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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
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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
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IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY,
PENNSYLVANIA
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+ $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
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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
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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
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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
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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.
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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.
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JOI?N A. 'MORRIS, JR.
IV CKI L. MORRIS
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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
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By the Court,
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