HomeMy WebLinkAbout00-03862
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JAMIE L. PYNE
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
PLAINTIFF
V.
HEIDI GILBERT
00-3862 CIVIL ACTION LAW
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW, this 30th day of June ,2000, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 onthe 2nd dayof August ,2000, at 3:00 PM
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: Isl
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 ATIORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATIORNEY 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
Telephone (717) 249-3166
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JAMIE L. PYNE,
Plaintiff
v.
CIVIL ACTION - LAW
IN CUSTODY
HEIDI GILBERT,
Defendant
NO. 2000- d;(.~
C~;( 't~
ORDER OF COURT
AND NOW, this
day of
,2000, upon consideration of
the attached Complaint, it is hereby directed that the parties and their respective counsel shall appear
before
, the Conciliator, at
on the
day of
, 2000 at
.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! 990. 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 THIS PAPER TO YOUR LA WYER 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, PA 17013
(717) 249-3166
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JAMIE 1. PYNE,
Plaintiff
v.
CIVIL ACTION - LAW
IN CUSTODY
NO. 2000- 3 it..:z ~ f ~
HEIDI GILBERT,
Defendant
COMPLAINT FOR CUSTODY
AND NOW, comes Plaintiff, JAMIE 1. PYNE, by and through his attorney, Richard 1.
Webber, Jr., Esquire, and files the following Complaint for Custody and in support thereof avers as
follows:
1. The Plaintiff is Jamie 1. Pyne, an adult individual residing at 15 Pin Oak Lane,
Newburg, Cumberland County, Pennsylvania.
2. The Defendant is Heidi Gilbert, an adult individual residing at 415 McCullough Road,
Shippensburg, Cumberland County, Pennsylvania.
3. The Plaintiff seeks primary custody and visitation of the following child:
Age
Name
Present Residence
Lauren R. Gilbert
415 McCullough Road
Shippensburg, P A 17257
8 (DOB 9/9/91)
The child was born out of wedlock.
The child is presently in the physical custody of the Defendant, Heidi Gilbert.
During the past five years, the child has resided with the Defendant at the following
addresses:
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Name Address Date
Heidi Gilbert Earl Street Unknown
Shippensburg, P A 17257
(Cumberland County)
Heidi Gilbert Lynn Avenue Unknown
Newburg, P A 17240
(Cumberland County)
Heidi Gilbert Shippensburg Mobile Estate Unknown
Shippensburg, P A 17257
(Cumberland County)
Heidi Gilbert Fayette Street Unknown
Shippensburg, PA 17257
(Cumberland County)
The mother of the child is the Defendant, with last known residence at 415 McCullough
Road, Shippensburg, Cumberland County, Pennsylvania. She resides with a boyfriend, Chris.
The father ofthe child is Plaintiff, who resides at 15 Pin Oak Lane, Newburg, Pennsylvania.
He resides with his wife, Erica 1. Pyne, stepdaughter Hailey Carbaugh and his son, Brian Pyne.
4. The relationship of Plaintiff to the child is that off ather.
5. Plaintiff has not participated as a party or witness, or in any other capacity, in other
litigation concerning the custody of the child in this or another court.
The Plaintiffhas no information of a custody proceeding concerning the custody of the child
in this or any other court.
The 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.
6. Plaintiff desires an Order of Court granting to him primary physical custody of the
child and shared legal custody.
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7. The best interests and permanent welfare of the child will be served best by granting
the relief requested because:
a) Plaintiff has a stable lifestyle;
b) Plaintiff is better able to provide the child with a home with adequate moral,
emotional and physical surroundings as required to meet the child's needs;
c) The Plaintiff is, and has always been, willing to accept custody of the child; and
d) Defendant has withheld partial custody from Plaintiff. Neither Defendant or her legal
counsel have offered any explanation.
8. 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. There are no
other persons who are known to have or claim a right to custody or visitation of the child.
WHEREFORE, Plaintiffrespectfully requests Your Honorable Court grant Plaintiff primary
physical and shared legal custody of Lauren R. Gilbert, subject to reasonable partial custody for
Defendant.
Respectfully submitted,
'7\:/rzr~~
Richard 1. Webber, Jr., Esqu
Attorney ID No. 49634
19 Brookwood Avenue, Suite 106
Carlisle, PA 17013-9142
(717) 249-5373
Attorney for Plaintiff
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VERIFICATION
I verifY that the statements made in this Complaint are true and correct. I understand that false
statements herein are made subjectto the penalties of18 Pa.C.S.A. Section 4904, relating to unsworn
falsification to authorities.
Date: 6"./.2.-6 )66
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JAMIE L. PYNE,
Plaintiff
vs.
CIVIL ACTION--LA W
IN CUSTODY
HEIDI GILBERT
Defendant
NO. 2000-3862 Civil Term
ACCEPTANCE OF SERVICE
I, Richard M. Morris, Jr., Esquire, accept service of the Complaint for Custody in the above-
captioned matter on behalf of my client, Heidi Gilbert, and I certifY that I am authorized to do so.
Date: \Sl\Al1 ') ~\)
Richard . Morris, Jr.,
Attorney ID No.
318 East King Street
Shippensburg, P A 17257
(717) 530-8579
Attorney for Defendant, Heidi Gilbert
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JAMIE L. PYNE, : IN THE CXlURT OF OOMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
vs. . NO. 00-3862 CIVIL TERM
.
.
.
HEIDI GILBERT, : CIVIL ACTION - LAW
Defendant : IN CUSTODY
ORDER OF COURT
AND NCII1, this ~l),
consideration of the attached
and directed as follows:
day of A '"'ft.....s. f
Custody Concilia on Report,
, 2000, upon
it is ordered
1. The Father, Jamie L, Pyne, and the Mother, Heidi Gilbert, shall
have shared legal custody of Lauren R. Gilbert, born September 9, 1991.
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 Mother shall have primary physical custody of the Child.
3. During the school year, the Father shall have partial physical
custody of the Child on a 4 weekend cycle as follows:
WEEKEI.\ID I - The Father shall have custody of the Child from Friday
at 6:00 p.m. through Sunday at 7:00 p.m.
WEEKEI.\ID II - The Mother shall have custody of the Child.
WEEKEI.\ID III - The Father shall have custody of the Child from
Friday at 6:00 p.m. through Sunday at 7:00 p.m.
WEEKEND IV - The Father shall have custody of the Child from
Friday at 6:00 p.m. through Sunday at 1:00 p.m. and the Mother
shall have custody beginning on Sunday at 1:00 p.m.
In addition, the Father shall have custody of the Child during
weeks following the Mother's weekend periods of custody from
Monday at 6:00 p.m. through Tuesday when the Father shall
transport the Child to school.
4. During the summer school break each year, the parties shall
alternate having custody of the Child on a weekly basis with the exchange
of custody to take place each Friday at 6:00 p.m. The summer custody
schedule shall begin on the first Friday following termination of the
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school year with the parent who would otherwise have custody of the Child
under the alternating weekend schedule. For purposes of this provision,
Weekend IV of the four week weekend cycle shall be considered to be the
Mother I s weekend period of custody. The summer custody schedule shall end
on the second to the last Friday before the new school year begins, in
order that the Child may be returned to the Mother's custody for a minimum
of one full week prior to the beginning of the school year. The school
year alternating weekend schedule shall begin with the Father having
custody of the Child on the first weekend after the beginning of the school
year.
5. The sununer custody schedule shall begin in 2000 with the Father
having custody of the Child on Friday, July 28.
6. The Mother shall have custody of the Child on Labor Day in 2000
under the regular custody schedule.
7. The parties and their counsel shall attend a second CUstody
Conciliation Conference in the office of the Conciliator, Dawn S. Sunday,
Esquire, on Thursday, October 26, 2000, at 9:30 a.m.
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 terns
of this Order shall control.
BY THE COURT,
J.
cc:
Richard L. Webber, Jr., Esquire - Counsel for Father
RIchard M. Morris, Jr., Esquire - Counsel for Mother
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JAMIE L. PYNE, : IN THE OOURT OF OOMMON PLEAS OF
Plaintiff . CUMBERLAND CClONTY, PENNSYLVANIA
.
:
vs. : NO. 00-3862 CIVIL TERM
:
HEIDI G!LBERT, : CIVIL ACTION - LAW
Defendant . IN CUSTODY
.
CUSTODY CXXIICILIATIClIJ SUMMARY REPORT
IN ACXXIIDANCE WITH CUMBERLAND COONTY RULE OF CIVIL PROCEDURE
1915.3-13, 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:
Nl\ME
DATE OF BIR'l'B
CURREl'lTLy IN CUS'l'ODY OF
Lauren R. Gilbert
september 9, 1991
Mother
2. A conciliation Conference was held on July 26, 2000, with the
fOllowing individuals in attendance: The Father, Jamie L. Pyne, with his
counsel, Richard L. Webber, Jr., Esquire, and the Mother, Heidi Gilbert,
with her counsel, Richard M. Morris, Jr., Esquire.
3. The parties agreed to entry of an Order in the form as attached.
Dath
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Dawn S. Sunday, Esqu-'fr1
CUstody Conciliator
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file:
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August 14, 2000
JAMIE L. PYNE,
Plaintiff
VS.
HEIDI GILBERT,
Defendant
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 00 - 3862 CIVIL TERM
IN CUSTODY
PRAECIPE TO WITHDRAW APPEARANCE
TO THE PROTHONOTARY:
Please withdraw my appearance on behalf of the Defendant, HEIDI GILBERT, in the above
captioned case.
Date: <'Si\. \ q \ \J tJ
By:
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318 East King Street
Shippensburg, PA 17275
(717) 530-8579
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file:
JAMIE L. PYNE,
HEIDI GILBERT,
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IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 00 - 3862 CIVIL TERM
vs.
Defendant
IN CUSTODY
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance on behalf of the Defendant, HEIDI GILBERT, in the above
captioned case.
Date: ~ ~I (pO
SAIDIS, SHUFF, FLOWER & LINDSAY, P.C.
Attorneys for Defendant
By:
Carol J Lindsay, Esquire
10#44 93
26 West High Street
Carlisle, PA 17013
(717) 243-5513
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JAMIE L. PYNE, . IN THE COURT OF COMMON PLEAS OF
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Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs. : NO. 00-3862 CIVIL TERM
.
.
HEIDI GILBERT, . CIVIL ACTION - LAW
.
Defendant : IN CUSTODY
ORDER OF COURT
AND l'Oi, this b If;,
consideration of the attached
and directed as follows:
day of f..j<S:!\)C .......,LaC.r
CUstody Conciliation Report,
, 2000, upon
it is ordered
1. The prior Order of this Court dated August 3, 2000 is vacated and
replaced with this Order.
2. The Father, Jamie L. Pyne, and the Mother, Heidi Gilbert, shall
have shared legal custody of Lauren R. Gilbert, born September 9, 1991.
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.
3. The Mother shall have primary physical custody of the Child.
4. During the school year, the Father shall have partial physical
custody of the Child on alternating weekends from Friday at 6:00 p.m.
through Monday morning when the Father shall transport the Child to school.
If there is no school on Monday, the Father shall retain custody until 5:00
p.m. The alternating weekend schedule shall begin with the Mother having
custody of the Child on the weekend of November 3 and the Father having
custody of the Child on the weekend of November 10.
In addition, during weeks following the Mother's weekend periods
of custody, the Father shall have custody of the Child from Monday at 6:00
p.m. through Tuesday morning when the Father shall transport the Child to
school. The Father's first period of custody under this paragraph shall
begin on Monday, November 6, 2000.
5. During the summer schoo! break each year, the parties shall
alternate having custody of the Child on a weekly basis with the exchange
of custody to take place each Friday at 6:00 p.m. The summer custody
schedule shall begin on the first Friday following termination of the
school year with the parent who would otherwise have custody of the Child
under the alternating weekend schedule. The summer custody schedule shall
end on the second to the last Friday before the new school year begins, in
order that the Child may be returned to the Mother's custody for the week
prior to the begiming of the school year. The school year alternating
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weekend schedule shall begin with the Father having custody of the Child on
the first weekend after the beginning of the school year.
In the event the Father, the Father's wife or the paternal
grandparents are not available to provide care for the Child during the
Father's weeks of summer custody, the Father shall first provide the
maternal grandparents with an opportunity to provide the care for the Child
if the maternal grandparents can provide transportation. If the maternal
grandparents cannot provide transportation, the Father may take the Child
to his regular babysitter.
6. The parties shall share or alternate having custody of the Child
on holidays as follows:
A. CBlUSTMAS - The Christmas holiday shall be divided into
Segment A, which shall run from Christmas Eve at noon through
Christmas Day at noon, and Segment B, which shall run from
Christmas Day at noon through December 26 at noon. Unless
otherwise agreed between the parties, the Mother shall have
custody of the Child during Segment A in every year and the
Father shall have custody of the Child during Segment B in
every year.
B. THANKSGIVING - Unless otherwise agreed between the parties, in
even numbered years the Mother shall have custody of the Child
on Thanksgiving Day from 9:00 a.m. until 2:00 p.m. and the
Father shall have custody from 2:00 p.m. until 9:00 p.m. In
odd numbered years, the Father shall have custody of the Child
on Thanksgiving Day from 9:00 a.m. until 2:00 p.m. and the
Mother shall have custody from 2:00 p.m. until 9:00 p.m.
C. ALTERNATING HOLIDAYS - The period of custody on New Years Day,
Memorial Day and Labor Day shall run from 9:00 a.m. until 8:00
p.m. and the period of custody on July 4th shall run from 9:00
a.m. until after the fireworks. In odd numbered years, the
Father shall have custody of the Child on New Years Day and
July 4th and the Mother shall have custody on Memorial Day and
Labor Day. In even numbered years, the Mother shall have
custody of the Child on New Years Day and July 4th and the
Father shall have custody on Memorial Day and Labor Day.
D. MCJmER'S DAY/FATHER'S DAY: The Mother shall have custody of
the Child every year on Mother's Day from 9:00 a.m. until 8:00
p.m. and the Father shall have custody every year on Father's
Day from 9:00 a.m. until 8:00 p.m.
E. In the event the Father's holiday period of custody falls
either immediately preceding or following his regular periOd
of custody, the holiday/regular period of custody shall run
continuously without interruption.
F. The holiday custody schedule shall supersede and take
precedence over the regular custody schedule.
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7 . Both parties shall ensure that the Child attends her regularly
scheduled activities during his or her periods of custody.
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 llRltual consent. In the absence of llRltual consent, the terms
of this Order shall control.
BY THE OOURT,
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Richard L. Webber, Esquire - Counsel for Father) . ~
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carol J. Lindsay, Esqu~re - Counse or Mot erg
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JAMIE L. PYNE,
Plaintiff
: IN THE OJURT OF OJMMON PLEAS OF
: CUMBERLAND OJUNTY, PENNSYLVANIA
.
.
vs.
: NO. 00-3862 CIVIL TERM
.
.
HEIDI GILBERT,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
PRIOR JUDGE: J. Wesley 01er, Jr.
CUSTODY OOOCILIATICISI SUMMARY REPCHT
IN AcxmDANCE WITH CUMBERLAND OOONTY 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
CURREl'ITLy IN CUSTODY OF
Lauren R. Gilbert
September 9, 1991
Mother
2. A Conciliation Conference was held on October 26, 2000, with the
following individuals in attendance: The Father, Jamie L Pyne, with his
counsel, Richard L. Webber, Jr., Esquire, and the Mother, Heidi Gilbert,
wi th her counsel, Carol J. Lindsay, Esquire.
3. The parties agreed to entry of an order in the form as attached.
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Dawn S. Sunday, Esquire
Custody Conciliator