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Home My WebLink About01-0654 FX ': ~ ~ > .. I . ~' ~ . . . " '~;",., . i ~" v. FEB () 2 oi/lil;\ IN THE COURT OF COMMON PLEAS OF r.oO\ CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW STEVEN A. TRAYER Plaintiff TAMMY 1. TRAYER, Defendant NO. ,!J!- {c51/ IN CUSTODY CIVIL TERM ORDER OF COURT AND NOW, this day of , 2001, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before . , Esquire, the conciliator, at , Cumberland County, Pennsylvania, on the day of ,2001, 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 may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent Order. BY THE COURT: By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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 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, P A 17013 (717) 240-3166 ~ ~ , lliI:;-,.'l<P STEVEN A. TRAYER, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 01- l.5"lj : IN CUSTODY CIVIL TERM TAMMY 1. TRAYER, Defendant COMPLAINT FOR CUSTODY 1. Plaintiff is Steven A. Trayer, an adult individual currently residing at 87 East Yellow Breeches, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Tammy 1. Trayer, an adult individual currently residing at 141 Trayer Lane, Carlisle, Cumberland County, Pennsylvania. 3. The parties are the natural parents of two (2) children, namely, Megan Marie Trayer, born May 9, 1989, and Bethany Ann Trayer, born July 7, 1991. The children were not born out of wedlock. 4. For the past five (5) years, or since the children's birth, the children have resided with the following persons at the following addresses for the following periods oftirne: NAME ADDRESS DATES Steven A. Trayer 141 Trayer Lane 1993 to Tammy 1. Trayer Carlisle, PA 17013 January 20, 2001 Tammy 1. Trayer 141 Trayer Lane January 20, 2001, to Carlisle, P A 17013 Present 6-""",f~- .' -, _d." ~ i -">~_,"bl"Yl_ The natural mother of the children is Tammy 1. Trayer who resides as aforesaid. She is married. The natural father of the children is Steven A. Trayer who resides as aforesaid. He is married. 5. The relationship of the Plaintiff to the children is that of natural father. The Plaintiff currently resides with his parents. 6. The relationship of the Defendant to the children is that of natural mother. Defendant currently resides with the children at issue. 7. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, conceming custody of the children. 8. Plaintiff has no information of any custody proceedings conceming the children pending in any Court of this Commonwealth. 9. It is in the best interest and permanent welfare of the children to grant the relief requested because: a) Plaintiff is better capable to provide for the children's moral, spiritual, and physical well-being; b) Defendant recently has demonstrated emotional instability culminating in verbal abuse of the parties youngest daughter; ,>",."~.'-". ,"' .. l~ ~ . " .., ,'. ~ "'"1'" 'cq" 10. Plaintiff does not know any person not a party to these proceedings who claims to have custody or visitation rights with respect to the children. WHEREFORE, Plaintiff requests your Honorable Court to schedule Custody Conciliation Conference followed by a hearing at which time he should be granted primary physical custody of the c,hildren, Respectfully submitted, CU- atas, Esquire Attorney or Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, P A 17013 (717) 243-5551 (800) 347-5552 ~~ ~ .~ "" U" """"'W~.< VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: / /:U/fJ/ / ~~~dx~~ STEVEN A. TRAYER, PI ntiff f,']! Ci' '-;'.'", 0'.: j ',,..:.L~.::..c/-l}j-HCC I : r..- ~J . " ;: ') ,r"""!" ,,~, L. . '- [,,'. "I." .'-'r'~I,"y ~' ',..--I,\)fMf1 o i .JAN 3 I PH 3: 2 I CUIv10E"" .." I~",i,- fiU'\"~U cou'<TY PcNNSYLVmiA ' tf/" '() fi ':J..~ . I'tl.(Z~ .1 '/')) ~-/ S L J( j'eI, ,)7!7{ji?rdi-A --;;:~:;;. /.a 71 j(/"~ /t'" '/' I " .~ ~ ~ , _W " tYz- ~ Iv.) 3 j!2;{li I {i '7 {it./ J- ~ -1 ~ ;t ~ , ~ I ~ ':m 'ill 1 i j,' ~ l~ " STEVEN A. TRAYER PLAINTIFF V. TAMMY L. TRAYER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 01-654 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 5th day of February, 2001, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear beforeJacqueline M. Verney, Esq. , the conciliat at 4th Floor, Cumberland County Courthouse, Carlisle on the 7th day of March, 200 I, at 8:30 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 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. FOR THE COURT, ,. ., By: Isl ac ueline M, Vern 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 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 , ." ~ - ~ I " :i j ;:1 ;-~ ~'"M,_ '> ., J)4'01 ;) -1 't/ I ;).-<f??! - I" 1 .CI' ,-......"> ,I \.)' i'-' r',~,' :':': :"V, ''''Y'!'JTAAY OIFfB-8 Ai'i 9:30 CUtvi8E:HiJ\ifJ C:OU\JTY PENN8YU~'IN!A j w.~~t;c4~ '7l~ ~ ~~- . ~ ;Jaa/ ~. :a; ~ ~ ~ ~ ,~_~g, "'llllI]<_IM~,~"",~""",,,-""P.~l\;;l;i~'!Il--~,,",,,......,,",,~~ _~P'!':~~~"~~!,,rjf';~,"r"'J"";~"PI,,;,_,~~;-,;'jQ'_'9"lI!~w_n~~i'#~1!'1!ll,ll\I'H"?rf"Wl~~ #. =".~ iUII6 ...~ ~, ~h -- ~ ~ ..,~ - . ^&~- 'aIil n_ ~' -';'"'>"'~~~"~--"I!Ii'-_f=\.'!'k'O'l , MAR 1 4 2001 rfJ STEVEN A. TRAYER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLV ANIA V. : NO. 2001-654 CIVIL ACTION - LAW TAMMY L. TRAYER, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 15 (i,daYOf VVl vd ,2001,upon consideration ofthe attached Custody Conciliation RerRlrt, it is ordered and directed as follows: 1. The Father, Steven a. Trayer, and the Mother, Tammy 1. Trayer, shall have shared legal custody of Megan Marie Trayer, born May 8,1989 and Bethany Ann Trayer, born July 7,1992. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. 2. Pending a resolution of the occupancy of the marital home and either party requesting to return to the Conciliator within sixty days of March 14,2001, the parties agree to the following interim shared physical custody schedule of the children: A. Father shall have physical custody of the children on alternating weekends from Friday at 5 :00 p.m. to Sunday at 9:00 p.m. B. Father shall have physical custody of the children every Tuesday and Thursday from 5:00 p.m. to 9:00 p.m. C. Mother shall have physical custody of the children all other times. 3. otherwise. Father shall be responsible for all transportation, unless the parties agree 4. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. :'1' ,--- ~ ~ ~ ,. . " ,~~-~ "= Fn.rJ; {)fffCE OF - ~. tr'HCNOTJv'if' 01 ~i.l.R IS Pi'i 2: 1.2 CUMBERLAND COUNIY PENl'.JSYLVANIA ~ - ~~""~/"<,:,If!i'l'!'wr_ "~ !1:~~!",1:',"o;!!i!;ll!!~r,q;W-\>'~~t"""""<__""'f,,,!'l!!i!L _ ," " IPlI!lll~r~"'''~''''--' !t!"~ _c___i.llll Il:!llt'~_. ~~_. .~,,-~ ._~~ ...~~ ..,""_1 ~ ~ "' ~ ....... -~",,-,,;, .f .' BY THE COURT, J. cc: Marylou Matas, Esquire - Counsel for Father Carol J. Lindsay, Esquire - Counsel for Mother -if ~\ \l~ 0"" ~ '''''Ul_'"","",~"- -~ "'--il-'-fc~" -"-"'~ - ~~~~~""-'-"~ -~ .=~.- -, ., .... ...... ~,-~",,,,,.I..~,~~ ,--_mf'~"-" "_~. ,.".'" ~~- ~.Jll1~~'~ ,-~",_",h' , . MAR 1 4 2001 tf STEVEN A. TRAYER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLV ANIA v. : 2001-654 CIVIL ACTION - LAW TAMMY L. TRAYER, Defendant IN CUSTODY PRIOR JUDGE: None 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 Megan Marie Trayer Bethany Ann Trayer May 8, 1989 July 7,1992 Mother Mother 2. A Conciliation Conference was held in this matter on March 14,2001. Father, Steven A. Trayer, was present with counsel, Marylou Matas, Esquire, and Mother, Tammy 1. Trayer, was present with counsel, Carol 1. Lindsay, Esquire. 3. The parties agreed to an interim Order in the form attached pending a resolution of the occupancy ofthe marital home by Father. The Conciliator shall retain jurisdiction for sixty days. If neither party contacts the conciliator within 60 days from today's date, the Conciliator shall relinquish jurisdiction. :3 -/'-1-0 I Date ~,?h'~~~r acq lme M. Verney, EsqUire Custody Conciliator