HomeMy WebLinkAbout01-3524CYNTHIA J. FERRY
PLAINTIFF
V.
MICHAEL FERRY AND ANGELA MILLER
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01=3524 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Thursday, June 14, 2001 , 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, July 13, 2001 at 8:30 AM
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 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 all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: M
Hubert X. Gilroy, Esq.
Custody Conciliator ~,J
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 incF~viduals 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. IF 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
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
CYNTHIA J. FERRY, :
Plaintiff :
MICHAEL FERRY, :
and ANGELA MILLER, :
Defendants :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. tg/- ~D~-c~9/C1ViL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW,
is hereby directed that the parties and their respective counsel appear before
, the conciliator, at
on the _ day of ,2001 , at
o'clock, .m., 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 may also be present at the conference. Failure to appear at the conference may
provide grounds fo3 entry ora temporary or permanent order.
FOR THE COURT:
,2001 upon consideration of the attached Complaint, it
By:
Custody Conciliator
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 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.
Office of the Court Administrator
Ctm~berland County Court House, Fourth Floor
Carlisle, PA 17013
(717) 240-6200
CYNTHIA J. FERRY,
Plaintiff
MICHAEL FERRY,
and ANGELA MILLER
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.O/-3YA~t CIVIL ACTION LAW
IN CUSTODY
COMPLAINT FOR CUSTODY
The plaintiffis Cynthia J. Ferry, residing at 233 East Garfield Street, Shippensburg,
Pennsylvania.
2. The defendant is Michael Ferry, residing at 1126 Rockledge Drive, Carlisle, Pennsylvania.
The defendant is Angela Miller residing at Cumberland County Prison, Carlisle,
Pennsylvania.
4. Plaintiff seeks custody of the following child:
Name
Alexis Ferry
Present Residence Age
1126 Rockledge Drive, Carlisle, PA 3 years
The child is presently in the custody of Michael Ferry who resides at 1 ! 26 Rockledge
Drive, Carlisle, PA.
During the past five years, the child has resided with the following persons and at the
following addresses:
List All Persons
Cynthia Ferry
Elaine Yeager
Cynthia Ferry
Michael Ferry
List All Addresses
233 Garfield Street, Shippensburg, PA
Weaver Road, Orrstown, PA
233 Garfield Street, Shippensburg, PA
1126 Rockledge Drive, Carlisle, PA
Dates present.
8/2/97 - 7/98
7/98 - 9/98
7/98 - 3/99
3/99 - Present
The mother of the child is Angela Miller, currently residing at Cumberland County Prison,
Carlisle, PA.
She is unmarried.
The father of the child is Michael Ferry, currently residing at 1126 Rockledge Drive,
Carlisle, PA..
He is unmarried.
5. The relationship of plaintiff to the child is that of grandmother.
The plaintiff currently resides with the following persons.
Name Relationship
No One
6. The relationship of defendant to the child is that of father.
The defendant currently resides with the following persons.
Narne
Shelly Keeseman
Daniel Keeseman
Luray Keeseman
Relationship
Girlfriend
Girlfriend's Son
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 not know ora person not a party to the proceedings who has physical
custody of the child and claims to have custody or visitation fights with respect to the
child.
The best interest and permanent welfare of the child will be served by granting the relief
request because Plaintiff has undertaken and performed the primary parental
responsibilities for the child; and Plaintiffis best able to provide the care and nurture
which the child needs for healthy development.
WHEREFORE, Plaintiff requests the Court to grant custody of the child to the Plaintiff
subject to structured partial Custody and visitation by the Defendant.
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.
DH6.5,00
Karl E. Rominger, Esquire
Attorney for Plaintiff
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
15,5 South H.anoger Street
Carl~e. ,Pennsylvania 17013
717,241,6Q70 · 800.734.0490 · lAX: 717.241.6878
CYNTHIA J. FERRY,
Plaintiff
MICHAEL FERRY and
ANGELA MILLER,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 01-3524 CIVIL
98-6169
IN CUSTODY
COURT ORDER
AND NOW, this ,~' day of August, 2001, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
The Father, Michael Ferry, shall continue to enjoy legal and physical custody of
Alexis Ferry, bom August 2, 1997.
The Paternal Grandmother, Cynthia J. Ferry, shall enjoy periods of temporary
physical custody with the minor child as tbllows:
On every Tuesday and Thursday fi.om 9:00 a.m. until 7:30 p.m., except for
those Tuesdays and Thursdays when Father is not working. Father shall
provide the Grandmother with a schedule in advance.
B. At such other times as agreed upon by the parties.
The parties shall meet again with the custody conciliator on Thursday, October 4,
2001 at 8:30 a.m. In the event the parties are able to reach a permanent agreement
prior to the conciliation conference, legal counsel for the parties may contact the
conciliator to cancel the scheduled conciliation conference.
In the event the parties are unable to reach an agreement after another conciliation
conference and this matter needs to proceed to a hearing before a Judge, it is noted
that the Father reserves any defenses he may have including a claim that the Paternal
Grandmother does not have standing to seek visitation rights.
This order shall be merged with the order entered at Docket No. 99-6169 insofar as
the Maternal Grandmother, Elaine Yeager shall continue to exercise custody on
alternating weekends until such time as the Mother is able to resume custodial
responsibility for the child.
6. It is further ordered that the cases at Docket No. 98-6169 and at 01-3524 are
consolidated as noted above in the caption.
Edward E. Guido
CC~
Karl Rominger, Esquire
Michael Scherer, Esquire
CYNTHIA J. FERRY,
Plaintiff
V
MICHAEL FERRY and
ANGELA MILLER,
Defendants
1N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 01-3524 CIVIL
98 -6169
IN CUSTODY
Prior Judge: Edward E. Guido
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 pertinem information pertaining to the child who is the subject of this litigation is as
follows:
Alexis Ferry, bom August 2, 1997.
A Conciliation Conference was held on August 17, 2001, with the following individuals in
attendance:
The Paternal Grandmother, Cynthia J. Ferry, with her counsel, Karl Rominger, Esquire; and
the Father, Michael Ferry, with his counsel, Michael Scherer, Esquire. The Mother, Angela
Miller, was not present. She is currently incarcerated.
3. The parties agree to the entry of an order in the form as attached.
DATI~
Humbert X.~Oil ~ Esquire
Custody Conciliator
CYNTHIA J. FERRY,
Plaintiff
MICHAEL FERRY and
ANGELA MILLER,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 01-3524 CIVIL
98-6169
IN CUSTODY
COURT ORDER
AND NOW, this $>'/'~ day of October, 2001, the conciliator being advised the parties have
reached an agreement, the conciliator relinquishes jurisdiction.
BY THE COURT,
ANGELA M. MILLER V. MICHAEL FERRY
CYNTHIA J. FERRY V. MICHAEL FERRY
AND ANGELA MILLER :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
98-6169// CIVIL ACTION LAW
01-3524 (
IN CUSTODY
ORDER OF COURT
AND NOW, Tuesday, December 23, 2003 , 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, January 16, 2004 at 10:30 AM
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 may also be present at the conference. Failure to apl~ear at the conference may
provide grounds for entry of a temporary or permanent order;.
The court hereby directs the parties to furnish any and all existing Protection from Abus ce~r_ de~
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing,
FOR THE COURT.
By: /s/ Hubert X. Gilroy, Esq.
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. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTtt 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
ANGELA M. MILLER,
Plaintiff
MICHAEL FERRY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 98-6169 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
CYNTHIA J. FERRY,
Plaintiff
MICHAEL FERRY and
ANGELA MILLER,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-3524
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NOW THIS day of ,200 upon
consideration of the attached Petition To Modify Custody, it is hereby directed that the
parties and their respective counsel appear before , Esquire,
the conciliator, at on the __ day
of ,200__ at A.M/P.M, 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. Absent a special request and prior
arrangements with the conciliator, children are discouraged from attending the
conciliation 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 all existing Protection from Abuse Orders, Special Relief Orders, and
Custody Orders to the conciliator at least 48 hours prior to the scheduled conference.
FOR THE COURT,
BY
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.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
ANGELA M. MILLER,
Plaintiff
MICHAEL FERRY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 98-6169 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
CYNTHIA J. FERRY,
Plaintiff
MICHAEL FERRY and
ANGELA MILLER,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-3524
CIVIL ACTION - LAW
IN CUSTODY
PETITION TO MODIFY CUSTODY
AND NOW, comes Michael Ferry, by and through his attorney, Michael A.
Scherer, Esquire, and respectfully represents as follows:
1. The father, Michael Ferry, is an adult individual who resides at 333 Burd
Street, Shippensburg, Cumberland County, Pennsylvania.
The mother, Angela Miller, is an adult individual whose present residence
is unknown.
3.
The paternal grandmother, Cynthia J. Ferry, is an adult individual who
resides at 233 East Garfield Street, Shippensburg, Cumberland County, Pennsylvania.
4. The mother and father are the parents of one child, Alexis Ferry, born
August 2, 1997.
5. The mother commenced the action docketed to 98-6169 against the
father and a custody Order dated April 13, 2000 provides that maternal grandmother,
Elaine Yeager, has partial physical custody of the child on alternating weekends until
mother is able to resume having partial physical custody of the child. The April 13,
5. The mother commenced the action docketed to 98-6169 against the
father and a custody Order dated April 13, 2000 provides that maternal grandmother,
Elaine Yeager, has partial physical custody of the child on alternating weekends until
mother is able to resume having partial physical custody of the child. The April 13,
2000 Order is attached hereto as "Exhibit A."
6. Until the end of November, 2003, mother had in fact been exercising
partial physical custody of the child on alternating weekends.
7. The paternal grandmother commenced the action docketed to 01-3524
against the mother and father and a custody Order dated August 30, 2001 provides that
paternal grandmother have partial physical custody of the child, and the practice of the
parties recently is that paternal grandmother has physical custody of the child one
weekend per month. The August 30, 2001 Order is attached hereto as "Exhibit B."
8. Mother has had an ongoing substance abuse problem.
9. Recently, mother missed two weekends of partial physical custody with
the child and failed to alert father in advance that she would miss her weekend with the
child.
10. Father has been advised that mother is staying in a "crack house" in
Harrisburg, PA and that mother sold her automobile to raise money to purchase drugs.
11. Mother's whereabouts have been unknown since Thanksgiving, 2003.
12. Father has been advised that prior to Thanksgiving, 2003, that mother
was drinking alcohol excessively and using drugs in front of the child and other minors.
VERIFICATION
The statements in the foregoing Petition To Modify Custody are based upon
information which has been assembled by my attorney in this litigation. The language
of the statements is not my own. I have read the statements; and to the extent that
they are based upon information which I have given to my counsel, they are true and
correct to the best of my knowledge, information and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to
unsworn falsifications to authorities.
DATE:
Michael Ferry
ANGELA M. MILLER,
Plaintiff
MICHAEL FERRY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 9~1-6169 CIVIL TERM
CIVIL ACTION-LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this I.~+1~ day of.J.~r ~ , 2000, the attached Stipulation
and Agreement is hereby made an Order of Court and all prior Orders on this matter
are hereby vacated.
BY THE COUR'r
"EXHIBIT A"
and the sealol sa~d Court
ANGELA M MILLER,
Plaintiff
MICHAEL FERRY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6169 CIVIL TERM
CIVIL ACTION-LAW
IN CUSTODY
CUSTODY STIPULATION AND AGREEMENT
THIS AGREEMENT AND STIPULATION entered into the day and year
hereinafter set forth, is made by and between Angela M. Miller (hereinafter referred to
as "Mother') and Michael Ferry (hereinafter referred to as "Father').
WHEREAS, the parties are the natural parents of Alexis Bree Ferry, born August
2, 1997 (hereinafter referred to as "child"); and,
WHEREAS, the parties are presently separated and living in separate
residences; and,
WHEREAS, the parties wish to enter into an agreement relative to the custody
and partial custody of the child.
NOW, THEREFORE, in consideration of the mutual covenants, promises and
agreements as hereinafter set forth, the parties agree as follows:
1. The parties shall have joint legal custody of the child.
2. Father shall have primary physical custody of the child.
3. The maternal grandmother, Elaine Yeager, shall have partial physical
custody of the child every other weekend until such time as Mother is able to resume
custodial responsibility of the child.
4. Either party may petition the Court to modify the terms of this Stipulation
and Agreement upon changed circumstances of the parties or the child.
5. The parties will keep each other advised immediately relative to any
emergencies concerning the child and shall further take any necessary steps to insure
that the health and well being of the child is protected.
6. Neither parent shall do anything which may estrange the child from the
other party, or injury the opinion of the child as to the other party or which may hamper
the free and development of the child's love or affection for the other party.
7. Any modification or waiver of the provisions of this Agreement shall be
effective only if made i~ '~f'iting end only if cxi:~uted with the~,an~e fbi reality es this '~'
Stipulation and Agreement. -
8. The parties desire that this Stipulation and Agreement be made an Order
of Court to the Court of Common Pleas of Cumberland County, and further
acknowledge that the Court of Common Pleas of Cumberland County does, in fact,
have jurisdiction over the issue of custody and the parties's minor child and shall retain
jurisdiction should circumstances change and either party desire or require modification
of said Order.
9. The parties agree that in making this Agreement, there has been no
fraud, concealment, overreaching, coercion or other unfair dealing on the part of the
other.
10. The parties acknowledge that they have read and understand the
provisions of this Agreement.
11. Each party acknowledges that the Agreement is fair and equitable and
that it is not the result of any duress or undue influence.
IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the
terms hereof set their hands and seal the day and year written below.
WITNESS:
Date:
Date:
Angela M. Miller
Michael Ferry
CYNTHIA J. FERRY,
Plaintiff
v
MICHAEL FERRY and
ANGELA MILLER,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-3524 CIVIL
98-6169
IN CUSTODY
CIVIL ACTION - LAW
COURT ORDER
AND NOW, this .3'0 e~ day of August, 2001, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
The Father, Michael Ferry, shall continue to enjoy legal and physical custody of
Alexis Ferry, bom August 2, 1997.
The Paternal Grandmother, Cynthia J. Ferry. shall enjoy periods of temporary
physical custody with the minor child as tbllows:
On eveo' Tuesday and Thursday from 9:00 a.m. until 7:30 p.m., except tbr
those Tnesdays and Thursdays when Father is not working. Father shall
provide the Grandmother with a schedule in advance.
B. At such other times as agreed upon by the parties.
The parties shall meet again with the custody conciliator on Thursday, October 4.
2001 at 8:30 a.m. In the event the parties are able to reach a permanent agreement
prior to the conciliation conference, legal counsel for the parties may contact the
conciliator to cancel the scheduled conciliation conference.
In the event the parties are unable to reach an agreement after another conciliation
conference and this matter needs to proceed to a hearing betbre a Judge, it is noted
that the Father reserves any defenses he may have including a claim that the Paternal
Grandmother does not have standing to seek visitation rights.
This order shall be merged with the order entered at Docket No. 99-6169 insofar as
the Maternal Grandmother, Elaine Yeager shall continue to exercise custody on
alternating weekends until such time as the Mother is able to resume c0.stodial
responsibility tbr the child.
"EXHIBIT B"
It is further ordered that the cases at Docket No. 98-6169 and at 01-3524 are
consolidated as noted above in the caption.
BY THECOURT,
Edward E. Guido
CC~
Karl Rominger, Esquire
Michael Scherer, E.squire
Mike Ferry 09/05/01
tRUE COPY FROM RECORD
~n Testimony whereof, I here unto set my hand
and the seal of said Ccurt at Carlisle, Pa.
1'hi--ay of~
,-./*~.. ,'2. ~,.,0.. ~,
Prothonotary
CYNTHIA J. FERRY,
Plaintiff
V
MICHAEL FERRY and
ANGELA MILLER,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 01-3524 CIVIL
98-6169
IN CUSTODY
Prior Judge: Edward E. Guido
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 child who is the subject of this litigation is as
follows:
Alexis Ferry, bom August 2, 1997.
A Conciliation Conference was held on August 17, 2001, with the tblloxving individuals in
attefidance:
The Paternal Grandmother, Cynthia J. Ferry, with her counsel, Karl Rominger, Esquire; and
the Father, Michael Ferry, with his counsel, Michael Scherer, Esquire. The Mother, Angela
Miller, was not present. She is currently incamemted.
3. The parties agree to the entry of an order in the form as attached.
DAT
Ht~ffbe n X~G il~s, Esquire
Custody Conciliator
CERTIFICATE OF SERVICE
I hereby certify that on December I ~ , 2003, I, Jennifer S. Lindsay, secretary to
Michael A. Scherer, Esquire, did serve a copy of the Petition To Modify Custody, by first
class U.S. mail, postage prepaid, to the party listed below, as follows:
Karl Rominger, Esquire
Rominger & Bayley
155 South Hanover Street
Carlisle, Pennsylvania 17013