The URL can be used to link to this page

Home My WebLink About01-1921 FX ,"" "'.- 1 J - -~ , ,_, '^ ~ "h ,,~,_ _'.' " "d, .. J (J"i' APR 0 3 zooJfP " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CRYSTAL MYERS, Plaintiff : v. NO. 01 - Jq ~i (!A--~ : ROBERT MYERS, Defendant IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , the Conciliator, at on the day of , 2001, at ___.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. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent Order. BY THE COURT: Custody Conciliator 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, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 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 the office set forth above. 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. , . .~.. .- 100--1'. , '..-- -."< '" ,.-:"~,-,-''''d~''__,__, ct. ~ ",,_" "~,__,, f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CRYSTAL MYERS, Plaintiff . . v. NO. (!JI- /9~1 ~ I~ ROBERT MYERS, Defendant' IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, CRYSTAL MYERS, by and through her attorney, Maryann Murphy, Esquire, of MidPenn Legal Services, and respectfully files this Complaint for Custody, and in support thereof avers as follows: 1. The Plaintiff is CRYSTAL MYERS whose current address is 1425 Apple Drive, Apartment #141, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is ROBERT MYERS whose current address is 400 South York Street, Mechanicsburg, Cumberland County, Pennsylvania. 3. The Plaintiff seeks primary physical and legal custody of the following children: RYAN MYERS, born June 14, 1996 and JESSICA MYERS, born February 24, 1986 4. The children were born in wedlock. ~ -.j. L_,' . ,;"~'_, <"M"~ ,~,._,.' ,,~ '~ . 4 5. Plaintiff currently resides with the minor children. 6. Defendant currently resides with his brother. 7. During the lifetime of the children, they have resided at the following addresses with the following persons: Time Address wi th Whom birth-1988 Mechanicsburg, PA Plaintiff/Defendant 1988-5/00 Dillsburg, PA Plaintiff/Defendant S/OO-present 1425 Apple Drive Apt. #141 Mechanicsburg, PA Plaintiff 8. The father of the children is ROBERT MYERS. He is married to Plaintiff. 9 . The mother of the children is CRYSTAL MYERS. She is married to Defendant. 10. Plaintiff has not participated as a party or witness or in any other capacity, in other litigation concerning the custody of the children in this or any other Court, except as set forth above. 11. The Plaintiff has no information of a custody proceeding concerning the children pending in a Court of this Commonwealth or in any other State. 12. The Plaintiff does not know of a person not a party to " ,,,",' ~ . ' "' .1'. ",;--, '>'-"">'-&_f_'.' . , the proceedings who has physical custody of the children, or claims to have custody or visitation rights with respect to the children. 13. Each parent whose parental rights to the children have not been terminated, and the persons who have physical custody of the children, have been named as parties to this action. There are no other persons known to have or claim a right to custody or visitation of the children and therefore, no further notice of the pendency of this action and the right to intervene shall be given, other than to the parties named herein. 14. The best interest and permanent welfare of the minor children will be served by granting Plaintiff primary physical and legal custody of RYAN and JESSICA. WHEREFORE, Plaintiff requests this Honorable Court to grant her primary physical and legal custody of the minor children. Respectfully submitted, Murphy, Esqui e MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 LD. # 61900 Attorney for Plaintiff --,';;,;';_""'1: ,~ """ ,.. '~." ~""",- " "",' "',-, "Lr ~~' ";'.' "j,__., 'I: . I VERIFICATION I, CRYSTAL MYERS, verify that the statements made in the foregoing Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. . . . c ~, ,..;' ,.'",~",- '.'_ > ,,'~ " .,-, ,,', "'" '<c-' - 'L.:~: .. j IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CRYSTAL MYERS, Plaintiff . . v. NO. . . ROBERT MYERS, Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Maryann Murphy, Esquire, do hereby certify that on the day of , 2001 I served a true and correct copy of the foregoing Complaint in Custody on the Defendant, ROBERT MYERS, at the address set forth below, by placing a copy of same in the United States Mail, postage prepaid, certified/restricted delivery. Robert Myers 400 South York Street Mechanicsburg, PA 17055 Respectfully submitted, Maryann Murphy, Esqui e MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 540-8600 I.D. # 61900 I~ <-. ,., '. .~ '. ll~" _'''i" " r"':-~""',k" '".~~_~~lliiIiiAl~l!liJil~I-~~m";""Iill'!.H~,';&,-'15h81,,'.ii-llili;,t~;;jI"'E,l\0;i'l!i.LiiiliiliM .~~~~~A -\ ~ .+ \.~ " ~ ,~. . <._~llJJ -~ o c -"[};:;.~ fTi r-]~.: 2::1:., ~~C "- -- :;.'>----. --,.-1... ' ~C-} C 2: -." -< .. a () <"I'j "'" -^D ..J , r-~,.) '-~' r~ L.) ~" r...:; ~,:::; :0 -< - . < W ^_ --,...;1-"',': .. ... CRYSTAL MYERS PLAINTIFF V. ROBERT MYERS DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 01-1921 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, April 05, 2001 , upon consideration of the attached Complaint, jt is hereby directed that parties and their respective counsel appear before Jacqlleline M. Vemey, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, April 18, 2001 at 2:30 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 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. The court hereby directs the parties to furnish any and aU existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Jacqueline M. Verney, Esq!t? 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 ammgements 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 ...') ~ . ~,:c,,~ . . ." _.. iIIiIlI~~~~lb~Bil"'~"'"'t".m""';'".ti;;"""",~~,~;,<*,,.~ili.>~~;:J;!I~~r" ~.lil D ("r /Iff' .~o~~~=~ . 0 ~~ - ~~ d.AAd7. ..L}f.. .1fp ~ ~1'.11 ~ /rJ- /J./; .,,rrv'1'L '$ ~ r.?71~/ Lk-d r'f . _-+"~ N- <fA 7"" f? '7 ~ M? -;P'l jt7-"Jj; Vfd"'''' I '" ,', WI ,}\SNI' I:J,~ I\...u\n/'("\ ['I'" r11 "i.J,-" ...,' ..,' '~~:;rmo I"": I" ') 1..;0 :C.. :J ,,~ , " - , "-.' '.') 0" {J(;;'J j;. .~ ,,-..<. ~--"~~ . .-' -". ,~y ,~-,.~,,~- . , .. ~, .,,~-. ,.." i ',' "_,,,, ""-' . ,-",,,p __ .~V' _._ " "a_,' ~co",,~., . II Ii -, ',I , ) II i I II Ii II I II :1 Ii . , ,'.-1 ;', -~"^ ">0'" "'~"';'-'^"'O'~""~~l'_'" <';'j"-1~ . . " , . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CML ACTION - LAW CRYSTAL MYERS, Plaintiff ; NO. t'f le,.>-! (].<.-",;JL, v. : IN CUSTODY ROBERT MYERS, Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, CRYSTAL MYERS, Plaintiff, to proceed in forma pauperis. I, Maryann Murphy, Esquire, of MidPenn Legal Services, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. Maryann urphy, Esquire MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 LD. # 61900 Attorney for Plaintiff l~ . "., -..--- ,. '.. "1- , .~ . --,"''''/,''l,'s0' "~-," ..' - . - ,- )..-' -"'~'~i- , , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CRYSTAL MYERS, Plaintiff : NO. of. 1'3.2-1 &:.-t v. : IN CUSTODY ROBERT MYERS, Defendant AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS L I am CRYSTAL MYERS, the Plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: CRYSTAL MYERS Address: 1425 Apple Drive. Apt. #141. Mechanicsburg. PA 17055 (b) Social Security Number: 167-56-4538 If you are presently employed, state Employer: Excel Logistics Address: 40 East Main Street. New Kingston. PA Salary or wages per month: $1.562.00 gross per month Type of work: Customer service ~. . - ",' . ~~,~,- ,,~, - .'" ".,--- " " -""'_d_~ I If you are presently unemployed, state N / A Date oflast employment: N/A Salary or wages per month: N/A Type of work: N/A (c) Other income within the past twelve months Business or profession: -0- Other self-employment: -0- Interest: -0- Dividends: -0- Pension and annuities: -0- Social Security benefits: -0- Support payments: $600.00 per month Disability payments: -0- Unemployment compensation and supplemental benefits: -0- Workman's compensation: -0- Public Assistance: -0- Other: -0- (d) Other contributions to household support (Wife)(Husband) Name: N/A If your (husband) (wife) is employed, state Employer: N/A , . _c_ I Salary or wages per month: N/A Type of work: N/A Contributions from children: -0- (e) Property owned Cash: $.50 Checking Account: Savings Account: Certificates of Deposit: $8.00 -0- -0- Real Estate (including home): believed to be in foreclosure Motor vehicle: Make Chevrolet Spectrum Year ......:<., ~" 1986 Cost $200.00 (approximate value) Amount owed -0- Stocks; bonds: -0- Other: -0- (t) Debts and obligations Mortgage: -0- Rent: $645.00 Loans: approximate total balance owed: $30.000.00 Monthly Expenses: Approximately $2.100.00 (g) Persons dependent upon you for support (Wife) (Husband) Name: N/A ". ~~~~'~. .~. -'.' " Q'\i i Children, if any: Name: JESSICA Age: Name: RYAN Age: 15 vears 4 vears 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Date:(;)~/5 /0/ 1 t::a CRYSTAL .' '", ~",",,') q:.> ,~ ~~t4IiiUiR!;;fii~~",~:Il...~...ii~~l!Ili~2l!b"t~~:#~"i",,,,,';;'6,,Jb~_i,,,-ij,f~~i\:;,g~I.l.(U ~- -., ~m~-' ~, =.. -"~ .. ,. ,- '" -,~ .~. ,".' ".< ,.'''. .-..'-'~ ^,- .. ,'-~', , ~~-_~~~IiHl.~ ,-' o f? -OS) rnr:', ~~~; / . ~L: :F~ c~, ~~() :r-....c: ~ CI ?; -;'-d . i I r.....~- ;1.: - -- "-~ :.0) -:~~-~ :.:.:> '-:~" --'r-l :,-~r'?l ~-:-:~ -:;.--,. :t 'J.) fv .~~ . ",,--,-.-1., _'<__0"".," ',', _, -.<{::t- f . } fAPA 16Z" tf ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW CRYSTAL MYERS, Plaintiff NO. () [- I q ~ I Civil Term v. ROBERT MYERS, Defendant IN CUSTODY ORDER OF COURT ANDNOW,this~daYOf Af-r: l ,2001, upon presentation of the attached Stipulation for Entry of Custody Order, IT IS HEREBY ORDERED AND DECREED that custody of the minor children: JESSICA MYERS, born February 24,1986; and RY AN MYERS, born June 14, 1996, is awarded as follows: 1. MOTHER shall have primary physical and legal custody of the minor children. MOTHER shall advise F ATHER of all important matters concerning the minor children. 2. FATHER shall have partial physical custody of the minor children, with specific times to be determined by mutual agreement of the parents. 3. While in the presence of the children, neither parent shall make, or permit any other person to make, any remarks or do anything which could in any way be construed as derogatory or uncomplimentary to the other parent. It shall be the express duty of each parent to uphold the other parent as one whom the children should respect and love. ~~~ililiii:"'i;]ff~~_j~1ri::t4';:tn~.ffiM""'k,",';;~'~j,;1l''''''If"''~i$t''''"'f~~t",,-;;f'"",,,,,,,-;;;,"_,,,<:;;;'-"..!f.i~I~'~!~~J~llW;'~W~"' Ji )' ~:JL _,", """~',, ",rnsr,lt,'!'f_"" ~ ~"",_ ~"",.' ",,,",,,",.,' "'_~" .., " ","'- '_'i,~~,~,,-,,~_,~ .e.'" F-c,".", .~~ V1~\1"/i\1),S(,Jl'J3d ri', 'f-;'I ~'::-.::1i\Jj0 " I,' !-, -~ ,-, , I nl'" ,"-I U.trfll .-,,..,,,",,,",,,,, T '. t. , " , .. JL' . 4. The parents shall share or alternate the holidays with the minor children. The specific times shall be determined by mutual agreement of the parents. 5. FATHER shall have the minor children on Father's Day and MOTHER shall have the minor children on Mother's Day. 6. MOTHER and FATHER shall each have the opportunity to have the minor children for sununer vacation every year. The specific times and days shall be determined bymutual agreement of the parents. MOTHER and FATHER shall give each other written notice of their chosen time for sununer vacation. In the event that both parents choose the same time for sununer custody, the parent who gives first notice shall prevail. 7. Neither parent shall abuse alcohol or use illegal drugs forty-eight (48) hours prior to and during their respective periods of custody with the minor children. To the extent possible, both parents agree that they shall not permit the children to be in the presence of third parties who abuse alcohol or use illegal drugs. 8. Each parent shall provide the other with a current telephone number and address 9. Neither parent shall take the minor children out of the Commonwealth of Pennsylvania without prior notice to the other parent. The parent who is traveling out of the Commonwealth with the children overnight shall provide a telephone number and address of their destination to the other parent prior to the trip. 10. Both parents shall permit reasonable telephone access between the children and the other parent. The children shall be permitted reasonable telephone access to place calls to each of their parents while they are with the other. . 11. This Order shall replace and supercede any and all prior Custody Orders, and shall remain in full force and effect until further Order of Court. BY THE COURT: J. t~ .0 \ 0('JD ~ .... CC ,. l I, J._ -, -, ,'=~ "_-"'~ ,-" ~ c .~ r :_~rn:~';i'; . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW CRYSTAL MYERS, Plaintiff NO. 0 \ - ( q 1 \ Civil Term v. ROBERT MYERS, Defendant IN CUSTODY STIPULATION FOR ENTRY OF CUSTODY ORDER The parties to this action, CRYSTAL MYERS (hereinafter referred to as "MOTHER"), and ROBERT MYERS (hereinafter ref~rred to as "FATHER"), desiring to amicably settle and resolve all outstanding issues concerning custody and partial custody with respect to the minor children: JESSICA MYERS, born February 24, 1986; and RYAN MYERS, born June 14, 1996, hereby stipulate and agree to the entry of an Order of Court awarding custody and partial custody of JESSICA and RYAN as follows: 1. The parents agree that MOTHER shall have primary physical and legal custody of the minor children. MOTHER agrees to advise F ATHER of all important matters concerning the minor children. 2. The parents agree that FATHER shall have partial physical custody of the minor children, with specific times to be determined by mutual agreement of the parents. 3. While in the presence of the children, neither parent shall make,(or~rmit any other ',-_~J person to make, any remarks or do anything which could in any way be construed as derogatory or I.......~ , ," "'-I., . ~ . . COlumonwealth of Pennsylvania v.ithout prior notice to the other pa.!'ent. The parent ,;vho is traveling out of the Commonwealth with the children overnight shall provide a telephone number and address of their destination to the other parent prior to the trip. , 10. Both parents agree to permit reasonable telephone access between the children and the other parent. The children shall be permitted reasonable telephone access to place calls to each of " ~~.._--, "1 " " P'J ~M"~111 ~ " . .. 1 their parents while they are with the other. II. The parents agree that this Agreement shall be submitted to the Court of Common Pleas of Cumberland County, Pennsylvania for approval and for entry of an Order awarding custody and partial custody as set forth herein, and the parents hereby request that this Honorable Court enter such an Order. IN WITNESS WHEREOF, the parties have executed this Stipulation for Entry of a Custody Order on the date indicated below. Witness ~- L(-s u ( Date 0~0'/ 'Date Witness "",z; ;"~~,~ .' "",':':"1" , . f;.-': .';ii ~~li~;!icl\>..cdi~i',i!j--e},;r,;;;!J.to;H'&i<1<IlIl'""-i'f~"~~'I;J~;l1",~"",;~:l.jf:'-';K~"j';';!Me-",,;<*~;f~;.~~~i~~~II\~ii<liIaAill~lil!IliilkMi!J~~ ~ \ ., < ~,- .u .""""""-"_n _" ." eo __'. "c. ~_., " ,,,,,,,. _. ,'" -0'<, ". ",,-- .^~~ _"L,",. ~,",,,,._,'.,"'n~, ''''. o"'_~,,,,"~~O~"" >_~. .~" '0"<," (') r.~ 1'1;:"- QjF7 6'- ...:~:: '!.J r> ?? ~--~ ~C) '- :2' ~ ~ - "_,J :r~" _.n] r, !"-' .'U t.....J W f",,;, ::;:-, S~ -<. - ~'" ~" ,,~ " ",_,t' . ~..