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Home My WebLink About99-06595V i? ,I ... QY ?I S G. TODD MYER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW CUSTODY KAREN C. MYER, Defendant #99-6595 CIVIL TERM AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO PA R.C.P. 1920.4 (a)(1)(11) COMMONWEALTH OF PENNSYLVANIA _ _ se COUNTY OF CUMBERLAND I, RUBY D. WEEKS, ESQUIRE, Attorney for G. Todd Myer, being duly sworn according to law, depose and say that a true and correct copy of the Custody complaint, was served on Karen C. Myer, at 219 Wyoming Avenue, Enola, Cumberland County, Pennsylvania, 17025, by mailing the same to her by, postage prepaid, certified mail,, No. Z 452 481118, on October 28, 1999. Service was accepted on October 30, 1999. Ruby D. Weeks, squire Sworn and subsc1Ed to befo me this '?}' day, of In,11iY11?L- 1P-q . G' p3 Notary Public ' MMppK'?°???'??? CCO,OO I. m rn 0 0 c? E LL Z 452 481 118 US Postal Service Receipt for Certified Mail No Insurance Coverago Provided. Dn nM mn In, Intamalinnai Mail lSpomvnisnl o I '? I ' Str 6 Nu. r C C L,-- IDlhce,State, 1-7( 3 --R 5 Postage 5 Cermed Fee -? Speca)DelnrryFoe Reslnded Dobvery Fee Return Receipt Swing to Khan 6 Dale Defvered Reim eecepxsk gWave ? Dale.BWheuees ass - IOTA apiDes Fees 4j ;3 Post m Dale r4 7 s. m m IS **** U.S. POSTAL SERVICE **** CMLISLE PA 17013 411168 41.00 RHOAIG 0 09 10-29-99 ---- 16:03:54 -------------- ----------- CUSTOMER RECEIPT -------- -------------- 109 POST VAL IMF' ------ 3.06 TOTAL 3.86 CASH T 10.00 CHANGE 6.14 *** THAt-1K YOU *** SENDER: Ialso wishto receive the hema t u d/or2 mradmlwrwwrnces_ . Comp l 9 following services (loran ,, stom • Cornplbla 3,4a. and 4b. • Pint your rums and eddleW art the 10V()w Of this form So that = return :Nei extra fee): t card to you. Ys form to the ham dOW mallplOCO, Or on the back V pace does not Attach r . 1.0 Addressee's Address I ppe • Ylde 'Relum Receipt Requeafeo'on the m opleae bet" the argdo number. 2• ? Restricted DBlivory . The Relum Receipt wW Show to whorn the article rue deWered and the date Consult postmaster for fee, ry deevered. _- s 4a. AFUCIe NUmoer - z tlC=-a Lj1 ) 1 1 4b. Service Type E3 Registered Carolled C3 Express Mall Q Insured 0 Return Recelptfor Merchandise 1--3 COD 7. Dale of Delil ery S. Addressee's Address (Only ll requesfed and lea Is pall) 21q C- X Cuu n l 2 PS Form 811, December 1994 1=9S90-B-0229 Ej - C'• L_ - G. TODD MYER, Plaintiff VS. KAREN C. MYER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ^ Uf?? /'? M1 CUSTODY 9 ) # CIVIL TERM ORDER OF COURT AND NOW, this _?__ day of nnt E- (- , 19GLJ, upon consideration of the attached complaint, it is hereby directed that the parties and their respective ??j \(C?J ?, the conciliator, at r3counsel appear before acoo tc4?1UT(?i'S (?`?(1? fltCli?, on the LJi day of ,'}'?• at IJ-D r 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:_._??L??."C?? x f.1J??1S? 1 S? Custody Conciliator (•? 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. 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 i,EGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 I? n?? ? ? ?? ???o G. TODD MYER, Plaintiff VS. KAREN C. MYER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CUSTODY # CIVIL TERM ORDER OF COURT YOU, Karen C. Mver, Defendant, have been sued in Court to obtain custody, partial custody or visitation of the child, born January 9, 1992. You are ordered to appear in person at Courtroom No. Cumberland County Courthouse, Carlisle, Pennsylvania, on the of 19_, at _.M. for a hearing. Until such hearing, custody of the child shall be and remain with the natural mother, Karen C. Myer. If you fail to appear as provided by this order, an Order for custody, partial custody or visitation may be entered against you or the Court may issue i a warrant for your arrest. 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. I Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 BY THE COURT, , i I J. VS. KAREN C. MYER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CUSTODY U # CIVIL TERM / % S 9 SQ ?fUr` COMPLAINT FOR JOINT AND SHARED CUSTODY TO THE HONORABLE, THE JUDGES OF SAID COURT: 1. The Plaintiff is, G. Todd Myer, hereafter referred to as the natural father, residing at 6571 Blue Bird Lane, Dover, York County, Pennsylvania, 17315. 2. The Defendant is Karen C. Myer, hereafter referred to as the natural mother, residing at 219 Wyoming Avenue, Enola, Cumberland County, Pennsylvania, 17025. 3. Plaintiff seeks shared legal custody of the following child: a. Name Present Residence Ace Hayley A. Myer 219 Wyoming Ave., 7 Enola, PA 17025 b. The child was born on January 9, 1992. C. The child is presently in the custody of the natural mother, who resides at 219 Wyoming Avenue, Enola, Cumberland County, Pennsylvania, 17025. d. The child has resided with the following persons and at the following addresses for the past 16 months: Persons Address Dates Karen C. Myer 219 Wyoming Ave. October 16, 1999 to present Enola, PA 17025 1100 Morton Drive, Apartment 5 Harrisburg, PA 3. 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. I V. 3uuL r,i a'.n, ?i Plaintiff 4. Plaintiff has no information of a cus_ody proceeding concerning the child pending in a Court of this Commonweal--h. 5. Plaintiff does not know of a person not aparty to the proceedings •rzho has physical custody of the child or claims to have custody or visitation rights with respect to the child. 6. Each parent whose parental rights to the child has not been terminated and the person who has physical custody off the child has been named as parties to this action. There are no other persons who are known to have or claim a right to custody or visitation of the child, so none will be given notice of the pendency of this action and the right to intervene. 7. Pursuant to the Custody and Grandparents Visitation Act, the father requests this Court to grant an award of shared legal custody to him. 8. The father requests shared physical custody of the child. 9. The best interests and permanent wel?are of the child and her physical, spiritual, emotional and moral well-being will be served by granting the relief requested of shared legal and Physical custody with the father. 10. Plaintiff father prays for an Order awarding shared legal custody of the minor child, Havley A. Myer, born January 9, 1992, to the Plaintiff father and with partial custody awarded to Defendant mother as this Court determines is in the best interests of the child. WHEREFORE, Plaintiff father prays for an Order awarding shared legal custody of the minor child, Hayley A. Myer, to the father, with actual physical custody to the mother with partial periods of custody to the father. Respectfully submitted, Date: Ruby D. we4k.s, Esquire Attorney for Plaintiff 1. 0 L9est High Street Carlisle, Pennsylvania 17013 ( 717)i-, 243-1294 1 G . Todd Myer / COMMONWEALTH OF PENNSYLVANIA , se COUNTY OF CUMBERLAND Personally appeared before me, A Notary Public in and for the commonwealth and county aforesaid, the under-signed, being duly sworn according to law, deposes and says that the facts set forth in the foregoing Complaint are true and correct. sworn to and sub cr?'bed to before me. th's _ da?•? of Z('.l (?-U'.l 19?. 6t (6-c (tl (,i Notary Public G. TOdCY Myer _ HOTNEAL II?AL CarQdo B y??ry ?? ?y. e?,?, E.Pr.a hne ze?soas ?:: _ ,. t Ir???fJ?? ?.,??? t_ ?.. 1 .. ? is .{2. .. ? .:1. JAI 1 0 20001' G. TODD MYI R. IN 'I'I Ili C'OUR'1' OI' CC)VI\40N I'I.IiAS OI' Plaintiff CUM[iE1t].AND C'OUN"I')'. 1'I:NNS)'LVANIA v . CIVIL ACTION - LAW KAREN C. M YE R. N0.99.6595 CI V I L Dcl ndant IN CUSTODY COURT OUDER AND NOW. this 17-4t-day of January. 2000, upon consideration of the attached Custody Conciliation Report. it is ordered and directed as follows: The Father. G. Todd Myer. and the Mother. Karen C. Myer. shall enjoy shared legal custodv of i lavlev A. Meer. born Januarv 9. 1992. 2. The Mother shall enjoy primary physical custody of the minor child. 3. The Father shall enjoy periods of physical custody of the minor child as fol lows: A. Father shall have the child file second and fourth weekend of each month during the school year from Friday at 8:00 p.m. until Sunday at 5:00 p.m. It' the month has live weekends, file parents shall alternate the child during file fifth weekend beginning with the Father having the first fifth weekend in the year 2000. B. During the summer months, the Father shall have custody the second, third and fourth weekends of the month from Friday night at 8:00 p.m. through Sunday night at 5:00 p.m. 4. On Thanksgiving and Easter, the Father shall have the child on odd numbered years front 9:00 a.m. until 8:00 p.m. and the ivlothcr shall have the child on even numbered years for the same timeRame. For Thanksgiving on even numbered years, the Father shall have the child from 3:00 p.m. on Thanksgiving until 6:00 p.m. the Friday following Thanksgiving. For Easter on even numbered ),cars, the Father shall have file child on Easter from 2:00 p.m. until 8:00 p.m. 5. The Christmas holiday shall be handled with the Father having file child on even numbered years from noon on Christmas Eve until noon on Christmas Day. And on odd numbered Years. from noon on Christmas Day until noon on December 26u'. The Mother shall enioy custody during the alternate fimeframes under this schedule. G. The Father shall have custody of the minor child on Father's Day and the Mother shall have custody of the minor child on Mother's Day. The tintcframe shall be From 9:00 a.m. until 8:00 p.m. This provision shall supercedc any alternating weekend custody provision. 'File Father shall always have custody of the minor child on the child's birthday from 5:00 p.m. until 7:00 p.m. 8. For all other holidays, the child shall spend the holiday with the parent whose period ofeustody falls on that holiday. 9. The parents shall remain flexible with pick up and delivery of the child, but a good faith effon shall be made to provide 72 hours notice if variations are to take place from this order. 10. If the child has an activity on the weekend and both parents have agreed that the child would participate in that activity, the parent who has the child is responsible for transportation to and from the activity. 11. The Mother shall provide Father will copies of all activity schedules, school schedules, school report cards, notices of parent/teacher conferences, copies of student pictures and other similar types of information and documentation relating to the ongoing educational. physical and emotional health of the child. 12. If the custodial parent is working the day that that parent has custody or otherwise requires a daycare provider for the minor child for an extended period of time, the custodial parent shall notify the other parent as to the child's whereabouts and who shall be providing the childcare. 13. Both parents shall have liberal phone contact with the minor child when the minor child is in the custody of the other parent, with the custodial parent encouraged to have the child herself initiate phone calls to the non-custodgial parent. BY THE COURT.' cc: Ruby D. Weeks. Esquire Jason F. Kutulakis. Esquire .,CQ)2a,Q) JI>2o 1-1.2-(9(3 RJ?s I: !:: I^.: ph I: 55 CUdf >;:;; ;' GC Fc??'?SYU41?i?W ' G. TODD MYER. I'laintifl' IN THE COURTOI' COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION - LAW KARE11 C. MYER. Defendant Prior Judge: NO. 99-6595 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT rN ACCORDANCE WITH THE CUMBERLAND COUINTY CIVIL RULE OF PROCEDURE 1915.3-5(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the child who is the subject of this litigation is as follows: -Tiayley A. Myer, bornJanuary 9, 1992. 2. 1A Conciliation Conference was held on January 6. 2000, with the following individuals in attendance: "-The Father, G. Todd Myer, with his counsel. Ruby alecks. Esquire; and the Mother, Karen C. Myer, with her counsel, Jason P. Kutulakis, Esquire. 3. 3'he parties agree to the entry of an order in the forni as attached. I? DATE Hubert X. Gilroy. squire Custody Concili. or