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Home My WebLink About99-05315??, -J Z 0 !,? h Kayer and. Brown` ' A Professional d&rporatiori,l Liberty Loft 4 E. Liberty Avenue• i Carlisle, PA 17013 (717) 243-7922 JASON BROWN, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99 - 5315 CIVIL TERM : CIVIL ACTION - LAW CYNTHIA BROWN, Defendant IN CUSTODY AFFIDAVIT OF SERVICE BY MAIL COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I, James J. Kayer, Esquire, being duly sworn according to law, deposes and says that he is the attorney for Plaintiff, JASON BROWN, and that he did serve a true and correct copy of the Petition for Custody that was filed in the above matter, by U.S. Mail, postage prepaid, certified with restricted delivery, return receipt requested, unto the Defendant, CYNTHIA BROWN, on August 30, 1999. The return receipt is attached hereto. Sworn to and subscribed before me tfils V' day of Septemb rr, 1'4 9. Notary P NOTARIAL SEAL F E PINAMCNTI, Notary Public Borough, Cumba'Itt County misswn Expires Nov. 20_2000 S a SS. rW« 2 for addWorW servbx. I also wish to receive the i addtmonthen *I ft A=w#at m=WUn W. ? f")MrvIces(tor an ew ford of de 111e0pleoe, W ontle Gal It rpeoe does not t. O Addressw e Aciftee ?rClt rpr ROAM W M the merpra brow are areae mmwr, 2. tR:?estrlcted DNiwry r? a wa NOM to M10M NN Wale war deMnd ark ee dtle i ?a? 49 Caneldtpoehneeterforfee. \o?a 1s?a9?? S? l?tr1kkAG to PR ?s9y3 v X 1L( PS Form 3811. December Md and fee le peld) 102585-07$9179 bc« W 13 insured o eoo Lr v , %j AUG 31 199( JASON BROWN, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99 -°'jClVIL "TERM CIVIL ACTION - LAW CYNTHIA BROWN, Defendant IN CUSTODY ORDER OF COURT AND NOW, this _ i _ day of-74= 1999, upon consideration of the attached Petition, it is hereby directed that the parties and their respective counsel appear before b2i y 6L[S?4. Esquire, 4 -?\c tl-,?' Flux \ ? Custody Conciliator,eu l (?, (?L_ZLkjj,L kLA 1999, at o'clock /A.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 also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By, 14&) V X, ' CT',? l , Esq i 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, Pennsylvania 17013 Telephone(717) 249-3166 J; CCU _? ..? i. LL.'. `I 9? ?s'y? ?'? ?r?a...(7s ? • 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. James J. Kayer, Esquire Attorney for Plaintiff 4 East Liberty Avenue Liberty Loft Carlisle, PA 17013 (717) 243-7922 cc: James J. Kayer, Esquire Attorney for Plaintiff Cynthia Brown, Pro Se Defendant ti g L c q C3 t.', (-? nay: r Q m 14 > SD 0 ??x o • N• I A N A m am) v w r d o N o Q O ID O W C !D i q Y' Kayer and Brown ; A Professional- Corporation Liberty Loft • 4 E. Liberty Avenue • Carlisle, PA 17013 ' :,.'. (717) 243-7922 JASON BROWN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA $3?? V. NO. 99 CIVIL TERM CIVIL ACTION - LAW CYNTHIA BROWN, Defendant IN CUSTODY PETITION FOR CUSTODY COMES NOW, Plaintiff, Jason Brown, by and through his attorney, James J. Kayer, Esquire and avers as follows: 1. Plaintiff is Jason Brown, an adult individual, residing at 950 W. Old York Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Cynthia Brown, an adult individual, whose current address is 1062 Wagner Street, Nanty Glo, Cambria County, Pennsylvania, 15943. 3. Plaintiff seeks custody of the following child: Name Present Residence Age Cody Michael Brown. 1062 Nanty Glo, Pennsylvania born January 1, 1998. The child was born in wedlock. The child is presently in the shared custody of both parents. During the past five years, the child has resided with the following person(s) at the below address(es): January 1 1998 until April 1998: With mother and t'ather at Ncwville Apartment. Newville. PA. April 1998 until August 1998: With both parents at Carlisle, PA. September 1998 to May 1999: With both parents in Nanty Glo. PA. May 1999 to Present: In each parent's household, one week at a time. 4. The mother of the child is Cynthia Brown, 11062 Wagner Street, Nanty Crlo, Cambria County Pennsylvania. She is married. 5. The father of the child is Jason Brown, residing at 950 W. Old York Road, Carlisle, Pennsylvania, 17013. He is married. 6. The relationship of Plaintiff to the child is that of father. The Plaintiff currently resides with the following person(s): Name Relationship None 7. The relationship of the defendant to the child is that of mother. The Defendant currently resides with child and the following person(s): Name Relationship Unknown 8. 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. 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. 9. The best interest and permanent welfare of the children will be served by granting shared physical custody of the child to the both parties. Defendant has threatened to restrict child's access to father. The child has thrived under the existing alternating weekly custody arrangement. No valid reason exists to disrupt the status quo. 10. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, names 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 requests the court to grant custody of the children to Plaintiff. Respectfully submitted, Jame's J. Kayer,Esquire At for Plpihtiff Kayer & Brown 4 E. Liberty Avenue Carlisle, PA 17013 Superior Ct. I.D. 50838 VERIFICATION OF PLEADINGS The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. The language of the document may, in part, be the language of my counsel and not my own. 1 have read the statements made in this document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the statements are that of counsel, I have relied upon counsel in making this Verification. 1 understand that false statements herein are made subject to the penalties of 18 PA. C.S. § 4904, relating to unswort falsification to authorities. Date: c` / , 1999 _4V a 1 tkLi41UL --- OCT 2 6 19996P JASON BROWN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW CYNTHIA BROWN, NO. 99-5315 CIVIL Defendant IN CUSTODY COURT ORDER V? AND NOW, this 1 day of October, 1999, the Conciliator being advised that the parties have reached an agreement, the Conciliator relinquishes j urisdiction. BY THE COURT, J. Hubert X. Gilroy, Esgy're Custody Conciliator ii