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Home My WebLink About96-06839 " I, 'I,'. " '" " !>:';-'-' j'I~.0.!I'.~,~,~j _1'1':; L '__.'_.' -.'{.' q :(;'./'.,'1, '/;II';,);II!'-/,}I':l I" , \I., , , ': " , " , , I.! " " 'rl' "",',',' 'I ',I " ,," , " " " " ... '/ " , ' " , " , ,I ,I" , , , I' , L" , .," " ~ " " " " , , , " " " ,'to I, " , " i',1 " 1;/ , iI, " " 1\, " , ' " " , , " , " \. 0',' ,\1' , ',' " ; ~.. 'rl': , " , " H:'I, , , I' ~ J ,I It " , , ,).', , ',' " " ", ", DREW MILLER, Plaintitt IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. CUSTODY/VISITATION lCAREN BOYER, Detendant NO. (j & ~ ~3 'I (I ~L~ tj ORDER OF COURt AND NOW, l7s:.< ;)<.' l"iq~ , upon consideration ot the attached complaint, it IIIhereby directed that the partie. and their respective counsel appear betore P'l.<k", I ( gOdJ~ t % ' the conciliator, at ~,,~ S, 15/h51. c(.~,,; fld). (II on the Th day ot -.LJ brloN""1 , 19'11, at q .Uu I) .m., tor a Pre- Hearihg custddy conterence:--At such conterence, an ettort will be made to resolve the issues in dispute; or it this cannot be accomplished, to detine and narrow the issues to be heard by the court, and to enter into a temporary order. All children age tive or older may also be present at the conterence. Failure to appear at the conterence may provide grounds tor entry ot a temporary or permanent order. FOR THE COURT, By: '-?f/L:e~f:/J 4 t. Custody Cone nator The Court ot Common Pleas ot Cumberland County i. required b~ to comply with the Americans with Disabilities Act ot 1990. For information about accessible tacilities and reasonable accommodations available to disabled individuals having business betore the court, please contact our ottice. All arrangements must be made at least 72 hours prior to any hearing or business betore the court. You must attend the scheduled conterence or hearing. YOU SHOULD TAXE 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. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 ""11I81111'0II "0 NOATH SECOND STAIIT . PO lOX IOU . HARRISIURG, PA. 11101 11111 7~947' . ,"'" 1111133&-7111 DREW MILLER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. q" - t../'I1~.J ',.......... v.. KAREN BOYER, Detendant CIVIL ACTION - LAW IN CUSTODY COMPLAINT FOR PARTIAL CUSTODY 1. The plaintift is Drew Miller an adult individual re.iding at 1030 Memory Lane, Mechanicsburg, Cumb.r1and County, P.nn.ylvania 17055. 2. The defondant is Rar.n Boyer an adult individual r.siding at 20 Cass.tt Street, Apartm.nt B, Eno1a, Cumb.rland County, P.nnsylvania 17055. 3. Plaintitt s..ks partial custody ot the following child: HAu Present Addr.ss Dat. ot Birth Gray.on Jo..ph Mill.r 20 Ca...tt Str..t S.pt.mb.r 18, 1996 Apartm.nt B Enola, PA 17055 Th. child was born out ot wedlock. Th. child is pr.sently in the custody ot Rar.n Boy.r who r.sid.. at 20 CasBett sereet, Apartment B, Enola, Cumberland county, Pennsylvania 17055. During the past tiv. y.ars, the child has r.sid.d with the tollowing p.rsons and at the tol1owing addre....: ](aren Boy.r 20 Ca..att street Apartm.nt B Enola, PA 17055. S.pt.mb.r 1996-Pr...nt ,,1 ! MlYlllIe._ 4'ONOATHseCONOSTAEeT . PO 10)1;1082 . HA....I!j.U~, PA 11101 1111123&9421 . 'AA 1717123&28" The mother ot the child i. Yaren Boyer currently re.iding at 20 Ca..ett Street, Apartment B, Enola, Cumberland County, Pennsylvania 17055. She i. divorced. The tather ot the child i. Drew Hiller currently re.iding at 1030 Memory L~ne, Mechanic.burg, Cumberland County, penn.ylvania 17055. He i. .ingle. 4. The relationship ot plaintitt to the child i. that ot natural tather. The plaintitt currently reBides with the tollowing persons I , HAD RelationshiD Mother Sister Bonnie Miller Kirsten Miller 5. The relation.hip ot detendant to the child i. that ot natural mother. The detendant currently re.ide. with the tollowing personBI HAD RelationBhiD Son Son trom previous marriage Gray.on Jo.eph Miller Jared Boyer I I I 6. Plaintitt haB not participated a. a party or witness, or in another capacity, in other litigation concerning the cu.tody ot the child in this or another court. Plaintitt has no intormation ot a custody prooeeding concerning the child pending in a court ot this Commonwealth. " 3 MlYlllla DIII'OIl 4'0 NORTH SleONO STAUT . PO BO)( loe:J . HAIlI.USIUMG PA 11101 17' n 23&"'21 . 'AX 1717) 23&2111 Plaintiff doe. not know of ft p.r.on not a party to the proceeding. who has phy.ical cu.tody of the child or claim. to have cu.tody or vi.itation right. with re.pect to the child. 7. The be.t intere.t and permanent welfare of the child will be eerv.d by granting the relief requested becauee Grayeon .hould have the opportunity to develop a strong and loving relationship with his Father. It i8 in Grayson'. be.t intereet to receive love and guidance from both of his parents. Furthermore, Grayeon .hould not be deprived of the o~portunity to e.tablieh a .trong bond with hie Father during hi. infancy which will la.t throughout his lifetime. 8. Each parent whose parental rights to the child have not been terminated and the person who hae phyeical custody of the child have been named as parties to this action. WHEREFORE, plaintiff requests the court to grant partial cuetody of the child. Br e . Desf I. .. 07168 MEYERS , DESFO 410 North Seco Street P.O. Box 1062 HarriSburg, PA 17108 Attorney tor the Plaintiff (717) 236-9428 ~I , 4 __.DI_ "O~ORTH5ICON05TRUT . PO 10"012 . HARR;SIURQ PA "'01 11111 23&".,1 . IIA.lC 111 11 ~J6.2." MAR 4 199-tf' DREW MILLER, I IN THE COURT OF COMMON PLEAS Plaintiff I OF CUMBERLAND COUNTY, I PENNSYLVANIA VB. I I NO 96-6839 CIVIL Tl'RM KAREN BOYER, I Defendant I CIVIL ACTION - LAW I CUSTODY /VISIT A TION ORDER AND NOW this -<J day of ;'1.,,(' ,2 , 1997, it being reported to the Conciliator that the parties have raached an agreement which makes further proceedings unnecessary, the undersigned Conciliator hereby relinquishes jurisdiction and returns the matter to the Court Administrator, If either of the parties wishes further proceedings in this action, they should petition the Court anew. FOR THE COURT, (1) .1/7' / {/(I,j; (/. /, MICHAEL ' BANG)l I Custody ConcilieV , / cc: Laurie A. Saltzgiver, Esquire Barbara Sumple-Sullivan, Esquire ../. I ',' , ~ M ~~ h'<; N "~.'. (I') M .: ~5 ~~;. }t;' ;c ;, /~ . <~ u.. ';:l , CO ~( .S ;;1) , I !? , : i (;j r.c1:1. c.' .i, p. '!o... j., ;t: a ~ ~ i' vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CUSTODY/VISITATION NO, 96-6839 Civil DREW MILLER, Plaintiff KAREN BOYER, Defendant ~ AND NOW this ~ day of , 1997, the attached Stipulation and Agreement of the Parties is hereby entered as an Order of Court. BY THE COURT: J. (-I \D , 1 -J -r'; ,-7 I C' " . I 'I i " " (' ,_ '[' :-, " ) (' : :/ -' ,p) " )Ir, .. ., I r" ';; " MlYIM.DI_ 410NO~TH SleONO STAIIT . PO lOX '012 . HA~~IS'U~O,'A 11101 111" 13&090111 . 'All 11111231-1111 DREW MILLER, . Plaint i ff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CUSTODY/VISITATION NO, 96-6839 Civil vs, KAREN BOYER, Defendant STIPULATION AND AGREEMENT FOR CUSTODY JG tA-.day of t~11 r!J. Drew Miller and Karen Boyer (hereinafter "Mother"), AND NOW this (hereinafter "Father") the parents of Grayson Joseph Miller, date of birth September 18, 1996, hereby agree and stipulate as follows: 1, The parties shall have shared legal custody of the child, Shared legal custody means that the parties shall equally share in the right to make all major decisions effecting thel child's growth, development and best interest of the child, including but not limited to medical, religious and educational decisions, It is the parties' specific agreement and intent that they equally share in these decisions and that they shall deliberate and make these decisions in the child's best interest, 2, Each party agrees to keep the other informed of the progress of the child's education and social adjustments, Each part agrees not to impair the other party's right to physical custody as provided herein, Each party agrees to give support to the other in the role as a parent and to take into account the concerns of the other for the physical and emotional well-being of the child. It shall be the MlytMADI_ 410NOA1HseCONOSTREET . PO IOlCl082 . HAPlPlISIUPlO, PA 11101 11"123...2. . FAX 1717123&-2111 obligation of each parent to make the child available to the other in accordance with the physical custody schedule and to encourage them to participate in the plan hereby agreed and ordt:red, 3. Each parent shall have the duty to notify the other of an event or activity that could reasonably be expected to be of significant concern to the other parent. The parents shall communicate directly with one another concerning any parenting issue requiring consultation and agreement and regarding any proposed modifications to the physical custody schedule, which may from time to time become necessary, and shall specifically not use the child as a messenger. Each parent shall be entitled to complete information from any hospital, doctor, dentist, teacher or authority and have copies of any reports given to them as a parent. 4, The Mother shall have primary physical custody of the child, The Father shall have rights of partial physical custody as follows: a, The Father shall have partial physical custody of the child everyday from 9:00 a,m. until 11:30 a.m. The parties agree that they shall be flexible with this partial custody schedule and shall have due concern for the child's schedule and needs, as well as the schedules and needs of the parties, It is the parties' intent by this agreement that the Father shall see the child on a daily basis, and that the 9:00 a.m. until 3 II I, Ii MlVlIII.OI_ 410NOATHSECONOSH~EET . PO 80X'082 . MAFlAISI!IUAG, PA 17101 111 'I 23&!W28 . FAX 1117123&2111