HomeMy WebLinkAbout02-4752DOUGLAS GL=YER,
Plaintiff
ANGELA GREEN,
Defendant
IN THE COURT OF COMMON PLE'AS
CUMBERLAND COUNTY, PENNSYL\fANIA
CIVIL ACTION - LAW
CHILD CUSTODY
COMPLAINT FOR CHILD CUSTODY
AND NOW, comes Plaintiff, Douglas Geyer, and by and through his attorney, Judith F. -~ol.qos,
Esquire, request that this Honorable Court grant him primary custody of the minor child, Nathan
and in suppor[ of his requests avers:
1. The plaintiff is Douglas Geyer, an adult individual, residing at 3810 Spring Road, Shr= rmansc~ale
Cumberland County, Pennsylvania 17090.
2. The defendant is Angela Green, an adult individual, residing at 332 Fourth Street, West Fair',fie~,
Cumberland County, Pennsylvania 17025.
3. Plaintiff seeks custody for the following child:
Nath~,n H. Geyer Age: 5 Date of Birth: May 2, 1997
4. The child was born out of wedlock.
5. The is presently in the custody of Angela Green, who resides at 332 Fourth Street, Wes: F:a*,'viE
Cumberland County, Pennsylvania.
6. During the past five years, the child has resided with the following persons at the following
addresses: Birth to 1999 Newville, PA with plaintiff & del'end;ant
1999 to Nov. 2000 Carlisle, PA with plaintiff & delend]nt
Nov. 2000 to Dec. 2001 Carlisle, PA with plaintiff
Dec. 2001 to present West Fairview, PA with defendant
7. The mother of the child is Angela Green, currently residing at 332 Fourth Streel, West Fai'v~ ~.
Cumberland County, Pennsylvania, she is divorced.
8. The father of the child is Douglas Geyer, currently residing at 3810 Spring :~oad, Sherm~r~s~ ah.
Cumberland County, Pennsylvania, he is single.
9. The relationship of the plaintiff to the child is that of father, plaintiff resides alone.
10. The relalionship of the defendant to the child is that of mother, defendant curre~tly r.~,side,~; v.itl*
the following persons:
Zack Rowe, age 14, son of defendant;
Linds,~y Rowe, age 10, daughter of defendant;
Cody Riegle, age 8, son of defendant
Nath~n H. Geyer, age 5, son of defendant and plaintiff.
11. Plaintiff has not participated as a party or witness, or in another capacity, ir~ ·
other I~tJ!..' ation
concerning c~.stody of the child in this or another court.
12. Plaintiff has no information of a custody proceeding concerning the child pendir~g in a ccurt ~,f t[ is
Commonwealth or any other state.
13. Plaintiff does not know of a person not a party to the proceedings who has phy,,;ical ,: usto¢ly of ~ ~e
child or claim.,; tc have custody or visitation rights with respect to the child.
14. The best interest and permanent welfare of the child will be served by granting the r,--lief
requested because the child is living in an unsafe, unstable, neglectful and abusive env'ronment. Ti"e
child is often I~ff in the care of his siblings Overnight, without adult Supervision, and has lived with an,J
been left in th,~ care of a known drug addict.
15. Each parent whose parental rights to the child have not been terminated and the pe~-son ',¥h~:, h~ s
physical custcdy of the child have been named as parties to this action.
WHEREFORE, plaintiff requests the court to grant custody of the child to him.
Respectfully submitted,
PO Box 60809
Harrisburg, PA 17106-0809
717 541-9660
Attorney for Plaintiff
I, Douglas Geyer, certify that the statements made in the foregoing COMPLAII,, T FOR
CHILD CUSTODY, are true and correct to the best of my knowledge and belief. I understand
false statements herein are made subject to the penalties of 18 Pa. C.S.A. ~ 4904, relating tc
unsworn fals fication to authorities.
uglas Geyer ......
DOUGLAS GEYER
PLAINTIFF
ANGELA GREEN
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:
: 02-4752 CIVIL ACTION LAW
:
IN CUSTODY
:
ORDER OF COURT
AND NOW, Thursday, Oetober 03, 2002 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator,
at 301 Market Street, Lemoyne, PA 17043 on Tuesday, November 05, 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/
Melissa P. Greevy, Esa,keq/~
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 heating.
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
DOUGLAS GEYER,
ANGELA GREEN,
Plaintiff
Defendant
NOV 31. 8 Z00Z
IN THE CC)URT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-4752 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
l/
AND NOW, this 2. o~'ff_, day of November, 2002, upon consideration of the
attached Custody Conciliation Summary Report, it is hereby ordered and directed as
follows:
1. Legal Custody. The parties, Douglas Geyer and Angela Green, shall have
shared legal custody of the child, Nathan H. Geyer, born May 2, 1997. Each parent shall
have an equal right, to be exercised jointly with the other parent, to make all major non-
emergency decisions affecting the child's general well-being including, but not limited to, all
decisions regarding his health, education and religion. Pursuant to the terms of Pa.C.S.
§5309, each parent shall be entitled to all records and information pertaining to the child
including, but not limited to, medical, dental, religious or school records, the residence
address of the child and of the other parent. To the extent one parent has possession of
any such records or information, that parent shall be required to share the same, or copies
thereof, with the other parent within such reasonable time as to make the records and
information of reasonable use to the other parent. Both parents shall be entitled to full
participation in all educational and medical/treatment planning meetings and evaluations
with regard to the minor child. Each parent shall be entitled to full and complete information
from any physician, dentist, teacher or authority and copies of any reports given to them as
parents including, but not limited to: medical records, birth certificates, school or
educational records, attendance records or report cards. Additionally, each parent shall be
entitled to receive copies of any notices which come from school with regard to school
pictures, extracurricular activities, child's parties, musical presentations, back-to-school
night, and the like.
2. Physical Custody. Physical custody shall be arranged as follows:
A. Father shall have custody each weekend from Friday at 7:00
p.m. until Sunday at 7:00 p.m., to commence November 8, 2002.
NO. 02-4752 CIVIL TERM
B. Upon seven (7) days notice to Father, one (1) time per month
Father's custodial weekend shall begin no later than 7:00 p.m. on Saturday,
unless otherwise agreed.
C. At all times when Father does not have custody, Mother shall
have custody.
3. Transportation. The parties shall share transportation by meeting at their
usually designated spot near the intersection of Route 1114 and the Wertzville Road in
Cumberland County.
4. Holidays.
A. Each year Father shall have custody from Thanksgiving Day until
the Sunday following Thanksgiving at 4:00 p.m., unless otherwise agreed.
Father shall provide transportation at the beginning .of his custodial period for
this holiday.
B. Christmas shall be broken into two (2) segments, Segment A and
Segment B. Segment A shall be Christmas Eve from 9:00 a.m. until 9:00 p.m.
Segment B shall be Christmas Eve from 9:00 p.m. until December 25th at 2:00
p.m. In even-numbered years, Mother shall have ^ and Father shall
Segment
have Segment B. In odd-number years, Father shall have Segment A and
Mother shall have Segment B. For this holiday, the Christmas Eve custodial
exchange shall occur at the usual meeting place unless otherwise agreed.
5. In the event either party is unavailable to provide care for the child for four
hours or more during his or her period of custody, that pady shall first make a reasonable
effort to contact the other party to offer the parent the opportunity to provide care for the
child before contacting third-party caregivers.
6. The child shall wear the appropriate helmet type head protection for any
activity during which he may ride a bicycle or four wheeler.
7. Summer.
A. Father shall have custody of the child during four (4) weeks in
the month of August each year during which time Mother shall have custody
for those periods which are in Father's custodial schedule during the school
year or as more specifically described in Paragraph 2.A. and 2.B. above.
NO. 02-4752 CIVIL TERM
B. Each party shall be entitled to one uninterrupted eight (8) day
block of custodial time for the purposes of summer vacation. The parties
shall provide each other with no less than thirty (30) days written notice of
their vacation plans which shall include the address; of the intended vacation
destination and the telephone number where they can be reached while
away. In the event that the parties schedule of a overlapping vacations, the
parent first providing written notice shall have the choice of the vacation time.
Father's eight (8) day vacation block shall be taken during his custodial period
in the month of August each year, unless otherwise agreed.
8. Father shall make arrangements for child care for the child during the month of
August by July 1st of each year and discuss these arrangements with Mother so that Mother
shall have an opportunity to meet the child care provider. The custodial plan for August
each year contemplates Father being able to be offwork by 5:00 p.m. each day.
BY THE COURT:
Dist: ....Judith F. Dolgos, Esquire, P O Box 60809, Harrisbur . p
~Angela Green, 448 Third Street, West Fa~rvlew, PA ~g~0~'~ 17106-080.q
DOUGLAS GEYER,
Plaintiff
V.
ANGELA GREEN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-4752 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY' RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the clhild who is the subject of this
litigation is as follows:
NAME
Nathan H. Geyer
DATE OF BIRTH
CURRI--NTLY IN THE CUSTODY OF
May 2, 1997 Mother
2. A Custody Conciliation Conference was held on November 5, 2002 in
pursuant to Father's complaint filed on September 30, 2002. Present for the conference
were the Father, Douglas Geyer, and his counsel, Judith Frances Dolgos, Esquire; the
Mother, Angela Green attended pro se.
3. The parties worked diligently at their first Cu.~s.tc~v~Conciliation and reached an
agreement in the form of an Order as attached.
./
Date Melissa Peel Greevy, 'Esquire
Custody Conciliator
:164938