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HomeMy WebLinkAbout08-6779SHANNON HARRYMAN, Plaintiff v ROBERT HARRYMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2008 - L 7 CIVIL ACTION - LAW IN CUSTODY COMPLAINT FOR CUSTODY 1. 2. 4 The Plaintiff is Shannon Harryman, currently residing at 457 East King Street, Shippensburg, Cumberland County, Pennsylvania, 17257. The Defendant is Robert Harryman, currently residing at 6 South High Street, Newburg, Cumberland County, Pennsylvania, 17240. Plaintiff seeks custody of Amanda M. Harryman, (DOB 10/14/98) and Ashton P. Harryman (DOB 5/19/00), currently residing at 457 East King Street, Shippensburg, Cumberland County, Pennsylvania. The children were born during the marriage. The children are presently in the custody of Shannon Harryman, currently residing at 457 East King Street, Shippensburg, Cumberland County, Pennsylvania. During the past five (5) years, the children have resided with the following persons at the following addresses: Shannon Harryman 457 East King Street, Shippensburg, PA Nov 2008 - present Shannon Harryman, Robert Harryman 6 South High Street, Newburg, PA Jan 1999 -Nov 2008 Shannon Harryman, Robert Harryman Oct 1998 - Jan 1999 McConnellsburg, PA The mother of the children is Shannon Harryman, currently residing at 457 East King Street, Shippensburg, Cumberland County, Pennsylvania. She is married. The father of the children is Robert Harryman. He is married. 5. The relationship of the Plaintiff to the children is that of mother. Plaintiff currently resides with the following persons: none. 6. The relationship of the Defendant to the children is that of father. Defendant currently resides with the following persons: None. 7. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff knows of the following persons not a party to the proceedings who have claims to have custody or visitation rights with respect to the children: None. 8. The best interest and permanent welfare of the children will be served by granting the relief requested because: a. Plaintiff has been the primary care provider for the children since their respective births. b. Plaintiff remains capable of providing for the child's daily physical, social, emotional, and medical needs, and will ensure the children maintain a close relationship with Defendant. c. Defendant has repeatedly effused to accept medical treatment for his alcohol addiction, thereby subjecting the children to Defendant's uncontrolled rages and daily verbal tirades directed towards, and exhibited in the presence of, the children and Plaintiff. 9. 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. All Page 2 other persons, named below, who are known to have or claim a right to custody or visitation of the child have been given notice of the pendency of this action and the right to intervene: None. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an Order granting her primary physical custody of the children, with limited visitation for Defendant. Respectfully submitted, '?" APLSM%^ C--AU Su e Spenc r Abel, Esq. Aey No: 202443 P.O. Box 1161 Carlisle, PA 17013 (717) 386-5612 Home Office (717) 386-5613 Fax SpencerAbel@comcast.net Page 3 SHANNON HARRYMAN, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v : No. 2008 - ROBERT HARRYMAN, CIVIL ACTION - LAW Defendant IN CUSTODY VERIFICATION I VERIFY that I have personal knowledge of all facts not of record set forth in the foregoing pleading, and that such statements 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.A. 44904 relating to unsworn falsification to authorities. Date: ?C.\-?Xr `'y-'Ck Shannon arryman SHANNON HARRYMAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v No. 2008 - ROBERT HARRYMAN, CIVIL ACTION - LAW Defendant IN CUSTODY CERTIFICATE OF SERVICE I certify that, concurrent with filing the foregoing Complaint forCustody, I am this day serving a copy of same via Certified First Class U.S. Mail, to the following Defendant: Robert Harryman 6 South High Street Newburg, PA 17240 Date: I // /I/w N It-ii il jJW SWMALJ44% SuzaUe, enc er A el, Esq. Attoo: 202443 P.O. Box 1161 Carlisle, PA 17013 (717) 386-5612 Home Office (717) 386-5613 Fax SpencerAbel@comcast.net v u © o Cr SHANNON HARRYMAN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-6779 CIVIL ACTION LAW ROBERT HARRYMAN IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, November 21, 2008 , 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 Thursday, December 11, 2008 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. 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: /s/ Hubert X. Gilroy, Esc Custody Conciliator r 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 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 "oe r. , JAN 2 ; 2009 4 q SHANNON HARRYMAN : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW ROBERT HARRYMAN, NO. 2008-6779 Defendant IN CUSTODY COURT ORDER AND NOW, this z 1 day of January, 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The mother, Shannon Harryman, and the father, Robert Harryman, shall enjoy shared legal custody of Amanda M. Harryman, born October 14, 1998, and Ashton P. Harryman, born May 19, 2000. 2. The mother shall enjoy primary phisical custody of the minor children. 3. The father shall enjoy periods of temporary physical custody of the minor children pursuant to a schedule arranged between the parties consistent with what the parties have been doing over the past few months. At a minimum, it is anticipated that the father shall have temporary custody with the minor children on alternating weekend and at other times as agreed by the parties. 4. Father shall not consume alcohol or be under the influence of alcohol while he has custody of the minor children. 5. This order is entered pursuant to an agreement reached by the parties as a Custody Conciliation Conference. In the event either party desires to modify this order, that party may petition the court to have the case again scheduled with the Custody Conciliator for a conference. BY THE COURT, Judge cc: Surobert e Spencer Able, Esquire Harryman 11ptles mgtLf '4 2.4`O? r- ??"'. ? .- .. ? ,? 1.r ?:: , .? .i e??. ??, 1? p .Cr" ffr .N"'? r w" _ MM ? 5.,_' i V` y .r?^' ?.?-? 1?q r? / t .k V. ? 'a? ? `' SHANNON HARRYMAN Plaintiff VS. ROBERT HARRYMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-6779 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: Amanda M. Harryman, born October 14, 1998, and Ashton P. Harryman, born May 19, 2000. 2. A Conciliation Conference was held on January 22, 2009, with the following individuals in attendance: The mother, Shannon Harryman, who appeared with her counsel, Suzanne Spencer Abel, Esquire, and the father, Robert Harryman, who appeared without counsel.. 3. The parties agreed to the entry of an Order in the form as attached. rh Date: January V , 2009 Hubert X. Gil y, Esquire Custody C ciliator