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Home My WebLink About99-03766S,T f'1< s :NL 1 1 MARK EDWARD BURKE, Plaintiff, VS. BARBRA EBY BURKE, Defendant. " IN THE COURT OF COMMON PLEAS " CUMBERLANDCOUNTY,PENNSYLVANIA x " NO. 99 - 371o(a x " CIVIL ACTION - LAW " CUSTODY ORDER OF COURT AND NOW, this a14 day of Uune , 1999, upon consideration of the attached complaint it is hereby directed that the parties and their respective counsel appear before M chc o I 1, , , Esquire, the Conciliator, at 3oI 5 16 ' "3L _00PIP N111 pc, 1700 , Pennsylvania, on the rr day of 1999 at 3 : Da o'clock, A. m., for a Pre-Hearing 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 a temporary order. Either party may bring the child who is 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. FOR THE COURT: By_ /) ZGe/it l.[ Z 1 A/ /r9 . Custody Conciliator 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. OFFICE OF THE COURT ADMINISTRATOR 1 COURTHOUSE SQUARE, 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 99 o 10 . Gs??9 MARK EDWARD BURKE, " IN THE COURT OF COMMON PLEAS Plaintiff, " CUMBERLANDCOUNTY,PENNSYLVANIA N Vs. " NO. N BARBRA EBY BURKE, " CIVIL ACTION - LAW Defendant. " CUSTODY I COMPLAINT FOR CUSTODY j AND NOW, Plaintiff, Mark Edward Burke, by and through his attorney, Edward J. Weintraub, Esquire, files a Complaint For Custody against Defendant, Barbra Eby Burke, and in support thereof, avers the following: 1. Plaintiff is Mark Edward Burke, Father, who currently resides at 208 April Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Barbra Eby Burke, Mother, who currently resides at 208 April Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff seeks shared legal and physical custody of the following child: NAME Present Address AU Logan Montgomery Burke 208 April Drive 5 (Date of Birth 11 /8/93) Camp Hill, PA 17011 4. The child was not born out of wedlock. 5. The child, Logan Montgomery Burke, is presently in the custody of both Father, Mark Edward Burke, and Mother, Barbra Eby Burke, who currently reside at 208 April Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 6. During the past five (5) years, the child, Logan Montgomery Burke, resided with the following persons at the following addresses: Persons Address Date Mark Edward Burke 208 April Drive Birth to Barbra Eby Burke Camp Hill, PA 17011 Present Logan Montgomery Burke 7. The Mother of the child is Barbra Eby Burke, who currently resides at 208 April Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 8. The Father of the child is Mark Edward Burke, who currently resides at 208 April Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 9. The parties are married. 10. The relationship of Plaintiff to the child is that of Father. Plaintiff currently resides with the following person: Person Relationship Barbra Eby Burke wife Logan Montgomery Burke son 11. The relationship of Defendant to the child is that of Mother. Defendant currently resides with the following persons: Person Relationship Mark Edward Burke husband Logan Montgomery Burke son 12. Plaintiff and Defendant have 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. 13. Plaintiff and Defendant have no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 14. Plaintiff and Defendant do 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. 15. The best interests and permanent welfare of the child, Logan Montgomery Burke, will be served by granting the relief requested, inter Aljd, because the Plaintiff Father has been equally involved in the nurturing and raising of the child. 16. Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene. Name Address Basis of Claim NONE WHEREFORE, Plaintiff respectfully request that this Honorable Court enter an Order granting shared legal and shared physical custody to Plaintiff, Mark Edward Burke, of the child, Logan Montgomery Burke. Respectfully Submitted, By( 4 war W tr , Esquire 2650 North Third Street Harrisburg, PA 17110 (717) 238-2200 Attorney ID. #17441 ATTORNEY FOR PLAINTIFF Dated: ?/?/ VERIFICATION I, Mark Edward Burke, hereby swear and affirm that the facts contained in the foregoing Complaint for Custody are true and correct and are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: 0-? y 5'T $U Mark Edward Burke ?- n o ? ? ? LJ <. i ? ) .:, ,, .? `? ,J MARK EDWARD BURKE, Plaintiff Va. BARBRA EBY BURKE, Defendant cw . ?..rnn {n ' IN THE COURT OF COMMON PLEAS ' CUMBERLANDCOUNTY, PENNSYLVANIA ' NO. 99-3766 CIVIL ' CIVIL ACTION - LAW ' CUSTODY CERTIFICATE OF SERVICE I, Beth A. Theurer, Paralegal to Edward J. Weintraub, Esquire, hereby certify that on June 29, 1999, 1 served a true and correct copy of Plaintiff's Complaint for Custody upon Defendant Barbra Eby Burke, by depositing same, certified mail, return receipt requested, postage pre-paid, in the United States Mail, Harrisburg, Pennsylvania, addressed as follows: Barbra E. Burke 208 April Drive Camp Hill, PA 17011 ?C . Date: "I ? lir?•??i ? Beth A. Theurer MARK EDWARD BURKE, Plaintiff Vs. BARBRA EBY BURKE, Defendant « IN THE COURT OF COMMON PLEAS " CUMBERLANDCOUNTY, PENNSYLVANIA NO. 99-3766 CIVIL " " CIVIL ACTION - LAW " CUSTODY CERTIFICATE OF SERVICE I, Beth A. Theurer, Paralegal to Edward J. Weintraub, Esquire, hereby certify that on June 29, 1999, 1 served a true and correct copy of Plaintiff's Complaint for Custody upon Defendant Barbra Eby Burke, by depositing same, certified mail, return receipt requested, postage pre-paid, in the United States Mail, Harrisburg, Pennsylvania, addressed as follows: Barbra E. Burke 208 April Drive Camp Hill, PA 17011 Date: l ?? Beth A. Theurer ?? - ;:, ,? - ?,, ' , :: -- - ?,_?: - -. ?:; ?-; ?? ,. ,,. ,. r. r.??.._? .__, I MARK EDWARD BURKE, • IN THE COURT OF COMMON PLEAS Plaintiff " CUMBERLANDCOUNTY, PENNSYLVANIA VS. * NO. 99-3766 CIVIL BARBRA EBY BURKE, . CIVIL ACTION - LAW Defendant ' CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. AND NOW, this 6th day of July, 1999 personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, Beth A. Theurer, who being duly swom according to law, deposes and says that on June 29, 1999, she mailed a certified copy of a Complaint in Custody by certified mail, restricted delivery, return receipt requested, to Barbra E. Burke, 208 April Drive, Camp Hill, PA 17011 and the same was received by her on July 2, 1999 as indicated by the return receipt card which is attached hereto. Sworn to and subscribed before me on this 0 ?h day of ?J U 1999. Wary Public/ Notarial Seal Oueena J. Shemmel, Notary Public Harrisburg, DauPhln County My Commission Expres Oct. 2, 2000 Beth A. Theurer i?j •Ca.PIM°ILprr9 i .Pore Yayro^wrn.r 1 ? .pcord W??y1t..Nb biml .Writ.'H R40 R.a .7rr R.run 1 ? yW.r.d. i 3. Ari1de Adds ', ?.rbr aD9 ? 5. R Nece?ed ? ? i g s. slgneN I also wish to rec" OW nda 2 to adMW W "F*" blloWng serv"G (for an am Mum via extra lee): .eO4b. e"r.ver..dW. brmpeW vn ?.., na 1. E3 Addressee's Address sr buk a SPW er trod of the mtlrd?'am Restricted DelNery 2)5 .pp.u b°t0M al.lrlkl. MN?b.6 B 1 • . B w the m p,q.d Wrier 4MPeaanaetef 10f K we Yww I. wlwm tlr. en?i. w.+tlWwM+4 46. Artlde Nu r a $5 r seed m: CL E. 3?lrKe 41).ger4weTwo oCertmed Registered Insured Drt Vc 0 Mall co -7 Mwe PR I IDII ?ROMRs ? ?l . ry t r • rase (Onty requealed 9. Addreessee? j ) ...._..,e..,.t December 1994 ?'• UNITE9 STATES POSTAL SERVICE Flnt•Olass Mail Postape 8 Pees Paid I USPS Perrdt No. 0.10 i • Print your name, address, and ZIP Code in this box • Edward S WeWr-aub, Es.. 2650 N. `T li rd s-; -Marri3[ILtrj, PR 1-7110 34 nnIIIIIiniln niIIuIJIIIIII AInII MARK EDWARD BURKE, ) Plaintiff ) vs. ) BARBRA EBY BURKE, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3766 CIVIL TERM CIVIL ACTION - CUSTODY ORDER AND NOW this 7?A day of Y? 1999, it being reported to the Conciliator that the parties have reached an agreement which makes further proceedings unnecessary, the undersigned Conciliator hereby relinquishes jurisdiction and returns the matter to the Court Administrator. If either of the parties wishes further proceedings in this action, they should petition the Court anew. FOR THE COURT, MICHAEL L. BANGS Custody Conciliator cc: Edward J. Weintraub, Esquire Barbra Eby Burke 208 April Drive Camp Hill, PA 17011 1 - rr; ??? ? .... i:.,, :,,_. .,