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HomeMy WebLinkAbout01-5727BRETT L. COY, Petitioner SUMMER R. COY, Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 2001 -~'7o~'~CIVIL TERM : IN CUSTODY PETITION FOR CUSTODY AND NOW, this ~ day o£~2001, comes the Petitioner, Brett L. Coy, by his attorneys, Irwin, McKnight and Hughes, and presents the following Petition for Custody. The petitioner is Brett L. Coy, an adult individual residing at 632 Brandy Run Road, Newville, Cumberland County, Pennsylvania 17241. The respondent is Summer R. Coy, an adult individual residing at One Willow Lane, Carlisle, Cumberland County, Pennsylvania 17013. The parties are the natural parents of one minor child, namely Taylor L. Coy, born November 21, 1997. Petitioner desires primary physical custody of the minor child and joint legal custody with periods of visitation to respondent as can be mutually arranged between the parties. The best interest of the minor child requires that the court grant the petitioner's request as set forth above. WHEREFORE, petitioner respectfully seeks the entry of an Order of Court seeking primary physical custody of the minor child and joint legal custody with periods of visitation to respondent as can be mutually arranged between the parties. Respectfully submitted, IRWIN, McKNIGHT & HUGHES ~i~'~squire Carlisle, Pennsylvania 17013 (717) 249-2353 Supreme Court I. D. No. 25476 Date: September 28, 2001 VERIFICATION The foregoing Petition for Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have head the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unswom falsification to authorities. Date: September 28, 2001 BRETT L. COY : PLAINTIFF V. SUMMER R. COY DEFENDANT : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-5727 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, October 04, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, October 31, 2001 at 10:30 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. FOR THE COURT, By: /s/ .Iacqueline M. Verney. 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 heating. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 V]NYA1ASNN_qd LO :8 [,acl ~- L3O 10 OCT BRETT L. COY, Plaintiff SUMMER R. COY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA _. : NO. 2001-5727 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY TEMPORARY ORDER OF COURT ANDNOW, this Ifl~ dayof ~~1 ,2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Brett L. Coy and the Mother, Summer R. Coy, shall have shared legal custody of Taylor L. Coy, bom November 21, 1997. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the C ' ' · · hild s general well-being mcluding, but not limited to, all decisions regarding her health, education and religion. 2. Mother and Father shall share physical custody of the child on the following schedule: a. Week on/week off from Thursday at 5:30 p.m. to Thursday at 5:30 p.m. Said week on/week off schedule shall begin Thursday, November 1,2001 with Father having the first week. b. Each parent shall be entitled to have a block of time with the child on the child's birthday at times as agreed by the parties. c. Mother shall have physical custody of the child on Mother's Day; Father shall have physical custody of the child on Father's Day; both at times agreed by the parties. d. The Christmas holiday shall be divided into two blocks. Father shall have physical custody of the child from 12:00 noon December 23 to Christmas Eve until 9:00 p.m. and Mother shall have physical custody from 9:00 p.m. Christmas Eve to Christmas Day at 12:00 Noon. e. The parties shall alternate the following holidays at times agreed by the parties: Thanksgiving, Easter, Memorial Day, July 4 and Labor Day. Father shall have physical custody on Thanksgiving, 2001. 3. The parties shall keep each other advised immediately relative to any medical care or medical emergencies concerning the child and shall further take any necessary steps to ensure that the health and well being of the child is protected. During such illness or medical emergency, both parents shall have the right to visit the child as often as he/she desires consistent with the proper medical care of the child. 4. Neither parent shall do or say anything nor let anyone in the child's presence to say or do anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent or hamper the free and natural development of the children's love o,,,~ ~,~* .~ap~ct lot [ne omer parent. parties. The receiving party shall transport the child unless otherwise agreed by the 6. The parties have agreed not to seek child support while they share physical custody of the child. 7. 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 terms of this Order shall control. cc: Marcus A. McKnight, III, Esquire, Counsel for Father .~ Summer R. Coy, pro se One Willow Lane Carlisle, PA 17013 - BRETT L. COY, Plaintiff V. SUMMER R. COY, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA .. : 2001-5727 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY 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 CURRENTLY 1N CUSTODY OF Taylor L. Coy November 21, 1997 Mother 2. A Conciliation Conference was held in this matter on October 31,2001, with the following individuals in attendance: The Father, Brett L. Coy, with his counsel, Marcus a. McKnight, III, Esquire, and the Mother, Summer R. Coy, who appeared without counsel but with her Father. 3. The parties agreed to entry of an Order in the form as attached. Date ~9(cqm(l{ne M. Vemey, Esquire Custody Conciliator