HomeMy WebLinkAbout98-00529
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Plaintiff
IN THE COURT OF COMMON PLEAS
CUMllERLAND COUNTY. PENNSYLVANIA
CIVIL ACTION - LAW
NO, 9f~I:~9 ~IU~'( ~/2..J'1
CUSTODY
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JASON ALLOYER.
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JACAL YN ALLOYER,
Defendant
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ORDER OF COURT
AND NOW. this (date) \ 12Ftlq 8 ,upon consideration of the attached cpmplaint, it i hereby
direc.t~d that ~~~~Il\n'hthe~~ct~e cPJw~el appear before .' 'I-x" ( (0 .-'.' the
concIliator, at r'0.<-\ ((~ qJ, .\€-on the ") day of \v\rN i, , 199~, at ~M.,
for a Prehearing 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. Either party may bring the child who is the
subject of the custody action to the conference, but the child/children's attendance is not
mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or
permanent order.
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For the Court,
By: J{l.ill)f'i\-k- Y. ~~.
Custody Conciliator (1)):')
YOU SHOULD 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 LEOAL HELP.
OFFICE OF THE COURT ADMINISTRATOR
CUMBERLANDCOUNTYCOURTHOUSE,FOURTHFLOOR
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 240-6200
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Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
JASON ALLOYER,
V
JACAL YN ALLOYER,
Defendant
NO. 'I'r.:;.) tf {!W.:.t '-';,,0-
CUSTODY
COMPLAINT FOR CUSTODY
1. The plaintiff is Jason Allgyer, residing at 1428 Bradley Drive #J212, Carlisle, 17103,
Cumberland County, Pennsylvania.
2. The defendant is Jacalyn Allgyer, residing at 949 Oreenspring Road, Newville,
17241, Cumberland County, Pennsylvania.
3. Plaintiff seeks custody of the following child:
Name
Present Residence
Born
KaitIyn Deanna Allgyer
1428 Bradley Drive #J212,
April 30, 1995
The child was not born out of wedlock.
The child is presently in the custody of the plaintiff, Jason Allgyer.
During the child's lifetime she has resided with the following persons and at the following
addresses:
Name
Address
Date
Jason Allgyer
1428 Bradley Drive #J212
Carlisle, PA 17013
Sept 1997 - present
(3 Ih days per week)
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Jacalyn AlIgyer 949 Greenspring Road Sept 1997- present
Neville, PA 17013 (3 'h days per week)
Jason AlIgyer 1428 Bradley Drive #J212 January 1996 - Present
Carlisle, PA 17013
Jason AlIgyer & 1428 Bradley Drive #J212 Sept. 1995 - Jan. 1996
John Goddard (Friend) Carlisle, PA 17013
Jason AlIgyer & 1428 Bradley Drive #1212 April 30 - Sept. 1995
Jacalyn AlIgyer Carlisle, PA 17013
4. The relationship of plaintiff to the child is that of Father.
5. The relationship of defendant to the child is that of Mother.
6. Plaintiff has not participated as a party or witness, or in another capacity, in other
litigation concerning the custody of the child in this or another court.
7. Plaintiff has no information of a custody proceeding concerning the child pending in a
court of this Commonwealth.
8. 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.
9. The best interest and permanent welfare of the child will be served by granting the
relief requested because the Father has provided a stable, loving environment since the Mother's
voluntary separation from the marital home in September 1995, and only recently, since
September 1997, has the Mother exercised partial custody in that the Mother has the child
approximately 3 'h days per week.
10. Each parent whose parental rights to the child have not been terminated and the
person who has physical custody of the child have been named as parties to this action.
WHEREFORE, the plaintiff, JASON ALLGVER, respectfully requests lhis Court to
grant primary physical custody of the child to the plaintifF with the Mother having partial custody
at times to be determined at the Custody Conference.
Respectfully submitted,
Austin F. Grogan sq
Attorney For PlaintiFf
24 North 32'1<1 Street
Camp Hill, PA 17011
(717) 737-1956
ID # 59020
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JASON ALLGYER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
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V
:CIVIL ACTION - LAW
JACALYN ALLGYER,
Defendant
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:NO: 98-529 CIVIL TERM
: IN CUSTODY
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:
Kaitlyn Deanna Allgyer, born April 30, 1995.
2. A Conciliation Conference was held on March 5, 1998, with the
following individuals in attendance:
The Father, Jason Allgyer, with his counsel, Austin F. Grogan,
Esquire; and the Mother Jacalyn Allgyer, with her counsel,
Wayne F. Shade, Esquire.
3. The parties agreed to the entry of an Order in the form as
attached.
31 tt/ p)j
DATE
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