The URL can be used to link to this page

Home My WebLink About03-1601KRISTA K. BAER, RONALD W. BAER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY Defendant NO. ('~.oq -- /(,o o / 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 may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also 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 and visitation of your children. When the grounds for a divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Domestic Relations Office at the County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT 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, Pennsylvania 17013 (717) 249-3166 Barbara Sumple-Sullivan, Esquire Supreme Court//32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 KRISTA K. BAER, RONALD W. BAER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY Defendant CUSTODY COMPLAINT 1. The Plaintiff is Krista K. Baer (hereinafter referred to as "Mother"), who currently resides at 71 Cold Springs Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Ronald W. Baer (hereinafter referred to as "Father"), who currently resides at 71 Cold Springs Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks legal and physical custody of the following children: NAME PRESENT RESIDENCE DATE OF BIRTH Emma Kay Baer 71 Cold Springs Road Carlisle, PA 17013 08/11/1997 Ella Grace Baer 71 Cold Springs Road Carlisle, PA 17013 09/05/2000 4. The children are presently in the custody of Plaintiff who is temporarily residing with her parents due to problems in the marital home resulting from Defendant's alcohol abuse issues. 5. During the past five years the children have resided with the following persons at the following addresses: DATES ADDRESSES NAMES OFPERSONS IN HOUSEHOLD 08/11/1997 to 02/1999 637 South College Carlisle, PA 17013 Mother and Father 02/1999 to 05/2001 114 Dogwood Drive Mt. Holly, PA 17065 Mother and Father 05/2001 to O4/O4/2OO3 71 Cold Springs Road Carlisle, PA 17013 Mother and Father 04/05/2003 to Present 199 Acre Drive Carlisle, PA 17013 Mother, Children Mother' s Parents 6. The Father of the children is Ronald W. Baer, currently residing at 71 Cold Springs Road, Carlisle, Cumberland County, Pennsylvania 17013. 7. The Mother of the children is Kfista K. Baer, currently residing at 71 Cold Springs Road, Carlisle, Cumberland County, Pennsylvania 17013, but temporarily located in her parent's home pending resolution of the crisis in the parties' home. The parties are currently married to each other. 8. The relationship of the Plaintiffto that of the children is that of Mother. The Plaintiff currently resides with the following persons: 2 NAME Emma Kay Baer Ella Grace Baer Sharon Olmstead Kim Olmstead RELATIONSHIP Daughter Daughter Wife's Mother Wife's Father 9. The relationship of the Defendant to the children is Father. The Defendant currently resides with the following persons: NAME RELATIONSHIP None 10. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 11. The Plaintiff has no information of a custody proceeding concerning the children pending in any court of this Commonwealth. 12. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 13. The best interest of the children will be served by granting the relief requested because Plaintiff is best suited to care for the children and provide a stable, loving environment for them. Defendant has significant issues related to his alcohol use which prevents his ability to care, supervise and/or otherwise provide for the children. The children need to be established in a secure environment. Pending addressing his alcoholism, Father should be limited to supervised visitation. 14. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, the Plaintiff requests the Court to grant legal and physical custody of the children to the Plaintiff. .. ~ '/~//~"h DATE: April 7, 2003 / [~ Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 4 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 KRISTA K. BAER, RONALD W. BAER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY Defendant NO. VERIFICATION I, Krista K. Baer, hereby certify that the facts set forth in the foregoing CUSTODY COMPLAINT are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unswom falsification to authorities. ,2003 KRISTA K. BAER PLAINTIFF RONALD W. BAER : : DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-1601 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, April 11, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Es .__sq:~, the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Monday, May 19, 2003 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 vresent at the conference. Failure to apvear 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, Sl~eeial Relief orders, and Custody orders to the conciliator 48 hours l~rior to scheduled hearinl~. FOR THE COURT, By: /s/ Meli~sa P. Greevy, 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 MAY 2 9 2003 KRISTA K. BAER, RONALD W. BAER, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1601 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER TO RELINQUISH JURISDICTION AND NOW, this 16th day of May, 2003, the parties having requested the Custody Conciliation Conference be continued generally, the Conciliator hereby relinquishes jurisdiction of the above captioned matter. FOR THAT: Melissa Peel Greevy, Esquire Custody Conciliator Dist: :213601 Barbara Sumple-Sullivan, Esquire, 549 Bridge Street, New Cumberland, PA 17070 Ronald W. Baer, 71 Cold Springs Road, Carlisle, PA 17013 OU :6 ~iV Og ,L~'N gO