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HomeMy WebLinkAbout98-07316 ~ ~ ~ ~ ! "- ) It i~ '1 ~ "'\' ~ ~ < ,^ ; q: !e- " ~ 'I.. ~ - . .:;) - ~ -0 ....... 1<'C') t"- I u,., C)- COo. ~l J .. JAN 41999 Christy Dawn Maynard IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA , ' . \ " ~. I ..,' . ' , - .' -" .' ," . . ..' " .'. . , , " .' . ' _', . .,... . ~ . ! . : .' Plaintiff vs. CIVIL DIVISION - LA W Erie Stephen Maynard NO. 9'8- - 73/10 ~ ~~ Defendant IN CUSTODY ORDER OF COURT AND NOW, this ,S day of ,'rr, Y. \ "--./\ ,1995., it is hereby directed that the parties 1 and their respective counsel appear before Dawn S, Sunday, Conciliator, at 39 W, Main Street, Mechaniesburg, P A 17055, on the l day of i-: \~I\ '.(1 r....i ,199.':1, at C(: UQ_.c~L-Ill., for a Pre-hearing Custody Conference. At such conterence, an elTort will be made to resolve the issues in dispute; or if this cannot be accomplished, to deline and naITOW the issues to be heard by the COUlt, and to enter into a tcmporary order. Either party may bring the child who is the subject of this custody action to the conterenee, but the child's attendance is not mandatory. Failure to appear at the conference Illay provide grounds for entry of a temporary or permanent order. FOR THE COURT: .~" . (.\D ) IV. I ';J I.~:J YOU SIIOULD TAKE TillS PAPER TO YOUR L\ \\'YER AT ONCr. IF YOU DO NOT HA VE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPIIONE IIII' OFFICI'. SU FOR] II BI'LO\V Hl rIND OUT WIlERI' YOU CAN GET LEGAL 1II'L1'. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE. PENNSYLVANIA 17013 (717) 249-3 J(,(, . ~ , , /' 'J, '/.''i' !fv-l ({:CY-Zy /-."~",,fJ d d;;t .4t4~J . /,:; t. / /.;;> ':;; ~~ (ltd6 Z;' t'jljt(, /' 7'1'f" A. /J , -/7/ / "j ~v /f(cz.ft/;/ Z <<417 '041<"":::7- , . .' . J ", " , ' .'; .' . .' " ,- ,~ . ^ :" : ' ", (TI.:, .' '" '. . , " - , :1;::<," - Christy Dawn Maynard IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA r '.'. . . '. " ,.' , ".'.'. ,', . I "' ~.. '. ' TO , ., ..' " ' . ' Plaintiff vs. CIVIL DIVISION - LAW Erie Stephen Maynard NO.1t - 731y, (i/l;'~ Defendant IN CUSTODY You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days afier this complaint and notice are served, by entering a written appearance personally or by attorney and tiling in writing with the court your defenses or objections to the elaims set u)rth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the complaint or tor any other claim or relief requested by the plaintiff You may lose money or property or other rights imp0l1ant to you, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VE A LA WYER 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 (717) 249-3166 Christy Dawn Maynard IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff \'s. CIVIL DIVISION - LA W Eric Stcphen Maynard NO. '1F- '1.3/& Defendant IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff: Christy Dawn Maynard. by and through her atlol11ey, Broujos & Gilroy, P.c., and avers as follows: J. Plaintiff is Christy Dawn Maynard an adult individual rl'siding at 3461 Wnggoners Gap Road, Carlisle, Cumberland County, Pennsylvania 17013, 2, Defendant is Eric Stephen Maynard an adult individual residing at III Bucher Hill, Apt. 2, Boiling Springs, Cumberland County, Pennsylvania 170()7. 3. PlaintitT seeks custody of the child Caylyn Dcanne Maynard residing at 3461 \Vaggoners Gap Road, Cumberland County, Pennsylvania 17013, Caylyn Deanne Maynard was bOI11 August 19, 1993. The child was bOI11 out ofwedlock. The child is presently in the cllstody of Plaintilf Plaintiff rcsiues at :14hl \Vaggon,'rs Gap Road. Cumberland County, Pennsylvania 17013. ~ ~ - , '. , I' . . l.', -, I . -:'.., " -',' , _ '.. ' . ~ . '. ....'" " . . ,", ,.. During the past five ycars, the child has rcsided with the following persons and at the 1()lIowing addresscs: Person Address Datcs Mothcr 3461 Waggoners Gap Road Carlisle, P A 17013 11198 - prcsent Mother & Father RRl Box ID Seven Valleys, PA 17360 Carlisle,PA 17013 02/97 - 11/98 Mother & Father 3461 Waggoners Gap R0ad Carlisle, PA 17013 12/96 - 02/97 Mother & Father Frankenthal, Germany 08/95 - 12/96 Mother & Father 948 Grant Avenue #177 Junction City, Kansas 66441 04/94 - 08/95 Mother & Fathcr 3461 Waggoners Gap Road 08/93 - 04/94 The mothcr of the child is Christy Dawn Maynard currently residing at 3461 Waggoncrs Gap Road, Carlislc, Cumbcrland County, Pennsylvania 17013. She is married to Defendant. The father of the child is Eric Stephen Maynard, currently residing at III Buchcr Hill, Apt. 2, Boiling Springs, Cumberland County, Pcnnsylvania 17013. He is marricd to PlaintilT. 4, The relationship ofPlaintitTto the child is that of mother. The PlaintitTcurrcntly resides with the following persons: Name Relationship Edgar Barrick Phyllis Bar.ick Edgar BalTick. II Hcnry Barrick t;nhcr mothcr hrothcr hrother . ",-' - "-'" _ ,.' " . '.', ., ",' . _.:'. ~~ '-; _,~;.:J.: -'" '. " .' I verity that the statements in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unswom falsification to authorities, {/~U4t;hYJ/76Lv~ Christy D. Maynard .... CHRISTY DAWN MAYNARD, Plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 98-7316 CIVIL TERM ERIC STEPHEN MAYNARD, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER tl. - , AND NOll, this 1.5 day of ----Ft(()IUz.J;:t ,1999, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Christy D. Maynard, and the Father, Eric S. Maynard, shall have shared legal custody of Caylyn Deanne Maynard, born August 19, 1993. Each parent shall have an equal r.ight, to be exercised jointly with the other p3.rent, 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. 2. 'l'be Mother shall have primary physical custody of the Child. A. The Fatber shall have a period of custody, to be supervised by the paternal grandfather, on saturday, February 27, 1999 from 9:00 a.m. wltil 6:00 p.m. I I I i r . ~ , , l 3. The Fatber shall have partial custody of the Child in accordance with the following schedule: B. The Fatber shall have periods of custody, also to be supervised by the p3ternal grandfather from Saturday, March 13, 1999 at 9:00 a.m. until Sunday, ~1arch 14, 1999 at 6:00 p.m., and from Saturday, March 27, 1999 at 9:00 a.m. until Sunday, March 28, 1999 at 6:00 p.m. C. Thereafter, the Father shall have partial physical custody of the Child on alternating weekends from Saturday at 9:00 a.m. until Sunday at 6:00 p.m. without the condition of supervision by the p3tema1 grandfather. The parties .shall cooperate in expanding the Father's periods of alternating weekend custody to include Friday evening when the Father gets off work on Friday at a reasonable time and provides reasonable advance notice to the Mother. i. D. The Pather my have custody of the Olild at additional times ;.., , . j .:- ',' , " '"," " . . . - ~ \ . " '''.~'~~'1 . ....r..:, , - .-..- r , r~ r:", ? ("" -; ..:: .-,' , " . 'I ,j ", ' - . """ . ......... :' '" as arranged by mutual agreement of the parties. 4. The parties shall share or alternate having custody of the Child on holidays as follows: A. CIlRIS'll>1AS: The Christmas boliday shall be divided into segment A, which shall run from Cbristmas Eve at 12:00 noon until Christmas Day at 12:00 noon, and Segment B, which shall run from Christmas Day at 12:00 noon until December 26 at 12:00 noon. The Mother shall have custody of the Child during Segment A in odd numbered years and during segment B in even numbered years. The Father shall have custody of the Child during Segment A in even numbered years and during segment B in odd numbered years. B. EASTER: The party who otherwise has custody of the Child over the Easter weekend under the regular custody schedule shall have custody of the Cbild on Easter sunday until 2:00 p.m. The other party shall have custody of the Child on Easter from 2:00 p.m. until 7:00 p.m. C. THANKSGIVING: The Father shall have custody of the Child on Thanksgiving in odd numbered years and the Mother shall have custody of the Child on Thanksgiving in even numbered years. The specific times for exchange of custody shall be arranged by agreement of the parties. The parties shall cooperate in scheduling the Thanksgiving holiday to accommodate traveling plans for either party. D. MEMJRIAL MY/JULY 4th/LABOR DAY: The Father shall have custody of the Child in even numbered years on Memorial Day and Labor Day, and in odd numbered years, on July 4th, from 9:00 a.m. until 7:00 p.m. The ~lother shall have custody of the Child in odd numbered years on Memorial Day and Labor Day and, in even numbered years on .July 4th, from 9:00 a.m. until 7:00 p.m. E. MOTI~'S DAY/FATHER'S DAY: The Mother shall have custody of the Child every year on ~lother's Day from 9:00 a.m. until 7:00 p.m. and the Father shall have custody of the Child every year on Father's Day from 9:00 a.m. until 7:00 p.m. 5. Each party shall be entitled to have custody of the Child for up to two non-consecutive weeks each summer upon providing sixty days advance notice to the other [~rty. 6. Neither party sball ddve after consuming alcohol during his or her periods of custody with the Child. 7. The party receiving custody of tbe Child shall be responsible to provide transportation for tbe exchange of custody and shall remain in his or her car during the excbange. The parties shall cooperate and shall ensure that tbeir family members cooperate in creating a positive atmosphere ...-hich is free of conflict during exchanges of custody of the Child. ~ CHRISTY DAWN MAYNARD, Plaintiff : IN THE COURT 01:' COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : vs. NO. 98-7316 CIVIL TE~1 ERIC STEPHEN MAYNARD, Defendant CIVIL ACTION - LAW IN CUSTODY CUSlOOY CONCILIATIOO SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the unde~signed Custody Conciliato~ submits the following ~epo~t: 1. The pe~tinent information conce~ning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENrLY IN CUSTODY OF Caylyn Deanne Mayna~d August 19, 1993 Motbe~ 2. A Conciliation Confe~ence was held on Feb~uary 17, 1999, with the following individuals in attendance: The Mothe~, Ch~isty D. Mayna~d, with he~ counsel, John fl. B~oujos, Esqui~e, and the Fathe~, Eric S. Mayna~d, with his counsel, Anthony L. DeLuca, Esqui~e. 3. The pa~ties ag~eed to ent~y of an Crde~ in the form as attached. ko.uo- / X I 'j (i (/ Date;:) /c::<.~,,-,-j .1,--.,...(;(,,</ Dawn S. Sunday, Esqui~e Custody Conciliato~ .' '. ' .,'. ',T ..,.. . ,', :, . . I " " ." ) ; . ' .' . '. '. . .