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Home My WebLink About00-01277 , - "-. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA STACEY COYLE, v. : CIVIL ACTION - LAW : CUSTODYNISITATION NEIL DARHOWER, Defendant : NO. 00-1,171 CIVIL TERM ORDER OF COURT AND NOW,~, 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before t'6'w\S.~~ \ \ G~. , the conciliator, at ~ W . ~""\C\\f\S\ ) \1r~\G..,\~ on the ~ day of ~c:\ \ , 2000, at.3 o'clock, ii.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. 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. FOR THE COURT: BY:~~'~~W . Custody Conciliator I ~ C ~ ) The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For infonnation 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 hearing. 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. Office of the Court Administrator Cumberland County Court House, Fourth Floor Carlisle, P A 17013 (717) 240-6200 "',~ r, _iIIIII!dl~liliHi1llili_I;ib~~WO~j'n-.'Ilrolfi!~~~t"-l 3 . /3. c':f:) .3 -/3, Ot:? .3 -/J.~tJ :l(1-:(__""',on , _~ ..,.."".9.. c c "", <-;~, _'~ - .,' '. '_ _~" ~ ,^ '.~, ,'~_' '-['-'- ~ .,~ ~ r-t.,.,. OF r4(JL~R--QFFICF , ',. I I ~:fl! ,r 11'\ ~ , "~uNOTARY 00 HA,? 13 p l1 3: 4 I CUMBERU1\J' _ PE5VNSygA~~UIVTy tU-~ ~~4~ ~":~Z~. ~ /U~ Z; 4~~ , ^ -~ I I ~-,,'. - ," --~. Ili::, r . .. , . .... Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA STACEY COYLE, v. : CIVIL ACTION - LAW : CUSTODYNISITATION NEIL DARHOWER, Defendant : NO. 00-).2 17 CIVIL TERM COMPLAINT FOR CUSTODY 1. The Plaintiff is Stacey Coyle, residing at 27 South High Street, Newville, Pennsylvania 17241. 2. The Defendant is Neil Darhower, residing at 179 Big Spring Terrace, Newville, Pennsylvania 17241. 3. Plaintiff seeks custody of the following children: DOB AGE NAME RESIDENCE Corey Darhower 27 South High Street, Newville, PA 17241 3/9/98 1 yr. 11 months 4. The child was bom out of wedlock. 5. The child is presently in the custody of Stacey Coyle. 6. During his life, the child has resided with the following persons and at the following addresses: NAME Stacey Coyle and Stacey's mother and sister ADDRESS 179 Big Spring Terrace, Newville DATES 3/98 - 6/98 Stacey Coyle, Neil Darhower and Stacey's mother and sister 179 Big Spring Terrace, Newville 6/98 - 8/99 Stacey Coyle, Neil Darhower and Neil's mother 160 Big Spring Terrace, Newville 8/99 - 9/99 Stacey Coyle, and Stacey's mother and sister 179 Big Spring Terrace, Newville 9/99 - 10/99 Stacey Coyle, Neil Darhower and Stacey's mother and sister 179 Big Spring Terrace, Newville 10/99 - 12/99 Neil Darhower 179 Big Spring Terrace, Newville 12/99 - 117100 Stacey Coyle and Stacey's mother and sister 27 South High Street, Newville 117100 to present ;~~, . ,- ---, , . . 7. The mother of the child is Stacey Coyle, currently residing at 27 South High Street, Newville, Pennsylvania 17241. She is unmarried. 8. The father of the child is Neil Darhower, currently residing at 179 Big Spring Terrace, Newville, Pennsylvania 17241 . He is unmarried. 9. The relationship of the Plaintiff to the child is that of Mother. The Plaintiff currently resides with the following persons: Juli-An Coyle, Plaintiffs Mother and Amanda Coyle, Plaintiffs Sister 10. The relationship of the Defendant to the children is that of Father. The Defendant currently resides with the following persons: N/A 11. 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. 12. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 13. Plaintiff does not know ofa 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. 14. The best interest and permanent welfare of the children will be served by granting the relief requested for the following reasons: A. Plaintiff has undertaken and performed the primary parental responsibilities for tile child; and B. Plaintiff is best able to provide the care and nurture which the child needs for healthy development; and C. A Court Order of custody and structured visitation is desired so that the Plaintiff and the child may plan their schedules accordingly, and so that misunderstandings and nnmet exceptions regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion. :-r:M ", ".' ,.~ T ~~ -- ""'lJ<' . . D. Plaintiff desires to maintain the family household which has been established, and the continued stability of the household is in the best interest of the child. E. A Court Ordered determination of custody is required to avoid continuing conflict between the parties regarding parental responsibility for custody and support. 15. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiff requests the Court to grant custody of the children to Plaintiff subject to structured partial custody by the Defendant. Respectfully submitted, l;JAT[: ~ $(&(0-0 By:/~~/a Ore ry utler, Esquire Attorney for Plaintiff 50 East High Street Carlisle, P A 17013 Telephone: (717) 258-8558 Supreme Court ID No. 73471 I , 'I "i;' .^ '" ~r ."''''''' "~ "" .--- . . . . COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. DATE: ~ - Lj_()O S~~:P&:if~ i ! '"w:IlIIJ ~. .' .. ,.,. .. , STACEY COYLE, . IN THE COURT OF COMMON PLEAS OF . Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. . NO. 00-1277 CIVIL TERM . : NEIL DARHOWER, : CIVIL ACTION - LAW Defendant : CUSTODY ORDER OF COORT AND r<<:M, this ';?1 ,. day of 1'>7~ upon consideration of the attached Custody Co ciliation ordered and directed as follows: , 2000, Report, it is 1. The Mother, Stacey Coyle, and the Father, Neil Darhower, shall have shared legal custody of Corey Darhower, born March 9, 1998. 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. 2. The Mother shall have primary physical custody of the Child. 3. The Father shall have periods of visitation with the Child at the Mother's residence as arranged by agreement of the parties. 4. In the event the Father objects to the provisions of this Order, the Father may file a Petition with the Court within thirty (30) days of the date of this Order, requesting an additional Custody Conciliation Conference to review the custody arrangements. 5. consent. control. The parties may modify the provisions of this Order by mutual In the absence of mutual consent, the terms of this Order shall BY THE COURT, cc: 7/1J . ,. Gregory L. Cutler, Esquire - Counsel for Mother ~ Neil Darhower, Father .5 - 31- C) 0 RK3 ~,.,......,. ," 'I -" ~~ ill " ...... :IJII - 'WlJlllNll M!f!."^~, .. -- - , ~I!l!:_.-..~~~~;mc~ ~ , ~ .<-~ ~. -, ~'W.. . ~ ~y ""-.if' :<v ..., w~ ;r- Q, ~ ;:> o 0 o ;r- o~ CA' Q ~ ,r;" i'" "".".~P~Wf'~~~l~~?",",""", ~ ,> ~ .., / ~ STACEY COYLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 00-1277 CIVIL TERM . . NEIL DARHOWER, . CIVIL ACTION - LAW . Defendant . CUSTODY . CUSl'ODY c:'aICILIATICI'i/ SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND cx:xJN'fi RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: DATE OF BIRTH CURRENTLY IN CUSTODY OF NAME Corey Darhower March 9, 1998 Mother 2. A Conciliation Conference was held on May 23, 2000, with the following individuals in attendance: The Mother, Stacey Coyle, with her counsel, Gregory L. CUtler, Esquire, and the maternal grandmother, Juli-An Coyle who also participated on behalf of the Mother, who is fifteen years of age. The Father, Neil Darhower, did not attend the Conference or have counsel attend on his behalf. 3. The Mother's counsel indicated that he served the Father with notice of the Conference by Certified Mail although return receipt had not yet been returned. The Mother indicated that she discussed the upcoming Conference with the Father by telephone. 4. Based on representations made by the Mother and her counsel at the Conference and the fact that the Father did not attend, the Conciliator recommends an order in the form as attached. Da~fu;;f::-t CUstody Conciliator Da~ ;:; C(. ,J.O f) (} , ',!!'- 1_' . -