HomeMy WebLinkAbout02-5954RONDA S. CARVER
DEF ENDAN i
:iN 'i HE. COUR i OF C~MON
....................... ~'Y PENNSYLVANIA
'V~. :Pit) CIVIL t CI'~,M
LEE A. MYERS
PLAiNTiFF
:t.,U',.'~ ! UL)Y
COMPLAINT FOR JOINT' LEGAL AND PHYSICAL C.;DS [ODY
The ~Jefendant is ROr~DA S ~,~v~-m, re~ at ~= ~uK: .~..~ ,_~uv~-~ ~ I ~-~- ~,
I ], U~. L
2. fhe Plaintiff is Li::E A MYERS, res~'Jmcj at 329 GRi=A$(,~ RD, C..ARLi~L~ PA
3. The Plaintiff seeks Joint Leaai and Physm.,ai Custody of the foiiowmg chiid: iiFFANY
MY~_RS .BQRN ~CH 5TM 1995.
The child was born out of wedlock.
During the past five years, the child has res~ with the following persons an~i at the
The ~her of the Chi~
HAhiOVER STREEi APT i, Carilsie
She is unmarr~3
The father of the chiid is LEE A MYERS, currently residing at 329 GRb. A~';~N RD,
He ~s unmarried.
4. The relationship of [he Defendant to [he ch~id is mother, the ~iain~ff curre~itiy resKies
with:
Tiffany ~viyers Daugh[er
5. The reiasonsh~p of the Piami~ff to the ch~i0 ~s FAf HER. The defer~3nt currercJy
re~ides w~th:
6. pia~ntiff HAS NOT pad~c~pated as a party of w~tnes$, or in another capactty, in other
ii~Jgaaon concerning the custody of the minor child in th~s or another court.
Defendant has no informatlort of a custody preceding concerning the chtid pef~iing irt a
cour[ of this C. ornmortweaith.
Der'ertdant does not know of a person not a pa~y of the pr(x;ccchnge wh~ has pi~ysicai
custody of the child or ciatrns ~e have cus[ody or Csltataon ngh~ w~th respect ~ ~e ctaid.
7. Yhe best interes~ and permanent weifare of the chiio w¢i be Served by granting the rei~ef
re(luesbed because: until Disremember 11~' 2002. ~ child resided wi~ both the ¢ain~iff
and the deT'endant, Both the defendant and the plaintiff was con~st, er~t m ~he ch{k;J;$ iife the
child has no{ experienced a 8me when she o~a no[ rercde wl~ the ~efendant and piamSff
until disremember 11~¢', 2002. the child has a significant bond with the defendant and the
pia~m~ff that should not be broken. The best interest and permanent weifere of the
would be served by bo~h ~he defendan~ and the piamtiff equaiiy raising anO carm
m~nor ~.
,~. E. acn parent whose parental #ghts to the chiid have no{ been terminated.
WHEREFORE., the Plaintiff request this court to grant joint Le~ai and ~hYS~Cai CuStody of
tne cntm.
Respectfuiiy suomitteo
LEE.
PLALNfiFF
RONDA S. CARVER
:FN ~E COUR¥ OF C~ PLEAS
v. :~o o,~.5-w'-/ CiVLL ~rcv~
L~ A M~2S
PLAIN i
:CUSTODY
ORDER OF COURT
ANcO NOW, upon considerat~ of the attached eompiaint, ii is her64~y &ir~c~d th~ ~
Og :ti ,t.l,.j 91 33g ~0
RONDA S. CARVER
PLAINTIFF
Vo
LEE A. MYERS
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
02-5954 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Friday, December 20, 2002 .... upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, January 09, 2003 at 9:30 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.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FORTHE COURT,
By: /s/
Hubert X. Gilroy, Esq.(~,~
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 heating or business before the court. You must attend the
scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN AT-I'ORNEY 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
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No. O~- _~q
Civil. 19
Prothonotary
19
Attorney for Plaintiff
FILED-OFFICE
03 J,~.~ -8 P~ 3:
No.
Filed
PRAECIPE
19