The URL can be used to link to this page

Home My WebLink About00-02846 "'-0". ' ,,- -c." ~__ ,_. ~- , ' ~- - - -~ '~-', ,'';; '''..; MAY 09 20~ Jessica L. Boyer, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN CUSTODY Ryan Maher, Defendant /)$ r C, NO. 2000- CIVIL TERM ORDER OF COURT You, Ryan Maher, defendant, have been sued in court to obtain custody of the child: Dackota Austin Daniel Boyer. You are ordered to appear in person at _ .m., for ,on , at a conciliation or mediation conference. a pretrial conference. a hearing before the court. If you fail to appear as provided by this order, an order for custody, partial custody or visitation may be entered against you or the court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER 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, Pennsylvania 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 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. ,- ~, . '0,"" _ "' '" ,~ - ,,, ~~,- ,,'~ ,'" , ' ~. -"'1, Jessica L. Boyer, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA CIVIL ACTION - LAW IN CUSTODY Ryan Maher, Defendant NO. 2000-,,{ ~'1~1VIL TERM ORDER OF COURT AND NOW, this II-\h day of \v\(k"\ ' 2000, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before, \t~~ "f,.. ~\~, the conciliator, a~ ~?\ol){" , Cumberland County Courthouse, on the ~g-l+, day of .J0\,/ ,2000, at IO:3/)om., 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. Either party may bring the child who is the subject of this custody action to the conference, but the child/children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: By: ~}\n.~x~,~~~ Custody Concihator I C~ ~- '" YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB 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, P A 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 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. 1'! 6-/~ .Co -5--- I? ,00 5" -Jb -OtJ r-_--. ^-',,' ,e_u -. -",'-' -,-' , ' FILED--OfFICE ~.. T' ~" r"-~-'" 'n 'O"T"^R f),.. J..:.., :-"~'.I I'e-< Jw Y \..., ,I '.. , . :~, -, ,,_',-, In 00 ~if\Y i 6 Pi.1 3: 25 ri I' 'I"""L"" r" ~vl\/rJt::.ri ;':,i\.iU l..;uUNTY PEN1~SYLv/\r\Jr;'\ &r.:I ~~ ~h ~~ X~ ~ ~.zj~'-. - t~~~ ff-4~ _," ':_ _,) _:_~'.'_ ~"., -_""'<f.~_,7,r-:'i''',r,,: . ,,, ," ~, ""I,,;i:~"',,",,,",,, nJl!ll8JUJlt ~-, ~"I-:','-i ' ,__,f_" , i . ~" , ".-,- C"' -I Jessica L. Boyer, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CNIL ACTION - LAW IN CUSTODY Ryan Maher, Defendant NO. 2000-.lWlPCIVIL TERM COMPLAINT FOR CUSTODY The plaintiff, Jessica L. Boyer, by her attorneys, the Family Law Clinic, sets forth the following cause of action: 1. The plaintiff is Jessica L. Boyer, residing at 17 Salt Road, Enola, Cumberland County, Pennsylvania 17025. 2. The defendant is Ryan Maher, residing at 401 Twin Creek Drive, Apt. IK, Killeen, Texas, 76543. 3. Plaintiff seeks custody of the following children: Name Present Residence Date of Birth Dackota Austin Daniel Boyer 17 Salt Road, Eno1a, P A 10/20/99 The child is presently in the custody of his mother, the plaintiff in this action. For his entire life, the child has resided with the following persons and at the following addresses: Persons Addresses Dates Jason Boyer (uncle) 17 Salt Road, Enola 10/20/99 - present 10/20/99- present 10/20/99 - present Jessica Boyer (mother) 17 Salt Road, Eno1a Armetta Boyer (maternal grandmother) 17 Salt Road, Eno1a 4. The relationship ofthe p1aintiffto the child is that of mother. She is single. She currently resides with the following persons: " oj,,; ~~-, . .;~" ,,,- , .' - .~ ,--,,,,-.~", '"._,,,~.,-,-, ',^-. .-' - ""' "'._,- ~ " .&!J,'.,-'I ,I :1 ,j I! I' I Name Relationship Dackota Austin Daniel Boyer Armetta Boyer son mother Jason Boyer brother 5. The relationship of defendant to the child is that of father. He is single. He currently resides with the following persons: unknown 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: Mother is the primary caretaker of the child and the child has lived with his mother since his birth. Father has never seen the child. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, plaintiff requests the court to grant to her sole legal and physical custody of the child. oi'e~~ Leann Mattoscio Certified Leg Intern T 0 SM. CE ROBERT E. RAINS Supervising Attorneys DONALD MARRITZ Staff Attorney FAMILY LAW CLIN1C 45 North Pitt Street ,;,- -~ .{.{~, '-'""'.'= '-,--,-,', . i;!!I,,": . Carlisle, PA 17013 717/243-2968 VERIFICATION ~ I verify that the statements made in this 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: Y/261CO , . I, .~_,,,."'__ _M,_"" -, . " ~- e _. ,.,_'!' --0',- ~ n -0 s:L \:r- ---<.. , ~ -o~ V\~- 16 '-J--;:S n'.-,"_',"."Y"-' ~!i- ~: :'-'" -:f. er-..W 0-(:;. ~ 'j:) r;:. ~ ~-~-, ,"~"""- o c ;;;: "'OUJ ITIrT1 ;?,:::Ii ZC (f)/ ~Z ~C:J )> zO 5',0 c ~ .,...1 0''- CJ CJ :x ,,. .-c , <...n a -n ~:~; 11 r~ -~, ITl :DD, ' f"' T . ";o~ --.' -f . (.L}:D " ~""'C) cjlll -. 'l> ::u -< ''0 3: y;;- .':- .." 'I ;_C__ ,,"'. .-'-"", ' - ,,- -, ,_,,- _ f~. JUN 21 200fJ~ Jessica Boyer, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION- LAW IN CUSTODY Ryan Maher, Defendant NO. 2000- 2846 CIVIL TERM ORDER AND NOW, this ~daY of June, 2000, the foregoing Custody and Visitation Agreement is approved and entered as an Order of Court. BY THE COURT: ~ \-fI\\l..ft',t("-i\I\::id 'J I< 'I \, ',;, ")'J: ,::::~~, "I'jrir.r, I'"~ :-~.,,', -:...-'\!(\'"'\ 1\1.\j i,_"j ",' .o,..'~,._" ., IV ,.., ~_ ('I I ") t.'j :...\\ ,", c',' -i:'I" :,n I,) {,J ~. I 1 l~, -. Fd-1..i_C :J,J "'f" ., . . JUN 2 1 200atp Jessica L. Boyer, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN CUSTODY Ryan Maher, Defendant NO. 2000- 2846 CIVIL TERM CUSTODY AND VISITATION AGREEMENT THE FOLLOWING AGREEMENT, made this _ day of June, 2000, between plaintiff, Jessica L. Boyer, (mother) and defendant, Ryan Maher, (father) concerns the custody and visitation of their child, Dackota Austin Daniel Boyer. Mother and father agree to the following: 1. Mother shall have sole legal and physical custody ofthe child. 2. Father shall have such visitation as agreed to by the parties. 3. Mother and father agree to be legally bound by the terms of this Agreement and desire it to be made a Court Order. 4. Mother and father may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Date: Jd9 ~DD Date: Lo ~.l ~ , Ry Maher - - - Defendant ,,- > . ., ~ , , ,-~ ",', , ^~. '-. ,--,*,'" "^ '<<T.' ~ '^_'^~ ,.'~o.c-"'.'. . .-~ ~ j J;nJ~n'fiJ/4'-' Andrew 1. Morrow Certified Legal Intern ~n,J-. THOMAS M. PLACE ROBERT E. RAINS SUPERVISING ATTORNEYS DONALD MARRITZ STAFF ATTORNEY F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Attorneys for Plaintiff '.""'''';-1' ,'.~- "j :;,. ~ ".,' i"' L"' '_iliil~~ ,~. .~il'/U''''~''';''''' - ~ .:..,,',,-' :..ii....;.-"""< " ~ " 'w~~ ", [1 ~-;;:, ,.- ?jf~i ::?'r' ~t~ ~rj Pc: Z =< "_e',', '_,' "0'.-=' : . " } . t.o ;1::;;:-. ~;iD ""'-171' u s;! :0 -< ...""" '2 en en . ,I ~--". ' "-- . . . .~ Jessica Boyer, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION- LAW IN CUSTODY Ryan Maher, Defendant NO. 2000-2846 CERTIFICATE OF SERVICE I, Andrew J. Morrow, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving a true and correct copy of the Custody and Visitation Agreement on Ryan Maher, 401 Twin Creek Drive, Apartment Ik, Killeen, Bell County, Texas, 76543, by depositing a copy of the same in the United States mail, this day of June, 2000. ~'",-P?n,~ Andrew J. Morrow Certified Legal Intern THE F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 i" , '.... I, ,'"?~ ,,' -: Iii~"'" ~~'1ili'l""""" ~,.,~ . n7h~"" ~"". >,,:',-- . V:':';";,~~",~,,,;_,,j-~~d ~.-, ";-';1\,'i~,,,,d'" ..._._ ':-",",.,., ~ ~ '""",',,," .. ''',,' --. ...... " 0 r:,"') c:: c::" :;:~~ V C::i ..,.. III Cr: ---,,~ ~ "'- Fe :z: "- (J) t;'_~~ t....c', , . rst-=; , , 2';~ - ~,~:: ,-:;--L -;7-1.. ) -.. ":;;~( ) ~o SJ ~F-i $' 'c ;;:: ':''1 ::< _u en -< " Jessica Boyer, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION- LAW IN CUSTODY Ryan Maher, Defendant NO. 2000-2846 CERTIFICATE OF SERVICE I, Andrew J. Morrow, Certified Legal Intern, Family Law Clinic, hereby certifY that I am serving a true and correct copy of the Custody and Visitation Agreement and Order of Court on Ryan Maher, 401 Twin Creek Drive, Apartment Ik, Killeen, Bell County, Texas, 76543, by depositing a copy of the same in the United States mail, this 28th day of June, 2000. ~#.If..,J~"HIQ~ Andrew J. Morrow Certified Legal Intern THE F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 g 0 ~ <::) Co- --I ~OJ lE ::L-r; nl_ ilJ~ N -oM ex> :0'9 9~ ~O ;x.. ,..,.-4 t _L,;-j ~o ::r ~~~ :;:;0 00 ~ ~ ?E &:" m --< J N ~ . ~ ,," - ,-- '.-=.' "1"'" , -;-" ~ ci _,,;,,_:" "';_""-' i;,_ _- --. , ~ j , JUt 3 1 zoortb JESSICA BOYER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v : NO. 2000-2846 CIVIL TERM RYAN MAHER, Defendant : CIVIL ACTION - LAW : CUSTODY COURT ORDER ~~ AND NOW, the ;)? day of July, the Conciliator being advised that the parties have reached an agreement, the Conciliator relinquishes jurisdiction. V)y Hubert X. Gilroy, Esq . Custody Conciliator", -- " ,. , -,-- -~ .--- . , ~ '"\) Jessica Boyer, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION- LAW IN CUSTODY Ryan Maher, Defendant NO. 2000- 2846 CIVIL TERM VERIFICATION OF SERVICE The undersigned, Ryan Maher, defendant, verifies that he received a true and correct copy of the above captioned Complaint for Custody and Order of Court for a Custody Conciliation Conference by first class mail on the --J ;) day o~ ~ , 2000 at 401 Twin Creek DRive Apt. 1k .m. at , Killeen, Texas 76543. (address) - ~".' "', '" "c__, ' ,', ' "~"V,- ,,',-,,',;- ., -~- _l, --~ ."~ ,.AC",,,,,CC,,,,,,,' , ,'. ",,";,;.k"""" W,",',' o c ~ -0 tT- 92,s.: g1~. ~'-./ "j?' (~") ~C) )>C ~ o C') --,- ,-.- ~ .,j' --,'.. '.,' """", -~\ .~'n l,,',:';' '_;".i.' -,;.() ?:: ...;,,~ .~{ ,,,-'.'.j (~Y'-'-; -4 ~> ?J 9 ell ~~. I<.~