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Home My WebLink About99-05287SHERI D. COOVER, :IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-5287 JEFFREY D. COOVER, :CIVIL ACTION - Custody Defendant PROOF OF SERVILE I do hereby certify that a true and correct copy of the Complaint for Custody in the above captioned matter was served on Defendant, Jeffrey D. Coover, by First Class, Certified Mail, Restricted Delivery, postage prepaid, on September 2, 1999. The receipt card is attached hereto. Respectfully submitted, CUNNIN G HAM & C HE R NICOFF, P .C. Date / ' ? yy ;' : September 7, 1999 By:dv1 '7?, Beth A. Theurer, Secretary to Paige Macdonald-Matthes, Es quire I.D. #66266 2320 North Second Street P.O. Box 60457 Harrisburg, PA 17106-0457 (717) 238-6570 a DE sip t gnaw s for span itleta lure a, µ ea /U. I also xdah to receive the fouowirtg seW"s (for an Print your rrwn. rtl e00mn on tM m. n. ofMh IMM w ftt wa M nWn NIP 9)dM fee); •=96,aMe soot aM. mWpha.aeon the boo d spsa dm not t. ? Addressas Address aahomR.Wp RMMtlr 9n the msepaa bW-sr artklaMW . 2XRe*IcW DeMry :The Rat= Reaelpl xe shoe to WtWM 90 enlde Me deevarad and Ma (1106 dolkwo Conadt poshnaeter for tee. . & Ardde Addressed to: 4a Artlde Ntdnber ver Jef rep D C T { . o e d 4b S / ? IQ Lj O cK Tlven Uc er c . ypO ? Registered Certified $h (U QA ) 7aS 7 PP 9 ? Express Mau (] insured dtendae ? COD R f M ? R , , stum 9oW or w 7. Date at Deuvery 5. Recetved By: (Pdnt Name) 5. Addressee's Address (Only hregLwW i and fee Is paid) 8. SlgneNre• or nt) PS F 7, mbar 1994 102596.97.8.0179 Domestic etufR eo6 „- _,! .:;1 (.? l`J i „ ? ` `•i ? a Ll le, 11? r` U iiCi 05 SHERI D. COOVER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-5287 ,JEFFREY D. COOVER CIVIL ACTION - Custody Defendant ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the par es and their respective counsel appear before A Asd( r_ Conciliator, on the -?\\1?V Esquire, the 1SZ day of ZX 1999, at X-oo P.m., in = 3' c? S: V'" ?. C p x"11\ \ I ptuusylvania, for a'Fre-Hearing Custody onference. 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 e into a Temporary Order. Nil . _ Conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT, Date of Order: \(3\Q)k'j9 By: 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 ,.-i . ?. : ? . ?, ,. ',;,'( i, :....., ;.. . /0?/9'?9 ?er.??'9?t?` ?„?r?,,? ? `' '??? `i+yac?lm„a?or- ?Q.?? y 1. Cf ? T a u u c v v F ?zz 0. G -a Cam. Sc U d ? U: LL W v¢a mW5. N W a 0 xzz V W I N =Z2 ZNN = N 2 = Q U = c m u m u `c a u N O t 9 V U _m J . T .: ? O U J .j C L L y O • a r CUNNINGHAM & CHEANICOFF, P.C. SHERI D. COOVER, :IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99 -69 d JEFFREY D. COOVER CIVIL ACTION - Custody Defendant NOTICE TO THE DEFENDANT NAMED HEREIN: 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 Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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. CUMBERLAND COUNTY COURT ADMINISTRATOR Cumberland County Courthouse 1 Courthouse Square-4th Floor Carlisle, Pa 17013-3387 Telephone: (717) 240-6200 NOTICIA Le han demandado a usted en la Corte. Si usted quiere defenderse de estas demandas expuestas en las paginas diguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avidaso que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TINE ABOGADO OSI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA OLLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJOPARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY COURT ADMINISTRATOR Cumberland County Courthouse 1 Courthouse Square-4th Floor Carlisle, Pa 17013-3387 Telephone: (717) 240-6200 Respectfully submitted, CUNNINGHAM & CHERNICOFF, P.C. Date: By: Paige Macdonald-Matthes, Esquire I.D. #66266 2320 North Second Street P.O. Box 60457 Harrisburg, PA 17106-0457 (717) 238-6570 2 SHERI D. COOVER, :IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 9. 5".J d 7 all, Ti. JEFFREY D. COOVER, CIVIL ACTION - Custody Defendant COMPLAINT FOR CUSTODY 1. The Plaintiff is Sheri D. Coover, residing at 35 North 4th Street, Apt. 1, Newport, PA 17074, Perry County, PA 17074. 2. The Defendant is Jeffrey D. Coover, residing at 12 Wyrick Avenue, Shippensburg, Cumberland County, Pennsylvania 17257. 3. The Plaintiff seeks sole legal and primary physical custody of the following children: NAME PRESENT RESIDENCE DOB Tyler M. Coover 35 N. 4th Street 1117191 Newport, Pa 17074 Andrew J. Coover 35 N. 4th Street 12/14/92 Newport, Pa 17074 Patrick S.J. Coover 35 N. 4th Street L2/27/94 Newport, PA 17074 The children were not born out of wedlock. The children are presently in the custody of Sheri D. Coover, who resides at 35 North 4th Street, Newport, Perry :ounty, Pennsylvania 17074. During the past five (5) years, the children have resided with the following persons and at the following addresses: (LIST ALL PERSONS) (LIST ALL ADDRESSES) (DATES) Sheri D. Coover Sheri D. Coover Jeffrey D. Coover 35 North 4th Street Newport, PA 17074 12 Wyrick Avenue Shippensburg, PA 7/31/99- Present 1994-7/31/99 The mother of the children is Sheri D. Coover, currently residing at 35 North Fourth Street, Apt. 1, Newport, Perry County, Pennsylvania. She is married. The father of the children is Jeffrey D. Coover, currently residing at 12 Wyrick Avenue, Shippensburg, Cumberland County, Pennsylvania. He is married. 4. The relationship of Plaintiff to the children is 2 natural mother. The Plaintiff currently resides with the following persons: NAME RELATIONSHIP HERSELF Lindsey Marie Barrick Daughter Tyler M. Coover Son Andrew J. Coover Son Patrick S.J. Coover Son 5. The relationship of Defendant to the children is that of natural father. The Defendant currently resides with the following persons: NAME RELATIONSHIP HIMSELF 6. Plaintiff has not participated as a party or witness, or in another capacity, in any other litigation concerning the custody of the children in this or another Court. Plaintiff has no information of a custody proceeding concerning the children pending in a Court of this 3 Commonwealth. Plaintiff does not know of a person not a party to these proceedings who has physical custody of the children or claims to have custody or visitation right with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: a. the children has always looked to Plaintiff as a constant source of love and support; b. the Defendant has recently admitted to Cumberland County Children and Youth Services that he has been sexually abusing Plaintiff's daughter for several months. Said sexual abuse of Plaintiff's ten year old daughter occured in the marital residence during periods where Plaintiff was attending classes at Harrisburg Area Community College and Defendant was supposed to be caring for all of the children; C. Plaintiff is fearful for the children's safety because Defendant has admitted that he sexual abused his 4 step-daughter; d. Plaintiff believes and therefore avers that the Cumberland County District Attorney's office will prosecute Defendant to the fullest extent of the law and consequently Defendant will be incarcerated for his admitted crime in the very near future; and e. the Plaintiff can provide a more stable, loving and nurturing environment for the children than the Defendant can provide. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children 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 children have been given notice of the pendency of this action and the right to intervene: None. 5 WHEREFORE, Plaintiff requests the Court to grant her sole legal and primary physical custody of Tyler M. Coover, Andrew J. Coover, and Patrick S.J. Coover. Respectfully submitted, CUNNINGHAM & CHERNICOFF, P. C. Date: cwt 3u X497 By: -euq¢? olJ-aQ? VHa?lnnA Paige Macdonald-Matthes, Esquire I.D. #66266 2320 North Second Street P.O. Box 60457 Harrisburg, PA 17106-0457 (717) 238-6570 6 l?. s 1 I, r 1 1 r nil '1 r. _ ; VERIFICATION I, Sheri D. Coover, verify that the statements made in the foregoing Complaint for Custody are true and correct to the best of my knowledqe, information nnr9 >oi;va r understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. C eri D. Coover J '0 1l Date: 9 a ^E s: 1?M' . • IAN l 0 moo SHERI D. COOVER, Plaintiff VS. JEFFREY D. COOVER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-5287 CIVIL ACTION - CUSTODY ?/ ORDER AND NOW, this 2.S ' day ot•?]J? u2jT_, 2000, upon receipt of the Conciliator's Report, it appearing that the parties have agreed to the terms and provisions of this Order which was dictated in their presence and approved by them and their counsel, it is hereby ordered and directed as follows: 1. Mother shall have primary legal and physical custody of the minor children, Tyler M. Coover, d.o.b. January 17, 1991; Andrew J. Coover, d.o.b. December 14, 1992; and Patrick S.J. Coover, d.o.b. December 27, 1994. 2. Father shall have periods of supervised visitation through the Harrisburg YWCA. The parties shall work together to set up those supervised visitations. Paige Macdonald-Matthes, Esquire H. Anthony Adams. Esquire mlb BY THE COURT, A R)d c? c, c.1 o 0 Uhi ? ;ty m ? C to 0 ? n. A SHERI D. COOVER, ) Plaintiff ) vs. ) JEFFREY D. COOVER, ) Defendant ) JUDGE PREVIOUSLY ASSIGNED: None CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child(ren) who is(are) the subject of this IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-5287 CIVIL ACTION - CUSTODY litigation is as follows: NAME BIRTHDATE CURRENTLYIN CUSTODY OF Tyler M. Coover Andrew J. Coover Patrick S.J. Coover January 17, 1991 December 14, 1992 December 27, 1994 Plaintiff Plaintiff Plaintiff 2. A Conciliation Conference was held on December 16, 1999, and the following individuals were present: the Plaintiff and her attorney, Paige Macdonald-Matthes, Esquire; the Defendant and his attorney, H. Anthony Adams, Esquire. 3. Items resolved by agreement: See attached Order. 4. Issues yet to be resolved: See attached Order. 5. The Plaintiffs position on custody is as follows: See attached Order. 6. The Defendant's position on custody is as follows: See attached Order. 7. Need for separate counsel to represent child(ren): Neither party requested. S. Need for independent psychological evaluation or counseling: None requested and the Conciliator does not believe any is necessary. Date: January 17, 2000 4JU- L ?. Mic ael L. Bangs Custody Conciliator