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Home My WebLink About00-07132 ~~ ,-I .~I "" Qriil.l~jW.li\b_ji . . JENNIFER S. ANTIIONY PLAINTIFF V. DAVID A. ANTHONY DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-7132 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 20th day of October, 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberlaud Couuty Courthouse, Carlisle on the ~ day of December , 2000, at 9:30 a.m. 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 defme 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 grQunds for entry of a temporary or permanent order. FOR THE COURT, By: Isl Hubert X. Gilroy. Esq, tP 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 1 I:"~ "~,~" . , ~, -, ~ " " ~ j/-C;3 -&0 /l7~m /tJ -.)3- t5I1 " .~ ",o,.WITl!1!!_,,, ~ J![~_., __. > ~__.> 'ye'I..... ., ..",-, " "_'''. '. T_''', ' "-n '",,' ".,~, _>_~ _, "" . ",. '>-0 -,," . .~ ,,- .1-. -\; o~.":. ? j F~i!i " 1.};9 CUri\;':~"':'~'~~.J"-,,:,"~_i COU\'{\'Y ""i-~', \\K....\/'L\ i ,\ \\1 ,., t-C\\\ i01 .-.'t",~lr\ M- ~ ~ /1;-4 /:"~ /l~ ~ --6 4f:I - , - CW 7" rL;d.w/~ -/f-~ r~ " , =,~~_~"'_ ~1IJl_~~..,._.~~!!flI;~Iffl"'P~:;YP!,;!,",;;'>:'i'R"'"f"',""";.\>"fh'f'--!'':~1I'i'..~ . ' ~~~~.~ . . ,'- - ".--'--'Y";'~~ " .... ~-~ c. , JENNIFER S. ANTHONY Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. DC- '7IJ~ C;uLL l~ CIVIL ACTION - LAW IN CUSTODY DAVID A. ANTHONY Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You, David A. Anthonv, defendant, have been sued in court to OBTAIN custody, partial custody or visitation of the child: Zane Garrett Anthonv . ORDER OF COURT , AND NOW, upon consideration Of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , Esquire, the conciliator, at on the day of , 2000, at o'clock _.m., 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 shall also be present at the Conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent order. FOR THE COURT: By Custody Conciliator Date AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cwnberland County is required by law to comply with the Americans with Disabilities At 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 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 ~~_..... _" I ~'-, JENNIFER S. ANTHONY Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. (JO- '/J3:l ~ I~ DAVID A. ANTHONY Defendant CIVIL ACTION - LAW IN CUSTODY CUSTODY COMPLAINT 1. The plaintiff is Jennifer S. Anthony, residing at 2801 Sunset Court, Grantham, Cumberland County, Pennsylvania 17027. 2. The defendant is David S. Anthony, residing at 110 Winston Way, Oxford, _County, Pennsylvania 19363. 3. Plaintiff seeks custody of the following children: lane Garrett Anthony, born March 6,1995. 4. The child was born in wedlock. The child is presently in the custody of the Plaintiff, Jennifer S. Anthony, who resides at 2801 Sunset Ct., Grantham, PA. 5. During the past five years, the child has lived with the following people at the following addresses for the periods indicated: Names Jennifer S. Anthony Addresses 2801 Sunset Ct. Grantham, PA Mechanicsburg, PA Allentown, PA Dates 1/99 - present Jennifer S. Anthony Jennifer S. Anthony Kathryn &Franklin Smith (Jennifer's parents) 4/96 - 1/99 2/96 - 4/96 ,;,.,1-""'-""'''' __~ I '.".~ .~ Jennifer S. Anthony David A. Anthony Jennifer S. Anthony David A. Anthony 24 Queens Way 6/95 - 2/96 Camillus, NY N. Syracuse, NY birth - 6/95 The mother of the child is Jennifer S. Anthony who resides at 2801 Sunset Ct., Grantham, PA. She is single. The father of the child is David A. Anthony who resides at 110 Winston Way, Oxford, PA 19363. He is married. 6. The relationship of the Plaintiff to the children is that of mother. The Plaintiff' currently resides with the following persons: Name Zane Garrett Anthony Relationship son 7. The relationship of the Defendant to the children is that of father. The Defendant currently resides with the following persons: Name unknown Relationship wife, stepchildren 8. 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 any other court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 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. 2 ""~..o_.." .'. ,-- I>i~_,,;t,_ 9. The best interest and permanent welfare of the child will be served by granting the relief requested because mother has been the child's primary caretaker since his birth; the parents separated prior to the child's first birthday and the child has had limited contact with the father since that time. 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, pursuant to the Custody Act, 23 Pa.C.S. ~5301 et sea., Plaintiff requests the court to grant her custody of the child. RESPECTFULLY SUBMITTED: & er, Esquire Attorney I o. 75899 4810 Derry Street Harrisburg, PA 17111 PHONE (717) 564-1084 FAX (717) 564-5158 Attorney for Plaintiff 3 .1 i_ ';',1 ~,; . . VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. -'rft.4 .L ()~ Je ifer S. thonY " 4 , - -,'-- ',,, '~*,~"~Iii":&'-~$t-&~~Itif -: " ,-'" !iil.'H~~"~. l.~t:sJ:i.~.h.iR .~"'~'""'-- ..~- - ~- . ~~-~,~,-~"--," ~, ~-'" ". '&' ~~ ~'~i" ~' (p ft:. -" .~ ~l!. ~. ll::. G' c-v -... ~ ~ , ~ I ~, t '-...(, ~ ..t "l~() . . . 8 & ~ I Q ~~ -r}Fi~ IT/f->, ~t- ~~~ '-'--' -""c :~ -< >. 'C~'_.~ c) ,:":) C') "-J C'. =-"'J ,',) '0 :-"., u ~?! .--,_J -< .. "C'i . . Q - , " ;'~'_ ,,-.: -.", -"I', .. .1 '.__n",' ' :M "~,,-: NOVOIJ JENNIFER S. ANTHONY, Plaintiff v : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 00-7132 DAVID A. ANTHONY, Defendant : CIVIL ACTION - LAW : IN CUSTODY COURT ORDER AND NOW, this ),/ r:ay of (}a- , 2000, the Conciliator being advised that the parties in the above matter have filed a Stipulation resolving the custody dispute, the Conciliator relinquishes jurisdiction, BY THE COURT, Hubert X, Gilroy, Esquire Custody Conciliator ,,,,-~ _..... i;-' , I! "'" " - ,~,_, . .~ 0 L;" (') 0 Gi?, c: C> s:: Z ~ '"'Or-D 0 ~~6 mrTi <::: Z:::::C1 I zc ;'Qt; d5 ~> ~~; , , '':::1 l,~ '"'0 ~S:B ~O ::K ""7'0 )>0 S:? (3m c ?6 ~ ::::> \D ~ ~"' "", _=__'--~",w, I j ..'-~ . . I" - i-'~ii:'" JENNIFER S. ANTHONY Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. OQ-7 ( 3:t CIVIL ACTION - LAW IN CUSTODY DAVID A. ANTHONY Defendant ORDER AND NOW, this '"]:f day of ~ , 2000, upon consideration of the attached Stipulated Agreement for Custody, said agreement is adopted in its entirety and made an order of court as if set forth at length herein. BY THE COURT: ,Judge 1 , '" ..M. ~'"r'~'--'~",;- ., ~~" ,-~-';--- .,-' l)iO!! ,;,! . ,.I\,.,"L' 11- OF FILED-OfFiCE ,"'r"n ,,,,. 'ThnY ,-'.--''-._.1 ! 1",{,)i\;OIKn ct2~ J' ~~ '} 00 NOIf -5 MilO: 1.0 CUMBEHU~'jD COUNW PENNSYLVANIA :2 l ~,_"~1~i;_~'~15''I!';glliJ'''R-~w<J<:m~~" _ _ 1tl!iJ~ =, ~~~."..~~ JENNIFER S. ANTHONY Plaintiff v. DAVID A. ANTHONY Defendant " ~ ~~": ~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 00 - 7/3 z CIVIL ACTION - LAW IN CUSTODY STIPULATED AGREEMENT FOR CUSTODY AND NOW, Jennifer S. Anthony, hereinafter "Mother," and David A. Anthony, hereinafter "Father," having reached agreement as to the custody arrangement currently in the best interest of their son, Zane Garrett Anthony, DOB 03/06/95, stipulate and agree as follows: 1. Mother shall have legal and physical custody of the child. 2. Father intends to effectively terminate his relationship with the child at this time and, contemporaneously with the execution of this agreement, has executed a consent for adoption. 3. Father acknowledges that he has been advised that he has the right to be independently represented by counsel and he hereby specifically waives that right and acknowledges that he has signed this document as an act of his own free will. 4. The parties intend for this agreement to become an order of court and hereby consent to the entry of such order. IN WITNESS WHEREOF, the undersigned, intending to be legally bound, . hereby set their hands and seals. Witness: , A .; (l/?U ~ ~/l Cindy . oser, Esquire Witness .5Gt <;,Af.{) ~ 4 teF I\J OJ A+I L Printed name and address of witness 303 ODeSSA WAL( , . !Vi::wA-.<2 Ie: DP 19 7// ~ j ~ (SEAL) J nife . Allthony SEAL) 1 ~ -~'=-".l."JlD '-.iiii~~~~iil,,,1!lli;~,.Iili'j;~ffiil11:'nn '-<~".:' 'i~.'. ;, iii,'.' ~ ;.J?':'l.'~"-_ -Fg"_,,'F<<, '.7 ^'".."""_?-""'''''''''~ ,.""_k-~.,."o-'J~""~-, ~ ~_ ,. __C','..y'{,,, co, o_~~o_,~,_~ .ti-^" "_." - ."..-1_ llili<l ,. ^. YO _, ~ .f ,~,- ~ ~ -,:i 0 C) 0 c 0 -n ~ :z: :;:j -OeD 0 ;;~~, -7'1 mm ~...~ " ;f=: z::tJ ~8 ~~ ?5(- -'<- cr"",t J CC -0 -'-~'I "'- :.=--1'1 z8 ::x ,,- :...~!:") W ~-rn :>c 0 ~ :9 N :IJ -< ~ ~ k' j' ~-, . ~ I. ": ._1 ~ _I" - . ... . PRECIPE FOR LISTING CASE FOR ARGUMENT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: JUDITH ESCHBERGER COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. CIVIL ACTION NO. 99-7132 DAIMLERCHRYSLER CORPORATION and BRENNER MOTORS, INC. and CONTINENTAL TOYOTA, INC., t/d/b/a CONTINENTAL TOYOTNDODGE OF HERSHEY and FREDERICK CHEVROLET/CADILLAC, INC., t1d/b/a FREDERICK DODGE 1. State matter to be argued (i.e. plaintiffs motion for new trial, defendant's demurrer to complaint, etc): DaimIerChrysIer Corporation's Motion for Sanctions against Plaintiff 2. Identify counsel who will argue cases: (a) for plaintiff: Judith Eschberger 2433 Adrian Street Harrisbnrg, P A 17104 (b) for defendant: Eric A, Weiss, Esquire Marshall, Dennehey, Warner, Coleman & Goggin 1845 Walnut Street Philadelphia, PA 19103 3. I will notify all parties in writing within two days that this case has been listed for argument. .. 4. Argument Court Date: . Date: 4/28/06 , = ~ July 12, 2006 By: &~ Cf(LL IfW67..JT' Print Your Name: Attorney for Defendant,DaimlerChrysler Corporation 2 IIIiIIIIll ~...--~" )-<..;- <,,", ~~~JIlM"""""-~~~!!';M&k~i!<ful!fuh(-"'!i~1';&.~""'~~kt'~"< - ~ ~,>^ ....."'''~~~ ,.- , ~-,,', , ,', ,~~,' .- ,-,' ,,~-- ""'~ - ,~- '~''''"'' ~et . "_~ 1- -._ '~lia~lIti~_Uilfi_ -~ .. n (-=-"; -, "c:;,' 'Jff: ""-". * ~ .~,. :.~-"~' -" o ", .-\ :L-!1 rne ~!J)~_~ :....;--), I N "'5:,',~ ~..~-. ...:;.." :.~:~ (~ ;~y'n '''t7.- :'q - 9 o U:l