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HomeMy WebLinkAbout99-07010/? 1 JOHN A. MORRIS, OR. and VICKI L MORRIS, Plaintiffs VS. BRANDON S. MORRIS, and MARIA E. ROSARIO, Defendants . IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7010 CIVIL TERM CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this 0`44 day of ?(?11X , 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Paternal Grandparents, John A. Morris, Jr. and Vicki L. Morris, the Father, Brandon S. Morris, and the Mother, Maria E. Rosario, shall have shared legal custody of Tyron A. Morris, born May 30, 1998. 2. The Paternal Grandparents shall have primary physical custody of the Child. 3. The Father and Mother shall have partial custody/visitation with the Child as agreed between the parties. 4. Either parent may file with the Court a Petition requesting additional custody rights with respect to the Child or to otherwise modify the provisions of this order. BY THE COUR cc: James K. Jones, Esquire - Counsel for Plaintiff Brandon S. Morris, Father Maria E. Rosario, Mother /-,220 -60 -W K5 ;i 2: r, 6 JOHN A. MORRIS, JR. and VICKI L. IN THE COURT OF COMMON PLEAS OF MORRIS, Plaintiffs CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-7010 CIVIL TERM BRANDON S. MORRIS and CIVIL ACTION - LAW MARIA E. ROSARIO, - Defendants CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Tyron A. Morris May 30, 1998 Plaintiff/Paternal Grandparents 2. A Conciliation Conference was held on January 19, 2000, with the following individuals participating: The Paternal Grandparents, John A. Morris, Jr. and Vicki L. Morris, with their counsel, James K. Jones, Esquire. The Mother, Maria E. Rosario, is currently incarcerated in the Cumberland County Prison and did not attend the Conference or contact the Conciliator. The Father, Brandon S. Morris, who currently resides with the Plaintiffs, did not attend the Conference or contact the Conciliator. 3. The Plaintiffs/Paternal Grandparents filed this Petition for custody of the Child based on the fact that they have been the primary caretakers of the Child since his birth by agreement of the parties. The Paternal Grandparents advised that the Father, their son, currently resides with them and the Child and does not oppose their request. The Paternal Grandmother further advised the Conciliator that she spoke with the Mother 1 week before the Conference at which time the Mother indicated that she was agreeable to the Paternal Grandparents request for custody. However, the Grandparents' counsel has not received the signed Stipulation from the Mother. The Grandparents' counsel confirmed that both the Mother and the Father had been properly served with advance notice of the Conciliation Conference. 4. Based on the representations made by the Plaintiffs and their counsel at the time of the Conference, the Conciliator recommends an Order in the form as attached. 90 Date U Dawn S. Sunday, Esqui Custody Conciliator ?. ;:; r," t . ,= - f ,`-. ,,<< .. ,. . _. IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA V. + $CG\C?OrI J , 1-'`OC C tS : CIVIL ACTION LAW Defendant : NO.1 U 10 CIVIL 19 cri CUSTODY VISITATION ORDER OF O rRT And now, this a ?I upon consideration of the attached complaint, it is hereb directed that the above parties and their respective counsel appear before Q. cam Esquire, the conciliator, at \.1. Hos -33 h Mt'C?Yn?c j Pennsylvania, on the 1? day of 2000, at for a Pre-hearing Custody Conference. At such co ference, 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 be present at the conference. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent order. FOR THE COURT: By: (? rl `i 9f(\ E? o a CcbY 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. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 _ _ _ ..? ...?„ . .. _. _ - ?, .__ _. --i ,' _a j ' /•SC{'? ?e?? Cr°%% ?"<a???? ??? '` yam/<e?; ,?c?7?t?i? i 1I I l ,. _;. ,- ?_:?_ . e:?? ewiawn?w DEC z z 1990 BROUJOS & GILROY, P. C. ATTORNEYS AT LAW TeI.ErIIONE: (717) 213.4574 JOHN H. EIROUIOS 4 NORTH HANOVER STREET FACSIMILE: (717) 243-8227 HUBERr X. GILROY CARLISLE, PENNSYLVANIA 17013 INTERNEr:brgi1roypC®a0LC0M NON-TOLL FOR HARRISuURG AREA 717-766-1690 December 21, 1999 Richard J. Pierce Court Administrator Cumberland County Courthouse Carlisle, PA 17013 RE: Morris v Morris No. 99 - 7010 Dear Rick: The above referenced case was assigned tome as a custody conciliator. I have a conflict because I represent Brandon S. Morris on other matters. Accordingly, please reassign this case to another custody conciliator. Sin ly yours, Hubert X. Gilroy be cc: James K. Jones, Esquire Brandon S. Morris Maria E. Rosario JOHN A. MORRIS. JR. and : IN THE COURT OP COMMON PLEAS OP VICKI L. MORRIS. CUMBERLAND COUN'T'Y, PENNSYLVANIA Plaintiffs v : No. 9 q- 7014) CNIL•I'ERM CIVIL ACTION -- LAW BRANDON S. MORRIS and MARIA E. ROSARIO, Defendants CUSTODY COMPLAINT IN CUSTODY 1. The Plaintiffs are JOHN A. MORRIS, JR. and VICKI L. MORRIS, residing at 311 Kerrs Road, Carlisle. Cumberland County, Pennsylvania. 2. The Defendants are BRANDON S. MORRIS and MARIA E. ROSARIO, residing at 311 Kerrs Road, Carlisle, Cumberland County, Pennsylvania and 207 North College Street, Carlisle, Cumberland County, Pennsylvania respectively. 3. Plaintiffs seek custody of the following child: NAME PRESENT RESIDENCE AGE Tyron A. Morris 31 1 Kerrs Road I yr. Carlisle, Cumberland Cty., dob 5/30/98 Pennsylvania The child was born out of wedlock. The child is presently in the custody of Plaintiffs. During the past five years, the child has resided with the following persons and at the following addresses: PERSONS ADDRESS DATE John A. Morris, Jr. 311 Kerrs Road 5/30/98-present Vicki L. Morris Carlisle, PA Brandon Morris JOHN A. MORRIS, JR. and VICKI L. MORRIS, Plaintilis VS. BRANDON S. MORRIS and MARIA E. ROSARIO, Defendants IN THE COURT Of COMMON PLEAS OP CUMBERLAND COUNTY, PENNSYLVANIA NO. CII?VILTTI?RM (/'J nn?} 77- Gd1V `;0tc CIVfLAC'ffON--LAW CUSTODY ORDER OE CO RT AND NOW, this day of 1>c c 1999, upon consideration of the attached complaint. it is hereby directed hat the parties and their r jpcL counsel appear bclore ?\ #Y. _, the conciliator, at (wLpaf lU CZAnei-?C. on the day of 1999, at 9.32L-rn., for a Pre-Flearing 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. BY THE COURT: By: r)r\k,,a ell Custody Conciliator -1i ('?? ) 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 YOU LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ON, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO 171ND OUT WHERE YOU CAN GET LEGAL FIELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 - .-;r ?: -,, s r;? . ?'. .. , z. . .. ?.?;? ??.::;4;?.,.:. la /fir ?' ?°>J??' ? ?i-.sEG????, ? - • ;; f i ?? The mother of the child is Defendant Maria 1. Rosario. She is single. The father of the child is Defendant Brandon Morris. Fie is single. 4. 'file relationship of Plaintiff's to the child is that of paternal grandparents standing in loco porentis. 'File Plaintiffs currently reside with the following persons: NAME RELATIONSHIP Brandon Morris son John A. Morris III son 5. 'Ihe relationship of Defendants to the child is that of natural parents. The Defendants currently reside with the following persons: NAME RELATIONSHIP (for Brandon Morris) John A. Morris, Jr. parent Vicki L. Morris parent John A. Morris III brother (for Maria E. Rosario) Unknown 6. Plaintiff has not participated as a party or witness, or in any other 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 or 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. ... ?srua:a 7. The best interest and permanent welfare of the child will be served by granting the relief requested for the following reasons: a. Plaintiffs at this time are better able to provide a stable environment for the child; b. Plaintiffs are the only party capable of providing health insurance for the child provided the child lives with them; C. All four parties for most of the child's life have agreed that it is in the best interest for the child to live with Plaintiffs. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiff requests the Court to grant custody of the child. Respectfully submitted, Jam, #W. Jones, Esquir A{(orney for Plaintiff 7 Irvine Row Carlisle, PA 17013-3019 (717) 240-0296 I VERIFY THAT THE STATEMENTS MADE IN THIS COMPLAINT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. k, (-,k _ _ JOI?N A. 'MORRIS, JR. IV CKI L. MORRIS C-- -:. CJ iT. t.J 10 ? q o a 0 c? ? JOYCE C. BOWERS, Plaintiff v. ROBERT E. BOWERS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 98-7010 CIVIL TERM ORDER OF COURT AND NOW, this 22nd day of October, 2002, upon consideration of a motion to strike case from purge list filed by Joanne H. Clough, Esquire, indicating that the case be stricken from the purge list, and there being no objection in open court to the request, the motion is granted, the case is stricken from the purge list, and the case shall remain active. Joanne H. Clough, Esquire For the Plaintiff ? Court Administrator wcy 11-I5-oa By the Court, .,- ;,. -_: