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Home My WebLink About00-01904 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ANGELA L. GOODYEAR, Plaintiff v. NO. o-o-/9o'f ~ I.L- HEATH W. GOODYEAR, Defendant : : IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel aPeear before ,~ , the Conciliator, at 2:>'1 "'-J~. \ \ on the \ '8 day of , 2000, at '3,', 00 ~.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. BY THE COURT: Custody )?t~ 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact the office set forth above. 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. --.-" .<". ~i~__lIIlllM!"" "~-"'~""""~lillll~i!iIiiIliI,i!l!i>,j\\iJi~i-'"'''' """""" , Mi!"'- ~~...J -I,"~ , '-" r:;! F[l-tY':F1n.-. OF Ti~,~L'~::'I:I(~T\,!(~~-f:..."t"~ - "',..', ".r-\'~J!h8Y Du" II,~D f>U pl' " ,,~,\ cl I rl cl: I ~ ... CUivlt3Fi;wJ (""u'''' "0'" IIY r=' \ .~J" v. uNI PcN0JSYLVfNIA 3 ':JQ ,('1/ -3 '30 -C'O c3 ;3:) , cJ~? M~~ ~r-#$: n~ ~2~ ,,~ ~~~~~t ,~ .Ie ,. ~ - ~- ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ANGELA L. GOODYEAR, Plaintiff v. NO. tnJ - /90 'f Ce;.;t I..e-- . . HEATH W. GOODYEAR, Defendant IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, this Q fj ~ day of \f#fJ JOl , 2000, comes the Plaintiff, ANGELA L. GOODYEAR, by and through her attorney, Maryann Murphy, Esquire, of Legal Services, Inc., and respectfully files this Complaint for Custody, and in support thereof avers as follows: 1. The Plaintiff is ANGELA L. GOODYEAR whose current address is 92 Betty Nelson Court, Lot #5, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is HEATH W. GOODYEAR whose current address is 1770 Sterrett's Gap Avenue, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff seeks primary physical custody of the following children: JACQUELINE GOODYEAR, born August 16, 1999 and CAITLIN GOODYEAR, born August 16, 1999 i1'_.,_, ,'-- ~1 --''',,~_ ~- -? ,-, . -~__, -~ 4. The children were born in wedlock. 5. Plaintiff currently resides with her son, Curtis, and the minor children involved in this action. 6. Defendant currently resides alone. 7. During the lifetime of the children, they have resided at the following addresses with the following persons: Time Address with Whom birth-3/00 116 Old State Road Gardners, PA Plaintiff/Defendant 3/00-present 92 Betty Nelson Ct. Lot#5 Carlisle, PA Plaintiff/Plaintiff's son 8. The father of the children is HEATH W. GOODYEAR. He is married to Plaintiff. 9. The mother of the children is ANGELA L. GOODYEAR. She is married to Defendant. 10. Plaintiff has not participated as a party or witness or in any other capacity, in other litigation concerning the custody of the children in this or any other Court, except as set forth above. 11. The Plaintiff has no information of a custody proceeding concerning the children pending in a Court of this Commonwealth or in any other State. 12. The Plaintiff does not know of a person not a party to - ~.c ,~ . -, -~ -, ,~ "" -. .-,", " - the proceedings who has physical custody of the children, or claims to have custody or visitation rights with respect to the children. 13. Each parent whose parental rights to the children have not been terminated, and the persons who have physical custody of the children, have been named as parties to this action. There are no other persons known to have or claim a right to custody or visitation of the children and therefore, no further notice of the pendency of this action and the right to intervene shall be given, other than to the parties named herein. 14. The best interest and permanent welfare of the minor children will be served by granting plaintiff primary physical custody of JACQUELINE and CAITLIN. WHEREFORE, Plaintiff requests this Honorable Court to grant her primary physical custody of the minor children. Respectfully submitted, Maryan Murphy, Legal Services, 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 LD. # 61900 Attorney for Plaintiff ~, , " 'r, ,~(;;;, VERIFICATION I, ANGELA L. GOODYEAR, verify that the statements made in the foregoing Custody Complaint 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. P/.~ ANGELA L. GOODYEAR ~,- ".","i ...", < H' ,~" _,; ." ", ~_"';_"'" ,,_ __ ~ ., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ANGELA L. GOODYEAR, Plaintiff : v. : NO. HEATH W. GOODYEAR, Defendant . . IN CUSTODY CERTIFICATE OF SERVICE I, Maryann Murphy, Esquire, do hereby certify that on the day of , 2000 I served a true and correct copy of the foregoing Complaint in Custody on the Defendant, HEATH W. GOODYEAR at the address set forth below, by placing a copy of same in the United States Mail, postage prepaid, certified/restricted delivery. Heath W. Goodyear 1770 Sterrett's Gap Avenue Carlisle, PA 17013 Respectfully submitted, Maryann Murphy, Legal Services, 8 Irvine Row Carlisle, PA 17013 (717) 540-8600 LD. # 61900 d , _ _0 _ _~ n'" ~H' , o "'1 , , ~-- ~~" -~", ~" ,~. '1'~~ ~ l) c:: d}~ If' );; CJ c:: :c: -:;J "'<;, \ ~pg-~~""om~~!I~I!I!I (~ c:-. o "'tJ :;:1 ; ',l::n _~E?'8 :::~;() B:P ;>-() arn 5;! :;;:, -< :?: :--~,. ':~J ;", Co ~o ::;:;;: ~ (}1 W ~ , \,:. "" "'" ~ -''''''"'I!''~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ANGELA L. GOODYEAR, Plaintiff : NO. 0-0 ~ / 96'1 Cu;.;t -r:.- v. : IN CUSTODY HEATH W. GOODYEAR, Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, ANGELA L. GOODYEAR, Plaintiff, to proceed in forma pauperis. I, Maryann Murphy, Esquire, of Legal Services, Inc., attorney for the party proceeding in forma pauperis, certifY that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. ~o ~AL Maryann urphy, EsqUlre Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 J.D. # 61900 Attorney for Plaintiff . _ C~. ~ _ _~ _, _ ~ " '.'-,' -.~" " . .. " _0 ~- ~I C) e, '" c <::> ,~ i"1 <' ::;;:: l..1'm mn'\ ;::..". :J.J Z:r:: :::!J Z, N ..~2rD Co~'~ CO ..:--"".' -<^~ :;.~ z:, r"::Li "'. -0 -',-' -r, J> _ ~-:".. ,:::':;' :IJ Zv ::::,:(-") ><-'1 't~ ~';:;;:: rn C '-' :z __001 ::;! :'J'! ~ .- -< -,,~ ,~!J!.P 'NI'TIRr'if~~'lrnli'W!fllf.Jlf~,.Qr_'~' ~__ ..'C"o.,I-.~~_ """'!'1.....~ '" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ANGELA L. GOODYEAR, Plaintiff :NO. v. : IN CUSTODY HEATH W. GOODYEAR, Defendant AFFIDA VII IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am ANGELA L. GOODYEAR, Plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: ANGELA L. GOODYEAR Address: 92 Betty Nelson Ct.. Lot #5. Carlisle. PA 17013 (b) Social Security Number: 175-62-6124 If you are presently employed, state Employer: Select Medical Corooration Address: 4716 Old Gettvsburg Rd.. Mechanicsburg. PA 17055 Salary or wages per month: $1.996.00 Type of work: billing clerk "" ,.~:, ~. .c 'l"'~ ,-^~ ~,_ _~ If you are presently unemployed, state N/ A Date oflast employment: N/A Salary or wages per month: N/A Type of work: N/A (c) Other income within the past twelve months Business or profession: -0- Other self-employment: -0- Interest: -0- Dividends: -0- Pension and annuities: -0- Social Security benefits: -0- Support payments: $139.96 Disability payments: -0- Unemployment compensation and supplemental benefits: -0- Workman's compensation: -0- Public Assistance: -0- Other: -0- (d) Other contributions to household support NONE (Wife)(Husband) Name: N/A the parties are separated If your (husband) (wife) is employed, state Employer: N/A ;; . _ c _"', _'" ~_____" .' ~ - Salary or wages per month: N/A Type of work: N/A Contributions from children: -0- (e) Property owned Cash: $20.00 Checking Account: -0- Savings Account: $30.00 Certificates of Deposit: -O- Real Estate (including home): -0- Motor vehicle: Make Dodg:e Cost unknown Year 1989 Amount owed $600.00 Stocks; bonds: Other: -0- -0- (f) Debts and obligations Mortgage: -0- Rent: $550.00 Loans: $6.565.00 Monthly Expenses: $2.200.00 (g) Persons dependent upon you for support (Wife) (Husband) Name: N/A ., ,'-^- '-', . .- -" ~,- ~ --, , J , - Children, if any: Name: Curtis Age: 7 Name: Caitlin Age: 7mos Name: Jacqueline Age: 7mos 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: 3~ .20' 06 P .i~.- ANGELA L. GOODYEAR , i , I I , , I I I , I I I , , I I I I , ! i . , i i I . i I f;" .,. '-, - '. .",~---- - . -~ '-i-~~-,' ._C.,'.,,'_,__ .\ ,_,_c " . _'i - ~.,-, '" , ..... (') C :;:.-"'. ~~l,; (;'1 ~~ ~~c5 fl~: ~ , ~. - ~~lfllRl'!l~~,,!~! e_" '".~-"""" . :..'1 .;;- - -' ,c. "_ .'~' CJ C:l :? .:...~ ~O N Co Cl -'n ::;j t"h:n r- 'I~,~ - ._~~ ; -'-:f() i~~ ;;;! .J:) -< ::;? r,.,) " rlllOO!II!!~,.. "f'~~w. MAY 2 2 200~ ANGELA L. GOODYEAR, : IN THE CDURT OF CDMMON PLEAS OF Plaintiff . CUMBERLAND CDUNTY, PENNSYLVANIA . : vs. : NO. 00-1904 CIVIL TERM . . : CIVIL ACTION - LAW HEATH W. GOODYEAR, : Defendant : IN CUSTODY ORDER OF <XXlRT AND l'DIJ, this 17th day of May, 2000, the Conciliator, being advised by plaintiff's counsel that the parties are reconciling and the Conciliation Conference scheduled for May 18 is no longer necessary, hereby relinquishes jurisdiction in this case. The CUstody Conciliation Conference scheduled for May 18, 2000 is canceled. FOR THE CDURT, Da~6 Custody Conciliator , .~ -".' '-',~ .';'. ~ (') C) 0 C <::) -n ? :J: ." ""\.1 ::::;t:J :1~ nl [L,' -.<; :D Z .- L:::: ',- r.....J --;"7f11 (fJ c..) :06 --< :~. ':::J ~~ C -;:; ~:::l~/- C.i ~". ::> -rl '--0 );-: () r::? orn c Z :,,-, :i;j :;,! :Sa '0 .< H ,~.-~"""'~~ M~;;iJl\""'''lJ.WP,I!,,,''S!'%!tl/''mJ!'~~~f!i~!!ll!l'r.I,~,_~ .~~~_mNj!!iI!il11~_~fil