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Home My WebLink About96-01290 f I I I , I I ~ 1 J i i ,) I J I I ~) ~ . .~. ~>~.. ,~. -,~ .. H''"~--t J ~_.._+-__ .u,. ,. I. j. .) ) : i: I ~ /. >~ ~'~- .,-~;! ~ - j : Thomas E, Cheffins. Esq, COURT ADMINISTRATOR ONE COURTHOUSE SQUARE CARLISLE, PA 17013 '..- .~ .....,;.;... i>" V" i...\ , , I! .\.,! U i,-; ~cj ....,.. ":0 ~,~i-) "(: 'IL.I L~ , l~: I '.-1 \; ," .'; l I. - V""lj ~ I \ i,l\ \ 1,' ' ~t~ -, ):' ""!I.\'f' \ 1\'-' '\ , \ ' Ms. Cheryl Harner 'J .-....R '~~ =:~~.,~ ...... Middletown, PA 17057 :-. ~ '" UI --', 5:i -< ~ ... ' ' '!' , .. . I ' , 'I< 'I , I 1" I I ',.. (.=ry~;tdl. c..Jmp, tC)[ ~j,-~vL'Ljl month~;. ~';hj_~ dppdr{~ntly resld(:~d with Cr'/'itd Cc,mp UI\I,:[ :,t!l' li,rsl wl,ek of ,h:fll', Crystal Camp has been the consi"c"nt day Cdre provider for ltw chi ld. G, The Defendant's position on cU5tody is as follows: The Defendant'" position is unknown, 7, Need for separate counsel to represent child: Neither party requested, 8, Need for independent psychological evaluation or counseling: None requested and the Con~iliator does not believe any is necessary. 9. Other matters or comments: rather wishes to have the custody rights with him given the Mother's current condition. The rather related at the conciliation that he talked with the Mother as late as July 20th and that the Mother agreed that the custody should be transferred with him, but the Mother failed to appear with Father at rather's attorney in order to sign a stipulation. rather relates that the Mother was aware of the conciliation, She did not appear. rather's attorney. Robert Lieberman. Esquire, has made repeated atte",pts to try to serve the Mother with the Petition. He has sent tr.e documents to her las t known address. His client had discussed the time and date of the cunciliation with her. - I I ~. t' ; _.' ( , f' I, (~ - ... l L... , I " l.__ '::l'~ . rJ1'~ :5:'1 :.<l;.; Il,;n ;z: 2:Z Or.<l ~'" ... 0-3: ug::.s ...z 0::>1 o ~rJZ ~ '::l ::>0--< ;.; OZ... 0 Uj~ ~ Cila:: Ul J:c..l-'l ::> F.-<<:Q..... U Z> . Z?.....OZ . . a:: c..l "" o o U 0. >< a:: Z U.l ,-' ~() lo<) ~V; ~ r", '" H "" Z ..... j '" . a:: Cil z a:: ,A ::2 , > ...1 ...1 ;.; a:: Cil ;c ~ ,~ "- E "";. ..::j"" :j;Q ~~ o Vl l.i) ~ .~ "" Z .0- ci Z c..l ;.. U.l o \J'.. ....... ,'I ...! V ~~ ~ ':ll~ J~ a:: o ... f-< Z H < .-1 ~I 81 <, r.rJ' ::J' U ~ I I. ~ ~ J d : !:l .. ~ i:> I ....l<ti~ln ~~i ~ 5 ffi Sf ~ f a ! I ...1 -< ..... E-i a:: -< '" . . " lInt P. COOPIR, III THE COURT or COIOCOII PUAB or Plaintiff CUMBERLAND COUIITY, PEIIIIITLVAKIA v. CIVIL ACTION - LAN 110. 9& - 1,).',0 C,ulLk""'1 CIIRn. L. IIJUUIIR, Defendant III CUITODY ORDER 0.. COURT AND NON, this _I ;)1-. day of (Y).,I, J, , 1996, upon consideration of the attached Complaint, it is hereby directed t at the parties and their respective counsel appear before ~_ cl \ ~. , the conciliator, at _~(\:::l ~.. I:u....u.....;.;, . rn pe~,.Y1Va a, on the ;;- "<IaI of ( I , 1996, at . v'O .m., for a Pre-Hear ng Custody Conference. At such aon erence, an effort will be made to resolve the issues in diepute; 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. FOR THE COURT, By: mJ_dl/J.lL 8a-r" f).,1f' ~~ Custody Conciliat ' YOU IIOULD TAD: TIIS PAPER TO YOUR LAWYER AT OIlCE. IF YOU DO .en BAVI A LAWYER OR CAllHOT AFFORD ONE, GO TO OR TELEPHOIIE 'lIB OrrIC. lIT rORTH BELON TO rIND OUT NBERI YOU CAB OET LEGAL HBLP. Office of The Court Administrator Cumberland County Courthouse 4th Floor 1 Courthouse Square Carlisle, PA 17013-3387 (717) 240-6200 ." .' Vl:RIPlCATION I verify that the statements made in ths foregoing Complaint for Cuatody are true and correct based upon my personal knowledge, information and belief. I understand that false atatementa herein are made subject to the penalties of 18 Pa.C.S. 54904, relating to unsworn falsification to authorities. DATED I 3 . ). 7(" ~'M;j I?~ E RY P. OOPER Plaint! -- '" , , I, l .___h_ "__." g~ t1 ~ i ! j~~ ... <J ... Cl .... " ."" j ~ ~ .. 5 <J ~ it J ~ i Cl Ul :i i'" ."" CIl a:l ... ~ ~ I ~!5 III .... ~ ~ <t ~ I .~ !! ...J ~i'~ g &!llo E-t ~ ~Ia~! ~ .... f-< ~ ~~ ~ ~ i: . d 3 Ul < if' . .... a:l . . ~ ~ 0 llo ::- ~ ~ ~ :~ ~ i ~ 'CIl 21 i8 .... , .. i ";, ROBERT [, 1 'Uli,i(\I:\,'; ^rTLHt:-;I;:Y :\r L.\',o. IlDIllY P. coo..a, I III 'lB. COUll., or COIINOR PUAS or Pla1JatUf , CUMB.RLlUID COUll':Y, P...SILVUIA , Y. I CIVIL ACTIOII - LAN I NO. 96-1290 CIVIL T.RM coan L. BAJUI.Jl, I Defead.at I 111 CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH or PENNSYLVANIA' : ss. COUNTY OF DAUPHIN I Personally appeared before me, a Notary Public, in and for said Commonwealth and County, ROBERT B. LIEBERMAN, ESQUIRE, who, being duly sworn according to law, deposes and saysl 1. That on March 11, 1996, a Complaint For Partial Custody was filed on behalf of the Plaintiff and against Defendant in the above case. 2. That on March 20, 1996, I forwarded, by certified mail, return rsceipt requested, restricted delivery, a certified copy of the Complaint For Partial Custody, to the Defendant, CHERYL HARNER, 1351 Old willow Mill Road, Mechanicsburg, Cumberland County, Pennsylvania, as evidenced by the sender's receipt attached hereto. " 3. That the aforesaid certified copy of the Complaint For Partial Custody, sent to the Defendant, CHERYL HARNER, was r I HENRY P. COOPER. Plaintiff ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 96-1290 CIVIL TERM CHERYL L. HARNER. Defendant IN CUSTODY JUDGE PREVIOUSLY ASSIGNED: None (No Judicial Conflicts) CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(bl. the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child(renl who is(are) the subject of this litigation is as follows: NAME BIRTHDATE CURRENTLY IN CUSTODY OF Teanna Lynn Cooper 11 November 1994 Defendant 2. A Conciliation Conference was held on 2 May 1996. and the following individuals were present: the Plaintiff and his attorney, Robert B. Lieberman. Esquire; the Defendant appeared with her attorney. Joan Carey, Esquire. 3. Items resolved by agreement: See attached Order. 4. Issues yet to be resolved: See attached Order. 1 -. Crystal Comp, for several months. She apparently resided with Crystal Comp until the first week of June. Crystal Comp has been the consistent day care provider for the child. 6. The Defendant's position on custody is as follows: The Defendant's position is unknown. 7. Need for separate counsel to represent child: Neither party requested. 8. Need for independent pSYChological evaluation or counseling: None requested and the Conciliator does not believe any is necessary. 9. Other matters or comments: Father wishes to have the custody rights with him given the Mother's current condition. The Father related at the conciliation that he talked with the Mother as late as July 20th and that the Mother agreed that the custody should be transferred with him, but the Mother failed to appear with Father at Father's attorney in order to sign a stipulation. Father relates that the Mother was aware of the conciliation. She did not appear. Father's attorney, Robert Lieberman, Esquire, has made repeated attempts to try to serve the Mother with the Petition. He has sent the documents to her last known address. His client had discussed the time and date of the conciliation with her.