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HomeMy WebLinkAbout99-0476911 Al. . * CC.1c ?I k-A. Nl 1 ? ? C r Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, :PENNSYLVANIA V. CIVIL ACTION LAW • c?1e1J.M.ZvC-Q\? Qr Defendant : NO. y CIVIL 19 9 c7 CUSTODY VISITATION ORDER OF COURT And now, this T I l l 199 'Upon consideration of the attached complaint, it is hereby directed that the above parties and their respeptive counsel appear before Esquire, the conciliator, at 3 ?~ ICJ n _ 1 1 Pennsylvania, on the day of C 1999, at ?7' Od A.M. 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 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 be present at the conference. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent order. FOR THE COURT: By:.9?N Custody Conciliator C \ 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. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 g•ia -99 ? ?d m?.s ? ?? AUG 10 1999'@' In the Court of Common Pleas of Cumberland County, Pennsylvania CORY M. MILLER, ) Plaintiff ) C9_c?7iy4 vs. ) No. of"" ? ? D T ?nl RACHEL J.M. ZUERCHER, and ) her Guardian or Custodian, ) Defendants ) CHILD 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 Esquire, the Conciliator, at Pennsylvania, on the day of _, 1999, 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. 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, 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 In the Court of Common Pleas of Cumberland County, Pennsylvania CORY M. MILLER, ) Plaintiff ) vs. ) RACHEL J.M. ZUERCHER, and ) her Guardian or Custodian, ) Defendants ) 917- Al7coq C..Jl Trn? No. f499T CHILD CUSTODY ORDER AND NOW, this day of 1999, having reviewed the complaint of the plaintiff, the matter is set for a hearing on 1999. J. r ?J J cC MICHAEL S. TRAVIS • A,rueuw Ar LAw ® 4076 MARKET SHEET, SUITE 209 CAMP HILL, PA 17011 TF LEP140NE 17171 7319502 In the Court of Common Pleas of Cumberland County, Pennsylvania CORY M. MILLER, ) Plaintiff ) VS. ) RACHEL J.M. ZUERCHER, and ) her Guardian or Custodian, ) Defendants ) 94- 4 769 No. of 1999 CHILD CUSTODY C«u9 T rfn COMPLAINT FOR CUSTODY TO THE HONORABLE JUDGES OF SAID COURT: 1. The Plaintiff is Cory Miller residing at 692 Front Street, West Fairview, Cumberland County, Pennsylvania 17025. 2. The Defendant is Rachel Zuercher, age 16, residing at 190 North Main Street, Box 148, Bendersville, Adams County, Pennsylvania 17404. 3. Plaintiff seeks shared legal and liberal periods of visitation of the following child: NAME PRESENT RESIDENCE DOB Veronika Miller 190 North Main Street, Box 148 03/05/99 Bendersville, PA 17404 The child was born out of wedlock. The child is presently in the care of foster parents Di and Travis Warren with the minor mother who resides at 190 North Main Street, Box 148, Bendersville, PA 17404. Since birth, the child has resided with the following persons and at the following addresses: Persons Addresses Dates Robin Parker (Paternal Grandmother) 210 Second Street 03/05/99- 7/22/99 Cory Miller (Father) W. Fairview, PA 17025 Rachel Zuercher (Mother) Di and Travis Warren (Foster Parents of Rachel Zuercher) 190 North Main Street 7/22/99- date Rachel Zuercher (Mother) Box 148 Bendersville, PA 17404 The mother of the child is Rachel Zuercher, currently residing at 190 North Main Street, Box 148, Bendersville, PA 17404. She is single. The father of the child is Cory Miller., currently residing at 692 Front Street, West Fairview, PA 17025. He is single. 4. The relationship of Plaintiff to the child is that of father. The Plaintiff currently resides with the following persons: Name Peter and Geraldine Bolash However, visitation would be with: Robin Parker Relationshin to the child Paternal Great-grandparents Paternal Grandmother 5. The relationship of Defendant to the child is that of mother. The defendant currently resides with the following persons: Name Relationship Di and Travis Warren (Foster Parents of Rachel Zuercher) 2 6. On or about March 10, 1999, a juvenile hearing, docketed 98-167, Cumberland County was held, and Rachel Zuercher, a dependent child and defendant herein, was placed in the custody of Robin Parker, mother of the plaintiff. A copy of the Order is attached hereto as Exhibit A. On or about March 10, 1999, ajuvenile hearing, docketed 98-167, Cumberland County was held, and Veronika Miller, a dependent child, was placed in the custody of Robin Paker, mother of the plaintiff. A copy of the Order is attached hereto as Exhibit B. 7. On or about July 22, 1999, a hearing was held, and Rachel Zuercher, defendant, and Veronkia Miller were placed with foster parents through Tressler Care. 8. The best interest and permanent welfare of the child will be served by granting the relief requested because: A. Plaintiff has participated in the primary care of the child throughout her life. B. Plaintiff can provide a stable environment. C. Plaintiff can provide a loving home. 9. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. 3 WHEREFORE, Plaintiff requests this Honorable Court to grant him shared legal custody and liberal periods of visitation. Respectfully submitted, . 'Michael S. Travis Attorney for Plaintiff Supreme Court ID No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. DATED: ?S O IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 98-167 JUVENILE IN THE MATTER OF RACHEL ZUERCHER, born 5183 ORDER OF COURT / AND NOW, this 10th day of March, 1999, after hearing, Rachel Zuercher, a dependent child, w s .Present represented by her court-appointed counsel Jacqueline Verney, Esquire. Her mother Susan Zuercher was not present, but was represented by her court-appointed counsel Frances Del Duca, Esquire, and Cumberland County Children & Youth Services by Ruby D. Weeks, Esquire. It is found by clear and convincing evidence after hearing testimony and the admissions to the juvenile petitions that Rachel Zuercher continues to be a dependent child. However, she is discharged from her placement at Lourdeshouse, and she is placed in the care and custody of Robin Parker pending further Order of Court. Cumberland County Children & Youth Services is directed to provide protective supervision. Rachel is ordered and directed to comply with the family service plan in this matter and to attend any and all counseling sessions that she is directed to by either Cumberland County Children & Youth Services, Lourdeshouse, Catholic Charities, and she is to successfully complete those programs. All reasonable efforts have been made to prevent further placement of the child. This order is deemed to be in the juvenile's best interests. Exhibit A Ruby D. Weeks, Esquire For CCC&YS Jacqueline Verney, Esquire Court-appointed counsel For Rachel Zuercher Lindsay Dare Baird, Esquire Court-appointed counsel For Veronika Miller James K. Jones, Esquire Court-appointed counsel j,jF,O,,r,,.Pa,ternal grandmother Robert Mulderig, Esquire Court-appointed counsel RXI-Ithe father Frances Del Duca, Esquire Court-appointed counsel For Susan Zuercher Z P bation CCC&YS Victim Witness Sheriff mae By the Court, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 98-167 JUVENILE IN THE MATTER OF RACHEL ZUERCHER, born 5/13/83 On Wednesday, March 10, 1999, a juvenile hearing was held in Juvenile Court before the Honorable Kevin A. Hess, J., on Petition 98-167 filed regarding the above-named juvenile. Present at the time and place of said hearing were the following persons: Rachel Zuercher Veronika Miller Jacqueline Verney, Esa. Lindsay Dare Baird, Esq Ruby Weeks, Esq. Cory Miller Robert Mulderia, Esq. Robin Parker James K. Jones, Esa. Alisa Closs Leslie Bink Heather Margerum Judy Thomas Frances Del Duca, Esq Juvenile & mother of Veronika Juvenile Attorney for Rachel Attorney for Veronika Attorney for CCC&YS Father of Veronika Attorney for Cory Miller Paternal grandmother of Veronika Attorney for Robin Parker Caseworker CCC&YS Supervisor CCC&YS Caseworker CCC&YS Caseworker CCC&YS Attorney for Susan Zuercher Following the hearing, the attached Order of Court was entered. i hele A. Eline Official Court Reporter IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 98-167 JUVENILE IN THE MATTER OF VERONIKA MILLER, born 3/5/99 ORDER OF COURT AND NOW, this 10th day of March, 1999, after hearing today's date at which Veronika Miller was present represented by her court-appointed counsel Lindsay Dare Baird, Esquire, and the natural mother Rachel Zuercher was present represented by her court-appointed counsel Jacqueline Verney, Esquire, and the natural father Cory Miller was present represented by his court-appointed counsel Robert Mulderig, Esquire, it is found by clear and convincing evidence based on the admissions to the juvenile petition and the testimony heard that Veronika is a dependent child. Her care and custody is placed with Robin Parker, and Cumberland County Children b Youth Services is ordered and directed to provide protective supervision. All reasonable efforts have been made to prevent placement of this child. This order is deemed in her best interests. All parties have agreed to waive the requirement for a ten day juvenile hearing. By the Court, _J . Z;?? Kev' A. Hess, J. Exhibit B Ruby D. Weeks, Esquire For CCC&YS Jacqueline Verney, Esquire Court-appointed counsel For Rachel Zuercher Lindsay Dare Baird, Esquire Court-appointed counsel For Veronika Miller James K. Jones, Esquire Court-appointed counsel For Paternal grandmother Robert Mulderig, Esquire Court-appointed counsel For the father Frances Del Duca, Esquire Court-appointed counsel For Susan Zuercher Probation l CCC&YS Victim Witness Sheriff mae IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 98-167 JUVENILE IN THE MATTER OF VERONIKA MILLER, born 3/5/99 On Wednesday, March 10, 1999, a juvenile hearing was held in Juvenile Court before the Honorable Kevin A. Hess, J., on Petition 98-167 filed regarding the above-named juvenile. Present at the time and place of said hearing were the following persons: Rachel Zuercher Juvenile & mother of Veronika Veronika Miller Juvenile Jacqueline Verney, Esq. Attorney for Rachel Lindsay Dare Baird, Esq .Attorney for Veronika Ruby Weeks, Esq. Attorney for CCC&YS Cory Miller Father of Veronika Robert Mulderig, Esq. Attorney for Cory Miller Robin Parker Paternal grandmother of Veronika James K. Jones, Esq. Attorney for Robin Parker Alisa Closs Caseworker CCC&YS Leslie Bink Supervisor CCC&YS Heather Margerum Caseworker CCC&YS Judy Thomas Caseworker CCC&YS Frances Del Duca, Esq. Attorney for Susan Zuercher Following the hearing, the attached order of Court was entered. 1 Michele A. Eline Official Court Reporter Michael S. Travis ID No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 In the Court of Common Pleas of Cumberland County, Pennsylvania CORY M. MILLER, ) Plaintiff ) vs. ) RACHEL J.M. ZUERCHER, and ) her Guardian or Custodian, ) Defendants ) No. 99 - 4769 CIVIL TERM CHILD CUSTODY PRAECIPE TO DISCONTINUE ACTION To the Prothonotary: Please mark this action discontinued as to all defendants. Date: October 4, 1999 ichael MSTravis Attorney for Plaintiff } co } C. I- lL'?1 CiL •i rin '.?iU G.` [L L t 01 .J OCT 0 6 19992 CORY M. MILLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4769 CIVIL TERM CIVIL ACTION - LAW VS. RACHEL J.M. ZUERCHER, and her Guardian or Custodian, Defendant ORDER OF COURT AND NOW this (J?, day of CCr-04 ? _, 1999, it being represented to the undersigned Conciliator that the Plaintiff has filed a Praecipe to mark the matter discontinued, the undersigned Conciliator hereby relinquishes jurisdiction of this matter. If either of the parties wishes further proceedings in this action, they should petition the Court anew. FOR THE COURT, MICHAEL L. BANG' Custody Conciliator Michael S. Travis, Esquire Ruby D. Weeks, Esquire L1 C CCT, '1 Johnson, Duffle, Stewart & Weidner By: David J. Lanza I.D. No. 55782 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 STEEL BUILDING ERECTORS, INC., Plaintiff V. AMERICAN BUILDING SYSTEMS, INC., Defendant PRAECIPE TO SATISFY AND DISCONTINUE TO THE PROTHONOTARY: NO. 96-4769 Civil Term CIVIL ACTION - LAW Kindly mark the above-captioned matter satisfied and discontinue this action. Respectfully submitted, Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOHNSON, DUFFIE, STEWART 8, WEIDNER By: David J. Lanza Attorney for Plaintiff :127866 U C. CL ate' C\, w gyn. N ?L 1lrr111 C :z O a U