently divorced from the same. 9. The father of the child is Robert C. Combs and is currently residing 1955 Fry Loop Avenue, Carlisle, PA. 17013. 10. The father is separated and divorced from the mother. 11. The relationship of the plaintiff to the child is that of a biological Father. The Plaintiff currently resides with the following persons: Name Relationship Ryan K. Mandelbaum Son 12. The 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. 13. The plaintiff has no other information of a custody proceeding concerning the child pending in a Court of this Commonwealth. 14. 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. 15. The best interest and permanent welfare of the child will be served by Granting the relief requested because: (a) The child currently resides with his father within which the child has grown accustomed and wherein he feels a sense of comfort, permanency, and familiarity. (b) The plaintiff has provided for the child's special needs conSisting of ADHD, by providing counseling services to the child to aid the child to fulfill his developmental needs both emotional and educational. (c) The child in enrolled in a school within the Commonwealth of Pennsylvania and has developed attachments to his peers, and teachers. (a) The mother is several thousand miles from the Commonwealth of Pennsylvania and is accordingly physically incapable of exercising a consistent period of custody with the child within the Commonwealth of Pennsylvania due to geographical constraints. (b) The father is a resident of Pennsylvania is employed and can accommodate the child's needs by providing a stable, consistent and predictable environment. (c) Plaintiff, believes and therefore avers that he can continue to provide a predictable and stable lifestyle for which, which will be in the best interest of the child during his formative years and throughout his life. WltEREFORE, Plaintiff, Robert C. Combs, respectfully requests for the aforementioned reasons, that the court grant and award him primary physical custody of the child. Dated: ~/L!/~ GRE O . HA ETT s. 21Ygouth Mar~ket Street Mechanicsburg, PA. 17055 (717) 790-5500 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. & 4904 relating to unswom falsification to authorities Date: Robert C. Combs, Plaintiff AMERICAN WITH DISABILITIES 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 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. BY THE COURT: Jo ROBERT C. COMBS PLAINTIFF ANGELA M. COMBS DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : : 02-4342 CIVIL ACTION LAW : IN CUSTODY : ORDER OF COURT AND NOW, Monday, September 16, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Meehanicsburg, PA 17055 on Tuesday, October 15, 2002 at 8:30 AM 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. All children age five or older may also be present at the 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 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 hearing 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 ROBERT C. COMBS, Plaintiff VS. ANGELA M. COMBS, Defendant :IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-4342 CIVIL ACTION LAW : : IN CUSTODY ORDER OF COURT AND NOW, this 15TM day of October, 2002, the Conciliator, being advised by Plaintiff's counsel that all custody issues are being resolved by agreement between the parties, hereby relinquishes jurisdiction. The Custody Conciliation Conference scheduled for today, October 15, 2002, is canceled. FOR THE COURT, Dawn S. Sunday, Esquire Custody Conciliator