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Home My WebLink About09-1043KEVIN M. RYAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW MELISSA L. RYAN, NO. e? - IG613CIVIL TERM Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Kevin M. Ryan, an adult individual currently residing at 15 Shover Drive, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Melissa L. Ryan, an adult individual currently residing at 141 Southside Drive, Newville, Cumberland County, Pennsylvania. 3. The parties are the natural parents of one (1) child, namely, Cameron R. Ryan, born February 13, 2005. The child was not born out of wedlock. 4. For the past five (5) years, or since the child's birth, the child has resided with the following persons at the following addresses for the following periods of time: NAME ADDRESS DATES Mother and Courtney J. Short (half sister)* Mother, Father, and Courtney J. Short 141 Southside Drive Newville, PA 17241 141 Southside Drive Newville, PA 17241 January 16, 2009 to Present Birth to January 16, 2009 **Courtney resides with her mother pursuant to a 5 0/50 custody schedule. The natural mother of the child is Melissa L. Ryan, who resides as aforesaid. She is married. The natural father of the child is Kevin M. Ryan, who resides as aforesaid. He is married. 5. The relationship of the Plaintiff to the child is that of natural father. The Plaintiff currently resides with his parents, Linda L. Beates and William H. Beates, and his brother, Sean P. Beates. 6. The relationship of the Defendant to the child is that of natural mother. Defendant currently resides with her daughter, Courtney J. Short, and the child at issue. 7. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning custody of the child. 8. Plaintiff has no information of any custody proceedings concerning the child pending in any Court of this Commonwealth. 9. It is in the best interest and permanent welfare of the child to grant the relief requested because: a) Plaintiff has been and continues to be very involved with the day to day care of the child; b) Plaintiff can provide a stable home for the child; and c) Both parties are equally capable of caring for the child, and he will benefit from equal involvement by both parents. 10. Plaintiff does not know any person not a party to these proceedings who claims to have custody or visitation rights with respect to the children. WHEREFORE, Plaintiff requests your Honorable Court to schedule a Custody Conciliation Conference, followed by a hearing, at which time he should be granted equally shared physical custody of the child. Respectfully submitted, Hannah Herman-Snyder, Esqui Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 ?, ? ?? f--- -' _? ? F ? ^.? _ \ `=` ?. ? ? ti • J yh\. t KEVIN M. RYAN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-1043 CIVIL ACTION LAW MELISSA L. RYAN IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, February 27, 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 Friday, April 03, 2009 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 Custodv orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ Hubert X. Gilroy, Es q. Custody Conciliator FP_ 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 04 W-7, ?y -"-/ ?A4W :I; W'd LZ UJ 60OZ iw APR 2120006 KEVIN M. RYAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW MELISSA L. RYAN, Defendant NO.2009-1043 IN CUSTODY 4ay COUORDER AND NOW, this At of April, 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. 2. 3. The father, Kevin M. Ryan, and the mother, Melissa L. Ryan, shall enjoy shared legal custody of Cameron R. Ryan, born February 13, 2005. The parties shall also share physical custody of the minor child under the following schedule: A. The parties shall do a two day, two day and three day schedule with an exchange of custody being at 6:00 p.m. This schedule generally contemplates the mother having the child for Monday and Tuesday, the father having the child for Wednesday and Thursday and then the mother having the child for the weekend with the parties flipping the schedule the following week. The legal counsel for the parties shall have a telephone conference with the custody conciliator on Wednesday, May 6, 2009, at 8:00 a.m. The purpose of this call is to discuss the potential for father flipping his work schedule at Land O'Lakes so that his weekend off from work would change and the parties could change the schedule outlined above such that mother would end up with custody of Cameron on a weekend that mother's other child is with her. In the event a resolution of that issue cannot be reached, the matter may be scheduled for a hearing before the court at which time mother may take any position she desires with respect to a suggested permanent order. Additionally, the Conciliator may at that time address a possible different custody arrangement pending the hearing which could include a week on/week off basis pending the hearing to insure that the other children of the mother are with Cameron at least a period of time custody. B) cc: ah Herman-Snyder, Esquire 4obert S. Bell, Esquire C6 r t¢S mat A//-I I? Judge y 8 8 = f l ¢WV Z3 JdV 60OZ I«{171 .''` ? i t i. t 3'H i. 3O 3` f:'JO-CI31H } 1 KEVIN M. RYAN, Plaintiff VS. MELISSA L. RYAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.2009-1043 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 child who is the subject of this litigation is as follows: Cameron R. Ryan, born February 13, 2005 2. A Conciliation Conference was held on April 16, 2009, with the following individuals in attendance: The father, Kevin M. Ryan, who appeared with his counsel, Hannah Herman-Snyder, Esquire, and the mother, Melissa L. Ryan, with her counsel, Robert S. Bell, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. Date: April, 2009 Hubert X. 0156y, Esquire Custody Conciliator