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Home My WebLink About99-03711 Ir r G 1 _M -J i WAYNE V. COOLEY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. Cl MINERVA COOLEY, CIVIL ACTION - LAW Defendant 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 ?CAII I1 S StUidCtii 60S , the Custody Conference Officceor, on the day o 4-1 9uJ 1999, at p.m., at °r1. achcn,c?b Pennsylvania, for a Pre-Healng 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 at the request of either party. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: Dated: to /QLi /,(I By: c o?? 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. Lawyer Referral Service Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 (717) 240-6200 114aA& WAYNE V. COOLEY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. MINERVA COOLEY, CIVIL ACTION - LAW Defendant CHILD CUSTODY N O T I C E YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property, or other rights important to you, including child custody, or child visitation. 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. Lawyer Referral Service Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 (717) 240-6200 WAYN7 V. r'_r7r.`,RY, ,ainl Ff v. MTNRRVA COOT,EY, ,;) rr nrlant. iN !',IF CnrJRT ()F ;'nMMON PLEAS -"JMRRRr,AND rOJINTY, PF.NNSYTNANTA r I VT T ? ACT MN J,AW cHTr.i-) -,nSTnnY C_OMPLAI__NT__-FOR__CHILU CUSTODY AND PIO`A comes `he Plainti ff, 'gaYnP '/. Cooley, by and through his attr>rne7, Mark T. SilIiker, and respertfuLly requests this Honorable Collrt award him r:ust.orly of the subject minor rhilrlren, and in suppor' thrnr,1tn, avers the following: Plaintiff is 4layne N. Cooley, an adult individual residinq at 61.1 R rieneVa !)T Apt:. 1 I, Cumber Land Count,/, Pennsylvania. 17055. ). O?Fenrlant is Minerv,) Conley, an adult individual resirlinq at Villar(n Knoll Apartments, Apt. 1, First Floor, Joya rircIn, Harrisburg, Dauphin r:rnlnt/, Penns7lvania. 17110. 3, Thn Su I) nrt chi1olren ire Wayne V. Cooley , Jr., born Snptembnr 16, 1989 , and Tylnn I). Cooley, horn October 6, 1991. 1i„ I at 11) of the PlaiW.iff to the subject till tlor rhi 1fit nil 1^ Ihat of oat oral Ia1 hRr. 5 l•hn Inl;ll If)IISIIIh of iln l 1tofenclant to the subject . nllnnr <.hlldt,t l Is Iltnt of nalutal mothrt 6. The minor children have resided at the following addresses, in the custody of the following individuals: a) From December, 1996 to present - the subject children reside with Plaintiff, Plaintiff's wife, Lisa R. Cooley, and her son,, Michael R. Allen, at 613 B Geneva Drive, Apt. 13, Mechanicsburg, Cumberland County, Pennsylvania. b) From December, 1995 until December 1996 - the subject children resided with Plaintiff at 1809 North Second Street, Harrisburg, Dauphin County, Pennsylvania. c) From 1992 until December, 1995 - the subject children resided with Defendant at several addresses in Dauphin County and Lancaster County. d) From birth until June, 1992, the subject minor children resided with Plaintiff and Defendant in Harrisburg, Dauphin County, Pennsylvania. 7. There have been no prior actions for custody of the subject minor children in this or any other jurisdiction. 8. The Plaintiff is not aware of the existence of any other individuals who have any type of claim whatsoever regarding the custody of the subject minor children. 9. The Plaintiff believes, and therefore avers that he is much better able to meet the needs of the subject minor children than the Defendant. 10. The Plaintiff believes, and therefore avers that it is in the best interest of the subject minor children that they be placed in his legal and physical custody. WHEREFORE, Plaintiff requests this Honorable Court award him custody of the subject minor children. Date: Respectful suuf end, rk T. Silliker Attorney for Plaintiff 5922 Linglestown Road Harrisburg, PA 17112 (717) 671-1500 I.D. No. 33671 A F F I D A V I T I,(1/IP V r n , hereby certify that the aforegoing J is true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 pa. C.S. 4904 relating to unsworn falsification to authorities. Dated: L./ti /gq ?J ti v? ?1 J I v ` M i? ,r7 V o ^- x %rz?_ Z 7" Z ; r Z ? z z z y`C O Z 7 - :EE.7za .? TyF n ' s z G SILI IhFR,C It l.i?HUi U AN G 1999 I?.AHIU,1111u1'1 ]!.,Y 1?VAhlA iii:1 ?' I I 1 LI'IIUM. I'll 1? o'I I •ui WAYNE V. ODOLEY, Plaintiff VS. MINERVA COOLEY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3711 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this - \ day of 1999, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Wayne V. Cooley, and the Mother, Minerva Cooley, shall have shared legal custody of Wayne V. Cooley, Jr., born September 16, 1989, and Tylon D. Cooley, born October 6, 1991. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. 2. The parties shall share having physical custody of the Children in accordance with the following schedule: A. The Mother shall be entitled to have custody of the Children on alternating weekends from Friday through Sunday, for one weekday evening per week and for up to 3 nonconsecutive weeks during the summer school vacation. The Mother shall provide at least thirty (30) days advance notice of the dates she selects for extended periods of summer custody under this provision. B. The Father shall have custody of the Children at all times not otherwise specified for the Mother under this provision. 3. The parties shall share having custody of the Children over holidays as arranged by agreement. 4. In the event neither party is available to take the Children to their medical appointments, the parties agree that the Father's wife, Lisa Cooley, shall be authorized to do so. 5. Neither party shall do or say anything which may estrange the Children from the other parent, injure the opinion of the Children as to os i w 33 j N N U i W aC 4 H = 9 u o x gg O i p J 'O H t? h m ?'?? a as ?$' g N m a E d U O VI oo ; ppF 3 AUG - 6 the other parent, or hamper the free and natural development of the Children's love and respect for the other parent. 6. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. 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 0OURT, cc: Mark T. Silliker, Esquire - Counsel for Father Minerva Cooley, Mother WAYNE V. COOLEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 99-3711 CIVIL TERM MINERVA CCOLEY, CIVIL ACTION - LAW Defendant IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CI!ffiERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Wayne V. Cooley, Jr. September 16, 1989 Father Tylon D. Cooley October 6, 1991 Father 2. A Conciliation Conference was held on August 3, 1999, with the following individuals in attendance: The Father, Wayne V. Cooley, with his counsel, mark T. Silliker, Esquire, and the Mother, Minerva Cooley, who is not represented by counsel. 3. The parties agreed to entry of an Order in the form as attached. Date r Dawn S. Sunday, Esquire Custody Conciliator