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HomeMy WebLinkAbout95-06315 i :v i' < ~, ! " f.; ~ I:; f ;i ;; ....n, BARBARA WILKERSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95*W>1f' CIVIL TERM CUSTODY v. REGINA RITTER, Defendant CUSTODY ORDER AND NOW, this ~daY of I'Y\{ V wf...t---- , 1995, upon consideration of the parties' Consent Agreement, the following Order is entered with regard to custody of the minor child. 1. The plaintiff, BARBARA WILKERSON, hereinafter referred to as the grandmother, shall have primary physical and legal custody of the child. 2. The defendant, REGINA RITTER, hereinafter referred to as the mother, shall have partial custody of the child at times mutually agreed upon by the parties. 3. The grandmother and mother shall notify each other of all medical care the child receives while in that party's care. Each party shall notify the other immediately of medical emergencies which arise while the child is in that party's care. By the Court, /Jc~vi J-~ . fL , . J. "0" I' 1 n J 2 28 PO '95 . "t,,:;.mcr ,'T : <S ~'>;~:"'IHI\;...':.it~. (;U)4~.t;.f,lt.,,;; {.(;;ih'(y , '. PEh~~f\.\;~!II' -:F;tf::J~ \~ftt.:";! I:}:;,' ... , ,.; F._ ,. ~ ,-, -,""",.. .'...."., ,,' '.~;" "H ,. ~'~ ., f ~ "{,!,...,,. .'i'~~ ; f~'J) - J,j."ir d:~:..'ft~~L!:' (F.......t. " ,~.'i ' ~', ",. ,"".'; ~:"i' :} Ii' i\: , ; '''-1'.,-, ,." , ," 'c,'. t-i \;;t ;., ~',~; t2 " - ~; . . , ,'," _..l .~ ;;'.., IjJ' ,i1 t...... '., <( " d.:,C" '."," '';'; l-.~J -::j~ j' ..."..:......._'..I.~,lt<........,,A\.u:.,.. " ',} ~::\~'~,.,l <- .': D,,:;~~,,';;' "'"("'.. -, :C',r~ i:, ~-. ,):: 'lH:-u-r.d ;-,,~-,:--, ~ t; . "I ;! .,~...--.,.,..~<...__......_..._~..""~..u'!.r " ......~" ~ BARBARA WILKERSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95- (,JI{ CIVIL TERM CUSTODY v. REGINA RI'l"l'ER, Defendant COMPLAINT FOR CUSTODY 1. The plaintiff is BARBARA WILKERSON, residing at 2200E Cedar Run Drive, Camphill, CUmberland County, Pennsylvania 17011. 2. The defendant is REGINA RITTER, residing at 202 York street, Apartment 14f, Brooklyn, New York 11201. 3. The plaintiff seeks custody of the following child: HAD Present RBsidence ASIA 2200E Cedar Run Drive camp Hill, PA The child was born out of wedlock. 5 years old Sephon Lawrence The child is presently in the custody of BARBARA WILKERSON, who resides at 2200E Cedar Run Drive, camp Hill, Cumberland county, pennsylvania. During the child's lifetime, he has resided with the following persons and at the following addresses: HAD Address I2Wl Barbara Wilkerson 2200E Cedar Run Drive 8/95 - present birth - 8/95 Regina Ritter, and E. Murphy (half-sister) 202 York Street Apartment 14f Brooklyn, NY The mother of the child is REGINA RITTER, currently residing at 202 York street, Apartment 14f, Brooklyn, New York. She is single. The father of the child is CHARLES LAWRENCE. . . 4. The relationship of plaintiff to the child is that of grandmother. The plaintiff currently is residing at 2200E Cedar Run Drive, Camp Hill, Cumberland county, Pennsylvania. 5. The relationship of defendant to the child is that of mother. The defendant currently resides with the followin9 persons: ~ RelationshiD E. Murphy Daughter 6. The plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerninq the custody of the child in this or another court. 7. The plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 8. The plaintiff does not know of a person not a party to the proceedin9s who has physical custody of the child or claims to have custody or visitation rights with respect to the child. The child's father has never sought visitation rights and his whereabouts is unknown to the parties. (See paragraph 11). 9. The parties aqree that the best interest and permanent welfare of the child will be served if the relief requested is granted. 10. The mother, and the qrandmother, who has physical custody of the child, have been named as parties to this action. 11. The father has not seen the child since birth and is currently unable' to be located; he is listed in the Absconded Search Unit of the New York Parole system. "-., . . WHEREFORE, the plaintiff requests this Court to grant primary physical custody of the child to the plaintiff with partial custody in the defendant at times that may be mutually agreed upon by the parties. The plaintiff requests any other relief which is just and proper. Respectfully submitted, J Carey Attorney for Plaintiff LEGAL SERVICES, INC. a Irvine Row Carlisle, PA 17013 (717) 243-9400 . . . .' . , The above-named plaintiff, BARBARA WILKERSON, verities that the statements made in the above complaint are true and correct. plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. 54904, relating to unsworn falsification to authorities. to/().1r.~ / ~~a4 tlg/~- Barbara Wilkerson, plaintiff Date: ,..' ..-........". <....,,~.. ,..."'...-....."",.... .... .~..... ....- , ....,. BARBARA WILl<ERSON, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. REGINA RITTER, NO. 95 CUSTODY CIVIL TERM Defendant This Agreement is CONSENT AGREEMENT entered on this ~ day of MlJunw 1995, by the plaintiff, BARBARA WILl<ERSON, hereinafter referred to as the grandmother, and the defendant, REGINA RITTER, hereinafter referred to as the mother. The grandmother is represented by Joan Carey, of Legal Services, Inc.; the mother is unrepresented but is aware of her right to have an attorney. The parties agree to the entry of the following custody Order regarding the minor child Sephon Lawrence. 1. The grandmother will have primary physical and legal custody of the child. ., .. The mother will have partial custody of the child at times mutually agreed upon by the parties. 3. The grandmother and mother will notify each other of all medical care the child receives while in that party's care. Each party shall notify the other immediately of medical emergencies which arise while the child is in that party's care. \.-",... . . .", .......... ~ '..... l , , WHEREFORE, the parties request that an Order of court be entered to reflect tile above terms. @M~A/A -/ Barbara Wilkerson, plaintiff t ~y~ Attorney for Pl intiff LEGAL SERVICES, INC. a Irvine Row Carlisle, pa 17013 (717) 243-9400 .';~ . \\: ~ "j ~ ~ ~ ,I..... '~ :, ~. "; : "<f -'-H; _~'. <:-: = - E ... N N ,,....,,;. , "'0- ' <z. ~ &"~::J.:!t 2% SIr, :::g;~ at-'ll:.... .0,-.(>- Qa::-J'" wC!o.o::C -' tu= -IUG1lLI Y.o:E:xa. ...", ~u f"ooI ".. _"i! ~ t: '-~' '<: " ':l ,,; -~ ,~ , , , ' . ~ .) -~ -....... ~tM:...;;-~,-1t\-,,=,'~"""'i.-#'T""9'''''''''"',~,''if;:l~~~ < '- ~ ~ '-'? .. I'l "::: ... l 4 ~ BARBARA A. WILJC:ERSON, plaintiff IN THE COURT OF COMMON PLEAS OF . . . I CUMBERLAND COUNTY, PENNSYLVANIA I : NO. 95- ~31S" CIVIL TERM : v. REGINA RITTER, : CUSTODY Defendant . . PRAECIPE TO PROCEED IN FORMA PAUPERIS To the prothonotary: Kindly allow, Barbara wilkerson, plaintiff, to proceed in forma n&UDeris, I, Joan carey, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free le9al services to the party. The party's affidavit showin9 inability to pay the costs of litigation is attached hereto. 9:::;:f}/u/~ Attorney for plaintiff LEGAL SERVICES, INC. a Irvine Row carlisle, PA 17013 (717) 243-9400 BARBARA A. WILKBRSON, Plaintiff IN THB COURT OF COMMON PLBAS OF CUMBBRLAND COUNTY, PBNNSYLVANIA v. NO. 95- CUSTODY CIVIL TBRM RBGINA RITTBR, Defendant AFFIDAVIT IN SUPPORT OF PBTITION FOR LBAVB TO PROCBBD IN FORMA PAUPBRIS 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: Barbara Wilkerson Address: 2200 B Cedar Run Drive Camp Hill. PA 17011 Social Security Number: 050-40-0344 (b) If you are presently employed, state Bmployer: None Address: NIA Salary or wages per month: NIA Type of work: If you are presently unemployed, state Date of last employment: Julv 1995 Salary or wages per month: 11258.60 Type of work: Nursinq Assistant (c) Other income within the past twelve months Business or profession: None Other self-employment: None , , ,. * ' , ~, '..... Interest: None Dividends: None Pension and annuities: None Social Security benefits: None Support payments: None Disability payments: None Unemployment compensation and supplemental benefits: None Workman's compensation: None Public Assistance: '316.00/mo. since 9/95 Other: None (d) Other contributions to household support (Wife (Husband) Name: None If your (husband) (wife) is employed, state Bmployer: None Salary or wages per month: NIA Type of work: NIA Contributions from children: NIA (e) Property owned Cash: None Checking Account: None Savings Account: None Certificates of Deposit: None Real Bstate (including home): None Motor vehicle: Make None Year Cost Amount owed Stocks; bonds: None Other: None ,'4 ' . . .-'.: . (f) Debts and obligations Mortgage: None Rent: 129.00/mo. Loans: None MonthlY Bxpenses: Blectric-160.00. Gas-160.00. Teleohone-140.00. Groceries-160.00. cable-121.00. Laundrv-140.00. Gasoline/or cabs-115.00. (g) Persons dependent upon you for support (Wife) (Husband) Name: None Children, if any: Name: SeDhon Lawrence Age: 5 vrs. 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 the 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: ID /cJy,ft~ !Y~f' C. :' (';'ft' f/.\\O'X,D :!, \:. '~'. <~ t~ ;ff\{'if j 1;,',;-" ,~ ,'.- ,.. ~, ,..,. " c,~ ;:: ftt' ~? ." ':i H " f" ''!J'' .~ . ~l D:J '" ;;U9':~ c;;; ~{ ~I,': ;~l v ,~ "" ",>- ..~.... ~ ;~~~ a.;; l&1r::').:;t~ .... 2"'''''3: IA}r;Cp ;N;'f::t:~~~).'>' "-. ot-z.... '... eQ..... . 'l r' ,- '- " "" a:: VI, i ,\ Ie . " , I. <<' ~. iJ 1"... Ii:.:" , . ~ ::!.u""z: t..,.:z:'fIUI ..zG. , 2a..= 0 aU ~~ r J )~ W';} , .. "'-" ;:,i. 7;)'.rnr. :OJ<., : ;~ ~':, '( '. }/;: ;:.1:. f.r':.~':n,(:t\ll -I',:r ,.. ~ -;;'::;'] ~ .t -n;:;!.G ,'J C( 1St Ti.tnJP~"(;prf{1~.{,i:r<:U.::: '3. -:h ~ ;,'. . ,; '"ii!.'~j Vilf: ~, ,,',:'~" ref;; ',';..-' :;'1. U, ti: 'i ~l :; t:~ (~)) ';-/f :J:t '! t:bhb K~' '.j );J~\~~~ ..~ -":-' i..,' LklE ": ;fh l- t:,,'J '~iL\~!:~~ j~{,5H"?-' t<~y (;:-; 1:)(";;:1'1'.- I' ~ .. :'1"'. -",'>f , . .. ,...... I ... .... .. . BARBARA WILKERSON, . IN THE COURT OF COMMON PLEAS OF . plaintiff I I CUMBERLAND COUNTY, PENNSYLVANIA v. . . . NO. 95-&315' CIVIL TERM . REGINA RITTER, . . Defendant . CUSTODY . CUSTODY ORDER AND NOW, this 1'1:tJ... day of -J:::l. tn>f'-. ~..~) , 1995, upon consideration of the parties' Consent Agre81llent, the following Order is entered with regard to custody of the minor child. 1. The plaintiff, BARBARA WILKERSON, hereinafter referred to as the grandmother, shall have primary physical and legal custody of the child. 2. The defendant, REGINA RITTER, hereinafter referred to as the mother, shall have partial custody of the child at times mutually agreed upon by the parties. 3. The grandmother and mother shall notify each other of all medical care the child receives while in that party's care. Each party shall notify the other immediately of medical 81lIergencies which arise while the child is in that party's care. By the Court, I~' ~.u.. ~. ..JI,"'7' J. Trur: ('''',,'' r!)N~ I1.!:CORD I:. i ;;.,' hand ;!:'l:: ."'_,f'i" I"; l'l.tz... ,'. '11OV-',.: 1'J9,s:: ....,....~a. ~~~........ ,I::),ftta.. r,,~,;i', );1olury ~ ." BARBARA WILKERSON, : IN THB COURT OP COMMON PLEAS OP Plaintiff . . . CUMBERLAND COUNTY, PBNNSYLVANIA . v. : : NO. 95 CIVIL TERM REGINA RITTER, . . Defendant : CUSTODY . . COMPLAYNT FOR CUSTODY 1. The plaintiff is BARBARA WILKERSON, residing at 2200B Cedar Run Drive, camphill, cumberland county, Pennsylvania 17011. 2. The defendant is REGINA RITTER, residing at 202 York street, Apartment 14f, Brooklyn, New York 11201. 3. The plaintiff seeks custody of the following child: BAD Presen~ Residence &Ul 2200B Cedar Run Drive camp Hill, PA The child was born out of wedlock. 5 years old Sephon Lawrence The child is presently in the custody of BARBARA WILKERSON, who resides at 2200E Cedar Run Drive, Camp Hill, cumberland county, Pennsylvania. During the child's lifetime, he has resided with the following persons and at the following addresses: BAD Address IlAU. Barbara Wilkerson Regina Ritter, and B. Murphy (half-sister) 2200E Cedar Run Drive 8/95 - present birth - 8/95 202 York street Apartment 14f Brooklyn, NY The mother of the child is REGINA RITTER, currently residing at 202 York street, Apartment 14f, Brooklyn, New York. She is single. The father of the child is CHARLES LAWRENCE. I . .. 4. The relationship of plaintiff to the child i. that of grandmother. The plaintiff currently is residing at 2200E Cedar Run Drive, Camp Hill, CUmberland County, Pennsylvania. 5. The relationship of defendant to the child is that of mother. The defendant currently resides with the following persons: ~ RelBtianshin E. MUrphy Daughter 6. 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. 7. The plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 8. The 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. The child's father has never sought visitation rights and his whereabouts is unknown to the parties. (See paragraph 11). 9. The parties agree that the best interest and permanent welfare of the child will be served if the relief requested is granted. 10. The mother, and the grandmother, who has physical custody of the child, have been named as parties to this action. 11. The father has not seen the child since birth and is currently unable' to be located; he is listed in the Absconded Search Unit of the New York Parole system. '~;''''.'''..''.~..':<'.;;..:-.''!. . . , ". WHERBFORE, the plaintiff requests this Court to grant primary physical custody of the child to the plaintiff with partial custody in the defendant at times that may be mutually agreed upon by the parties. The plaintiff requests any other relief which is just and proper. Respectfully submitted, J Carey Attorney for Plaintiff LEGAL SERVICES, INC. a Irvine Row Carlisle, PA 17013 (717) 243-9400 - '. ,,,,-^~'~~i':-}\~:'" r', "'~":'<_'~~1;"t~W,r:,.;:.\'>-__,; ....o--~-,. ,';'. ':''''It , . ~ . The above-named Plaintiff, BARBARA WILKERSON, verifies that the statements made in the above Complaint are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. 54904, relating to unsworn falsification to authorities. Date: LO/;J'fjr.C / . ~ ~hzuL tt~C4- Barbara Wilkerson, Plaintiff <,,~^-'" -",';..', ."', .. '( -. BARBARA WILKERSON, I IN THE COURT OF COMMON PLEAS OF plaintiff . . CUMBERLAND COUNTY, PENNSYLVANIA v. . . I NO. 95 CIVIL TERM REGINA RITTER, . . Defendant . CUSTODY . Thb Agre8lllent CONSENT AGREEMENT is entered on this ~ day of )JQU.evnbev . 1995, by the plaintiff, BARBARA WILKERSON, hereinafter referred to as the grandmother, and the defendant, REGINA RITTER, hereinafter referred to as the mother. The grandmother is represented by Joan Carey, of Legal Services, Inc.; the mother is unrepresented but is aware of her right to have an attorney. The parties agree to the entry of the following custody Order regarding the minor child sephon Lawrence. 1. The grandmother will have primary physical and legal custody of the child. 2. The mother will have partial custody of the child at times mutually agreed upon by the parties. 3. The grandmother and mother will notify each other of all medical care the child receives while in that party's care. Each party shall notify the other immediately of medical emergencies which arise while the child is in that party's care. ~ , Ic(L . befendarlt WHEREFORE, the parties request that an Order of Court be entered to reflect the above term.. @/i/}fhldl:A ~ Barbara Wilkerson, Plaintiff IJ )4t1,~~~,~. , Regina! itter, ~-'1tJ (fltL(,,/ f.! an- carey ~ Attorney for Pl intiff LEGAL SERVICES, INC. a Irvine Row Carlisle, pa 17013 (717) 243-9400 , ' .. BARBARA WILKERSON, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KO. 95.t>Jl5'" CIVIL TERM CUSTODY v. REGINA RITTER, Defendant CUSTODY ORDER AND NOW, this . 17.t1o. day of ~ .n",~l...~./ , 1995, upon consideration of the parties' Consent Agreement, the following Order is entered with regard to custody of the minor child. 1. The plaintiff, BARBARA WILKERSON, hereinafter referred to as the grandmother, shall have primary physical and legal custody of the child. 2. The defendant, REGINA RITTER, hereinafter referred to as the mother, shall have partial custody of the child at times mutually agreed upon by the parties. 3. The grandmother and mother shall notify each other of all medical care the child receives while in that party's care. Each party shall notify the other immediately of medical emergencies which arise while the child is in that party's care. By the court, '51 J...J-a.ue..R- ~. .Jk~1.a cr. TRUj" (""r>Y rr("vI. PECORD I: l [,j}' hand .' Pa, , ',i"~s 17..tJ.., , : ~lV' '. 1?9~- .......,........,--J/~J..1-..(i. . f~~1..',uo....... .oM I"J')l:.Oi\v'~ry ,. I. . D.:; . '. ,. ~. ,,' BARBARA WILKERSON, I IN THE COURT OF COMMON PLEAS OF plaintiff I I CUMBERLAND COUNTY, PENNSYLVANIA v. I . NO. 95 CIVIL TERM . REGINA RITTER, I Defendant I CUSTODY . . COMPLAINT FOR CUSTODY 1. The plaintiff is BARBARA WILKERSON, residinq at 2200E Cedar Run Drive, Camphill, cumberland county, Pennsylvania 17011. 2. The defendant is REGINA RITTER, residinq at 202 York street, Apartment 14f, Brooklyn, New York 11201. 3. The plaintiff seeks custody of the followinq child: BID Present Residence Asm 2200E Cedar Run Drive camp Hill, PA The child was born out of wedlock. 5 years old Sephon Lawrence The child is presently in the custody of BARBARA WILKERSON, who resides at 2200E Cedar Run Drive, Camp Hill, cumberland County, Pennsylvania. During the child's lifetime, he has resided with the following persons and at the following addresses: BID Address ~ Barbara Wilkerson 2200E Cedar Run Drive 8/95 - present birth - 8/95 Regina Ritter, and E. Murphy (half-sister) 202 York street Apartment 14f Brooklyn, NY The mother of the child is REGINA RITTER, currently residing at 202 York street, Apartment 14f, Brooklyn, New York. She is single. The father of the child is CHARLES LAWRENCE. I . " . ~ '. 4. The relationship of plaintiff to the child is that of grandmother. The plaintiff currently is residing at 2200E Cedar Run Drive, camp Hill, cumberland County, Pennsylvania. 5. The relationship of defendant to the child is that of mother. The defendant currently resides with the following persons: ~ Relationshin E. Murphy Daughter 6. 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. 7. The plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 8. The 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. The child'S father has never sought visitation rights and his whereabouts is unknown to the parties. (See paragraph 11). 9. The parties agree that the best interest and permanent welfare of the child will be served if the relief requested is granted. 10. The mother, and the grandmother, who has physical custody of the child, have been named as parties to this action. 11. The father has not seen the child since birth and is currently unable' to be located; he is listed in the Absconded Search Unit of the New York Parole system. ,-" ."".:.,,~~,...4i~~'~'.___t, ~"...;;..,~...;.~:;.. ,.,~~",,~~~~,,'~l."" ~.__ 'VL t,.~ ft... J.. L Wl~~~.;J",........,:~..,;~..,~ . '. ~ ~ WHEREFORE, the plaintiff requests this Court to grant primary physical custody of the child to the plaintiff with partial custody in the defendant at times that may be mutually agreed upon by the parties. The plaintiff requests any other relief which i. just and proper. Respectfully submitted, J Carey Attorney for Plaintiff LEGAL SERVICES, INC. a Irvine Row Carli.le, PA 17013 (717) 243-9400 _.~,.m~~fi:'I1.~t~'~~"""'i'.. ~ .."r+....y.,.,;"...,;..,., -'J:$'t,~ ~"':-.'."'.-:;" .. ~ ., . , The above-named plaintiff, BARBARA WILKERSON, verifies that the statements made in the above complaint are true and correct. plaintiff understand. that false statements herein are made subject to the penalties falsification to of 18 Pa. C.S. 54904, relating to authoritie.. unsworn Date: i 0 /:J. 'fj c;.C / ~. L /.iCk "vCLtul. vL- -- Barbara Wilkerson, Plaintiff ..~ . BARBARA WILKERSON, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. REGINA RITTER, NO. 95 CUSTODY CIVIL TERM Defendant This CONSENT AGREEMENT Agreement is entered on this t9,M day of AJovembev . 1995, by the plaintiff, BARBARA WILKERSON, hereinafter referred to as the grandmother, and the defendant, REGINA RITTER, hereinafter referred to as the mother. The grandmother is represented by Joan Carey, of Legal Services, Inc.; the mother is unrepresented but is aware of her right to have an attorney. The parties aqree to the entry of the following custody Order regarding the minor child Sephon Lawrence. 1. The grandmother will have primary physical and legal custody of the child. 2. The mother will have partial custody of the child at times mutually agreed upon by the parties. 3. The grandmother and mother will notify each other of all medical care the child receives while in that party's care. Each party shall notify the other immediately of medical emerqencies which arise while the child is in that party's care. . ~L. befendant WHEREFORE, the parties request that an Order of Court be entered to reflect the above terms. cP~/ffb)A//1: -/ Barbara Wilkerson, Plaintiff /! 1Iv'/"t:;o,tt Rigina/ itter, ~I (flu~/ (.1 ait- Carey ~ Attorney for Pl intiff LEGAL SERVICES, INC. a Irvine Row Carlisle, pa 17013 (717) 243-9400 ,. '. . ."\ ... HOV 0 6 1995 V- BARBARA WILKERSON, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95 '~3/{ CIVIL TERM v. REGINA RI'l"l'ER, Defendant . . . CUSTODY ~CVkJ SU~~ residing at 2200E COMPLAINT FOR CUSTODY 1. The plaintiff is BARBARA WILKERSON, Cedar Run Drive, Camphill, cumberland County, Pennsylvania 17011. 2. The defendant is REGINA RI'l"l'ER, residing at 202 York street, Apartment 14f, Brooklyn, New York 11201. 3. The plaintiff seeks custody of the following child: liAJIUl Present Residence AsUl 2200E Cedar Run Drive Camp Hill, PA The child was born out of wedlock. 5 years old Sephon Lawrence The child is presently in the custody of BARBARA WILKERSON, who resides at 2200E Cedar Run Drive, Camp Hill, cumberland County, Pennsylvania. During the child's lifetime, he has resided with the following persons and at the following addresses: liAJIUl Address 2200E Cedar Run Drive I2Wl Barbara Wilkerson 8/95 - present birth - 8/95 Regina Ritter, and E. Murphy (half-sister) 202 York Street Apartment 14f Brooklyn, NY The mother of the child is REGINA RI'l"l'ER, currently residing at 202 York street, Apartment 14f, Brooklyn, New York. She is single. The father of the child is CHARLES LAWRENCE. .",..', .';<'h':."''':'o'..'''''<"''::S\.' ."..' t . . .. ~ 4. The relationship of plaintiff to the child is that of grandmother. The plaintiff currently is residing at 2200E Cedar Run Drive, Camp Hill, cumberland County, Pennsylvania. 5. The relationship of defendant to the child is that of mother. The defendant currently resides with the following persons: liAma E. Murphy Rela~ionshib Daughter 6. 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. 7. The plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 8. The 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. The child's father has never sought visitation rights and his whereabouts is unknown to the parties. (See paragraph 11). 9. The parties agree that the best interest and permanent welfare of the child will be served if the relief requested is granted. 10. The mother, and the grandmother, who has physical custody of the child, have been named as parties to this action. 11. The father has not seen the child since birth and is currently unable' to be located; he is listed in the Absconded Search Unit of the New York Parole system. ~".*.._._'F":,"""-'-'~''''!f'''''",,''''''~'''';~' ,. .- 'f;~j.:."~'-;~, . ~ WHEREFORE, the plaintiff requests this Court to grant primary physical custody of the child to the plaintiff with partial custody in the defendant at times that may be mutually agreed upon by the parties. The plaintiff requRsts any other relief which is just and proper. Respectfully submitted, J i:arey Attorney for Plaintiff LEGAL SERVICES, INC. a Irvine Row Carlisle, PA 17013 (717) 243-9400 ~ .. , . ~ . .. The above-named plaintiff, BARBARA WILKERSON, verifies that the statements made in the above complaint are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. c.S. 54904, relating to unsworn falsification to authorities. D'''' 10 /{)'7/c;.C , / eih~ ti~~-- Barbara Wilkerson, plaintiff