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Home My WebLink About09-0748STAGY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF MATTHEW J. GEYER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW HEATHER N. GEYER, : NO. 2009- ~YY" CIVIL TERM Defendant CUSTODY COMPLAINT FOR CUSTODY NOW comes the plaintiff, Matthew J. Geyer, by his attorney, Stacy B. Wolf, Esquire, and presents the following complaint for custody, representing as follows: 1. The plaintiff is Matthew J. Geyer, an adult individual residing at 82 Shippensburg Mobile Estates, Shippensburg, Cumberland County, Pennsylvania 17257. 2. The defendant is Heather N. Geyer, an aduh individual residing at 8596 Elliot Run Road, Three Springs, Pennsylvania 17264. 3. Plaintiff seeks custody of the following children: Present Residence Shawna L. Geyer 8596 Elliot Run Road 'T'hree Springs, PA 17264 Elizabeth L. Geyer 8596 Elliot Run Road Three Springs, PA 17264 4. Plaintiff and defendant are the natural parents of the children. 3 years D.O.B. 1012812005 1 year D.O.B. 5/29/2007 5. The children were born prior to the marriage of the parties. 6. The children are presently in the custody of Mother but resided with both parents from the time of birth until mid January, 2009 when Mother left the marital residence with the children. 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. 8. Plaintiff has no information of a custodyproceeding concerning the children pending in a court of this Commonwealth or any other state. 9. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 10. Mother is frequentlyusing marijuana, including in the presence of the children. Further, marijuana. is being grown at the residence where Mother is now living with the children, her mother, and step-father. Such drug usage and cultivation present a detriment to the children's physical and emotional well being. 11. Father has additional concern about the suitability of the residence where the children are now residing because to his knowledge the children are sleeping with their Mother in the living room, one child on a chair and the other on the floor. 12. The best interests and permanent welfare of the children will be served bygranting the relief requested herein. 13. Plaintiff acknowledges the need for the children to have a relationship with Mother and will, if given the opportunity, work to reinforce that relationship provided protection is in place for the welfare of the children in the form of supervised visitation and/or an agreement by Mother to attend counseling and receive treatment. WHEREFORE, for the reasons set forth herein, Plaintiff, Matthew J. Geyer, respectfully requests that the Court enter an order granting primary physical custody of the children to the plaintiff. Respectfully submitted, Dated: February '~, 2009 ~, Stacy B. W ,Esquire 10 West High Street Carlisle, PA 17013 (717) 241-4436 Attorney for Plaintiff Supreme Court I.D. No. 88732 VERIFICATION I do herebyverifythat the facts set forth in this complaint are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. February ~~ , 2009 ~~!~~~.k Matthew J. Geyer . w STACY B. WOLF, ESQUIRE ATTORNEY ID N0.88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF MATTHEW J. GEYER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. . CIVIL ACTION -LAW HEATHER N. GEYER, : NO. 2009- CIVIL TERM Defendant CUSTODY CERTIFICATE OF SERVICE I, Stacy B. Wolf, Esquire, have served a true and correct copy of Complaint for Custody upon the following person and in the matter indicated: SERVICE BY U.S. MAIL: Heather N. Geyer 8596 Elliot Run Road 'T'hree Springs, PA 17264 WOLF & WOLF February ' ~ , 2009 By: ~' STACY B. W LF, ESQUIRE Attorney for laintiff 10 West High Street Carlisle, Pennsylvania 17013 (717) 241-4436 Supreme Court I.D. No. 88732 ('~ ~v C^ ~ ~ f J r = '~"r f `7'; ~-ry J ~ ~~jj~1 `- ~..~~ 7---•. f"-' ~i , ~t ~~W l t ~j N Q ~ ~ ~ ~\ y~ :_t ~_~;~. ~ V '> ~~~ ~. ~" ~ N MATTHEW J. GEYER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA u• 2009-748 CIVIL ACTION LAW HEATHER N. GEYER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, February 17, 2009 ,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, March 12, 2009 at 9:30 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. 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. 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 1701.3 Telephone (717) 249-3166 ~'~/~~~'~J 6a8i~~ ~, ~ r.d ri ~ ff,~; t`,f ~~ u _ ,.~1"~a ~3~ '`~ F~~ 8 ~ Q~,~ ITlIS1G ~~~11(Ji'viJ w(.;4~ ''~!'. ~~ HEATHER GEYER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2009-722 CIVIL TERM MATTHEW JAMES GEYER, Defendant CUSTODY - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - MATTHEW J. GEYER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Zr. NO. 2009-748 CIVIL TERM HEATHER GEYER, Defendant CUSTODY ORDER OF COURT AND NOW, this 18th day of February, 2008, by agreement of the parties, both of the above-captioned actions are consolidated into 2009-722, with mother being the Plaintiff and father being the Defendant. heri D. Coover, Esquire Attorney for Heather Geyer Stacy B. Wolf, Esquire Attorney for Matthew J. Geyer Sheriff srs eo - ~ ,7,~.~L~. P ~~~~f~~ By the Court,