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Home My WebLink About01-03641 ,- ~ ". '..:1""" '" .""~ r., _.__ .', ,. ;.1:'.'"< ~ of I' r-' PAULD.MYERS PLAINTIFF V. KELLY MYERS DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 01-3641 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, June 20, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties ood their respective counsel appear before Hnbert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, July 20, 2001 at 9:30 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 cmmot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All childTen age five or older may also be present at the conference. Failure to appear at the conference may provide gTounds for entry of a temporary or permooent order. The court 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 THE COURT, By: Isl Hubert X. Gilroy. Esq./J// Custody ConciliatOT The Court of Common Pleas of Cumberlood County is required by law to comply with the Americoos with Disabilites Act of 1990. FOT information about accessible facilities ood reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arroogements must be made at least 72 hours prior to any hearing 01' 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 HA VB 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, Pennsylvooia 17013 Telephone (717) 249-3166 .i --=" ,~, -- ., ~, . OJ:; 01 Jil"!? I 'h CQ I '-->,;~ ,_ (_" .,10;1' CUM2Er,IJ"Je) COUNTY PENNSYLVNIiIA ~. ,;v'elf &vi ~ ~ :$4: /PI b /JCY-GJ t,-,;)/-c;J/ 71~~"/ ~ ~. ~7 t-c)/-tJ/ ~ ~ ~ W:~ ~. fl' I. el I .,j , H ~ ::ji 'I. il 'i i! i '" ,Irfil.JW!~~rnl~~${~'~~~f-'llW'\l~'~'W"E~I":'l;Wll!Il!'"'tJJ"=,~" J4"'Y"_",";~~~:i'i;Hl~t%'ill1)ff'C""B'inS,!j:'.""1-""':<''>"'8-''1!~'1},,_,{"i":'C;"!'!i;-:Pit'i"!~~l'f<H'R'-'>1~7"~"'~!MiM!<jil'rMH'l~~N- ,~"'o~ ~ ,- " . -," .- ,~"'-', .~'.~ ~ -r::.. '~ ,~ -'"""J;": ~ F:\FILES\DATAFILE\Gendoc.cur\I0346_cus.com Created; 05/15/0102:03:13PM ftevised: 051\1i/OI02:19:13PM . PAULD.MYERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO.01- 3fptf/ CIVILACTION-LAW KELLY MYERS, Defendant IN CUSTODY ORDER OF COURT AND NOW, this_day of it IS hereby directed that the paliies and , the conciliator, at , upon consideration of the attached Complaint, their respective counsel appear before 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 cmmot 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 oldeT 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 ,-""- , ~ " ~ -, . ... j'" ' " ~'f',I,~ t-' ~w, . J PAULD. MYERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO.01- 3''1/ CNILACTION - LAW KELLY MYERS, Defendant IN CUSTODY PLAlNTIFF'S COMPLAINT TO CONFIRM CUSTODY 1. Plaintiff is Paul D. MyeTs, an adult individual currently residing at 103 Third Street, Boiling Springs, Cumberland County, Pennsylvania, 2. Defendant is Kelly Myers, an adult individual currently residing at 617 Whiskey Springs Road, Boiling Springs, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the children: Andrew Joseph Myers May 23,1988 Seth Douglas Myers June 18, 1993 Zachary Alan Myers August 19, 1994 The children were not born out of wedlock. Since their birth, the children have resided with the following persons at the following addresses for the following periods of time: The children resided with the parties at Defendant's address, until the parties separated on May 3, 1998, and the children have continud to resided at the Defendant's residence. 4. The Telationship of the Plaintiffto the children is that off ather He is married and living separately. The Plaintiff currently resides with the following: Nmne Relationship Lisa Cook Girlfriend , "'_T -"^~,,,'I~....,'~' -" o!l;1~Jg 5. The relationship ofthe Defendant to the children is that of mother. She is married and living separately. The Defendant currently resides with the following: Nmne Relationship Andrew Joseph Myers Son Seth Douglas Myers Son Zachary Alan Myers Son 6. The parties have not participated in previous litigation concerning the custody of the children in this court or any court. The Plaintiff has no information of a custody proceeding concerning the children pending in any other court. 7. The best interest and permanent welfare of the children will be served by granting custody to Plaintiff because he can best provide a stable and nurturing enviromnent for his sons. 8. Plaintiff does not know of 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 set a time and place for a hearing at which Plaintiff requests the Court to grant him the Custody Order. Pending said hearing, Plaintiff requests temporary custody. MARTS ON DEARDORFF WILLIAMS & OTTO ~, By ~L LvJJ- ~ Thomas J. Wil s, Esquire Ten East High eet Carlisle, PA 17013 (717) 243-3341 t. (,1/61 Date: May _,2001 Attorneys for Plaintiff - ~' , ;"" . +I-~."' -" ~,' ;':''''1'. ,,,_,I " .' ~ -,,~-;*,~, VERIFICATION The foregoing Complaint to Confirm Custody is based upon infofl11ation 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 Tead 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 subj ect to criminal penalties. 7rwJ Do ~ Paul D. MyeTs ~~j(;'i< '''~~jrfii --"~\~~~:$:~1l!ik;~hK->:':t:fi (;'it"".~1~J-~_,,-i.;-;ill~,,01iw.'~.i,~r,w;a!ii:n~jjiliiO~~M~W,j;~~~-1 ar" n--'- 'iJli'Rlll ~"~ :It ~. ~~ ~ ~ C;; ~ '\'S . '-& ~ \ ~ (") c -oS:: mo., P'"' Z:x, Zr"-~ 0) '}-:.. -r ~: ~c; ;g;c --c >~ ~ z :< ~r;- ~'" ~ <:::> '- c.-:: Z e ,-? J'~ :-;::1 --> " i';"'~ .. ,1;T; -,d'~' .", r -~',;~~) w ",. :~: VJ ~-~? co:) C~)n.. s;: 51 -< j";,) -..l ~, ~ ~; 'I, , 'L. '...' -~ -.' i:.C""'~~;:! '..... .~ ~~~ . PAULD.MYERS PLAINTIFF V. KELLY R MYERS DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-3641 CIVIL ACTION LAW IN CUSTODY ORDER OF COURt AND NOW,. Wedn~sday, Jnly 18,,2001 , upon consideration ofthe attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqneline M. Verney, Esq. , the conciliator, at 4th Floor, Cnmberland County Courthouse, Carlisle on Wednesday, August 22, 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 cmmot be accomplished, to define and narrow the issues to be heard by the court, and to enteT 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 fOT entry of a temporary or permanent order. The court 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 THE COURT, By: Isl Jacqueline M. Verney. Esq.rJ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americalls with Disabilites Act of 1990. For information about accessible facilities alld reasonable acconunodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to allY hearing or business before the court. You must attend the scheduled confeTence 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. Cumberlalld County Bar Association 2 Liberty Avenue Carlisle, Pennsylvallia 17013 Telephone (717) 249-3166 ,- ; - _,;",",..==,.L~' , ~'o~~'~_.~... .",~,~'~ -' -- ':a!lilji"-""~;""" . ~. = ~ ~i'oi ""jjh~W~~'&;!ij4',,-,Bi:,,",$"'~"',,*J$.'lMliJi,~",WMi~i@j!lli.'iilf';#;~j,*:;;'$_;(;Hf,-Mo5!!M~W.Jli!;l.j~~fr~ --............. """ . W-. . ,-.[ "'. ., \: ,.,. ij " 7/;'0/01 - Coo- Cbtt malk( --10 ~ wffi~u'J\s A:d-1t:.E..- ma~tul--lc )~. (2.op'f p~("~rLI~..J,~lr .fJ.LL ""',~',-~,~~~, ~ ,,_ _~_. ~,,,,<_, "~_,_',.,,~">,,"'''',~,,". _ _"",~O~,_ . - ~ ~,' ".~ - ~ . - __ to v JOHN H. BROUJOS HUBERT X. GILROY BROUJOS & GILROY, P.c. ATTORNEYS AT LAW 4 NORTH HANOVER STREET CARUSLE, PENNSYLVANIA 17013 TELEPHONE' (717) 243-4574 FACSIMILEo (717) 24~8227 INTERNET: brgilroypc@aoLcom NON-ToLL FOR HARRISBURG AREA 717-766-1690 July 9, 2001 Richard J. Pierce, Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, P A 17013 Re: Myers v MyerslNo. 01 - 3641 Dear Rick: One of the parties in the above referenced matter had contacted my office for representation. Accordingly, I cannot serve as Custody Conciliator. Please refer the case to another Conciliator for the scheduling of a conference. 7rs, Hubert X. Gilroy dca cc: Thomas J. Williams, Esquire Kelly B. Myers , '''~ , : ,fi"''' ~",..~ '!~ '.,9 0 _ ~""',~-/Ji)-1 '" ~ ( \ , , "- - .. '~~. ~-. '.. ~, iIIi.~ ' ^,~'f,f, NOV 2 8 2001~ PAULD.MYERS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2001-3641 CIVIL TERM KELLY B. MYERS, Defendant : CIVIL ACTION -LAW : IN CUSTODY ORDER OF COURT AND NOW, this 28th day of November, 200 I, the Conciliator having continued the Conciliation Conference for more than thirty days and the parties have not contacted the Conciliator to rescheduled the conference, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, ~,u cqu . eM, Verney, Esquire, Custody Co lliator : , 1 ,~ ~'"'1"~""" ~~ ~ ". __ ~ J<'_ "' ~ ," "~~.,." " '''~''''''''"', ~:-~LEj) O}:FlCE OF T~' ::'" ! }:ONOTARY G I DEe 27 Pi'l 2; r. ! CU' "'"I' ',,', COUNTY Mdl:,-iLAj'"L; , I PENNSYLVANIA ,~ ,"'", "~~Il!!.l!1l,. W"r" ~. ~~{I~ml~%~(F~j'1~(*;~,'-B"j~~~~~il"l;il)1M~~"',Wiffi~!ID!!~,jIIii!~~,Ni>