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Home My WebLink About99-06955I E7. -I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA ROBERT D. PORTER. Plaintiff V. ROBYN R. PORTER, Defendant CIVIL ACTION - LAW IN CUSTODY N0.99- b63S I,nti ORDER OF COURT ANDNOW,this --I_dayof `-YCC 1999, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel shall appear before ?? theConciIiator.at'? on the day of V"C C 1999 at in,, 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 shall/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; a ltot xcL 1tC11R?} CSI, C>\J? Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAW YER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TFIE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle. PA 17013 (717) 249-3166 NOV 19 t99? i iI f l i Aw /V- cr c. ' _t C ?n iJ Y P r+l O 3 ? , N$ n U rY 8 P v gY ?? e? Q O¢ A a u W 0. r Q 0 ?n- m O uaz a W 0. m 4] U U I'! ' - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT D. PORTER, Plaintiff CIVIL ACTION - LAW V. IN CUSTODY ROBYN R. PORTER, NO. 99- 65755' Defendant NOTICE 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 CANNOTAFFORD 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 (717) 249-3166 NOTICIA Le ban demandado a Listed en la torte. Si Listed quiere defenderse de estas demandas expuestas en las paginas siguientes, 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 cone en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la cone tomara medidas y puede entrar una orden contra Listed sin previo aviso o notificacion y per cualguier queja o alivio que es pedido en In petition de demanda. Usted puede perder dinero o sus propiendades o otros derechos importantes para usted. LLEVE ESTA DEMANDAA UN ABOGADO IMMEDIATAMENTE. SINOTIENEABOGADO 0 SI NO TIENE EL DINERO SOFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONAL 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA. LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 c Miftnl J. Hanft, Esquire Attorney ID No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 (717) 249-5373 Attorney for Plaintiff ROBERT D. PORTER, Plaintiff V. ROBYN R. PORTER, Defendant CIVIL ACTION - LAW IN CUSTODY NO. 99- 6 4 t?S Ltowl -ru.... COMPLAINT FOR PRIMARY CUSTODY AND NOW. this j0day of 11pyCn-lbcr , 1999, comes Plaintiff, Robert D. Porter, by and through his attorney, Michael J. Hanft, Esquire, and files the following Complaint for Primary Custody in support thereof avers as follows: The Plaintiff is Robert D. Porter, an adult individual with a mailing address of P. O. Box 24, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 2. The Defendant is Robyn R. Porter, an adult individual residing at 205 West Pine Street, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 3. The Plaintiff seeks primary custody and visitation of the following children: Name Present Residence Ace Date of Birth Anthony Robert Porter 205 West Pine Street 14 March 9, 1985 Mt. Holly Springs, PA 17065 Alex James Porter 205 West Pine Street 1 1 January 27, 1988 Mt. Holly Springs, PA 17065 The children were not born out of wedlock. The children are presently in the physical custody of Defendant, Robyn R. Porter. In addition to the children's present address, during the past five years, the children have IN TI-m COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA resided with either Plaintiff or Defendant at the following addresses: The mother of the child is the Defendant. who resides at 205 West Pine Street, Mt. Holly Springs. Cumberland County, Pennsylvania 17065. The father of the children is Plaintiff, who has a mailing address of P. 0. Box 24, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 4. The relationship of Plaintiff to the children is that of father. 5. The relationship of the Defendant to the children is that of mother. 6. Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation conceming the custody of the children in this or another court. The Plaintiff has no information of a custody proceeding concerning the custody of the children in this or any other court. The Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interests and permanent welfare of the children will be served best by granting the relief requested because: a) The Plaintiff has had shared physical and legal custody of the children since the childrens' birth; b) The Plaintiff provides the children with a home with adequate moral, emotional and physical surroundings as required to meet the childrens' needs; C) The PlaintifTis, and has always been, willing to accept custody of the children; and d) The Plaintiff continues to exercise parental duties and responsibilities and enjoys the love and affection of the children. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children 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 children. WHEREFORE, Plaintiff respectfully requests Your Honorable Court grant Plaintiff sole physical and sole legal custody of Anthony Robert Porter and Alex James Porter. Rcspcctfully submitted Mi?hacl J. Hanft> uire Attorney ID No. 5 976 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 (717) 249-5373 Attorney for Plaintiff Verification I verify that the statements made in the foregoing Complaint for Primary Custody are true and correct to the best of my knowledge, information and belief. This Verification is made only as to the factual averments contained herein, and not to legal conclusions and averments authored by counsel in his capacity as attorney for the party or parties hereto. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. Section 4904, relating to unswom falsification to authorities. Robert D. Porter FAU.'Fold rm Lw.+'?Gwdwc7Tl1b0.1.mfiarionI f FEB 1. 5 20001 ROBERT D. PORTER, IN TIME COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION-LAW ROBYN R. PORTER, : NO. 99-6955 CIVIL Defendant : IN CUSTODY COURT ORDER AND NOW, this ?~day of February, 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: The Mother, Robyn R. Porter, and the Father Robert D. Porter, shall enjoy shared legal custody of Anthony R. Porter, bom March 9, 1985 and Alex J. Porter, born January 27, 1988. 2. The Mother shall enjoy primary physical custody of the minor children 3. The Father shall enjoy periods of temporary physical custody of the minor children at such times as agreed upon by the parties. In the event the Father is dissatisfied with the custody arrangements as provided to him by the Mother, Father may petition the court to have the case again scheduled with the Custody Conciliator for a Conference. At this conference, the Father will not in any way be prejudiced by this Order which was entered on the basis of a Conciliation Conference where the Father did not attend. / BY THE COURT. cc: Michael J. Hanft, Esquire Thomas S. Diehl, Esquire 3 .r,..s? ROBERT D. PORTER, N THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW ROBYN R. PORTER, NO.99-6955 CIVIL Defendant N CUSTODY Prior Judge: CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the children who are the subject of this litigation is as follows: Anthony R. Porter, born March 9,1985; and Alex J. Porter, bom January 27, 1988. 2. A Conciliation Conference was held on February 11, 2000, with the following individuals in attendance: The Mother, Robyn R. Porter, with her counsel, Thomas S. Deihl, Esquire; and Attorney Michael J. Hanft who appeared on behalf of the Father. 3. The Father was the petitioner in this case. However, for some reason he missed the conciliation hearing. The Conciliator recommends and order confirming the status quo while giving the Father the opportunity to petition the Court again for a new custody order if he is dissatisfied with the custody arrangement. 4LD)11E ubert X. Gilro , Esquire Custody Conci iator .?. __ _.. _.: _? ::.? ';i. ._, -,? ?? ;. ?-? ?_;