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Home My WebLink About00-07570 i,-l~ - I -, >I.~, ~J<>;)c " TO! HARON PLAINTIFF V. MICHAEL HARON DEFENDANT IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-7570 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 3rd day of November, 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenne, Suite 105, Camp HiD, PA 17011 on the ~ day of December ,2000, at --.!.'15 p.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 grounds for entry of a temporary or permanent order. FOR TIlE COURT, By: Isl Melissa P. Greev Es 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 TIllS PAPER TO YOUR ATIORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE mE 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 ~ Ij I' i Ii t: ii I:, _~ . M~~ ".'._ )'m~~r, ~., ..l Jil, OF n~!~fF:;:f;-:~;~~TI'jD\{ ., ,<..I, '1(1 00 NOV - 7 PM I. n I E '" 4. U CUI' Aqr'I" '"' 'P8Jtf~~g~~UN1Y Jl7-&tl M ~ ~~, ~. 4ML If 7-t)tJ ~.b ~ z . j(-7'{}t) ~ /Y<'a4 ~ ~ pii'<ll" ~1~""_,",_,,,,_m"'P"\1. ~"'_ ,,.ij!IC'n~~~M'W~~~~\!tillif1"!'w-ml1lf",.~I~:''Il~!'Ii!!I'l!I!lj!~!a;m~,"", f. r ,c. _ J,,~.~= w~ I.',. I ,~'-- ". --'~li;ll TOI HARON Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. fXxJo-75"70 ~llIi ( VS. MICHAEL HARON Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this _ day of ,2000, upon consideration of the attached complaint, it is hereby directed that the above parties and their respective counsel appear before , Esquire, the conciliator, at , Pennsylvania, on the Day of A.M./P.M., for a Pre-hearing Custody Conference. At such ,2000, at 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 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 YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB 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 LffiERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 ,-".. ~L,.j" - ':; L " ikiiibi TO! HARON Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ~NO. o-v- 7S70 &;J -r~ VS. MICHAEL HARON Defendant : CIVIL ACTION - LAW : IN CUSTODY TO THE HONORABLE JUDGE OF SAID COURT: COMPLAINT FOR CUSTODY 1. The Plaintiff is Toi Haron, residing at 823 Highland Court, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Defendant is Michael Haron, residing at 823 Highland Court, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. The Plaintiff seeks physical and legal custody of the following children: Name: Michael Haron II, and Parris Jackson Present Residence: 823 Highland Court, Mechanicsburg, Pa Date of Birth: 6/1/96, and 7/20/90 4. The child was not born out of wedlock. 5. The child is presently in the custody of both parents. ," ' l; .L .'-,"':>:1 -'(Ii!~i 6. Since birth, up until the present, the child has resided with the following person(s) at the following address: Name: Address: Date: Toi and Michael Haron 823 Highland Court Birth to present 7. The mother of the child is Toi Haron, Plaintiff. 8. The father of the child is Michael Haron, Defendant. 9. The relationship of the Plaintiff to the child is that of mother. The Plaintiff currently resides with the following: Name: Michael Haron Relationship: Husband 10. The relationship of the Defendant to the child is that off ather. The defendant currently resides with the following: Name: Toi Haron Relationship: Wife 11. The Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning custody of the child in this or another court. 12. The 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. 13. The best interest and permanent welfare of the child will be served by granting primary physical custody to the Plaintiff, Toi Haron. .;,~~ ~ L ".,; 14. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, the Plaintiff, Toi Haran, respectfully requests this Honorable Court grant physical and legal custody of the rninor children, Michael n and Parris, to her. Respectfully submitted, v~ ryan . Attorney at Law 108-112 Walnut Street Harrisburg,PA 17101 (717) 238-5113 ID. No. 63881 J.; '- .1. _ . " ' . ~ . , . . VERIFICATION I verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904, relating to unsworn falsification to authorities. Date: (j~ .2..l.t I UlJl) ~, ~cW .'i ~-""i;...,; TOI HARON Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. MICHAEL HARON Defendant : CIVIL ACTION -LAW : IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that on the :J..,{pt]J. day of 0 ckb.vu , 2000, I served by fust class mail, certified restricted delivery, return receipt requested, a copy of the Plaintiff's Cornplaint upon the person named below in accordance with the applicable Rules of Procedure, addressed as follows: Michael Haron 823 Highland Court Mechanicsburg, Pa 17050 &t/dIc- AttomeyIDNo.63881 108-112 Walnut Street Harrisburg, P A 17101 (717) 238-5113 Counsel for Plaintiff ^Ii l "" J ~'~' "'Wi) , . TO! BARON Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. tJO-':f5?Q '-l'vil VS. MICHAEL BARON Defendant : CIVIL ACTION - LAW : IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that on the / s/"'~ day of NCf)cfl"",ikr. , 2000, I served by fIrst class mail, certified, return receipt requested, a copy of the conciliation order upon the person named below in accordance with the applicable Rules of Procedure, addressed as follows: Michael Haron 823 Highland Court Mechanicsburg, Pa 17050 ~~~ B S. Walk Attorney ill No. 63881 108-112 Walnut Street Harrisburg, PA 17101 (717) 238-5113 Counsel for Plaintiff .. ~='~__ .j,-,';,;..',e", ,.- ,.". .~ ~. ~. '"If ". > 'JIilHJ.ntl'~~01i1ifr~~!!l!~~""""'- -.", . _,,~. " . ,>_ ,,,~_ .,., ,~_ _ ,_ ~, _ O,V".'. '--''''-' . ." -~" " ~ ~ .. . r' , (") (,::;? (~) c: c::> -1"1 $: ~ ";J Tl CC ~:.2 r-p,,~ , ---~~! z::L '- zr- . u: CD~ O-t , "-' '-?: , -<L ~:-.. r-'-- .. ~ -~ -~ -U jj 3>- ~" ~~~ ZL. (') -0 rn )>C:: G) c> ~ 04 :::;) ,J:: 0:> =< ~ .. ;11 -I I ._m .....- ~!i r..' ". JAN 2 2 200l D v} TOI HARON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-7570 MICHAEL HARON, Defendant CIVIL ACTION - LAW CUSTODY TEMPORARY ORDER OF COURT AND NOW, this '2~ -OOy of January, 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody: The parties, Toi Haron and Michael Haron, shall have shared legal custody of the minor Child, Michael Haron, II, born June 1, 1996. 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 his health, education and religion. Pursuant to the terms of 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 of 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. 2. Physical Custody: Father shall have primary physical custody, subject to Mother's rights of partial physical custody which shall be arranged as follows: A. Weekends: Alternating weekends from Friday after school until Sunday at 6:00 p.m. effective December 15, 2000. B. Weekdays: Monday through Friday from 4:15 p.m. until 6:30 p.m. Additionally, Mother shall have one night during each week of overnight physical custody when she will pick the Child up after she gets off work and returns him to Father in the morning. The day of the week may vary by agreement of the parties. C. Summer: During the month of July each year, the school year calendar shall be reversed wherein the Child shall be in the primary physical custody of Mother and Father shall have alternating weekends and weeknight evening physical custody as further described above. \ \ No. 00-7570 ~ j .,1, ~ : j """,--' ~" . '-;0 , ' D. Vacation: Each party shall be entitled to two non-consecutive one-week periods of vacation each summer. Father shall not schedule his vacation time to occur during the month of July. Each party shall provide at least a thirty-day notice to the other parent of their intended vacation schedule. In the event a conflict arises, the party first giving written notice to the other parent shall have the choice of vacation week. The party shall have the option of including a custodial weekend at the beginning or end of a vacation week. E. Holidays: For even-numbered years, Mother shall have physical custody on Christmas Eve from 1 :00 p.m. until 6:00 p.m. and from Noon on December 25th until 8:00 p.m. on December 25th. Father shall have physical custody from December 24th at 6:00 p.m. until December 25th at Noon. In 2001 and subsequent odd-numbered years, Mother shall have custody from December 24th at 6:00 p.m. through December 25th at Noon, which shall be known as Segment A. Father shall have custody from 1 :00 p.m. until 6:00 p.m. on Christmas Eve and from December 25th at Noon until 8:00 p.m. on December 25th, which shall be known as Segment B. In even-numbered years, Mother shall have Segment B and Father shall have Segment A. F. Mother's Birthday: Mother shall have physical custody from 2:00 p.m. until 5:00 p.m. on January 1, 2001. Additionally, each parent shall be entitled to spend time with the Children on the parents' birthday. G. Mother's Day/Father's Day: Mother's Day shall be with Mother; Father's Day shall be with Father. The custodial period for these days shall be as agreed upon by the parties. H. Thanksgiving: Unless otherwise agreed, the period of custody for Thanksgiving Day shall be from 9:00 a.m. until 3:00 p.m. for Father and from 3:00 p.m. until 9:00 p.m. for Mother each year. Additionally, Mother shall have custody the Friday following Thanksgiving and Father shall have custody the Monday following Thanksgiving. I. Child's Birthdays: In the event that a parent plans to give the Child a birthday party, that parent shall give the other parent a thirty-day notice and an invitation to attend the party. Each parent shall have time to spend with the Child on the Child's birthday. ~, .'-. '[U.: ;'1 " I:: '-I if] :'~ I ! ;:1 ;1 iJ L,: "1 \,; I :1 'I ,.j j "j ;j :i ~j 1'1 :! 'i '] .' H j ,,~ ',I :,1 ~;j ;~; " -, !lj - .~ . '" ,><' ~ - .'-~'i~] ~ No. 00-7570 J. Other Holidays: Easter shall be observed each year with Father. Memorial and Labor Day holidays shall be shared by the parties as follows: In odd-numbered years, Mother shall have custody from 9:00 a.m. until 3:00 p.m. and Father shall have custody from 3:00 p.m. until 9:00 p.m. In even-numbered years, Father shall have custody from 9:00 a.m. until 3:00 p.m. and Mother shall have custody from 3:00 p.m. until 9:00 p.m. In odd-numbered years, Father shall have custody on Independence Day from 9:00 a.m. until 3:00 p.m. and Mother shall have custody from 3:00 p.m. until 9:00 p.m. In even-numbered years, Mother shall have custody from 9:00 a.m. until 3:00 p.m. and Father shall have custody from 3:00 p.m. until 9:00 p.m. 3. The Plaintiff's Complaint for custody of Parris Jackson, born July 20, 1990, is dismissed in as much as the Defendant is not the Father of the child and the Father has not been named as a Defendant, nor served with a copy of the Complaint and Orders scheduling the Custody Conciliation Conferences. 4. This Order is temporary in nature. The parties may vary from this Order by their mutual agreement. In the event that the parties are unable to agree, the terms of this Order shall control. Disl: Byan S. Walk, Esquire, 108-112 Walnut Street, Harrisburg, PA 17101 Michael Haren, 823 Highland Ceurt, Mechanicsburg, PA 17050 J. ~ 0\ ~- 0\' j..1\-~ i. .....I!l!..U;; l'JllrJlJIi ~~'ff;:flllbililrll:hil;fr~-' - "-"i1liK~r~~~~~,M~'''''>-;'' VlNVA1ASNN3d N.Nnm QN\n~i:lm'\lna 90:'1 ~jd SZ NVr 10 AH';/lON'" ".'" '" " '0 "\1""111)>-"'1 ,.,..! -,' " (~_! '.....,"."_ ,_'l I).. _ :JObJoiCdJ3TJ ,., ~, ~; '"~""'" ,-,-~~ ;J 'I il 11 I ,I il 'J il i.! ,I il 'I !I II I I p. r ., '" '",'-, ,-.e.. I~' . '_c'. .', :: . ... TOI HARON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-7570 vs. MICHAEL HARON, Defendant CIVIL ACTION - LAW CUSTODY 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 Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Michael Haron, \I Parris Jackson June 1,1996 July 20, 1990 Father Michael Haran 2. Custody Conciliation Conferences were held on December 12, 2000, and again on January 19, 2001with the following individuals in attendance: the Mother, Toi Haron, and her counsel, Brian Walk, Esquire; the Father, Michael Haron, pro 5e. 3. The parties reached an agreement in the form of an Order as attached as to the minor child, Michael Haran II. The named defendant is not the Father of Parris Jackson. Mother did not name the Father as a party in the Complaint and Father was not served with the Complaint or Orders scheduling the Custody Conciliation Conferences. Mother reports that Father is presently incarcerated. Mother's complaint as to Parris Jackson is dismissed with agreement of her counsel. I #9/ 07 Date I I Meli sa Peel Greevy, Esquire Custody Conciliator