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Home My WebLink About01-2040 FX j- , .1" BRIAN L. HAIR, Plaintiff V APR 0 9200tW : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION -LAW JANE M. HAIR, Defendant : NO.Of -a:l'KlCIVIL TERM : IN CUSTODY ORDER OF COURT AND NOW, this day of 2001, upon consideration of the attached Complaint, it is hereby directed that the parties and their on the day of 2001, at o'clock the conciliator, Cumberland County, Pennsylvania, .m., for a Pre-Hearing Custody respective counsel appear before at 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. Either party may bring the children who are the subject of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent Order, BY THE COURT: By: Custody Conciliator YOU SHOULD TAKE TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTII BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue CARLISLE,PA 17013 (717) 240-3166 "'-.~,:r*1\II _ 'ffi'!'llf ~,~,~ "0"__ c""cI _c-" ,."' - I, - }--",~. --", -,- . BRIAN L. HAIR, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION -LAW JANE M. HAIR, Defendant . 'fO : NO.tll->>' CIVIL TERM : IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Brian L. Hair, an adult individual currently residing at 1328 Pine Road, Lot 6, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Jane M. Hair, an adult individual currently residing at 592 Lake Meade Drive, East Berlin, Cumberland County, Pennsylvania. 3. The parties are the natural parents of one child, namely, Dylan Leigh Hair, born, July 10,2000. 4. The child was born out of wedlock. Since the child's birth, the child has resided with the following persons at the following addresses: NAME ADDRESS DATE Jane Hair Bailey (Jane's daughter) Jane and Barry McDermitt (Jane's parents) Lake Meade Drive Hanover, PA Birth to Sept. 2000 Jane Hair Brian Hair Bailey 1328 Pine Road Carlisle, P A Sept. 2000 - Feb. 10,2001 :i~"'~",,_, .^. '---',!,"_d"A~o ~,~,_ -r. '--__,<; "_Y0' ,-,<;",d",,"-'- c__V"_'_' -~~'__7___._ _ -, -, '-'-.,,_., ~- , . . Jane Hair Bailey Jane & Barry McDermitt 5. The relationship of the Plaintiff to the child is that of natural father. Plaintiff is married Lake Meade Drive Hanover, PA Feb. 10,2001- Present and resides alone. 6. The relationship of the Defendant to the child is that of natural mother. Defendant is married and resides with her parents, Jane and Barry McDermitt, her daughter, Bailey, and the child at issue in these proceedings, Dylan. 7. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning custody of the child. 8. Plaintiff has no information of a custody proceeding concerning the child pending in any Court of this Commonwealth. 9. The best interest and permanent welfare of the child will be served by granting Plaintiff shared legal and physical custody of the child for the following reasons: (a) Sine the time of the parties' separation on February 14, 2001, Father has not seen his son because Mother refuses to let him see him; (b) Mother will agree to Father spending time with his son only at her parents' house under their supervision, which is unacceptable to Father; (c) Plaintiff is equally capable to provide for the child's moral, spiritual and physical well-being; (d) Plaintiff is capable of providing for and meeting the day-to-day needs of the child; and (e) Plaintiff desires to be an equal parent and remain involved in his son's life. ~f '-_,F~"''''.,'_''D'"""_"_,_''-,,,,,~ - -f ."., ,- ". - L I".^_' '" co", _~,_ ", ,.__ . _ ~ - - ~', 10, Plaintiff does not know of any person not a party to the proceedings who claims to have custody or visitation rights with respect to the child. WHEREFORE, Plaintiff requests your Honorable Court to schedule a custody Conciliation conference followed by a hearing, at which time he should be granted shared physical custody of the child. Respectfully submitted, GRIFFIE & ASSOCIATES 17/ Maryl Attorney for laintiff 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 i';~~" "-~. '. --'nJ~.,i""',," P"'ii'\:"';'"" ,~,"~-~ -"-",,~,_-", ,-; '1_,',,"'__" ,:"1 ~-'_';_"t ,"- -- "'or' ,-- ":- _"~ 1'_ -," " - ~ ,,- , 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: J-d"it- 0\ /i~- ;yI /L BRIAN L. HAIR, Plaintiff ! ""~PJiNlll!ll!'>lili_l" . "'_h, , ~I'-'I, " - . ~ 1- - -'"I - ., -I ' ~i: ~ ~, ,=,.~ ~" ~. I ~, ",~.^"--~." ~..- ~.~, "' "".........m..".f 0 0 ~~ ~ C i) ~ :;,::,~ ~ 1L ~ -rJ("f7 ~,I C;.'U, :'.J ~ .<-.. I 2:1."" U)) C', ~ ~ -< ~ r-::; '''r) ~>) r r 5>~: :...) -;<' ~- :;1 -.c: -' -< r- 1- C<- (;._l Kf ,'_ .~ ~~j!'('!~'''''f''\W!~~WfK1'l\;<,'W!~I'li;"<}Il'I$f)%'ill~~~~_~l~~.",! ,~.~~i _?1;\;~ BRIAN L. HAIR PLAINTIFF V. JANE M. HAIR DEFENDANT IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-2040 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, April I?, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueliue M. Veruey, Esq. , the conciliator, al 4th Floor, Cumberland County Conrthouse, Carlisle on Wednesday, May 02, 2001 at 3:30 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 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 permanenl order. The court hereby directs the parties to furuish any and all 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 Iacqueline M. VemtO'. Esq. fP Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. Por information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please conlact 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 ATIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTIl 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 -,~ , - , -~ ,--, ';<J~i\Ii!"I:.;m~{i~!b;~Il;r,~"'~"""lli",>_'<ltit;!;fu&i,l1~~;;lli'.;;,w.,~,8\;I:.tJi-"""''''-;j,;,'~-',jH,>'.,i.j,:.~::i!"""~I-,-"",,,",<!;h~f~~~-' ,. ~ --L:illi" ~W~;l!;lIit~'_.' ctJ.s;, i"-- -- r::! /: ;~ . :-. r (', " ~~' ,; ~'i i PEN !\!S")I~;;.i!~J\n:i; .l/'N~I dr/~~/b 4~ 1/-!/I,t'l/ ~ ~ t~- Lfflf)( ~ M~-t;df~ --,r~'';'2'_~'-' r,,~r...~, ~~" "_~""_~"_'",, _ _ "< ,,,,,-\,. ,'""_,,.,. - , -', "__ "'" "._ _>~,^," ~__ ". 1!flm11l!f I L.~ '~~ ~""... ill '" Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA BRIAN L. HAIR, v. : CIVIL ACTION - LAW Defendant : NO. 2001-2040 CIVIL TERM : IN CUSTODY JANE M. HAIR, CERTIFICATE OF SERVICE I, Marylou Matas, Esquire, hereby certify that I did, the 24th day of April, 2001, cause a true and attested copy of the Complaint for Custody and related Order of Court dated April 17, 2001, to be served upon the Defendant, Jane M. Hair, by serving her attorney of record, Mark T. Silliker, Esquire, at 5922 Linglestown Road, Harrisburg, Pennsylvania, 17112, by first class mail, postage pre-paid on April 24, 2001. DATE: 4) Z 4 / 0 I . /1 0..; " ILL I clh.-u Marylou , Esquire Attorney for aintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800) 347-5552 ,~_\m.,... <. I" "'" "i,o:,-"c'm_1'~,-,~,VJ,u';_' _,' _.,:" , 'I"-~I-'-"--'-'-' +." I' .~-, ; ] I-~ -? . ., .,,- ;~ I I, "" "~ . '''''.- .,'- """'--, , "' 1l!!I~1~ -,' .,'" ,~ --~., ~. "' ~-" .~, ><. ~" ",;,,,,-"' -~-.~.~' ,. "0-""'- ",.'"" ,_'-;<_".~_,"''''i&<''''''''' ~ ~ [rirrt{[rtff~-~J{'~',~':~fi;e C') Cl 0 C " s:: ",.. "., ~\JJ -0 -,.. rn ::u ,"~::;,:D :::tl ~~~ ~C l'..) ~"<::;: en L"" v...... 0 -0 ~~~ ~ :::r. 8 z~-c5. ~~ - ,-..,Tfl "--" .. ._!~ U1 53i en -<: ~ "",,!l:'~~!fflj<'~![~!WIl~~~'~i!'~~!f~~Ii,!l~~~lf'~f'jf;~~~!iii~.jj!lI~i 1 JAN 0 9 200]11 BRIAN L. HAIR, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2001-2040 CIVIL TERM JANE M. HAIR, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 8th day of January, 2003, being advised that a custody complaint was filed by the within defendant at Docket No. 2001-2104 and the parties have proceeded under that docket number, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, A.~ Custody Conciliator "'''flil'_1:4 .~._. ~ , I"""> ---, '. , ,~~~ .- ~ - II "\- ".._~ ,.~.-,"Il!l!l~!;l"''''"'''' .~-~~'" ~, ViNI/i\lASNN3rl )J"NfI"'" 111, :',nlJ~j;:;V' ,'nn _,,,U " -', :'_ '_?; ~l II.,) J'\ f. 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