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Home My WebLink About95-05247 " _ H " n lml~~U01I ji:~~:~";;'~~ .. ,- " ,:f{;:~}~1;\t~1~~~!;~tf_~J;;';'i:' ii~~~k"'''''''\#''~''~tr . ;:::;~;~'f10i~ ': " Michelle Sollenberger, Plaintiff IN THE COURT OF COMMON PLEAS OF . . CUMBERLAND COUNTY, PENNSYLVANIA : NO. 95- 5";;;1./) CIVIL TERM v. : : CUSTODY Joseph M. Powley, Defendant . . ORDER OF COURT AND NOW, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before --Jr1.th-,.~ I L. &,...~ , the conciliator, at '3(~ ~, I ff t~ 51, (.llhf ~"I\ on the ~{'\A day of ~ L.'L.,rm b< r d., 1995, at lo'~/j .m., 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. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. ~the Court, f\tl'~.h~il'11;;, ~' 1 .4 /JJ:.~1 t-r~/~ E YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF tou 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, 4th FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717) 240-6200 AMERICANS 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 to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any scheduled hearing or business before the court. You must attend the scheduled conference or hearing. I( I - ~I . I.;'j GCI II 10 10 AM '95 i'\\(-<.......c. u.\ i,J c,l',n \ (,> Dl &\. \\-~I'<.~i. ~ 'J <A,'II:'\ \C" l, ,S , 1\'. ( .\!I .~ " Michelle Sollenberger, plaintiff IN THE COURT OF COMMON PLEAS OF . . CUMBERLAND COUNTY, PENNSYLVANIA NO. 95- CIVIL TERM v. CUSTODY Joseph M. Powley, Defendant COMPLAINT FOR CUSTODY 1. The plaintiff is Michelle Sollenberger, residing at 5229 Simpson Ferry Road, Mechanicsburg, cumberland county, Pennsylvania 17055. 2. The defendant is Joseph M. Powley, residing at 106 E. columbia Avenue, Enola, Cumberland County, Pennsylvania 17025. 3. Plaintiff seeks custody of the following child: ~ Present Residence &m Joseph M. Powley, Jr. 5229 simpson Ferry Rd. Mechanicsburg, PA 2 mos. The child was born out of wedlock. The child is presently in the custody of Michelle Sollenberger, who resides at 5229 Simpson Ferry Road, Mechanicsburg, Pennsylvania. During the child's lifetime, the child has resided with the following persons and at the following addresses: ~ Address ~ plaintiff, 5229 simpson Ferry Rd. Bonnie Mechanicsburg, PA Goodling (grandmother), Frederick Goodling (step-grandfather), Kim Sollenberger (aunt) Shawnie Goodling (cousin) Christopher Zeigler (half-brother) The mother of the child is Michelle Sollenberger, currently 7/95- present residing at 5229 Simpson Ferry Road, Mechanicsburg, Pennsylvania. She is single. The father of the child is Joseph M. Powley, currently residing at 106 E. Columbia Avenue, Enola, Cumberland County, Pennsylvania 17025. He is single. 4. The relationship of plaintiff to the child is that of mother. 5. The relationship of defendant to the child is that of father. The plaintiff currently resides with the following persons: ~ Bonnie Goodling Frederick Goodling Kim Sollenberger Shawnie Goodling Christopher M. Zeigler Joseph M. Powley, Jr. Relationship Mother Step-father Sister Neice Son Son 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. 7. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 8. 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. The best interest and permanent welfare of the child will be served by granting the relief requested because: a. The mother has been the primary caretaker of the child. b. The mother can best provide for the needs of her child. 10. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have boen named as parties to this action. WHEREFORE, the plaintiff requests this court to grant primary physical and legal custody of the child to the plaintiff. Respectfully submitted, (i) ,l...-t!...J \./~"u<.- oan Carey Attorney for PlaIntiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 The above-named plaintlff, MICHELLE SOLLENBERGER, verifies that the statements made in the above Complaint are true and correct, The plaintIff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. section 4904, relating to unsworn falslfication to authorities, J -1 .., Date:_?t:251-_~____ __ ______~~:B"t-tl_J~S,4~.~liJ~_., Michelle Sollenberger, plaintiff HI CHELLE SOLLENBERGER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 95- CIVIL TERM JOSEPH M. POWLEY, Defendant CUSTODY AFFIDAV,IT IN SUPPORT OF PETITION FOlL.J...EA VE~J,'Q]ROCE~ILJJL~QRHt. PAUPERI S 1. I am the plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the 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: ,Mici}ellELpoLtenQM~L, _~_~______~______~_~__,_~ Address: _5;2-19_~Si!llPson _Ferrj',_R9a(l_, __ ".. _u _~______, _______ l1.ecban1<;!;J:>,.!I!:gL}>~~ _17P55~___ __ _ __u~'u~ Social Security Number: ,194-::.9..6:::~U5__,__u_u___,___ If you are presently employed, state Employer: ..Al,p!}..'! R~ql!etJ:>itll_GluQ ,__ _ ,., Address: _QJ,d_ G.etJYJ;;J:lI,,-rgR~L. ~. .we.!; IElY . Dr:~YEl,_ ~_ _ 0- Mecl1anj,c!:iburg, PA 17Q~5 _ ___ Salary or wages per month: J180~QO Type of work: daycare If you are presently unemployed, state Date of last employment: N/A Salary or wages per month: N/A Type of work: NI A Other income within the past twelve months Business or professlon: eVA- $340,00 @mo. for 3 mos, Office Max- $680,00 @mo, for 5 mos, (b) (c) Other self-employment:, _None,_ ,__.' ..,...,_._ __.._, __.___ Interest:,_None,_,____,___..__._.____,__. ..... _._ ..__,,__,_,_..___ ______ Dividends: Jfo!,!e _,___ __ __, _.____ Pension and annuities: _.Bgne,__,_____,. ___,__ _.________,.___ Social Security bene fits: ,. None ____,___,_ ____,___._,____ Support payments: _ NOJHL__.u_ _ oo__..'__ ,_' __m'_ _______ Disability payments :_.No!'!~_ ' _ _ . .,_,_ ..___,__._______ Unemployment compensation and supplemental benef its: NonJL, Workman's compensation: _NonJ!.__n__.__,_________,..____ Public Assistance: _UOX' Q_0"per...Jll9-,__~~JlS!LJan~.._9.2___ Other: _ltone _____._.____,___ ,_______ (d) Other contributions to household support (Wife (Husband) Name :..t!onen_,_ If your (husband) (wife) is employed, state Employer: tilA Salary or wages per month: lilt._, _ __ Type of work: _ MiA, Contributions from children: _N.J Pt..,__ __n' ____'__n__'_'__ (e) Property owned Cash: _.M()p~_ __ ' Checking Account:tionl! Sav ings Account: . Nope_ Certificates of Deposit: _Ji.oIl_e_,. Real Estate (including home): NO!'!e Motor vehicle: Make Non~. Year Cost Amount owed Stocks; bonds: None Other: __NQ.!lEL_ __,.. _. ___.._ ,., ___, (f) Debts and obligations Mortgage: -1:IonJL_________. ______ Rent: _m~'-OjL~r_l!)Q_.__...__________._______, Loans: ..lion.!L._ ___,__.,_ __ _ _, _._ ,__ ___ Honthly Expenses :.J'!i!tElJ' - $1.ti~ ,.o.O.,_Gas _____lg.Q. 00 .___. __ . .iiJ.i!P.El VL:,HO_. Q. 0_" . 9.r9~.ElLiEl,$____1.4!0 ,.0. 0,. c.lo_t.Qi.ng::-_.i.?~,Jl 0_ _mi~C;;ElUatlElOUS -_$1,5.00, POOnE! -$3.5Lo.o.-L_11!1!I1.9.JY::,llJLOO (g) Persons dependent upon you for support (Wife) (Husband) Name: J{omL__,. ..., Children, if any: Name: _~h~istopoer:.Ze.igJ.ElL____ Age: .'l...YL______, _ J Q.sepI:LPo1i! !rr...._. ..___ ., " ~-.!!!os-,-___.____ 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 toe 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: 9'~/.~~-'" -rOt ck4 ;.,S..iJtut-L;~ ,,_ '."'- - ---------...1'...-------'--- Michelle Sollenberger, Plaintiff (".-' ,- '> ("~J ~ ~ .~ c.= ) r... IJ") 0") - ,<- ", N ry - '-' = MICHELLE SOLLENBERGER, Plaint iff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-5247 CIVIL TERM v. JOSEPH M. POWLEY, Defendant CUSTODY AND NOW, this CUSTODY ORDER ~ day of October, 1995, upon consideration of the parties' Consent Agreement, the following Order is entered with regard to custody of the child, JOSEPH POWLEY, JR. 1. The plaintiff, Michelle Sollenberger, shall have primary physical and legal custody of the child. 2. This Order shall remain in effect until further Order of Court. By the Court, ~, " .. ~ , .. ,', , . I' MICHELLE SOLLENBERGER, Plaintiff IN THE COURT OF COMMON PLEAS OF v. CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-5247 CIVIL TERM JOSEPH M. POWLEY, Defendant CUSTODY CONSENT AGREEMENT This Agreement is entered on this ~~ day of October, 1995, by the plaintiff, MICHELLE SOLLENBERGER, and the defendant, JOSEPH M. POWLEY. The plaintiff is represented by Joan Carey of LEGAL SERVICES, INC.; the defendant is unrepresented but is aware of his right to have an attorney. The parties agree that the following may be entered as an Order of Court. The mother shall have primary physical and legal custody of the chi ld. WHEREFORE, the parties request that a Custody Order be entered to reflect the above terms. lZ2rr;j ,/'& fr; A:& 4Z ("J~[{\ Michelle Sollenberger, PlaintAff () <'I ' /fi~:n'''ta'r~~~~ Attorney for ptlintiff LEGAL SERVICES, INC. S Irvine Row Carlisle, PA 17013 (717) 243-9400 "~ 1..,. O"<>y - - -.:::. o ... @ ~ '1 , ~ ~ ~ ..... en .t-=: ~ '" ,"') - L,) = NOV Ol1995dV\ MICHELLE SOLLENBERGER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 95-5247 CIVIL TERM JOSEPH M. POWLEY, Defendant CUSTODY ORDER AND NOW this 31st day of October, 1995, it being reported to the Conciliator that the parties have reached an agreement which makes further proceedings unnecessary, the undersigned Conciliator hereby relinquishes jurisdiction and returns the matter to the Court Administrator. If either of the parties wishes further proceedings in this action, they should petition the Court anew. FOR THE COURT, I/lA' ," 'l rI V t\ r)vA 1..6 c,O MICHAEL L. BANGS r Custody Conciliator ef"') , )0- CT> , = 0- "" r.> . ...' " V') ,~, ., --