HomeMy WebLinkAbout95-05588
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JENNIFER M. QUIGLEY,
Plalntlff,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VSo
DANIEL L. COOK,
Defendant,
NOo 95. o~5'ffg CIVIL TERM
IN CUSTODY
AND NOW, upon consideration of the attached Petition, It 15 hereby directed that
the parties and their respective couns appear before Hubert Xo Gilroy, Esquire, the Conclllator,
on tha ~ day of , I ( rn hr ,1995, at '1 ~ co'c1ock ..!l-.omol
In ~~ L C IU,){ ( v"'" I <J (n", \I.,,, ". ., Carllsle,
Cumberland County, Pennsylvania, lor a pre-hearing custody conlerenceo At such conlerence,
an effort will be made to resolve the issues In dispute; or II this cannot be accomplished, to
dellne and narrow the issues to be heard by the Court, and to enter Into a Temporery Order.
All children age five or older" /jlso be present at the Conferenceo Failure to appear at the
Conference may provide grounds for the entry of a Temporary or Permanent Order.
BY THE ~T, t.-
Date: /O.;}q,c/J' /' j'1..l-l-f!t,:! A. :J.."7~~lt,r;:y-(~'>'I.
Custody Conciliator r;:r--:~
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 Admlnlstrator, Fourth Floor
Cumberland County Court House
Carlisle, Pennsylvania 17013
(717) 240.6200
AMERICANS WITH DISABiliTIES ACT OF 199Q
The Court 01 Common Ploas 01 Cumberland Counly, Ponnsylvanla, Is requlrod by law 10 comply with the
Americans wllh Dlsablllllos Acl 011090, For Inlormallon aboul accosslhlo lacllillos and reasonable accommodallons
avellable to disabled Individuals having buslnoss boloro Iho court, ploaso conlact our olllco. Ail arrangoments musl
be mado etloast 72 hours prior loony hoarlno or buslnoss boloro Iho Court,
BY THE COURT:
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JENNIFER Mo QUIGLEY,
Plaintiff,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs,
NO, 95-
IN CUSTODY
CIVIL TERM
DANIEL L. COOK,
Defendant.
SIO.D.Y
1. The Plaintiff Is JENNIFER M. QUIGLEY, residing at 201 South Side Drive,
Newville, Cumberland County 1 Pennsylvania 172410
2, The Dafendant Is DANIEL L. COOK, residing at 825 Newcombe Avenue,
Hampton, Virginia 233600
3, The Plaintiff seeks custody of her child, PRESTON L. COOK, residing at 201
South Side Drive, Newville, Pennsylvania 17241, about ten months oldo
The child was born out of wedlock. The child is presently In the custody of Plalntlff,
who resides at 201 South Side Drive, Newville, Cumberland County, Pennsylvania 17241.
From the child's birth In December of 1994, until April of 1995, the child lived with
Plaintiff and Defendant at 42 Town Mills, Shlppensburg, Pennsylvania 172570 From April of 1995,
until October 13, 1995, the child lived only with Plaintiff at that address, From October 13, 1995
until the present, the child Is living with the Plaintiff and her parents at their home at 201 South
Side Drive, Newville, Pennsylvania 172410
The mother of the child Is JENNIFER M. QUIGLEY, currently residing at 201 South
Side Drive, Newville, Cumberland County, Pennsylvania 1724157. She Is slngleo
,
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The father of the child Is DANIEL L. COOK. currently residing at 825 Newcombe
Avenue, Hampton, Virginia 23360. He Is single.
4. The relationship of the Plaintiff to the child Is that of natural mother. The
Plaintiff currently resides with the child at 201 South Side Drive, Newville, Cumberland County,
Pennsylvania 17241.
5. The relationship of the Defendant to the child is that of natural father. The
Defendant currently resides at 825 Newcombe Avenue, Hampton, Virginia 23360.
6. Plaintiff has not participated as a party or witness, or In any other capacity
In other litigation concerning the custody of the child In this or another jurisdiction.
7. The Plaintiff has no Information of a custody proceeding concerning the child
pending In a court of the Commonwealth.
B. The Plaintiff does not know of a person not a party to tha 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 Plaintiff has had primary custody of the child since the date of
his birth, and since moving out In April of 1995, Defendant has had only limited contect with the
child of ebout one weekend per month.
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I, JENNIFER M. QUIGLEY, Plaintiff In the within action, the undersigned, hereby
verily that the statements made herein are true and correct. I understand that false statements
herein are made subject to the penaltlas of18 Pa. C.S, !i 4904, relating to unsworn falsification
to authorities.
Q)l!LL~i'1J7J7 [jlltglJlLI-.
JEu::mlfer M. Quigley (j
Date:! () / / I r / ql)
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JBNNIFER M. QUIGLBY,
Plaintiff
:IN THE COURT OF COMMON PLBAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:
:NO. 5588 - CIVIL - 1995
:
:
:CIVIL ACTION - CUSTODY
v
DANIBL L. COOK,
Defendant
CONCILIATION CONFERENCE S[HtIARY REPORT
IN ACCORDANCB WITH CUMBBRLAND COUNTY CIVIL RULB OF PROCEDURE,
1915.3-8(b), the undersigned Custody conciliator submits the
following report:
1. The information pertaining to the child who is the subject
of this litigation is as follows:
Preston L. Cook, born December 3, 1994.
2. A Conciliation Conference was held on December 14, 1995, with
the following individuals in attendance:
The Mother, Jennifer M. Quigley, with her oounsel, Carol J.
Lindsay, Esquire. The Father did not appear. The Father was
served by oertified mail on November 3, 1995.
3. Mother indicates that she ourrently has physical oustody of
the minor ohild and that the Father is living at an unknown
looation in Virginia. Mother relates that the parties
separated approximately 4 months ago and that the Father has
had no contaot with the child since that time. Mother
expresses a concern with respeot to Father's living
arrangements and Father's current emotional status. Father
has had limited contact with the child over the past four
months but it has always been under a supervised arrangement
with other adults present.
4. Mother requests an Order giving her primary custody and the
Father periods of temporary custody under supervised
arrangements as agreed upon by the Mother.
5. The Conciliator recommends an Order in the form as attached.
I~ J 11/ f/J
DATE
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