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Home My WebLink About08-6223Elizabeth A. Hoffman, Esquire 106 Walnut Street Harrisburg, PA17101 (717) 236-2956 TAMIKA E. SYLVESTER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 0g- G2a ? ? -c - DUJUAN W. SYLVESTER CIVIL ACTION - IN CUSTODY Defendant COMPLAINT IN CUSTODY 1. Plaintiff Tamika E. Sylvester ("Mother") is an adult individual whose current mailing address is 2A Misty Wood Circle, Timonium, Maryland 21093. 2. Defendant DuJuan W. Sylvester ("Father") is an adult individual whose current mailing address is P.O. Box 467, Beaver Meadows (Potter County), Pennsylvania 18216. 3. Mother and Father are the natural parents of the following minor children: DuJuan Donte Sylvester - DOB 6/27/95 Bryanna Elaine Sylvester - DOB 5/13/97 4. Until June 14, 2008, the minor children have lived in Cumberland County at the following addresses with the following persons: Address Persons Living With Dates 810 Erford Road Mother and Father 5/03 - 9/06 Camp Hill, PA 204 Erford Road Mother and Father 9/06 - 10/07 Camp Hill, PA 204 Erford Road Mother 10/07 - 6/08 Camp Hill, PA 5. 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 any other court. 6. There are no other persons known to have or claim to have a right to custody or visitation of the child, and therefore no further notice of the pendency of this action and the right to intervene shall be given, other than to the parties named herein. 7. Mother is pursuing a custody order which grants her primary physical custody of the children and which sets forth a definite partial custody schedule for Father because she believes that said order will be in the best interests of the children. WHEREFORE, it is respectfully requested that this Honorable Court enter an order which grants primary physical custody of the children to Mother and partial physical custody to Father. Respectfully submitted, 6 ?-' d . 4? A -g - 119914 AL'- ? Eliza eth A. Hoffma , Esquire Attorney for Plaintiff 106 Walnut Street Harrisburg, PA 17101 (717) 236-2956 1 D #71000 2 VERIFICATION I verify that the information provided in the attached document is 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.A. §4904, relating to unsworn falsification to authorities. W Date: R /('Q 0 *JM4 Tamika S ster CERTIFICATE OF SERVICE I, Elizabeth A. Hoffman, Esquire, do hereby certify that a true and correct copy of the attached complaint will be sent by U.S. mail to the following person pursuant to the procedures in the Cumberland County Prothonotary's Office: DuJuan Sylvester P.O. Box 467 Beaver Meadows, PA 18216 Date: /Q /? /1W , Eliz eth A. Hoffman, quire Attorney for Plaintiff 106 Walnut Street Harrisburg, PA 17101 (717) 236-2956 1 D #71000 -?R- C=:o n +j C ? t M TAMIKA E. SYLVESTER PLAINTIFF V. DUJUAN W. SYLVESTER DEFENDANT AND NOW, _ Thursday, Octob it is hereby directed that parties and their resp at 4th Floor, Cumberland County Courth for a Pre-Hearing Custody Conference. At su if this cannot be accomplished, to define and i order. All children age five or older may also provide grounds for entry of a temporary or pi IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • 2008-6223 CIVIL ACTION LAW IN CUSTODY t3, 2008 , upon consideration of the attached Complaint, ive counsel appear before Hubert X. Gilroy, Esq. , the conciliator, e, Carlisle on Friday, November 21, 2008 at 9:30 AM conference, an effort will be made to resolve the issues in dispute; or row the issues to be heard by the court, and to enter into a temporary present at the conference. Failure to appear at the conference may ianent order. The court hereby directs the parties t furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to he conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /$/ Hubert X. Custody Conciliator The Court of Common Pleas of C Berland County is required by law to comply with the Americans with Disabilites Act of 1990. For informati n 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 earing or business before the court. You must attend the scheduled. conference or hearing. YOU SHOULD TAKE THIS PA ER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AF ORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. C mberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 "', 7? 46P ,WOW r--W*4 -yothc'- O/ ViNVAI AIN N?44mno OS :E wd ?z 130 OOOZ 1911031??L,4i? y NEC 0 3 2008 U' TAMIKA E. SYLVESTER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW DUJUAN W. SYLVESTER, NO. 2008-6223 Defendant IN CUSTODY COURT ORDER AND NOW, this day of 3r, ? , 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: The mother, Tamika E. Sylvester, and the father, Dujuan W. Sylvester, shall enjoy shared legal custody of Dujuan Donte Sylvester, born June 27, 1995, and Bryanna Elaine Sylvester, born May 13, 1997. 2. The mother shall enjoy primary physical custody of the minor children. 3. The father shall enjoy periods of temporary physical custody of the minor children as follows: A. On three alternating weekends from Friday at 7:00 p.m. until Sunday afternoon with the exchange to be 5:00 p.m. when the children have school the next day but 7:00 p.m. when the children do not have school on Monday. B. At such other times as agreed upon by the parties. 4. A holiday schedule shall be handled as follows: A. The Thanksgiving Holiday shall be from Wednesday at 7:00 p.m. through Sunday at 5:00 p.m. Custody shall be alternated each year with the father having custody in 2008 and the parties alternating thereafter. B. For the Christmas Holiday, the holiday shall be divided into two segments: Segment A shall be from December 23 until Christmas Day at 1:30 p.m., with Segment B being from Christmas Day at 1:30 p.m. through New Years Eve at 6:00 p.m. The other parent shall then have the New Years Eve Holiday through January 2 (if the children do not have school that day) at 6:00 p.m. For 2008, mother shall have the first portion of the Christmas Holiday being from December 23 through Christmas Day and also the New Years Eve/New Years Day Holiday as set forth above with the father having the time in Ywh 3:3A WCM,iai%vya Wj 5- 330 ?6' between. The parties shall alternate that in future years.. C. The other four holidays of Easter, Memorial Day, July 4 and Labor Day, the parties shall alternate those holidays pursuant to a schedule agreed upon by the parties. D. Each parent shall have up to three weeks of custody with the children during the summer months with the parties giving each other at least twenty days notice as to when they shall exercise the vacation. 5. The parties shall share transportation and meet at a mutually agreed upon halfway point for transfer of custody of the children. 6. This Order is entered pursuant to an agreement reached by the parties reached at a Custody Conciliation Conference. The parties may modify this Order as they agree. Absent an agreement, the parties shall follow the Custody Order set forth above. In the event either party desires to change the Order, that party may petition the Court to have the case again scheduled with the Custody Conciliator for a conference. BY THE COURT, cc: XElizabeth A. Hoffman, Esquire ,/Mr. Dujuan W. Sylvester l.DP t,c r»2-L I.S?GIJ 1a-108108 10 TAMIKA E. SYLVESTER, Plaintiff vs. DUJUAN W. SYLVESTER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2008-6223 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Dujuan Donte Sylvester, born June 27, 1995,and Bryanna Elaine Sylvester, born May 13, 1997. 2. A Conciliation Conference was held on November 21, 2008, with the following individuals in attendance: The mother, ,Tamika E. Sylvester, who appeared with her counsel, Elizabeth A. Hoffinan, Esquire, and the father, Dujuan W. Sylvester, who appeared without counsel. 3. The parties agree to the entry of an Order in the form as attached. Date: December 1, 2008 ert X. Gilroy, Esquire ustody Conciliator