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HomeMy WebLinkAbout08-59890 Pamela L. Purdy Attorney ID No. 85783 308 N. Second Street, Suite 200 Harrisburg, PA 17101 (717) 221-8303 (717) 221-8403 facsimile pipurdy@verizon.net Attorney for Plaintiff JENNIFER SAYER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA JOEL MORISSON, V. NO. Defendant : IN CUSTODY NOTICE TO DEFEND 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 AN 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 TODO 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 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 S. Bedford Street Carlisle, PA 17013 1-800-990-9108 (717) 249-3166 - 110fl.M A d ?0 '0 PPAIEIA L. PURITY, ESQUIRE Pamela L. Purdy, Esquire Attorney ID No. 85783 308 N. 2^d Street, Suite 200 Harrisburg, PA 17101 (717) 221-8303 tel (717) 221-8403 fax plpurdy@verizon.net Attorney for Plaintiff JENNIFER SAYER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JOEL MORISSON, V. Defendant : NO. 4 P-F9 CIVIL ACTION - LAW IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, Plaintiff, by and through her attorney, Pamela L. Purdy, Esquire, files a Complaint for Custody against Defendant, and in support thereof, avers the following: 1. Plaintiff Jennifer Sayer (hereafter referred to as "Mother") is an adult individual who currently resides at 3121 Dickinson Avenue, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant Joel Morrison (hereafter referred to as "Father") is an adult individual who currently resides at 616 Hilltop Drive, New Cumberland, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following child: Name Present Address Birthdate Ava Richelle Morisson 3121 Dickinson Avenue 12/12/05 Camp Hill, PA 4. Ava was born out of wedlock. 5. Ava is currently in the custody of Mother. 6. Since birth, Ava has resided with the following person(s) and at the following address(es): Person(s) Address(es) Date(s) Father 225 S. High St., Apt 2A birth to 5/08 Mother Mechanicsburg, PA Father 3121 Dickinson Avenue 05/08 to 07/08 Mother Camp Hill, PA Mother 3121 Dickinson Avenue 07/08 to present 7. The father of the child is Joel Morisson, who currently resides at 616 Hilltop Drive, New Cumberland, PA. He is unmarried. 8. The mother of the child is Jennifer Sayer, who currently resides at 3121 Dickinson Avenue, Camp Hill, PA. She is unmarried. 9. The relationship of Plaintiff to the child is that of Mother. Plaintiff currently resides with the following person(s). Name(s) Relationship Ava Richelle Morisson Daughter 10. The relationship of Defendant to the child is that of Father. Defendant currently resides with the following person(s). Name(s) Relationship Unknown N/A V 11 11. Mother 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. 12. Mother has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 13. Mother does not know of 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. 14. Mother and Father have come to an agreement regarding custody and are filing a Stipulation for an Agreed Order of Custody simultaneously with this Complaint. 15. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter as an Order the attached Stipulation for an Agreed Order of Custody. Respectfully submitted, Vo. mA /- Pal 0'- Pamela L. Purdy Attorney for Plaintiff Dated 3 7L a r VERIFICATION I verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. (11 -11-f ?- 12 Jen fifer ayer Dated: O&O+LM 312.OOg ? o a rl 4*1 M c l y j ;p ? O-Z e 3 • JENNIFER SAYER Plaintiff V. JOEL MORISSON Defendant • 01 OCT 0 7 2008cn IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - .5189 61 U I" L "'" CIVIL ACTION - LAW IN CUSTODY STIPULATION FOR AN AGREED ORDER OF CUSTODY THIS Stipulation is made this 961 0", day of August, 2008, by and between JOEL MORISSON (hereafter referred to as "Father") of 616 Hilltop Drive, New Cumberland, Cumberland County, Pennsylvania, and JENNIFER SAYER (hereafter referred to as "Mother") of 3121 Dickinson Avenue, Camp Hill, Cumberland County, Pennsylvania. WHEREAS Mother and Father are the parents of Ava Richelle Morisson, born December 12, 2005; and WHEREAS, the parties, by this Agreement, wish to determine a custodial arrangement for Ava. AND NOW, the parties stipulate and agree as follows: 1. Mother shall have legal and physical custody of Ava. 2. Father shall have physical custody of Ava in supervised visits by agreement of the parties. 3. Mother may terminate Father's supervised visits at any time if she believes that Father is under the influence of alcohol or any other controlled substance. 3. The parties may petition the Court for modification of custody at any time. 4. This Stipulation supercedes any prior Order of Court with regard to the custody of the child. 5. Mother is represented by Pamela L. Purdy, Esquire. Father has acknowledged that he has had the opportunity to seek the advice and assistance of independent counsel, but has chosen not to do so. Father acknowledges that he is not represented by Pamela L. Purdy, Esquire. 6. This Stipulation may be executed in counterparts and all such counterparts shall then constitute the entire Stipulation. 7. All the statements and paragraphs set forth in the preceding WHEREAS clauses to this Stipulation are incorporated herein by reference, and are made a part hereof with the same force and effect as if restated in full. To the extent the paragraphs are inconsistent, however, the provisions of this Stipulation shall prevail over any inconsistent provisions contained in the WHEREAS clauses to this Stipulation. 8. This Stipulation shall be entered as an Order of the Court. Je Wife Sayer, Mothe Pamela L. Purdy J q9 Mor on, Father i ess V Z--? Attorney for Jennifer Sayer -2- • • By THE CURT J.UOC pate: a 8lo8 ?,?I & ?pIo X P ,? %, d%f-t r -3- Y ,?2rl 6S :I I IIV 8-130 HE JENNIFER SAYER, Plaintiff v. JOEL MORISSON, Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 08- '5q81 ? i u i (T rn? CIVIL ACTION IN CUSTODY AFFIDAVIT OF ACCEPTANCE OF SERVICE I hereby accept service of the Custody Complaint in the above matter. J I Morisson Dated: J a ,, 1 - o > - ?` cn JENNIFER SAYER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 2008-5989 CIVIL ACTION LAW JOEL MORRISON Defendant IN CUSTODY ORDER OF COURT AND NOW, this — day of 2013, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated August 27, 2008 shall continue in effect as modified by this Order. 2. The Father shall have physical custody of the Child on alternating weekends from Saturday at 11:00 a.m. through Sunday at 9:00 a.m., which shall take place in the home of the paternal grandmother who shall supervise the Father's overnight periods of custody and generally supervise daytimes. However, the Father may have custody of the Child without supervision in the grandmother's home for limited periods of time during the day if the grandmother needs to run errands or leave the house on a limited basis. The Father may also have custody of the Child at additional times as arranged by agreement between the parties including at public places without supervision. 3. The Father shall make arrangements to promptly begin participation in the Child's counseling with Debbie Bauer and the parties shall follow the guidance of the Child's counselor as to the Child's needs as related to the Father's custodial time and the need for supervision. 4. The parties shall participate in therapeutic family counseling with a professional selected by agreement for the purpose of establishing a gradually expanding partial custody schedule for the Father to enable the parties to reach their goal of regular, expanded,unsupervised periods of physical custody with the Child. The process may involve counseling, mediation and evaluation. The parties shall sign all authorizations deemed necessary to enable the professional under this provision to consult with and obtain information from the Child's counselor and any other information pertaining to either party or the Child which the professional requires to provide these services. 5. Within four months of the date of this Order, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference if necessary to review the parties' progress toward expanding the Father's periods of custody with the Child. 6. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, J. cc: /Michael Sedor Esquire—Counsel for Father ✓Joanne Harrison Clough Esquire—Counsel for Mother 0�� lei' 17/ aPx 3 m c fir' N p r-C) C:) JENNIFER SAYER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2008-5989 CIVIL ACTION LAW JOEL MORRISON Defendant IN CUSTODY Prior Judge: J.Wesley Oler Jr. 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 Ava Richelle Morrison December 12, 2005 Mother 2. A custody conciliation conference was held on March 13, 2013, with the following individuals in attendance: the Mother, Jennifer Sayer, with her counsel,Joanne Harrison Clough Esquire, and the Father, Joel Morrison, with his counsel, Michael Sedor Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator