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Home My WebLink About01-05378.~~~ ~__ ~.-, • KEITH D. JOHNSON IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF 01-5378 CIVIL ACTION LAW V. JOEL N. BRYAN DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, September 18, 2001 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. ,the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on Monday, October 29, 2001 at 9:15 a.m. for aPre-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 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: /s/ Melissa P. Greev~, Esq. 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 informafion 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 ek'SU.pBt Ewa i ~ -rti-caste a ~. ,~r' i" ~ ~~.~' _'~ ~O off- ~ ~'iNdAI,~SNN3d } : fi, ~ ~,r 1 ,~j i / 1 s~P,:i 7~4~J1/y KEITH D. JOHNSON, Plaintiff v. JOEL N. BRYAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA No. Ul - .S',~2'd~ ~~U~~~~ CIVIL ACTION - AT LAW FOR CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint/Petition it is hereby directed that the parties and their respective counsel appear before the Custody Conference Officer at, on the day of 2001, at o'clock a.m./p.m. for a Custody Conciliation Conference. At such Conference, an effort will be made to resolve the issues to be heard by the Court and to enter into a Temporary Order. Children need not be present at the Conference unless their presence is requested by the Custody Conference Officer. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent Order. FOR THE COURT: Date: By: Custody Conference Officer YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO THE OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP Cumberland County Bar Association !~ Two 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 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. KEITH D. JOHNSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,P/nENNSYLVANIA v. No. Dl - Su' "j~'' ~1u~L JOEL N. BRYAN, CIVIL ACTION - AT LAW l~ Defendant FOR CUSTODY COMPLAINT FOR CUSTODY The Plaintiff, Keith D. Johnson, by and through his attorney, The 'Law Offices of Patrick F. Lauer, Jr., files this Complaint for Custody against the Defendant, Joel N. Bryan, and in support thereof, avers the following: 1. The Plaintiff is Keith D. Johnson, an adult individual and the natural Father, who currently resides at 4 Fairfield~l Street, Apt. #1, Newville, Cumberland County, Pennsylvania 17241. 2. The Defendant is Joel N. Bryan, an adult individual and the natural Mother, who currently resides at 224 B Street, Carlisle, Cumberland County, Pennsylvania 17013. I 3. The Plaintiff seeks custody of the following child: Name Present Residence ~ I Jarrod S. Johnson 4 Fairfield Street 5 month ~, Apt. #1 (March 21, 2001) I~ Newville, PA 17241 The child was born out of wedlock. i The child is presently in the custody of his mother, Joel N.' . Bryan, who resides at 224 B Street, Carlisle, Pennsylvania. During the past five years, the child resided with the following persons and at the following addresses: Name Joel N. Bryan, Bill, Heather, Jules and Harley Keith D. Johnson Address 224 B Street Carlisle, PA 17013 4 Fairfield St., Apt. #1 Newville, PA 17241 Dates 3/21/01 (birth) 9/2/01 9/2/01 - present The Father of the child is Keith D. Johnson, currently residing at 4 Fairfield Street, Apt. #1, Newville, Pennsylvania 17241. He is single. The Mother of the child is Joel N. Bryan, currently residing at 224 B Street, Carlisle, Pennsylvania 17013. She is single. 4. The relationship of the plaintiff to the child is that of natural Father. The plaintiff currently resides with the following persons: Name Relationship None 5. The relationship of the defendant to the child is that of natural Mother. The defendant currently resides with the following persons: Name Bill Heather Jules Harley Relationship Friend Friend Friends Child Friends Child 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interests and permanent welfare of the child will be served by granting the relief requested because: (a) Plaintiff is the natural Father of the child. (b) Defendant has not made an effort to accommodate Plaintiff spending time with the child, including purposely not disclosing to him when she was going into labor. (c) Defendant's family lives in the state of Missouri and defendant has expressed her desire to take child and move to Missouri. (d) Plaintiff's parents and Defendant's step-mother live near Plaintiff and have expressed a desire to !I be an active part of the child's life. 8. Each parent whose parental rights to the child have not VIII been terminated and the person who has physical custody of the child have been named as parties to this action. No other persons are known to have a right to or have claimed to have a right to custody or visitation of the child. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an Order granting to him custody of his child. Respec~f~illy t eet, A tec uilding Camp Hill, Pennsylvania 17011-4706 PA Supreme Ct. ID No. 72655 /,~ /~~ I Phone: (717) 763-1800 Date: /J Law Offices of atrick F. Lauer, Jr. 2108 Market S z B ' KEITH D. JOHNSON, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA v. No. JOEL N. BRYAN, CIVIL ACTION - AT LAW Defendant : FOR CUSTODY VERIFICATION I, Keith D. Johnson, state that I am the Plaintiff in the above-captioned case and that the facts set forth in the above Complaint for Custody are true and correct to the best of my knowledge, information, and belief. I realize that false statements herein are subject to the penalties for unsworn falsification to authorities under 18 Pa. C.S. § 4940. Date: q / 0 r ~' ~c~ C ~ ~ d ~ ~ y~ l_/ C ~:~i° ~,~~: ~~ D ~'~ »C~ -G LJ 'n ~y .~ a C.1 cs ~t +1 _._~ rn _j Cii ~~ 7 Ci i- -~G KEITH D. JOHNSON, Plaintiff vs. JOEL N. BRYAN, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 01-5378 CIVIL ACTION - AT LAW -CUSTODY Kindly mark the above-captioned matter settled and dismissed with prejudice. Date: -D ~ ® ~ MatthevJ~T. Eshelt Esquire Law Offices of Pa ' k F. Lauer, 7r. 2108 Market Street, Aztec Building Camp IFill, Pennsylvania 17011-4706 ID# 72655 Tel. (717) 763-1800 (' S V~ ~ ~ _ __• t _ - (' ""(J ~ Lei _ 'i 1 ' U~ .,.. tSJ y .! :'... I ~'~ ...-. __. (~ j Q ;4 Cs ~r ~ ex~ ~~ NOV U 5 2001 KEITH D. JOHNSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01-5378 JOEL N. BRYAN, CIVIL ACTION -LAW Defendant CUSTODY ORDER TO RELINQUISH JURISDICTION AND NOW, this 25~h day of October, 2001, the Conciliator, having been informed by counsel for the Plaintiff that the parties have reconciled, hereby relinquishes jurisdiction of the matter. FOR THE COURT, Me issa Peel Greevy, Esquire Custody Conciliator %~ ti.? - ~" J_ ~_ 7 ii ~. _ - l %t ~ :~ 'y~ - f ~ Y ~ :" _ ^J ; i- , (l' ,~; =~. r _ ~. ~..7 /~~ .~,D