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Home My WebLink About00-03543 , . . - .~ "~ ";'. "" , TIMOTIIY PALMER, I, PLAINTIFF V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CORREEN UBILES 2000-3543 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 19th day of June ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear beforeHubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthonse, Carlisle on the 25th day of August ,2000, at8:30 AM 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 TIlE COURT, By: Isl Hubert X. Gilroy. Esq./IJ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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. YOU SHOULD TAKE TIllS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTIl BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 " ~,.~~ '. "'"'' ~ . ()F (".n II \\\ 2 f\ 1'):""1 h: n ~ Ul,.l J,,,l;" ~'.; ,''''' ,', :,' (,\i;''"' '-'''"").I;,sev vUMi:x.:nL,!"\, '.;U \j__ l".. I 'II 1 PENNSYlVN'.j1A ~c;?(). ?i() /, ;Xi.cQ:/ ~ "d)-&O tU-~~~~ 4 ~ 7!~~$~. _ ~~~7/- ~yM . - _~""""."""",~" ~ " W!llTI1jr. ~',",,' ,'. ~~ ,~ !IN- ~""~.)~;., .-,jiij ~ ., ,. ."i. -~~~. ~ ~ "~~l";-,,,,- TIMOTHY PALMER, I, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND CQUNTY, PENNSYLVANIA : CIVIL ACTION - LAW CORREEN UBILES, Defendant . : NO. 2000- "35'-\:) CIVIL ACTION : IN CUSTQDY ORDER OF COURT AND NOW, this day of ,2000, upon consideration of the attached Custody Complaint, it is hereby directed that the parties and their respective counsel shall appear before , the Conciliator, at on the day of ,2000 at o'clock. 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: Custody Conciliator 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. YOU SHQULD 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, P A 17013 (717) 249-3166 .,' J,~,__~..~~ ^ ~ 'I 0." ~ :il!i.liaj:lj;-,li:",-;; TIMOTHY PALMER, I, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLV ANIA CIVIL ACTION - LAW V. CARREEN UBILES, Defendant : NO. 2000 - 35'13 CIVIL TERM : IN CUSTQDY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, Timothy Palmer, I, by and through his attorney, Jacqueline M. Verney, Esquire and represents the following: 1. Plaintiff is Timothy Palmer, I, who resides at 309 West Ridge Street, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Carreen Ubiles, who resides at 611 Kelker Street, Harrisburg, Dauphin County, Pennsylvania, 17102. 3. Plaintiff seeks custody of the following child: NAME PRESENT ADDRESS AGE Timothy Palmer, II 309 West Ridge St. Carlisle, P A 17013 7 yrs DOB 4/25/93 The child was born out of wedlock. The child is presently in the custody of Timothy Palmer, I, who resides at 309 West Ridge St., Carlisle, Pennsylvania, 17013. During the past five years, the child has resided with the following persons and at the following addresses: LIST ALL PERSONS ADDRESSES DATES Shanda Palmer, Timothy Palmer, I, Jedaiah Palmer 309 West Ridge St. Carlisle, P A ll/99-present " J _I ~~" ~"W'- Shanda Palmer, Timothy Palmer, I 154 Elm St. Carlisle, P A 10/98-11/99 Shanda Palmer, Timothy Palmer, I 153 E. Louther St. Carlisle, P A 10/97-10/98 Timothy Pahner, I, Margaret Palmer College Park Apts Carlisle, P A 10/96-10/97 Timothy Palmer, I, Michael Bulger 202 Mary St. Harrisburg, PA 4/96-10/96 The mother of the child is Carreen Ubiles, currently residing at 611 Kelker Street, Harrisburg, Pennsylvania, 17102. She is single. The father of the child is Timothy Palmer, currently residing at 309 West Ridge St., Carlisle, Pennsylvania, 17013. He is married. 4. The relationship of Plaintiff to the child is Father. The Plaintiff currently resides with: NAME RELATIONSHIP Shanda Palmer wife Jedaiah Palmer son 5. The relationship of Defendant to the child is Mother. The defendant currently resides with: NAME RELATIONSHIP Brittany roommate Child son , ' .~ '::'l!YL 6. The Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody for the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child 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 child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: a. Plaintiff has been the primary caregiver for the last four years. b. Plaintiff is capable of providing a healthy, safe, nurturing, and loving environment for the child. c. The child has been attending Carlisle schools for the last two years and to change schools would disrupt his education. d. The child has a half brother with whom he has bonded. 8. Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the child have been named as parties to this action. WHEREFORE, plaintiff requests the court to grant shared legal custody and primary physical custody of Timothy Palmer to Plaintiff. " -h. ~ "o~ Date: t ~/Z--d)) ~_I -'lL. ~'.i,- Respectfully submitted, ~e~~ 44 South Hanover Street Carlisle, P A 17013 Supreme Ct. ID 23167 Attorney for Plaintiff " ~-~' -~ .> "~~;- VERIFICATION I verify that the statements made in the within Complaint are true and correct to the best of my knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S.A. ~ 4904 relating to unsworn falsification to authorities. Dated~/oo C'<f' -;l!pl,i?4 k Timo al er, I . -~" '.' '-' - ~,~.;, ,-'.-- "- " f f/I-. AUG 2 9 2~ TIMOTHY PALMER, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW CORREEN UBILES, Defendant NO. 2000 - 3543 CIVIL IN CUSTODY COURT ORDER AND NOW, this ~ day of ~ ' 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Timothy Palmer, shall enjoy legal and primary physical custody ofTimothy Palmer, II, born. April 25, 1993. 2. The Mother, Correen Ubiles, shall enjoy periods of temporary physical custody of the minor child at such times as agreed upon by the parties. 3. In the event the Mother is not provided sufficient time pursuant to negotiations with the Father, Mother may at any time petition the Court to have this case again scheduled with the Custody Conciliator at which time she may request a specific detailed schedule of visitation or any other appropriate modification of this Custody Order. 4. The parties shall share transportation for exchange of custody with the minor child pursuant to a schedule worked out between them. J. cc: Jacqueline M. Verney, Esquire Correen Ubiles 611 Kelker Street Harrisburg, PA 17102 ~ . ,tm.... ~'-i 1>30. N 'f-1' , ~' - ,,,._-"--:~ .~ . ',-,n Al,l!' r;O" U-J {..:I_"7 ,,J I _'__ =', _'rl< _,.. . '''<,,'- " -'-'- -,'X-";GIAR''i' /," '0-.....('\ .:;, I . .( rl; J'", . ."..... C'", ", ",', "~'UNTY utvtx:;-''iU'\; '~Li GUi j i Pl:NNS'rlvANiA ~~'_ ,~ III C'.., - ,~, --,~" -~ - " -"I~ ( .. . ..'.. ..,,'~' ,_, < - 1 - , -" ~__I. . , ~O:' ...;. ~ ,:,_; '. -''-, "'-',,, " _.__, '; -'~ .:11.< -.. TIMOTHY PALMER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW CORREEN UBILES, Defendant NO. 2000 - 3543 CIVIL IN CUSTODY Prior Judge: CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Timothy Palmer, II, born. April 25, 1993. 2. A Conciliation Conference was held on August 25, 2000, with the following individuals in attendance: The Father, Timothy Palmer, with his counsel, Jacqueline M. Verney, Esquire; and the Mother, Correen Ubiles, who appeared without legal counsel. 3. The parties agree to the entry of an order in the form as attached. .,/ {/;;.~/ 00 DATE Hubert X. Gilroy, Esquire Custody Conciliator