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Home My WebLink About00-01632 , , MELISSA L. McCOY, Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA II, <-, -, 0 ? tJt-r't-7\~.. /(p702. ~ No. 0\)' U v v, RYAN S, BENSON, Defendant CIVIL ACTION- CUSTODY ORDER of COURT AND NOW, this rl. \ day of ~O \(/\1 , 2000, upon due consideration of the attached Complaint in Custody, it is hereby ORDERED and DECREED that the parties and their respective counsel appear before tn'-..\\ ~ . ~~ , Esquire, the Conciliator, at~'f\1.l.\1ail\~\tc\m(~ on the en · dayof ~r:'\ \ ,2000 at L O() , .m, fora 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 (5) or older shall be present at the conference. Failure to appear at the conference may provide grounds for a temporary or permanent order. FOR THE COURT: By: ~H~ J\,~\\~~ Custody Conciliator c '1 YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO On. TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, CUMBERLAND COUNTY COURT ADMINISTRATOR'S OFFICE Fourth Hoor, Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 (717) 240-6200 """ "F ... ,C!Li::o-.,,;:W'c \.t thE- r-;I:/"y';" 4---'i_ ..). "''''\'(')'''RY . ,- __,J, !-_.) fl, ao HAD 2" . b" .. iiI) ,J rri2:2l1 -... CUM8E.r:>" . . . Rr:,-"N'LArvO COU/\I1'v. <::/ v. sYLVANIA" J .3013.00 0/- ~ /4Af;;W ~ 4- ~ ~C)3 0 ~~ ~ ~ dr' c,I-~< .3 d3 . DC' fi . - /1 / ..k /?A-- u~~~ ~~.~ ,~~WI!!I!ilfiIllII!!!!!IlIIlIl~I!I!!I_,. .~1lIMIllI! _~_ _0_' ,~~~'r~)WF'R'iR"P"""''''''~i~'''~~''''m~,'-'W';_""-_",,,.~illll'~:!I!!Il''m~im\'~lmji!PlJ(IlIIIlQlf!!1!ll!l$~ - """"-;j MELISSA L, McCOY, Plaintiff : IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA No. :u-vv - / (, ,) ~ (!,;,;;j f JA- v, RYAN S, BENSON, Defendants : CIVIL ACTION - CUSTODY Complqint for Custod)!. AND NOW, comes MELISSA I. McCOY, Plaintiff above named, by and through her attorney, John M, Glace, Esquire, and respectfully presents the below Complaint for Custody, and , in Sl/pport thereof, avers the following: 1. Plaintiff, MELISSA L. McCOY is an adult individual whq resides at113 Spring Farm Circle, Carlisle, (South Middleton Township), Cumberland County, PA 2. Defendant is an adult individual who resides at 36 Mill Street, Mount Holly Springs, Cumberland County, P A. 3. The above parties are the biological parents of ALEXIS BETTY RunI BENSON (DOB: May 26, 1995); whose custody is now amicably shared between parents due to the proximity of their respective residences. 4. In August, 2000 , the minor child will begin school. The above parties live in different school districts ( South Middleton and Carlisle) and establishment of primary physical custody will be required for registration. 5. There has been no prior adjudications or actions relative to custody of the above minor child . , "" ,'........... -.J , 7. Since the above minor child's birth, she has resided at the following: a. 36 Mill Street, Mount Holly Springs, P A ( with both parents from May 26, 1995 until July, 1998): and b. between parents' residences thereafter. 8. Because of the age of the minor daughter and the presence of nine (9) year old half sister, Emily, in the Plaintiff's home, it would be in the best interests of the minor child that primary physical custody be granted to Plaintiff and that the minor child be allowed to matriculate and begin her education in the South Middleton School District with her half sister. WHEREFORE, above Plaintiff Melissa L, McCoy respectfully requests this Honorable Court to grant her primary physical custody of Alexis Betty Ruth Benson and that shared legal custody be granted to both parents with liberal partial custody granted to Defendant. Respectfully Submitted, THE LAW OFFICE of JOHN M. GLACE e, Esquire e 000 10: 23933 1 -134 Walnut Street Harrisburg, PA 17101-1612 (717) 238-5515 Attorney for Plaintiff . , . ' VERIFICATION The Undersigned hereby verifies that the facts averred in the foregoing Complaint for Custody are true and correct to the best of her knowledge, information, and belief. This verification is made subject to the penalties of 18 Pa. C.S.A., Section 4904 relating to unsworn falsification to authorities. ?'-ll-OlJ Date ~Ml~lill5i~_lIllilItiIIllll.IIIl~ "lillW"'". -_"'''''''''~~,"0.:I.r'''-~''''<lh,!~~'lkl;_''-llliilll.llI/iM!!:ll~~iillilillillllillllllillilll , . ~~f --S\ ~ /~ '}...J ,... ~ ~ 0l ~ ~ \.}.J ~ ~ ~1 ~ ~ u-~ , ) C' " 8m () ~ s.. '"0 co fTl {T1 Z:Il :Z:C <Ad; ~.,. ~O ~:z:- 0 -"'0 :PC ~ .........J..w.~ . " Cl Cl ::::: "'" "'" ~ -1 -1'~ _ fii;1l ~~. O-H :z~ 9 ~ -' ""0 ::::: N .. 0\ , - -, MELISSA L. McCOY, : IN THE COURT OF COMMON PLEAS OF plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. . NO. 00-1632 CIVIL TERM . : RYAN S. BENSON, : CIVIL ACTION - LAW Defendant . IN CUSTODY . ORDER OF COORT AND lUl, this IJ, l{ day of Vl1..l ~ consideration of the attached Custody Conciliation and directed as follows: , 2000, upon Report, it is ordered 1. The Mother, Melissa L. McCoy, and the Father, Ryan S. Benson, shall have shared legal custody of Alexis Betty Ruth Benson, born May 26, 1995. 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 her health, education and religion. 2. The parties shall share having physical custody of the Child on an alternating weekly basis. During weeks when the Father is receiving custody of the Child, the custody exchange shall take place on Sunday morning before church. During weeks when the Mother is receiving custody of the Child, the exchange of custody shall take place on Sunday after church. The alternating weekly schedule shall begin with the Father receiving custody of the Child on Sunday, April 30, 2000. 3. The non-custodial parent shall have an overnight period of custody with the Child on Wednesdays each week with the specific times to be arranged by agreement of the parties. 4. The parties shall share having custody of the Child on holidays as arranged by agreement. The Father shall have custody of the Child every year on Father's Day and the Mother shall have custody of the Child every year on Mother's Day. 5. The parties agree that the paternal grandmother shall continue to provide care for the Child during the custodial parent's periods of employment. 6. For purposes of school enrollment, the Child's residence shall be 113 Spring Farm Circle, Carlisle, PA, where the Mother currently resides. Designation of the Mother's address as the Child's residence for purposes of school enrollment is contingent upon the Mother remaining in her current residence. 7. In the event either party intends to change his or her residence, the moving party shall provide the other party with at least 60 days advance notice to enable the parties to adjust the custody arrangements by agreement or obtain a resolution through the legal process. 8. This Order is entered pursuant to an agreement of the parties at a custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, J. cc: John M. Glace, Esquire - Counsel for Mother Johnna J. Deily, Esquire - Counsel for Father ~~ .6-/5-00 ~K.3 k ~ "> Il~;i MELISSA L. McCOY, : IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. . NO. 00-1632 CIVIL TERM . . . RYAN S. BENSCN, . CIVIL ACTION - LAW . Defendant . IN CUSTODY . CUS'lOOY COOCILIATICl\/ SUMMARY REPOOT IN Acccm>ANCE WITH CUMBERLAND <XXlNTY 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: NAME DATE OF BIRTH CURRENTLY IN CUS'lOOY OF Alexis Betty Ruth Benson May 26, 1995 Father/Mother 2. A Conciliation Conference was held on April 27, 2000, with the following individuals in attendance: The Mother, Melissa L. McCoy, with her counsel, John M. Glace, Esquire, and the Father, Ryan S. Benson, with his counsel, Johnna J. Deily, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date ~ ,J ,k;,m / (Q._~ Dawn S. Sunday, Esquire Custody Conciliator