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HomeMy WebLinkAbout99-06297 T a Fq -Ai ' ' «( q e ASV l ? 3 r l:li59f .1 e t ? 1 9 ? 1 t {t WASS w?t 1 t - r, k :0000, gas *?> low. z , > ka ?5 g ? j ' Fi ) f d 9i?£gg 3 F t f j .J ? p k ,t M1 OC 1 1 5 199 TERRY DASHER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA !„297 V. : NO. 99 - CIVIL TERM : CIVIL ACTION -LAW BOBBIE MASTERTON, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this ?)_.1 day of C)C-\_, 1999, upon consideration of the attached Petition, it is hereby directed that the parties and their respective counsel appear before , Esquire, Custody Conciliator, QO`a ?.NOt 1 .;tyn?itl?t p ? IBC g 1999, at ? k 00 o'clock A,.M., for a Pre-Hcaring 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, Esquir 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 Oil 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 99 f.!Ci 26 1' 12: 32 Lv(Y C fo G? / oll, 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. 4 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 Bobbie Masterton, Pro Se Defendant TERRY DASHER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99 -G)IJIVIL TERM : CIVIL ACTION -LAW BOBBIE MASTERTON, Defendant : IN CUSTODY PETITION FOR CUSTODY COMES NOW, Plaintiff, Terry Dasher, by and through his attorney, James J. Kayer, Esquire and avers as follows: 1. Plaintiff is Terry Dasher, an adult individual, residing at 639 North East Street, Carlisle, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Bobbie Mastcrton, an adult individual, whose current address is: 70 West Louther Street, Carlisle, Cumberland County, PA, 17013. Name 3. Plaintiff seeks custody of the following child: Present Residence Age Marianna Jean Dasher, 639 North East Street, Carlisle, PA, 17013 born, 2/22/97, 2yrs. The child was born out of wedlock. The child is presently in the custody of the father. During the past two years, the child has resided with the following person(s) at the below address(es): February 22, 1997 until October 5, 1999. With mother and father at 639 North East Street, Carlisle, PA October 5, 1999 until Present: With the father at 639 North East Street. Carlisic, PA 17013. 4. The mother of the child is Bobbie Mastcrton, residing at, 70 West Louther Street, Carlisle, Cumberland County, PA, 17013. She is not married. 5. The father of the child is Terry Dasher, residing at 639 North East Street, Carlisle, Cumberland County, Pennsylvania,17013. He is not married. 6. The relationship of Plaintiff to the child is that of father. The Plaintiff currently resides with the following person(s): Name Relationshin 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 Unknown Relationshin 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 Plaintiff primary physical custody of the child as the mother has left the parties' home and has abandoned the child. 10. Each parent whose parental rights to the child has not been terminated and the person who has pnysical 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, Superior Ct. I.D. 50838 a c I . 1 N rl C ? Y a Y.; TERRY DASHER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99 - 6297 CIVIL TERM CIVIL ACTION -LAW BOBBIE MASTERTON, Defendant : IN CUSTODY AFFIDAVIT OF SERVICE BY MAIL COMMONWEALTH OF PENNSYLVANIA : SS. COUNTY OF CUMBERLAND I, James J. Kayer, Esquire, being duly sworn according to law, deposes and says that he is the attorney for Plaintiff, TERRY DASHER, 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, BOBBIE MASTERSON, on October 16, 1999. The return receipt is attached hereto. Sworn to and subscribed before me this 20th day of October, 1999. '1' WR: Notary Public ¦caro .Iwr.tuw«aameonre«.+?.. •conpel. tt«n e, e., ard4bNOTARIAL SEAL DENISE PINAMONTI. Notary Public Cerhsla Borough. Cumberland County [IiAy?:oc?m.ssmn.Expores Nov. 20, 2000 I also wleh lotecelva lf- klowling; tr lswvlou (for an ex N fee 1. O Addrueaa'e Addrw 2 t lUdrldW DaWaly Cornun poeanaater for he. ? y.O?,,? O Rapatered (?V.1lJL p ?? 110 t3 13 Express 7. Date of D40 ?_ll 8. RecoW Dr. (Print Nutty) B. Addreeeea'a A end hs Is pak 8. Signatu • (A gApent) P$ Form 3811, Dwentber 1094 rmseaeraorn a Print your name •name and aAdem an MN nr M ofd* brm to 0*" an MlUnW Card la •pAWtlr?aMch lIir tort b er Yore of Ir mall0o , on fu W& 11 pea dow M :The Rohn n? - a fie r mme novae eelwedd dd ww ew er delAwe0. 3. ArtldeAd to: ou1S+ r Q_ k ?o. } qY3 ,.mnaa O lnwrad 13 COD . TERRY DASHER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99 - 6297 CIVIL TERM CIVIL ACTION - LAW BOBBIE MASTERTON, Defendant : IN CUSTODY PRAECIPE FOR SETTLEMENT AND DISCONTINUANCE TO THE PROTHONOTARY: Please mark the Plaintiffs claim filed in the above referenced matter as discontinued, settled and ended. Respectfully submitted, James, . Kaye . sq 'fe Kayct rid B I 4 East ibert? Street Carlisl PA 1013 (717)243-7922 1D# 50838 Dated: October 26, 1999 J W t... ljl r: ! t 77r? NOV - J 1999 y? TERRY DASHERt IN THE COURT of COMMON PLEAS OF Plaintiff CUMBERLAND COUNTYo PENNSYLVANIA VS. CIVIL ACTION - LAW No. 99-6297 BOBBIE MASTERTONi Defendant IN CUSTODY ORDER CF cow MID NOW, this 3rd day of November, 1999, the Conciliator, being advised by Plaintiff's counsel that all custody issues have been resolved by agreement of the parties# hereby relinquishes jurisdiction in this case. The Custody conciliation conference scheduled for December 8, 1999 is canceled. FOR THE OOURTi 6?) Dawn S. Sundays Esqu r Custody conciliator