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HomeMy WebLinkAbout03-1089Kimberly A. Haymire, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 03- i6 91 CIVIL TERM Jeffrey E. Haymire, : CIVIL ACTION - LAW Defendant : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case will proceed without you and a decree in divorce or annulment may be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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 LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Kimberly A. Haymire, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 03- /OF? CIVIL TERM Jeffrey E. Haymire, : CIVIL ACTION - LAW Defendant : IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Kimberly A. Haymire, an adult individual, currently residing at 1909 George Avenue, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Jeffrey E. Haymire, an adult individual, currently residing at 115 S. Charles St., Apt. A, Red Lion, York County, Pennsylvania 3. Plaintiff and Defendant are bonafide residents of the Commonwealth Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on August 23, 2001 in Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America, or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, the Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that Defendant will, after ninety days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce. COUNT II rl icrnnv 11. Paragraphs 1 through 11 are incorporated herein by reference as if set forth in their full text. 12. Plaintiff seeks custody of her child Kaitlyn Marie Haymire, born February 22, 2002, currently residing at 1909 George Ave., Carlisle, PA 17013. 13. The child is presently in the custody of Plaintiff. WHEREFORE, Plaintiff requests your Honorable Court to enter an Order and Grant custody of Kaitlyn Marie Haymire to the Plaintiff, Kimberly A. Haymire. Respectfully Submitted TURO LAW OFFICES 1/ za Date Robert J. ul erig, quire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Divorce 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. ?3 d3 Date t Kimberly A. Hay ire ?. . n" . ? ?,, ?. f? , ??' - " _.. ) . ?t'- ? i i'? y. ; . , e ?" --: c Jz -C A ?, ? ? ,? L? ? c i ,?. '.. ?? c a O ?„ c- v d ? ? Kimberly A. Haymire, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 03- / F7 CIVIL TERM Jeffrey E. Haymire, : CIVIL ACTION - LAW Defendant : IN DIVORCE COMPLAINT FOR CUSTODY 1. Plaintiff is Kimberly A. Haymire, an adult individual, currently residing at 1909 George Avenue, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Jeffrey E. Haymire, an adult individual, currently residing at 115 S. Charles St., Apt. A, Red Lion, York County, Pennsylvania. 3. Plaintiff seeks custody of her child Kaitlyn Marie Haymire, born February 22, 2002, currently residing at 1909 George Avenue, Carlisle, Cumberland County, Pennsylvania.. 4. The child is presently in the custody of Plaintiff. 5. Since the children's births, the children have resided at the following addresses: Name Address Dates Kimberly & Jeffrey Haymire 1909 George Ave. June 2002 - Present Carlisle, PA Kimberly & Jeffrey Haymire 351 Trayer Lane February 2002- June 2002 Carlisle, PA 6. The relationship of the Plaintiff to the children is that of natural mother 7. The relationship of the Defendant to the children is that of natural father. 8. The Plaintiff has not participated as a party or in any other capacity, in other litigation concerning the custody of the child in this or any other Court. 9. Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. 10. The best interest and permanent welfare of the child will be served granting the relief requested because the Plaintiff is the primary care giver with res to the child. 11. 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 this action. Not other persons are known to have or claim to have any right to custc or visitation of the child other than the parties to this action. WHEREFORE, Plaintiff requests your Honorable Court Date Respectfully Submitted TURO LAW OFFICES Robert J. ulderig, Es ire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Custody 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. Date Ki berly A. Ha mire r' ; t_ _ ?-- c;= , .?- _,_ r- i.: x _ ?.1 ?I ' ? 1 t + ? \ Kimberly A. Haymire, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 03-1089 CIVIL TERM Jeffrey E. Haymire, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT I served a true and correct copy of Divorce Complaint and Custody Complaint filed in the above captioned case upon Jeffrey E. Haymire, by certified mail, return receipt requested on March 12, 2003 addressed to: Jeffrey E. Haymire 115 S. Charles St.,, Apt. A Red Lion, PA 17356 and did thereafter receive same as evidenced by the attached Post Office receipt card dated March 13, 2003. 1 VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE 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. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. TURO LAW OFFICES 1 Date Robert J. Iderig, EsquirUR". 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff O r- m CO ru '/ 31I`I Postage ((2 $ O ? D/ ?I // ?' V ?p1?C?e (-?(,s'?Dp?{ cc ru Certified Fee O ' Postmark I' Return Receipt Fee (Endorsement Required) ) -2 / Here O O O Restricted Delivery Fee (Endorsement Required) 3,5D O Total Postage & Fees $ 8. 3 a UI r7J Sent To ` Street, Apt. N .; r 0 or PO Box No. ---- 2,4 111 l i O Cty, State, ZIP+4 J C! ZJd`/ -7 / 36-6 i > ?dre- e Ft 4us4 1Qrn-? SENDER: I Wei wish to receive the follow- w t] complete items 1 armor 2 for additional services. ing services (for an extra fee): Complete items 3, 4a, and 4b. • Print your name and address on the reverse of this form so that we can return this card to you. 1. ? Addressee's Address _ o Attach this form to the front of the mailpiece, or on the back if space does not permit. 2. estricted Delivery 17 Write 'Return Receipt Requested' on the mailpiece below the article number. 0 The Return Receipt will show to whom the article was delivered and the date o delivered. 3. Article Addressed to: -- ?Q -1, /YI, v'2 7001 2510 0009 2827 8370 4b. Service Type s ? Registered Certified ? Express Mail ? Insured F ? Return Receipt for Merchandise ? COD g ?-C / OvI? 10 7 35Lo 7. DatQ pf D/I' er, o UL? 5. Received By: (Print Name) S. Addressees Address (Only if requested and fee is paid) c ?. i re (Address or Agent) 0 PS Fo 381 December 1994 102595-99-B-=3 Domestic RNum Receipt ? +=_? ?? m ? ?° r Z ? ? ? -- :r r -- _' ? T . , ? ? `::? ?? -< t ? KIMBERLY A. HAYMIRE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 03-1089 CIVIL ACTION LAW JEFFREY E. HAYMIRE IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Monday, March 24, 2003 _______.,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, Wednesday, April 09, 2003 at 1:30 PM at 4th Floor, Cumberland County Courthouse, Carlisle on 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/ Tacaucline M. Ve?TCY, q, 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 FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 cSc+ ?r? A J ? : Kimberly A. Haymire, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 03-1089 CIVIL TERM Jeffrey E. Haymire, : CIVIL ACTION - CUSTODY Defendant CUSTODY PETITION 1. On April 4, 2003, the parties signed the attached Stipulation in the above- captioned case WHEREFORE, Plaintiff requests your Honorable Court to enter an Order incorporating said Stipulation. Respectfully Submitted TURO LAW OFFICES Z { Date Robert J. ulderig, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff Kimberly A. Haymire, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 03-1089 CIVIL TERM Jeffrey E. Haymire, : CIVIL ACTION - CUSTODY Defendant CUSTODY STIPULATION AND NOW, this day of 1 2003, it is hereby stipulated and agreed between the parties as follows: 1. Kaitlyn Marie Haymire, born February 22, 2002, currently residing ai 1909 George Avenue, Carlisle, Cumberland County, Pennsylvania is the natural child of Kimberly A. Haymire and Jeffrey E. Haymire. 2. Shared legal custody of the child as contemplated by the Act of October 30, 1985, P.L. 264, 23 P.S. §5301, et seg., will be in both of the parties, as the natural parents. 3. Primary physical custody of the child shall be in the mother subject to such periods of partial custody with the father as the parties may mutually agree. 4. The custodial parent shall inform the non-custodial parent immediately of all medical appointments and problems pertaining to the child. 5. Neither parent shall do or say anything which 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 child's love and respect for the other parent. 6. Both parents shall have liberal and reasonable telephone contact with the child when the child is in the custody of the other parent. 7. The custodial parent shall provide copies of the child's report card and other reasonable papers affecting the child's educat?n, medica?condition, or welfare. 4J, 63 Date Ki berly A. H mire `1- 3- o 3 lV, rz, L", z0i Date e v E. Havmi C) c--) t . 7 ?._: !a •? rT'i APR 0 8 2003 KIMBERLY A. HAYMIRE, Plaintiff V. JEFFREY E. HAYMIRE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-1089 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this 4ch day of April, 2003, the parties having advised the Conciliator that a stipulation has been signed, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, cqu ne M. Verney, Esquire, Custod onciliator t C:, r - -, F V =;t A40 7 Kimberly A. Haymire, 1003 : IN THE COURT OF! COMMON PLEAS OF Plaintiff : CUMBERLAND CO6NTY, PENNSYLVANIA V. : NO. 03-1089 CIVIL TERM Jeffrey E. Haymire, : CIVIL ACTION - CUSTODY Defendant ORDER OF COURT AND NOW, this _ day of ` 00 3, upon consideration of the within Stipulation, the parties agreement is hereby made an Order of Court. I RXS oy-fa-a3 BY THE COURT, ?',, i ???; ., ?? t. _ 1,.' `_; Kimberly A. Haymire, Plaintiff V. Jeffrey E. Haymire, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COI NTY, PENNSYLVANIA NO. 03-1089 CAVIL TERM I CIVIL ACTION - CU?TODY CUSTODY PETITION 1. On April 4, 2003, the parties signed the attached 'I Stipulation in the above- captioned case WHEREFORE, Plaintiff requests your Honorable Court to enter an Order incorporating said Stipulation. Respectfully Submittedl TURO LAW OFFICES Z,,? ! L/ ??3 Date Robert J. ulderig, E 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff Kimberly A. Haymire, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 03-1089 CIVIL ?BERM Jeffrey E. Haymire, : CIVIL ACTION - COSTODY Defendant CUSTODY STIPULATION AND NOW, this day of 2003, it is hereby stipulated and agreed between the parties as follows: 1. Kaitlyn Marie Haymire, born February 22, 21p02, currently residing at 1909 George Avenue, Carlisle, Cumberland County, Pennsylvania is the natural child of Kimberly A. Haymire and Jeffrey E. Haymire. 2. Shared legal custody of the child as contemplated by the Act of October 30, 1985, P.L. 264, 23 P.S. §5301, et seq., will be in both of the parties, as the natural parents. 3. Primary physical custody of the child shall be in tl?e mother subject to such periods of partial custody with the father as the parties may mutually agree. 4. The custodial parent shall inform the non-custodial parent immediately of all medical appointments and problems pertaining to the child. 5. Neither parent shall do or say anything which may estrange the child from the other parent, injure the opinion of the child as to the other Oarent or hamper the free and natural development of the child's love and respect for the?other parent. 6. Both parents shall have liberal and reasonable t4lephone contact with the child when the child is in the custody of the other parent. 7. The custodial parent shall provide copies of the child's report card and other reasonable papers affecting the child's education, medicl?condition, or welfare. Date Ki berly A. H mire Date e v E. Hav i Q r_.> r? L co ?z " n i ^ GT ( I CT7 ? L?\ ihhit{) A. Ndyw7? AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on March 12th, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. 1 consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. 1 VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT 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. Date Kim erly A. Hay ire ,._, ; > -„ <?? , ;:> .. .. ?> KIMBERLY A. HAYMIRE, Plaintiff V. JEFFREY E. HAYMIRE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 03-1089 CIVIL TERM IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER & 3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final Decree of Divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. 4. 1 have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT 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. j - Date _? -s ^, z KIMBERLY A. HAYMIRE, Plaintiff v JEFFREY E. HAYMIRE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1089 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on March 12, 2003. 2. Defendant acknowledged receipt and accepted service of the Complaint on March 13, 2003. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. 1 consent to the entry of a final decree in divorce without notice. 5. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 6. 1 understand that I will not be divorced until a divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. 7. 1 have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.S/ection 4904 relating to unsworn falsification to authorities. Date: , `7- Z 2 - os- 90LVy ffi . Hay ire, Defendant ' `„ r c? . , . . .? u: ,' .. ?, -- ;- ?,. C`' Kimberly A. Haymire, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 03-1089 CIVIL TERM Jeffrey E. Haymire, : CIVIL ACTION - LAW Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the court for entry of a Divorce Decree: 1. Ground for divorce: irretrievable breakdown under § (3301(c)) of the Divorce Code. 2. Date and manner of service of the complaint: Certified, Returned Receipt mail delivered on or about March 13, 2003. 3. Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce Code: 4. By Plaintiff: May 16, 2005. Related claims pending: None. Date the Waiver of Notice in §3301(c) divorce was filed with the By Defendant: April 27, 2005 Prothonotary: By Plaintiff: May 18, 2005 By Defendant: May 18, 2005 Michael M. Jeromihski, Esquire Attorney for Plaintiff Supreme Court I.D. No. 92977 Turo Law Offices 28 South Pitt Street Carlisle, PA 17013 r-, ui -r? r _.I ,.. ?.- __ __ \l ,•7 -rte.., C?: ??' ?;? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Kimberly A. Haymire Plaintiff No. 03-1089 VERSUS Jeffrey E. Haymire Defendant DECREE IN DIVORCE AND NOW, IM Z`I 2005 , IT IS ORDERED AND DECREED THAT Kimberly A. Haymire PLAINTIFF, AND Jeffrey E. Haymire DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; BY THE COURT: ATTESTF/ v J. V PROTHONOTARY f? 3? avL -;O `fir S KIMBERLY A. HAYMIRE, Plaintiff V JEFFREY E. HAYMIRE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1089 CIVIL TERM IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY ORDER 1. The petitioner is Jeffrey E. Haymire, residing at 115A South Charles Street, Red Lion, York County, Pennsylvania. 2. The respondent is Kimberly A. Haymire, residing at 1909 George Avenue, Carlisle, Cumberland County, Pennsylvania. 3. This Honorable Court issued an Order in this matter on April 10, 2003, based upon a stipulation by the parties. Said order and stipulation are attached and marked Exhibit "A". 4. Petitioner is seeking overnight periods of partial custody with his daughter whom he believes is now old enough to be comfortable doing so. 5. Respondent has been unwilling to allow this to date. Wherefore, Petitioner respectfully requests the court grant him periods of overnight partial custody with the child. Respectfully submitted, L' dsay Dare Baird, squire 7 South Hanover Carlisle, PA 17013 Attorney for Petitioner I verify that to best of my knowledge and belief, the statements made in this Complaint are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S.§4904 relating to unsworn falsification to au o i ies. E. aymire Petitioner APR 0 7 20 Kimberly A. Haymire, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 03-1089 CIVIL TERM Jeffrey E. Haymire, : CIVIL ACTION - CUSTODY Defendant ORDER OF COURT AND NOW, this IUD day of A b %A 2003, upon consideration of the within Stipulation, the parties agreement is hereby made an Order of Court. BY THE COURT, ):5j LA J J. MIBIT "A„ TRUE C07 'y FROM In Tas#irrcn/ whsrc;;?, I h?re In,,, s? t"Iy hand afld the Seal of Magid {?ur' a# Ca ii'+e, Pa. E'rLth notety' - Kimberly A. Haymire, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 03-1089 CIVIL TERM Jeffrey E. Haymire, : CIVIL ACTION - CUSTODY Defendant n c-, o c n- o CUSTODY PETITION >- - sv -n On April 4, 2003, the parties signed the attached Stipulation in the 6ove- captioned case WHEREFORE, Plaintiff requests your Honorable Court to enter an Order incorporating said Stipulation. i ? Date Respectfully Submitted TURO LAW OFFICES J 41- Robert J.Mulderig, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff Kimberly A. Haymire, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 03-1089 CIVIL TERM Jeffrey E. Haymire, : CIVIL ACTION - CUSTODY Defendant CUSTODY STIPULATION AND NOW, this day of , 2003, it is hereby stipulated and agreed between the parties as follows: 1. Kaitlyn Marie Haymire, born February 22, 2002, currently residing at 1909 George Avenue, Carlisle, Cumberland County, Pennsylvania is the natural child of Kimberly A. Haymire and Jeffrey E. Haymire. 2. Shared legal custody of the child as contemplated by the Act of October 30, 1985, P.L. 264, 23 P.S. §5301, et seq., will be in both of the parties, as the natural parents. 3. Primary physical custody of the child shall be in the mother subject to such periods of partial custody with the father as the parties may mutually agree. 4. The custodial parent shall inform the non-custodial parent immediately of all medical appointments and problems pertaining to the child. 5. Neither parent shall do or say anything which 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 child's love and respect for the other parent. 6. Both parents shall have liberal and reasonable telephone contact with the child when the child is in the custody of the other parent. 7. The custodial parent shall provide copies of the child's report card and other reasonable papers affecting the child's education, medical condition, or welfare. Date Ki erly A. Ha mire Date Je y E. Ha m' e ( T...1 t}1 __1 y d L 4 U C? r- KIMBERLY A. HAYMIRE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 03-1089 CIVIL ACTION LAW JEFFREY E. HAYMIRE IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, February 07, 2006 __, 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 Tuesday, March 07, 2006 at 1030 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues it) 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: IsL__Jacqueline M i erney?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 FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ;? KIMBERLY A. HAYMIRE, Plaintiff v JEFFREY E. HAYMIRE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1089 CIVIL TERM IN CUSTODY STIPULATION FOR CUSTODY "A"ff STIPULATION made this ?41day of J.y, 2006, between Kimberly A. Haymire, hereinafter referred to as Mot het, and Jeffrey E. Haymire, hereinafter referred to as Father. WHEREAS, the above-named Mother and Father had born to them the following child on the following date: NAME Kaitlyn Marie Haymire BIRTH DATE February 22, 2002 AND WHEREAS, the above-named Mother and Father desire to enter into a Stipulation as to the custody of the above-said child and to the partial custody rights of the non-custodial parent: NOW, THEREFORE, in order to effectuate the above purpose, the above-named Mother and Father hereby stipulate that: 1. The parties shall share legal custody of the child. 2. The Mother shall have primary physical custody of the child. 3. The Father shall have periods of partial custody for a day at a time to begin with expanding to overnights as the parties agree is in Kaitlyn's best interest. TO THIS PURPOSE, The parties hereto intend to be legally bound by the terms of this Stipulation and desire to have the Stipulation entered as an Order of Court. Witness: i zzq? ?X??Vn indsay D re air ,Esq. Kim rly A. Haymir other 4L f- 4""", of a E. Haymire, ather KIMBERLY A. HAYMIRE, Plaintiff v JEFFREY E. HAYMIRE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1089 CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW, this I day of ?_, 2006, upon consideration of the attached custody stipulation with respect to the parties' child, Kaitlyn Marie Haymire, born February 22, 2002, the terms of the stipulation are entered as an order of court. BY THE COURT, ,,-t?'indsay Dare Baird, Esquire 37 South Hanover Street Carlisle, PA 17013 Attorney for Father 11'. Kimberly A. Haymire 1909 George Avenue Carlisle, PA 17013 Mother 03 ?. V E ! -Z Pi L ! ?VW of KIMBERLY A. HAYMIRE, Plaintiff v JEFFREY E. HAYMIRE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1089 CIVIL TERM IN CUSTODY STIPULATION FOR CUSTODY ow" STIPULATION made this / day of fabency, 2006, between Kimberly A. Haymire, hereinafter referred to as Mothe , and Jeffrey E. Haymire, hereinafter referred to as Father. WHEREAS, the above-named Mother and Father had born to them the following child on the following date: NAME Kaitlyn Marie Haymire BIRTH DATE February 22, 2002 AND WHEREAS, the above-named Mother and Father desire to enter into a Stipulation as to the custody of the above-said child and to the partial custody rights of the non-custodial parent: NOW, THEREFORE, in order to effectuate the above purpose, the above-named Mother and Father hereby stipulate that: 1. The parties shall share legal custody of the child. 2. The Mother shall have primary physical custody of the child. 3. The Father shall have periods of partial custody for a day at a time to begin with expanding to overnights as the parties agree is in Kaitlyn's best interest. TO THIS PURPOSE, The parties hereto intend to be legally bound by the terms of this Stipulation and desire to have the Stipulation entered as an Order of Court. Kim rly A. Haymir other ?- mdsay D re air ,Esq. Aeen7E. Haymire, ather OP RECEIVED MAR 23 Fl KIMBERLY A. HAYMIRE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 03-1089 CIVIL ACTION - LAW JEFFREY E. HAYMIRE, Defendant IN CUSTODY ORDER OF COURT AND NOW, this 23`d day of March, 2006, being advised that the parties have reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, 4acgtaline M. Verney, Esquire, Custod onciliator r o :1I ?V U dui'! 9u0Z a 4 KIMBERLY A. HAYMIRE, Plaintiff V. JEFFREY E. HAYMIRE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1089 CIVIL TERM IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY ORDER 1. The petitioner is Jeffrey E. Haymire, residing at 115A South Charles Street, Red Lion, York County, Pennsylvania. 2. The respondent is Kimberly A. Haymire, residing at 1909 George Avenue, Carlisle, Cumberland County, Pennsylvania. 3. This Honorable Court issued an Order in this matter on March 16, 2006, based upon a stipulation by the parties. Said order and stipulation are attached and marked Exhibit "A'. 4. Petitioner is seeking overnight periods of partial custody with his daughter whom he believes is now old enough to be comfortable doing so. 5. Respondent has been unwilling to allow this to date. Wherefore, Petitioner respectfully requests the court grant him periods of overnight partial custody with the child. Respectfully submitted, '(.Lvt 1 t.L dsay Dare Bai It Esqui e `_y 37 South Hand r Carlisle, PA 17013 Attorney for Petitioner I verify that to best of my knowledge and belief, 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 au orities. Jeffrey t. Haymi e Petitioner KIMBERLY A. HAYMIRE, Plaintiff v JEFFREY E. HAYMIRE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1089 CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW, this day of 1A h , 2006, upon consideration of the attached custody stipulation with respect to the parties' child, Kaitlyn Marie Haymire, born February 22, 2002, the terms of the stipulation are entered as an order of court. Lindsay Dare Baird, Esquire 37 South Hanover Street Carlisle, PA 17013 Attorney for Father Ms. Kimberly A. Haymire 1909 George Avenue Carlisle, PA 17013 Mother t y t i BY THE COURT, KIMBERLY A. HAYMIRE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V : NO. 03-1089 CIVIL TERM JEFFREY E. HAYMIRE, : IN CUSTODY Defendant : _-..a STIPULATION FOR CUSTODY STIPULATION made this ?L day of? , 2006, between Kimberly A. Haymire, hereinafter referred to as Moth, and Jeffrey E. Haymire, hereinafter referred to as Father., WHEREAS, the above-named Mother and Father had born to them the following child on the following date: NAME Kaitlyn Marie Haymire BIRTH DATE February 22, 2002 AND WHEREAS, the above-named Mother and Father desire to enter into a Stipulation as to the custody of the above-said child and to the partial custody rights of the non-custodial parent: NOW, THEREFORE, in order to effectuate the above purpose, the above-named Mother and Father hereby stipulate that: 1. The parties shall share legal custody of the child. 2. The Mother shall have primary physical custody of the child. 3. The Father shall have periods of partial custody for a day at a time to begin with expanding to overnights as the parties agree is in Kaitlyn's best interest. TO THIS PURPOSE, The parties hereto intend to be legally bound by the terms of this Stipulation and desire to have the Stipulation entered as an Order of Court. Witness: i /Ifindsay Dare airc)%Esq. t Kimtrly A. Haymire other ? F . "' a !. Haymire, ather T 1-- 7: T L ?L KIMBERLY A. HAYMIRE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JEFFREY E. HAYMIRE DEFENDANT 03-1089 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, October 13, 2006 , 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 Thursday, November 09, 2006 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 THE COURT, 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 FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ?? ? tG?-? ?`? . ?? ?o C. / ? a/ ?:?' ?? -? _, s ? ?-?, ,E ,?? KIMBERLY A. HAYMIRE, Plaintiff v JEFFREY E. HAYMIRE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1089 CIVIL TERM IN CUSTODY STIPULATION FOR CUSTODY STIPULATION made this day of 8etelaeF 2006, between Kimberly A. Haymire, hereinafter referred to as Moth r, and Jeffrey E. Haymire, hereinafter referred to as Father. WHEREAS, the above-named Mother and Father had born to them the following child on the following date: NAME Kaitlyn Marie Haymire BIRTH DATE February 22, 2002 AND WHEREAS, the above-named Mother and Father desire to enter into a Stipulation as to the custody of the above-said child and to the partial custody rights of the non-custodial parent: NOW, THEREFORE, in order to effectuate the above purpose, the above-named Mother and Father hereby stipulate that: 1. The parties shall share legal custody of the child. 2. The Mother shall have primary physical custody of the child. 3. The Father shall have periods of partial custody for one overnight every other weekend for a few weekends then expanding to Friday afternoon through Sunday evening every other weekend as soon as Kaitlyn is ready. TO THIS PURPOSE, The parties hereto intend to be legally bound by the terms of this Stipulation and desire to have the Stipulation entered as an Order of Court. Witness: Ally 6 i r L? _--f 4mby A. aymir , Mother 1:2w ze LG'Ql /rte • Lindsay Dare Baird, Es qefl4y . Haymire, ather 1. .• c'„? ? ? ? ?. s'.- ? C°'* . -? ? ?» ++rs i?? ` _.i?1...1 __ ? / y ? ._ ? ?, ?..'7 __ r^<'-f ? J ?_1 _+-J. . ?{ '? NOV 0 8 2006 KIMBERLY A. HAYMIRE, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2003-1089 CIVIL ACTION - LAW JEFFREY E. HAYMIRE, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 7"' day of November, 2006, being advised that the parties have reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, A154 ac line M. Verney, Esquire, Cu y Conciliator 6 0 'Ai -10 6 Nov la zone 0d %v KIMBERLY A. HAYMIRE, Plaintiff v JEFFREY E. HAYMIRE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03-1089 CIVIL TERM : IN CUSTODY ORDER OF COURT AND NOW, this day of 0 , 2006, upon consideration of the attached custody stipulation with respect to the parties' child, Kaitlyn Marie Haymire, born February 22, 2002, the terms of the stipulation are entered as an order of court. Lindsay Dare Baird, Esquire 37 South Hanover Street Carlisle, PA 17013 Attorney for Father Ms. Kimberly A. Haymire 1909 George Avenue Carlisle, PA 17013 Mother -w BY THE COURT, ,r ,,,?r? 1?,.?.?,y? `? ??. vWv 1 a IVY/ 9/ JUN 18 2007 JEFFREY HAYMIRE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-2563 CIVIL ACTION - LAW KIMBERLY ANN HAYMIRE, . Defendant : IN CUSTODY KIMBERLY A. HAYMIRE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2003-1089 CIVIL ACTION - LAW JEFFREY E. HAYMIRE, : IN CUSTODY Defendant ORDER OF COURT AND NOW, this day of T ?„ c- , 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A Hearing is scheduled in Court Room No. of the Cumberland County Court House, on the - day of , 2007, at 136 o'clock, --&. M., at which time testimony will be taken. For purposes of this Hearing, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten days prior to the Hearing date. 2. The case at docket number 2003-1089 is hereby consolidated with this docket. The prior Order of Court dated March 16, 2006 is hereby vacated. 3. The Father, Jeffrey Haymire and the Mother, Kimberly Ann Haymire, shall have shared legal custody of Kaitlyn Marie Haymire, born February 22, 2002. 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. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be -Y ,no 111 0 ;9 111V U FlAr «OZ ZIHI do entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 4. Mother shall have primary physical custody of the child. 5. Father shall have periods of partial physical custody on alternating weekends beginning Friday June 15, 2007 from Friday at 6:00-6:30 p.m. to Sunday at 6:00-6:30 p.m. 6. Christmas shall be divided into two Blocks. Block A shall be from Christmas Eve at 2:00 p.m. to Christmas Day at 2:00 p.m. Block B shall be from Christmas Day at 2:00 p.m. to December 26 at 2:00 p.m. Mother shall always have physical custody of the child for Block A and Father shall always have physical custody of the child for Block B. 7. All other holidays shall be split by the parties. 8. Father shall always have physical custody of the child for his family reunion. 9. Father shall always have physical custody of the child on Father's Day and Mother shall always have physical custody of the child on Mother's Day. 10. Both parties shall have physical custody of the child for 2 non-consecutive weeks in the summer provided they give the other party 30 days prior notice. 11. Transportation shall be shared such that the parties shall exchange custody at the route 174/74 crossroads. 12. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, cc: ?1 k F. Bayley, Esquire, counsel for F ,mberly Ann Haymire, pro se 1909 George Avenue Carlisle, PA 17013 J r _ f-V o?% JEFFREY HAYMIRE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-2563 CIVIL ACTION - LAW KIMBERLY ANN HAYMIRE, . Defendant : IN CUSTODY KIMBERLY A. HAYMIRE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2003-1089 CIVIL ACTION - LAW JEFFREY E. HAYMIRE, : IN CUSTODY Defendant PRIOR JUDGE: J. Wesley Oler, Jr., J. 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 IN CUSTODY OF Kaitlyn Marie Haymire February 22, 2002 Mother 2. A Conciliation Conference was held June 12, 2007 with the following individuals in attendance: The Father, Jeffrey Haymire, with his counsel, Mark F. Bayley, Esquire, and the Mother, Kimberly Ann Haymire, pro se. 3. The Honorable J. Wesley Oler, Jr. previously entered an Order of Court dated March 16, 2006 at Docket Number 2003-1089, providing for shared legal custody, Mother having primary physical custody and Father having alternating weekends. 4. Father's position on custody is as follows: Father seeks shared legal and periods of partial physical custody on alternating weekends. He requests shared transportation, for the parties to meet at Baker's in Dillsburg, since Mother lives in Carlisle and Father lives in Dover. 5. Mother's position on custody is as follows: Mother seeks shared legal and primary physical custody with Father having alternating weekends. Mother maintains that Father should be responsible for all transportation but is willing to meet at the route 174/74 crossroads to exchange custody. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing, consolidating the dockets, vacating the prior Order and ordering shared legal custody, Mother having primary physical custody and Father having alternating weekends. Pending the hearing the parties shall exchange custody at the route 174/74 crossroads. It is expected that the Hearing will require one-half day. (0-( q ?67 Date V( ac eline M. Verney, Esquire Custody Conciliator Jeffrey Haymire, Plaintiff V. Kimberly Ann Haymire, Defendant In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2007-2563 Civil Action Law In Custody Kimberly A. Haymire, In the Court of Common Pleas of Plaintiff Cumberland County, Pennsylvania V. No. 2003-1089 Civil Action Law Jeffrey E. Haymire, In Custody Defendant MOTION FOR CONTINUANCE AND NOW, .comes Jeffrey Haymire, by and through his attorney, Mark F. Bayley, Esquire, and in support of the within motion avers as follows: 1. A hearing with regard to the above custody matter was previously scheduled for October 4, 2007 at 9:30 AM. 2. The sole issue to be decided at the hearing relates to where the parties will exchange the child. 3. Undersigned counsel does not expect testimony on this issue to exceed one- half hour. 4. ` Undersigned counsel has been scheduled for argument court in Franklin County for the same morning which is only held once a month. 5. Undersigned counsel would prefer to continue the custody hearing to a later date to solve this conflict. 6. Ms. Haymire is pro se and her position with regard to this motion is unknown. WHEREFORE, undersigned counsel respectfully requests a continuance to the hearing currently scheduled for October 4, 2007. Respectfully submitted, BAYLEY & MANGAN Date: Mark F. Bayley, Esquire 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D. # 87663 Attorney for Jeffrey Haymire V F Jeffrey Haymire, In the Court of Common Pleas of Plaintiff Cumberland County, Pennsylvania V. No. 2007-2563 Civil Action Law Kimberly Ann Haymire, Defendant In Custody Kimberly A. Haymire, in the Court of Common Pleas of Plaintiff Cumberland County, Pennsylvania V. No. 2003-1089 Civil Action Law Jeffrey E. Haymire, In Custody Defendant VERIFICATION Mark F. Bayley, Esquire, states that he is the attorney for Jeffrey Haymire, in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. Pa.C.S. §4904, relating to unworn falsification to authorities. Date: ? Mark F. Bayley, Esquir Attorney for Jeffrey Haymire S Jeffrey Haymire, In the Court of Common Pleas of Plaintiff Cumberland County, Pennsylvania V. No. 2007-2563 Civil Action Law Kimberly Ann Haymire, Defendant In Custody Kimberly A. Haymire, In the Court of Common Pleas of Plaintiff Cumberland County, Pennsylvania V. No. 2003-1089 Civil Action Law Jeffrey E. Haymire, In Custody Defendant CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Jeffrey Haymire, do hereby certify that I this day served a copy of the Motion for Continuance upon the following by fax and depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Dated: Kimberly Ann Haymire 909 George Ave. Carlisle, PA 17013 -VIA Mark F. Bayley, Esq ire Attorney for Jeffrey Haymire 1 JEFFREY HAYMIRE, Plaintiff V. KIMBERLY ANN HAYMIRE, Defendant KIMBERLY A. HAYMIRE, Plaintiff V. JEFFREY HAYMIRE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-2563 CIVIL TERM IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 03-1089 CIVIL TERM ORDER OF COURT AND NOW, this 7t' day of December, 2007, following a hearing on December 6, 2007, on the issue of where exchanges of custody should occur with respect to the parties child, Kaitlyn Marie Haymire (d.o.b. February 22, 2002), and it appearing that both parties believe that the exchange point provided for in the Order of Court dated June 19, 2007, is no longer satisfactory, the exchange point hereafter shall be at Baker's Restaurant on Route 15, Dillsburg, Pennsylvania. BY THE COURT, r' L<7 ' J" Wesley Olen-Y, J. Mark F. Bayley, Esq. 57 West Pomfret Street Co r•" er'.0tLr-c Carlisle, PA 17013 Attorney for Father /;./?/0 7 ,r ????C/ ?? ???? ?? ?' ? ,?? Kimberly A. Haymire 909 George Avenue Carlisle, PA 17013 Mother, pro Se :rc JEFFREY HAYMIRE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW KIMBERLY ANN HAYMIRE, Defendant NO. 2007-2563 CIVIL TERM ************************************** KIMBERLY ANN HAYMIRE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW JEFFREY HAYMIRE, Defendant N0. 2003-1089 CIVIL TERM ORDER OF COURT AND NOW, this 6th day of December, 2007, upon consideration of the custodial issue in the above-captioned case of where the exchanges of custody should occur with respect to the parties' child and following a hearing on that issue, the record is declared closed and the matter is taken under advisement. By the Court, ,Xa"rk F. Bayley, Esquire 17 W. South Street Carlisle, PA 17013 For the Plaintiff/Defendant J?'Wesley r, Jr-, J. J ,,,?iberly A. Haymire, Defendant/Plaintiff Pro Se 1909 George Avenue Carlisle, PA 17013 pcb V? ?n 1a Tes0mv whereof, i here wrio set my and Mo eW of said court at Caruste ''. -7 dam I'A ku Ant. `? ? ? t? ?_ . ,? o,? -n q t gib, ?? ??3t ?? ? ? ? ?X ?? ^' g ? '?" a `? 1..