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Home My WebLink About96-05268 ~ <:) '" ~i ~ ~ o 11 ~ ~ ~ :- 6., ~ q I , "'" ~ , i I CI'I '> I I ! (f) Debts and obligations Mortgage: _. .MQll~ . .' .'. ._~..__._."___. ..___ ,.____ n_ "_'~_'_ _,____ _. Rent :-.t;UlQLl1ltl),. ____________._.....__.._.. Loans: _ St1,1dE!n.t. Loans L $3090 Monthly Expenses: Electr ic$;! 5, ..Ph_one_$4 5 ,_Cl)i td S.1!PPQrt_$.2.~~, Insurance. $11. 30, _Cl.Qtl:!iJlgHL--Gr~erie~ $159 ._..._.._._---_.~._--------_..__._- (g) Persons dependent upon you for support (Wife) (Husband) Name: ......1!L!L.____ Children, if any: Name: _Jus t Y1L.I1XY!;.Ql\ Age: ~ vrs. __"~!ll e y.JITY s oJ) 11 vrs. J_orm.. [hJ!.dlg 8 mths. 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: 9-()<:.9C . fi/ 7 ~j;~/{. 4~y~ Burton K. Bryson, Plaintiff . .. , .:1 r. , 1.~ I ! (;. C:' I!, y, ) r.....' t7j' ~ [1.' ( :.....:i I C I <.:.. '.. v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 96-9trVIL TERM CONSTANCE M. BRYSON, Defendant CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before M. ( k-.~_I at..3Q? S' lr \10-. S\. (,.<lY\f O...t.U2M.L--' 1996, at (5'''17'- ff, \ \ t~~ ,the conciliator, on the ~ day of ~~_ ,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, &WJ-tj#' ( s,t. f~.v ) 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 ADMINISTRATOR, 4th FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717) 240-6200 For.-J;fJe c~urt, . ~ f/' 1.dUt:fY -4 Custody Conciliator AMERICANS WITH DISABILITlES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Acto 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, BURTON K. BRYSON, Plaint if f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96- S::lt-J> CIVIL TERM v, CUSTODY CONSTANCE M, BRYSON, Defendant COI1P LA I N.'I'.J:91LJ:.\1S TQ!;1,{ 1, The plaintiff is BURTON K, BRYSON, residing at 119A Ridge Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is CONSTANCE M, BRYSON, residing at 38 Stephens Road, Apt. 4E, Camp Hill, Cumberland County, Pennsylvania 17011. 3, Plaintiff seeks custody of the following child: Name Present Residence Aqe Justyn Alan Bryson 38 Stephens Road, Apt, 4E Camp Hill, PA 17011 5 yrs, The child was not born out of wedlock. The child is presently in the custody of Constance M, Bryson, who resides at 38 Stephens Road, Apt. 4E, Camp Hill, Pennsylvania, During the past five years, the child has resided with the following persons and at the following addresses: Name Address pate plaintiff & Camp Hill, PA 1991 -- approx, 2/92 defendant plaintiff & Lemoyne, PA approx. 3/92 - 7/92 defendant defendant Carlisle, PA approx, 7/92 -- 1/93 plaintiff & Mechanicsburg, PA approx. 2/93 - 8/93 defendant defendant 38 Stephens Road approx. 8/93 - present The mother of the child is Constance M. Bryson, currently residing at 38 Stephens Road, Apt, 4E, Camp Hill, Pennsylvania. The father of the child is Burton K, Bryson, currently but are now divorced, residing at 119A West Ridge Street, Carlisle, Pennsylvania, The plaintiff and defendant were once married to each other 4, The relationship of plaintiff to the child is that of father, The plaintiff currently resides with the following persons: Name Relationship Jeannine Miller Mildred Glass Mother Maternal Grandmother 5. The relationship of defendant to the child is that of mother. The defendant currently resides with the following person: Name Relationship Justyn Alan Bryson 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, Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth, 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, 7. The best interest and permanent welfare of the child , will be served by granting the relief requested for reasons including, but not limited to, the following: a, The father is a fit parent who is capable of exercising partial physical and shared legal custody. b. The father has a relationship with the child and this relationship should continue, c, The child has a relationship with his half-sister, Ashley Bryson, and this relationship should continue. d. The mother has not acted in the best interests of the child by denying the father any contact with the child, despite repeated efforts by the father to see the child and lengthy negotiations between Legal Services, Inc., and the mother's attorney, 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, the plaintiff requests this Court to grant him shared legal custody and partial physical custody of the child, ,. ,... r.. l1.1' ~:::: ", I c;; : l~.' c~: u.. .' c .. v , BURTON K, BRYSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96,52t.a CIVIL TERM vs, CONSTANCE M, BRYSON, Defendant CUSTODY AND NOW, this I.A, ORDER ~~ , , 1996, upon receipt day of of the Conciliator's Report, it appearing that the parties have agreed to the terms end provisions of this Order which was dictated in their presence and approved by tham and their counsel, it is hereby ordered and directed as follows: 1, The parties shall share legal custody of the minor child, Justyn Alen Bryson, d.o,b, May 31, 1991. 2, Mother shall have primary physical custody of the minor child subject to the following schedule with Father: A, For a period of two weeks on Monday night from 6:00 p,m, until 7:00 p.m., commencing on Monday, November 4, 1996, This visitation shall occur at the Mother's residence. B, For the following two weeks, for a period of three hours, on Saturday, from 1 :00 p,m. until 4:00 p.m, This visitation shall occur at the Mother's residence. C, For the following four weeks on Saturday from 1 :00 p.m, until 4:00 p,m" at which time the Father is entitled to take the child from the Mother's residence, D. For the following four weeks on Saturday from 10:00 a.m. until 6:00 p,m., at which time Father is entitled to take the child from the Mother's residence, 3, Upon the conclusion of the phase-in schedule as described in Paragraph 2, Subparagraphs A through D above, the Father will begin overnight visitation on an alternating weekend basis from Saturday at 9:00 a,m, until Sunday at 9:00 a,m. This alternating schedule will occur for a period of one month at which time it will be expanded to include from Friday at 5:00 p.m. until Sunday at 5:00 p.m., which expanded schedule will continue thereafter, 4, Upon commencement of the alternating weekend visitation, the Father shall also be entitled to visitation on the Wednesday evenings preceeding his weekend visitation from 5:00 p.m. until 7:00 p,m, 5, The parties shall alternate the holiday schedule, those holidays being defined as Easter, Memorial Day, Fourth of July, Labor Day, and Thanksgiving. This alternating holiday schedule will commence with the Easter holiday in 1997, Father will have that holiday and the schedule will alternate thereafter, This period of visitation will occur from 9:00 a,m. until 7:00 p,m. 6, The parties will evenly share the Christmas holiday as agreed upon by the parties, 7, Both parties will be entitled to a minimum of one uninterrupted week of summer vacation to spend with the child. The parties shall provide each other with thirty (30) days notice as to when they intend to exercise this period of visitation. 8, Such other times as the parties may agree, / BY THE COURT. J. Joan Carey, Esquire Arthur K, Oils, Esquire .~ ~ 11- r. -q6 .ta.w- mlb