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Home My WebLink About01-03561 ,< ,L'I ~. ;".' ~~~~ ,;", . . , DENNIS EUGENE GARMAN AND FAYE MARLENE GARMAN PLAINTIFF V, HEATHER RENEE GARMAN AND LARRY ANDREW FREET DEFENDANT IN TIIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-3561 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, Juue 14, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, June 21, 2001 at 8:30 AM 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 C01l1rt hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR TIIE COURT, By: Isl 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 ATIORNEY AT ONCE, IF YOU DO NOT HA VB AN ATIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE 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 ,~""A '.,",'-'.1,' '~__ ~,~"'" _ '.'.___ '''~' .' ~__,,~>~""~',,~, .'< ",',~," ;,"--J. C~'. _",' ,~. . . ',"". d? /t/.cY/ IRllf.tf)/ Ir/tf.t!J( !:: II I i ii I I 1 :1 :'1 :',1 \ 'E,~ , .~=" ~, . (),c .HC~U)Pi?()TARY o I JUII Ii:, PN 3: 5 : CUMB~RLA!'JD COUNTY PcNNSYLViWIA o} sJ w-~~ ~4JJ~ ~~ ~~.~'t7IAk:l , t'~ ~ ---. ~ ~:-~ _....._~"'""""'" --." i WTr-~l1I!!IllII'~~~~~'~I!iWf"Y~{l'Off'''''''",,",'' ,'"","0",''-''1'''-'>'''''''' '''''~',''''''<i'1''i-1;,~!i'''',>r'cJi?''')''~';~'',''I'''''rlW~"Jl'AO';<!-J1?!Wi:l':'.~"",_:~'r,iIl! , . < --",,1>.1 "," ,,', ,',,' F:\FILES\DA T AFILE\Gendoc,cur\95302_com, I/tde ICreated: 0610610109:01:12AM Revis~: 06/06/011~:41'34AM " DENNIS EUGENE GARMAN and FAYE MARLENE GARMAN, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, NO, 01-.] r {., I CIVIL ACTION - LAW HEATHER RENEE GARMAN and LARRY ANDREW FREET, Defendants IN CUSTODY ORDER OF COURT AND NOW, this _ day of , 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 ,_, 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. 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: 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 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 I ~' , """"Ii , . DENNIS EUGENE GARMAN and FAYE MARLENE GARMAN, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, NO, 01- ..35''-/ CIVIL ACTION - LAW HEATHER RENEE GARMAN and LARRY ANDREW FREET, Defendants IN CUSTODY PLAINTIFFS' COMPLAlNif TO CONFIRM CUSTODY AND NOW, comes Plaintiffs, Dennis Eugene Garman and Faye Marlene Garman, by and through their attorneys, MARTSON DEARDORFF WILLIAMS & OTTO, pursuant to 23 Pa, C.S, S 5313(b), and, in support thereof, avers as follows: 1, Plaintiffs are Dennis Eugene Garman and Faye Marlene Garman, adult individuals residing at 590 McClures Gap Road, Carlisle, Cumberland County, Pennsylvania, 2, Plaintiffs are the parents of Heather Renee Garman, born April 5, 1980, whose address is presently unknown, 3, Plaintiffs are the grandparents of Jesime Renee Freet, born September 5, 2000, and who is presently residing with Plaintiffs at 590 McClures Gap Road, Carlisle, Cumberland County, Peunsylvania, 4, Defendant Larry Andrew Freet is the father of said child, Defendant is presently incarcerated at Mahoney Prison, BS7000, 301 Morea Road, Frackville, Pennsylvania 17932, Said Defendant has been incarcerated since August, 2000 on a parole revocation arising out of a conviction for burglary in the Court of Common Pleas of Franklin County, 5, Until approximately May 26, 2001, Plaintiffs' daughter, Heather, and granddaughter, Jesime, resided with Plaintiffs, 6, On or about May 26,2001, Heather left home and her whereabouts are presently unknown, Plaintiffs have not heard from Heather since she left home, 7, At about the same time Heather left the Plaintiffs' residence, she lost her job in Scotland, Franklin County, due to excessive absenteeism, .1,,-- l.I . ~:,' , . 8, At the present time, neither Defendant is able to provide for Jesime and Plaintiffs are functioning in loco parentis, 9, It is believed that the best interest of Jesime would be to grant legal and physical custody to Plaintiffs until such time as Defendants are willing and able to assume normal parental responsibilities, WHEREFORE, Plaintiffs pray Your Honorable Court to issue a temporary Order awarding Plaintiffs legal and physical custody of Jesime Renee Freet, MARTSON DEARDORFF WILLIAMS & OTTO BY1Lq LwIt~ Thomas J, ~Iiams, Esquire Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiffs Date: ? / II 01 " ,~ L, I ~ -,'" '-'-', M ""'"", , . VERIFICATION The foregoing Complaint to Confirm Custody is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language ofthe document is that of counsel and not my own, I have read the Complaint and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief, To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification, This statement and verification are made subject to the penalties of 18 Pa, C,S, Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false >v=~", I m,y be ""joct to crimi"" P~."]J~ ~ Dennis Eugene Gannan ."'~' 1I ._, o. '"'~'iOM&__: " , . VERIFICATION The foregoing Complaint to Confirm Custody is based upon information which has been gathered by my counsel in the preparation ofthe lawsuit. The language of the document is that of counsel and not my own, I have read the Complaint and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief, To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification, This statement and verification are made subject to the penalties of 18 Pa, C,S, Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties, ~L&n~A/\ Faye Marlene Garman ~k:" ,. i":"~J. "m~~~itMitl~(<'1<,,"i!ti&'il~,rr,;"&i~~~.!Iii~lo "Jjl 'ad"'~"~'<>-~~ > ,'J ~" " . ,',~ ~',= ".' "~ ~-- .u:; I: " <> <=> 0 C -n ~ <:: L "..{ (J S2~; c:: "," F ::;::: /1iffJ Q ~ I '.;Jrn ~ ~5'~, "':J'y CO .-', ~~ ~~; () ~c' -V ;1; -+-1 :> zO ~ 'oj;:') ,0 :<>2 w om ...... U Z :;:! ....... ~ :;:! :Xl <(:: 1-) ~ (J1 -< -...J \J ~ ---:D ~ ~ -~~ , , , "-,~.~"~. "" ,~. ' " - ,,~~ - ',~ ,j' 1,1 , ~ .".'- :;.";. F:\FILES\DA T AFILE\Gendoc.cur\95302_aff.ser Created: 06121/0108:19:13AM Revised: 06121/0108:24:21 AM DENNIS EUGENE GARMAN and FAYE MARLENE GARMAN, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v, NO, 01-3561 CNIL ACTION - LAW HEATHER RENEE GARMAN and LARRY ANDREW FREET, Defendants IN CUSTODY AFFIDAVIT OF SERVICE I, Dennis Eugene Garman, being duly sworn according to law, depose and state that I personally handed a copy of the Complaint to Confirm Custody and Order of June 14, 2001 " scheduling a Conciliation Conference to Heather Renee Garman, at 590 McClures Gap Road, Carlisle, Cumberland County, Pennsylvania on June I:), 2001, g~~ Deunis Eugene Garman Swo~to and subscribed before me this.,lf day of ~, O!.CtJ/ ' ~L;j () ~jJ Notary Public . NOTARIAL SEAL TRICI~ 0, ECKENROAO, Notary Public M~~~Sle Bore" Cumbetland County cI, 23, 2004 ~~:;..i;',,:;' ~i~~''--~~~'''''~~N~~%~i:tfuli~~';''''~'H ~J''''''tlij;~-- '.~~1,.,","~,,,,~ , ',< '~'~'''llillmijl( 'Ii '.." ~" ' t?~ C) Q c:: _$: rR ce, ,,= 2:'" ~ 2F'" ciS ,).'.. "" -<;:-.., i:.I; ~C~ ):""""" ::::> 2:' :r $,g Z ---j f\., -; W ",-~.' _Ji! C.. -1;;'1 :::::! i;i\~l -a~E "I i :~r;~ ;::~:' ....;.; t~~~ ~ 53 -< @ 1e,'1 _ "M""'" ~,,~\,;,' ^' ''''-''~.;:[;j., F:\FILES\DA TAFILE\Gel1doc,cur\95302_affserJfre Created' 0612.\~\QI\,\9'\3AM R<~vised: 06/25/0109'35':17 AM DENNIS EUGENE GARMAN and FAYE MARLENE GARMAN, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, NO, 01-3561 CIVIL ACTION - LAW HEATHER RENEE GARMAN and LARRY ANDREW FREET, Defendants IN CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) : SS, COUNTY OF CUMBERLAND ) I hereby certify that a copy of the Order Scheduling Conciliation Conference and Custody Complaint was mailed to Defendant Larry Andrew Freet at Mahoney Prison, 301 Morea Road, Frackville, P A 17932 on June 18,2001 by certified mail, return receipt requested, Attached is the Post Office return receipt signed "L. Ryan" and dated June 19,2001, '11\; JtIJl-r.;:.... s, Esquire Sworn to and subscribed before me this z.01ay of June, 2001. NOTARIAL SEAL TRICIA 0, ECKENROAO, Notary Public Carlisle Bora" Cumberland County MaD 04 , '"~ ..lI .., .-'l ::r I:J .-'l ,." I"- Postage $ Certified Fee I"- nJ '0 o Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) " o o Total Postage & Fees $ ..lI CJ :t(;f.iez:;:;.;e (P'A~ prin;:~~~ (to be completed by mailer) g t~9PJll/J~~~"""fi;;'~~~"''''~;'ji;..m...ii;. ~ '(r;:zl'~d~..mmm ....T..........TJm.....""~m...... " ',',.,~"_!-?:", ,_<",,' ',0" ",!", '",'C"',' '."'n____'- .. Complete aem. 1, 2, and 3, Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. .. Attach this card fa the'oacK6fthe rnl'lilp1ece; or on the front if space permits. 1. Article Addre~d to: Jtt, &.rrj ,4, t:"v~-r 6 S 7600 M.~, ~~ <P(';s~ 3D{ ~ ~o-d. r::ro.Jty;(j'{, fJ.4. 1793.)..,- I x D. Is delivery dress different from item 1? If YES, enter delivery address below: ":1.'1 ".~ o Agent o Addressee Dyes o No 3. Service Type ~ Certified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2, 'Aiflcfe Number (Copy from service label) 74Pd i :4@,(J'()o.1.lJ/O ,,<11 r6 PS Form 3811; July 1999 ' , 'Dom.;.tlc Return Receipl 102595-0o.M.0952 ,.,",,' l'~ ;;; "M,',,~" '"1 j~~~~"iuitli. Ifl~;Ltt~<i~<'i,,,i"~'';:W'~'~'''~"filclil'MiiN~M< ~, _li'''~'..lIJ!I.' &,~ ~^"''''';,.,,~1IIiIlI1HI ~'~,_. "" ,-~ 0 0 .-., n c :0,.--1 ,is: I:ltC' L mlT~ ~I Z::r' .,-- ZC {'....) " (j) -~' (- "" -<;C' ,,;', ~ ~?~' >?? ~, 2:: tJ ~ -j :., - :"'tJ \N ..... ..~ -< ~ -t:. :>. ~ .~- t ~, """- ",l '~I.I~ 'L " ~ -""""~...-.""'" . .-, lJUN 2 2 Z.fIJ DENNIS EUGENE GARMAN, and: IN THE COURT OF COMMON PLEAS OF FAYE MARLENE GARMAN, : CUMBERLAND COUNTY,PENNSYLV ANIA Plaintiffs V, HEATHER RENEE GARMAN and LARRY ANDREW FREET, Defendant NO.2001-3561 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this Z q rtaay of :r u.J) t".. , 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1, The Grandparents, Deunis Eugene Garman and Faye Marlene Garman, shall have sole legal custody ofthe child and primary physical custody of the child with the parents having periods of visitation and partial physical custody as the grandparents and the respective parent agree, 2, 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. BY THE COURT, (5 / < \-1. cc: Thomas 1. Williams, Esquire - Counsel for Grandparents fuoY'. Heather Renee Garman, pro se ~ ;;p.:\l ';1 590 McClures Gap Road r()\ .l 0\ 't\\ Carlisle, PA 17013 })..'b' Larry Andrew Freet )g (i1W,t9NO~ Prison BS 7000 301 Morea Road Frackville, P A 17932 c c' '-'~ .' ;~~ '--I -::J i - r;-'l f"-l L_ , "., ;::::: F- ,".,) .0 (j) CJ -< -'-, " '--' ::':..- ., "-- -- -." , Z \"." ('-'. . > '-~' C) (j C Z -I 'c-" :<! (..) :::0 -< ,""'''' "'" "''"=', ',.~ , . =~ ~. I ...... ~ ,1:1 -', ,~ r~' ~ "' >' ~J"~",I;"":;.",,,'~ J' ~... JUN 2 2 Z001 DENNIS EUGENE GARMAN and: IN THE COURT OF COMMON PLEAS OF FAYE MARLENE GARMAN, : CUMBERLAND COUNTY,PENNSYLVANIA Plaintiffs V. HEATHER RENEE GARMAN and LARRY ANDREW FREET, Defendants : 2001-3561 CIVIL TERM : CIVIL ACTION -LAW : 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 Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Jasime Renee Freet September 5, 2000 Grandparents 2, A Conciliation Conference was held in this matter on June 21, 2001. Grandparents, Dennis Eugene Garman and Faye Marlene Garman, were present with counsel, Thomas 1. Williams, Esquire~ Although served, neither parent appeared at the Conciliation Conference, Father is incarcerated at Mahoney Prison, Mother, although living at the home of her parents, Plaintiffs herein, leaves the residence from time to time without indicating her location or length of stay, in effect abandons the child, 3, attached, The parties present at the Conference agreed to an Order in the form ~ -,}..I -0 I Date ~Jh'~/ tyacq line M, Verney, Esquire Custody Conciliator ,::; .. '-. ,.....;..1 '~ ;', "'j' F:lfILESIDATAFILE\Gendoc,curll0346-cus,cer Creq.ted: 051l:5/o1'02:03:1)PM Revised: 06127/01 05:33:38 PM , .. PAUL D, MYERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, NO, 01-3641 CIVIL ACTION - LAW KELLY MYERS, Defendant IN CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) : SS, COUNTY OF CUMBERLAND ) I hereby certifY that a copy of the Complaint in Custody was mailed to Defendant Kelly Myers at 617 Whiskey Springs Road, Boiling Springs, P A 17007 on June 21, 200 I by certified mail, restricted delivery, return receipt requested, Attached is the Post Office return receipt signed "Kelly Myers" and dated June 23, 2001, 'I Thomas J. Wil J[~ Sworn to and s~~ribed before me this Lg"day of )@o,200L k , ~ to. ~ O~P"bli' or NOTARIAL SEAL TRICIA D, ECKENROAD, Notary Public Carlisle Bora" Cumberland Coun~ M Com ' I n lS pel. 23, 2004 , '" 1:.....,_ ~-i;; " ij-""'" - l"- n! CJ , CJ CJ CJ --D CJ CJ CJ CJ :1"- ( IT" I"- ;.-'1 :r CJ .-'I IT1 I"- Postage $ Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) -->~; c~';;pW ~W~;;~'T,2,';';'d3:AIS()c::ompi.;t~" item 4 il R""tricted Delivery is desired, . print your name and address on the reverse 50 that we can return the card to you. . Allach this card to the back 01 the mailpiece, X or' on the front if space permits. 1. Article Addressed to: u~~vL [~~ ti b~I\'t1l3")~;1\ ~-l~~ 17007 3. Service Type Q'Certified Mail o Registered o Insured Mall o Exp~s Mail D Return' Receipt for Merchandise OC,O,O, 4. Restricted Delivery? (Extra Fee) gyes 2. Article Number, (C00 ~,rom se~,iC labeQ tJ. '. 7QVoi ,a ,~,~(L~d:( 171ft,: i P$ FolIhii 3'811! aiJIyi1i999 i ij ii" i' Ooin';"ic Return Receipt ; ; ~ ' \ , " 102595-99-M-1789 " ii~ ., '" ' , " ~!fJO!'" ~' "'1I~~~~OCt'o.~..~"i\iilii_~i>::i.13~' - .'~ ~ o,~ ~ '~ ~ ~ ~,. ," ~~, ~' 1Uiltt i i'lLi i~ liM.llilf.i iiI1!iI:iil'" '", 0 C") c- C <'" ~ :Pf~ r:-:-;;: fl1U ~;~ 1': r -) ('> L:l.: J-".';- ",-. '" " " -'? eo ~- - ):.:: ~:.' ~ , <? :--"1 <! (tl ::':;J VI -<" VI >- :s (; ~ ,~ . J