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Home My WebLink About07-4725 MARK F. BAYLEY, ESQUIRE BAYLEY & MANGAN 57 WEST POMFRET STREET CARLISLE PA 17013 (717) 241-2446 ATTORNEY ID N0.87663 ATTORNEY FOR PLAINTIFF Christina Bohr, Plaintiff v. Brian Byrem, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No. 07 - ~/ 7a ~ CIVIL IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Christina Bohr, residing at 17 Independence Drive, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 2. The defendant is Brian Byrem, residing at 24 Bailey Run, Newport, Perry County, Pennsylvania 17074. 3. Plaintiff seeks custody of the following child: Name Sky Leona Byrem Present Residence 17 Independence Dr. Mt. Holly Springs, PA The child was born out of wedlock DOB Age 07-01-2002 5 yrs. 17065 The child is presently in the custody of Christina Bohr, residing at 17 Independence Drive, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. During the past five years, the .child has resided with the following persons and at the following addresses: List All Persons Christina & Brian Byrem Christina & Winnie (mother) & Donald Shafer . List All Addresses 714B Ayers Ave. Lemoyne, PA 17043 15 Our Lane Marysville, PA 17053 Dates 7/ 1 /02 to 12/26/02 12/26/02 to 4/1/03 r Christina & Jeff Bohr 102 Louisa Lane 4/ 10/03 to 11 / 18/04 Mechanicsburg, PA 17055 Christina & Jeff Bohr 17 Independence Dr. 11/18/04 to present Mt. Holly Springs, PA 17065 The mother of the child is Christina Bohr, residing at 17 Independence Drive, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 4. She is married. The father of the child is Brian Byrem, residing at 24 Bailey Run, Newport, Perry County, Pennsylvania 17074. He is not married. The relationship of plaintiff to the child is that of mother. 5. The plaintiff currently resides with the following persons. Name Jeff Bohr, Sr. Octavian Bohr Jeff Bohr, Jr. Relationship Step-father Half-brother Half-brother The relationship of defendant to the child is that of father. 6. The defendant currently resides with the following persons. Name Amie Hartman Bailey Hartman Relationship girlfriend girlfriend's daughter 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. 7. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does riot know of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. r 8. The best interest-and permanent welfare of the child will be served by granting the relief requested because: A Court. Order of custody is desired so that the parties can plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody can be avoided. WHEREFORE, Plaintiff requests this Court grant Plaintiff primary physical custody subject to partial physical custody by Defendant at times agreed upon or, should the parties fail to agree, at times the Court determines to be in the best interests of the child. Respectfully submitted, BAYLEY & MANGAN Date: Mark F. Bayley, Esquire 57 W. Pomfret Street Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D. # 87663 Attorney for Plaintiff .~ Y •...,+~ Christina Bohr, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Brian Byrem, No. 07 - CIVIL Defendant IN CUSTODY VERIFICATION 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. Cons. Stat. § 4904 relating to unsworn falsification to authorities. Date: ~ ~~ ~~~ Christian Bohr, Plaintiff ~ /~ap~ ~j ~ ~~py t ? ~ l t, \ - :~ -~ ~.. , " ~ ~ ? ~ ft7 ~ "~ t~ ~". ~ '~ ~ '~ , .' . ~ \ ~ r MARK F. BAYLEY, ESQUIRE BAYLEY & MANGAN 57 WEST POMFRET STREET CARLISLE PA 17013 (717) 241-2446 ATTORNEY ID NO.87663 ATTORNEY FOR PLAIlVTIFF Christina Bohr,. Plaintiff v. Brian Byrem, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No. 07 - ~/ 7~u~ CIVIL IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Christina-Bohr, residing at 17 Independence Drive, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 2. The defendant is Brian Byrem, residing at 24 Bailey Run, Newport, Perry County, Pennsylvania 17074. 3. Plaintiff seeks custody of -the following child: Name Present Residence DOB Age Sky Leona Byrem 17 Independence Dr. 07-01-2002 5 yrs. Mt. Holly Springs, PA 17065 The child was born out of wedlock The child is presently in the custody of Christina Bohr, residing at 17 Independence Drive, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. During the past five yeazs, the ,child has resided with the following persons and at the following addresses: List All Persons Christina & Brian Byrem Christina & Winnie (mother) & Donald Shafer . List All Addresses 714B Ayers Ave. Lemoyne, PA 17043 15 Our Lane Marysville, PA 17053 Dates 7/1/02 to 12/26/02 12/26/02 to 4/ 1 /03 0 4. 5. 6. 7. Christina & Jeff Bohr Christina & Jeff Bohr 102 Louisa Lane Mechanicsburg, PA 17055 17 Independence Dr. Mt. Holly Springs, PA 17065 4/ 10/03 to 11 / 18/04 11 / 18/04 to present The mother of the child is Christina Bohr, residing at 17 Independence Drive, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. She is married. The father of the child is Brian Byrem, residing at 24 Bailey Run, Newport, Perry County, Pennsylvania 17074. He is not married. The relationship of plaintiff to the child is that of mother. The plaintiff currently resides with the following persons. Name Jeff Bohr, Sr. Octavian Bohr Jeff Bohr, Jr. Relationship Step-father Half-brother Half-brother The relationship of defendant to the child is that of father. The defendant currently resides with the following persons. Name Amie Hartman Bailey Hartman Relationship girlfriend girlfriend's daughter 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 riot know of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. r 8. The best interest and permanent welfare of the child will be served by granting the relief requested because: A Court. Order of custody is desired so that the parties can plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody can be avoided. WHEREFORE, Plaintiff requests this Court grant Plaintiff primary physical custody subject to partial physical custody by Defendant at times agreed upon or, should the parties fail to agree, at times the Court determines to be in the best interests of the child. Respectfully submitted, BAYLEY & MANGAN Date: Mark F. Bayley, Esquire 57 W. Pomfret Street Carlisle, PA 17013 (717) 241-2446 Supreme Court LD. # 87663 Attorney for Plaintiff r .,,;~ Christina Bohr, Plaintiff v. Brian Byrem, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No. 07 - CIVIL IN CUSTODY VERIFICATION 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. Cons. Stat. § 4904 relating to unsworn falsification to authorities. Date: ~ ~~ ~~~ Christian Bohr, Plaintiff l .f t'" V ~~) i 1 ~ , _ ~ 4 ,~, - r'.T Q ~ '' ~ ~ , -~ ~~ ~ i G "C CHRISTINA BOHR IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA v. BRIAN BYREM DEFENDANT • 2007-4725 CIVIL ACTION LAW 1N CUSTODY ORDER OF COURT AND NOW, Tuesday, August 21, 2007 ,upon consideration of the attached. Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. ,the conciliator, at~___4th Floor, Cumberland County Courthouse, Carlisle on ~ Friday, September 21, 2007 at 10:30 AM for aPre-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. The court hereby directs the parties to furnish any and aII existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gllro Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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 ATTORNEY AT ONCE. 1F YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ,~toj ~p.~P1 ~iea /`"r7 ~°~~~ ~ ~~ .~ ? ,~a ,~ _~ } -,.~ ..~ ~, ...+ ~l . Christina Bohr, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVII. ACTION -LAW Brian Byrem, No. 07 - 4725 ClV1L Defendant IN CUSTODY STIPULATION The undersigned~parties hereby agree to have the following terms entered as an Order of Court: ~. 1VCother and Father shall share legal custody of Sky Byrem, born July 1, 2002. 2. Mother shall have primary physical custody subject to Father's periods of partial physical, custody on alternating weekends from Friday at 6:00 p.m. to Sunday at 6:00 p.m. 3. Mother and, Father shall share physical custody on holidays. ~ C~ -- Q7 Christina Bohr Date Brian Byrem Date _ .~ -r .. ~~ 5 r r~ J ~ S ~' '~ A W .. ,•r* ~' ' s~ is~~ Christina Bohr, Plaintiff v. Brian Byrem, Defendant . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No. 07 - 4725 CIVII, IN CUSTODY ORDER ~ COURT 3~ ~ AND NaW, this t day of , 2007, based on stipulation of the parties, it is hereby Ordered as follows: 1. 2. 3 Mother`and Father shall shaze legal custody of Sky Byrem, born July 1, 2002. Mother shall :have primary physical custody subject to Father's periods of partial physical custody an .alternating weekends from Friday at 6:00 p.m. to Sunday at 6:00 p.m: Mother and Father shall shaze physical custody on holidays. J. cc. Mark F. Bayley, esquire ~rian Byrem, pro se ~ ~~~~ 9 l ~ 11 Wig ~~'r~tilOt .; ~~~ . ,. ,, SEP 1 ~2007~''1~ CHRISTINA BOHR, Plaintiff v BRIAN BYREM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVII. ACTION -LAW NO. 2007-4725 IN CUSTODY COURT ORDER IIY~ AND NOW, this Cd day of September, 2007, the Conciliator being advised the parties have reached an agreement, the Conciliator relinquishes jurisdiction. ubert X. Cilr y, Esquire Custody Co iliator ~~~~f~1`~lSNN3d ~ S +8 Nti '~ ! d3S !.~lZ dbdlON~~.LG~d Wit. ICJ ~~