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HomeMy WebLinkAbout02-6085RICHARD PEYSER, Plaintiff THERESA PEYSER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002- ~ o ga"' CIVIL TERM : : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Richard Peyser, an adult individual currently residing at 1640 Williams Grove Road, Dillsburg, Cumberland County, Pennsylvania 17019. 2. Defendant is Theresa Peyser, an adult individual currently residing at 5446 Autumn Drive, Harrisburg, Dauphin County, Pennsylvania 17111. 3. The Plaintiff is the natural father of the children, Tristen Peyser, bom August 4, 1994; Johnathan Peyser, bom April 8, 1992; and Matthew Peyser, bom 18, 2000. 5. following addresses for the following lengths of time: The children were bom in wedlock. For the past five years, the children have resided with the following persons at the NAME ADDRESS DATES Theresa Peyser 5446 Autumn Drive May 2002 to Harrisburg, PA present 1640 Williams Grove Road Dillsburg, PA Richard Peyser Theresa Peyser o married. 7. is married. 1997 to May 2002 The natural father of the children is the Plaintiff, who resides as foresaid. He is The natural mother of the children is the Defendant, who resides as foresaid. She 8. The relationship of the Defendant to the children is that of natural mother. The Defendant currently resides with the children. 9. The relationship of the Plaintiff to the children is that of natural father. The Plaintiff currently resides alone. 10. The Plaintiff has no infom~ation of a custody proceeding concerning the children pending in any Court of this Commonwealth. 11. The Plaintiff does not know of any person not a party to the proceedings who claims to have custody or visitation fights with respect to the children. WHEREFORE, the Plaintiff, Richard Peyser, respectfully requests this Honorable Court to enter an Order scheduling the Parties for a Custody Conciliation. Date: E)I::C 1 6 2002 Respectfully submitted, Thomas S. DieM, Esquire Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 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. § 4904, relating to unsworn falsification to authorities. mCHARD RICHARD PEYSER PLAINTIFF Vo THERESA PEYSER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-6085 CIVIL ACTION LAW CUSTODY ORDER OF COURT AND NOW, Friday, January 03, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear betbre Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, January 22, 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. FOR THECOURT, By: /s/ Jacqueline 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 hearing 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 ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTIt BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 RICHARD PEYSER, Plaintiff THERESA PEYSER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-6085 CIVIL TERM : : CIVIL ACTION - LAW : IN CUSTODY PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: On January 3, 2003, the above-captioned Plaintiff filed a Custody Complaint. It has since been determined that Dauphin County has jurisdiction of the children at issue, and would therefore be a more appropriate venue. Accordingly, the Plaintiff respectfully requests that this matter be discontinued. Respectfully submitted: DATE: February 7, 2003 ~~Esqmre Attorney for Plaintiff One West High Street, Suite 208 Post Office Box 1290 Chambersburg, Pennsylvania 17201 (717) 240-0833 MAY 13 ZO03~ RICHARD PEYSER, Plaintiff V. THERESA PEYSER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-6085 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT AND NOW, this 13th day of May, 2003, the Conciliator not being contacted for another Conciliation Conference for 90 days, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, ~cqu01ine M. Vemey, Esquire, Custodydgonciliatm