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10/95 to Present
-
158 East High Street
Carlisle, P A 17013
With Wham
Oat.
Plaintiff, DOMa L. Myers
e,) The mother of the child is Plaintiff, currently residing at 158 East High Street,
Carlisle, Cumberland County, PeMsylvania, 17013,
f.) Plaintiff is single,
g,) Tht" father of the child is David W, Myers, Defendant, who resides at 32 North
Hanover Street, Carlisle, Cumberland County, Pennsylvania, 17013,
h,) Defendant is single.
4. The relationship of Plaintiff to child is that of natural mother, The Plaintiff currently
resides with the following persons:
Name
Tara Christine Myers
Michael S. Myers
R"atioouhip
Natural Daughter
5. The relationship of the Defendant to the child is that of natural father, The Defendant
currently resides with the following persons:
Philip H. Monyer
Rclatioouhip
None
Name
6. a.) 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. The parties had,
however, previously entered into a custody agreement and stipulation that was entered as
an Order of Court pursuant to the parties' divorce. The Court, term and number and its
relationship to this action are: Cumberland County, 95-212, Civil Term.
b,} Plaintiff has no information ofa custody proceeding concerning the child pending
in a court of this Commonwealth,
c,} Plaintiff does not know of a person not a party to the proceeding who has physical
custody of the child or claims to have custody or visitation rights with respect to the child.
7. The best interests and permanent welfare of the child will be served best by granting the
relief requested because:
a), The PlaintitT provides the child with a home with adequate moral, emotional and
physical surroundings as required to meet the child's needs;
b), The Plaintiff continues to exercise parental duties and responsibilities and enjoys
the love and affection of the child;
r), The Plaintiff provides the child with a more stable and emotionally balanced home
and home life than does the Defendant;
d), The partics have been advised by Ms. Eileen Powell, Child's third grade teacher,
that Child is in dangcr of failing the third grade due to her reading skills, Plaintiff provides
Child with comprehensive, structurcd, and consistent tutelage of her reading skills;
e), The Defendant currently resides with Mr. Philip H. Monyer in a three room
apartment comprising a kitchen, bcdroom, and living room. Child has no separate
bedroom in Defendant's apartment; and
I), The Defendant currently resides with Mr. Philip H, Monyer, who was charged with
IOSI. Forcible Compulsion, Prostitution, and Conuption of Minors, in early 1995. On
August 8, 1995, Philip H. Moyner pled guilty to the Corruption of Minors at criminal
docket number 1995-00332,
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. There are no
other persons who are known to have or claim a right to custody or visitation of the child.
WHEREFORE, Plaintiff respectfully requests Your Honorable Court to grant Plaintiff
primary physical and legal custody ofthc child, TARA CHRISTINE MYERS.
Respectfully submitted,
athleen D. Keating, uire
Attorney I,D. # 66271
44 South Hanover Street
Carlisle, P A 17013
(717) 240-0145
Attorney for the Plaintiff
.
Dw
10/95 to Present
,\ddMO
Wilh Whom
158 East High Street
Carlisle, PA 17013
Plaintiff, DOMa L. Myers
e,) The mother of the child is Plaintiff, currently residing at 158 East High Street,
Carlisle, Cumberland County, Pennsylvania, 17013,
f.) Plaintiff is single,
g,) The father of the child is David W, Myers, Defendant, who resides at 32 North
Hanover Street, Carlisle, Cumberland County, Pennsylvania, 17013.
h,) Defendant is single,
4, The relationship of Plaintiff to child is that of natural mother, The Plaintiff currently
resides with the following persons:
Name
Rdlltiomhip
Tara Christine Myers
Michael S. Myers
Natul';\1 Daughter
5. The relationship of the Defendant to the child is that of natural father. The Defendant
currently resides with the following persons:
Name
Rcl4lioo.,hip
Philip H. Monyer
None
6, a.) 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 anotl:er court, The parties had,
however, previously entered into a custody agreement and stipulation that was entered as
an Order of Court pursuant to the parties' divorce, The Court, term and number and its
relationship to this action are: Cumberland County, 95-212, Civil Term.
b,) Plaintiff has no information ofa custody proceeding concerning the child pending
in a court of this Commonwealth,
c,) Plaintiff does not know of a person not a party to the proceeding who has physical
custody of the child or claims to have custody or visitation rights with respect to the child,
7, The best interests and permanent welfare of the child will be served best by granting the
relief requested because:
a), The Plaintiff provides the child with n home with adequate moral, emotional and
physical surroundings as requircd to meet the child's needs;
b), The Plaintiff continucs to cxercisc parental duties and rcsponsibilities and enjoys
the love and affcction ofthc child;
c), The PlaintilTprovides the child with a more stablc and cmotionally balanced home
and home life than does thc Defcndant;
d), The parties have been advised by Ms, Eileen Powell, Child's third grade teacher,
that Child is in dangcr of failing the third grade due to her reading skills, Plaintiff provides
Child with comprchensive, structured, and consistent tutelage of her reading skills;
e), The Defendant currcntly resides with Mr, Philip H, Monyer in a threc room
apartment comprising a kitchen, bedroom, and living room, Child has no separate
bedroom in Defendant's apartment; and
t), The Defllndant currently rcsides with Mr, Philip H. Monyer, who was charged with
IOSI - Forcible Compulsion, Prostitution, and Conuption of Minors, in early 1995. 0:1
August 8, 1995, Philip H, Moyncr pled guilty to the Corruption of Minors at criminal
dockct number 1995-00332,
8, Each parent whose parental rights to thc child have not been terminated and the person
who has physical custody of the child havc been named as parties to this action, Thcre are no
other persons who are known to havc or claim a right to custody or visitation of the child,
WHEREFORE, Plaintiffrcspectfully requests Your Honorable Court to grant Plaintiff
primary physical and legal custody of the child, TARA CHRISTINE MYERS,
Respectfully submitted,
athlccn D, Keating,
Attorney I.D, # 66271
44 South Hanovcr Street
Carlisle, PA 17013
(717) 240-0145
Attorney for the Plaintiff
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