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Home My WebLink About09-1635DANIELLE BEATTIE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW GEORGE MILLER, No. 09 - 163--( CIVIL Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1 2. 3 4 The plaintiff is Danielle Beattie, residing at 1154 Pheasant Drive, North, Carlisle, Cumberland County, Pennsylvania 17013. The defendant George Miller, residing at 1233 Trindle Road, Carlisle, Cumberland County, Pennsylvania 17013. Plaintiff seeks custody of the following child: Name Present Residence DOB Age Christian Miller 1154 Pheasant Drive, North 03/13/1997 11 yrs old Carlisle, PA 17013 The child was born out of wedlock. The child is presently in the custody of Daniel Beattie, residing at 1154 Pheasant Drive, North, Carlisle, Cumberland County, Pennsylvania 17013. During the past five years, the child has resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Daniel Beattie 1154 Pheasant Drive, North 1/26/04-present Carlisle, PA 17013 The mother of the child Daniel Beattie, residing at 1154 Pheasant Drive, North, Carlisle, Cumberland County, Pennsylvania 17013. She is not married. The father of the child George Miller, residing at 1233 Trindle Road, Carlisle, Cumberland County, Pennsylvania 17013. He is not married. The relationship of plaintiff to the child is that of Mother. The plaintiff currently resides with the following persons. Name Self Relationship 6. The relationship of defendant to the child is that of Father. The defendant currently resides with the following persons. Name Relationship Dennis Miller Father 7. 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 of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. 8. The best interest and permanent welfare of the child will be served by granting the relief request because: Mother wants a no alcohol provision while the child is in each respective parties custody. A Court Order of custody and structured visitation is desired so that the Plaintiff and the child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion. Plaintiff desires to maintain the family household which has been established, and the continued stability of the household is in the best interest of the child. A Court Ordered determination of custody is required to avoid continuing conflict between the parties regarding responsibility for custody and support. WHEREFORE, Plaintiff requests this Court grant Plaintiff primary physical custody subject to structured visitation by the Defendant. Respectfully submitted, Rominger & Associates Date: March 16, 2009 Kmf'E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court I.D. #81924 Attorney for Plaintiff DANIELLE BEATTIE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW GEORGE MILLER, No. 09 - CIVIL Defendant IN CUSTODY VERIFICATION 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. n? Daniel Beattie, Plaintiff w ? C7 c=:) c3 -Ti 7 i-n r- j Cam) =' c;' rJ DANIELLE BEATTIE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-1635 CIVIL ACTION LAW GEORGE MILLER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, March 20, 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, April 30, 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 Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ Hubert X. G&o Es q. 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 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 -A o 9Z :Z Wd OZ HVW 6002 ?iS i.CJi v, dd:N?. JO O r 3 APR 3 o zooe? DANIELLE BEATTIE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW GEORGE MILLER, NO. 2009-1635 Defendant IN CUSTODY COURT ORDER AND NOW, this S' day of May, 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The mother, Danielle Beattie, and the father, George Miller, shall enjoy shared legal custody of Christian Miller, born March 13, 1997. 2. The mother shall enjoy primary physical custody of the minor child. 3. The father shall enjoy periods of temporary physical custody of the minor child at such times and under such circumstances as agreed upon by the parties. Is is directed that father shall not be under the influence of alcohol when he has custody of the minor child. 4. In the event the father desires to have this order modified in any way, the father may petition the court to have the case again scheduled with the custody conciliator for a conference. Y THE COU T, Judge cc: arl E. Rominger, Esquire ? Mr. George Miller e4Pl ¢.S rnt11zC.. L p :8 WV 9- AVV 1Wt CiiCW DANIELLE BEATTIE, Plaintiff vs. GEORGE MILLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2009-1635 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: Christian Miller, born March 13, 1997 2. A Conciliation Conference was held on April 30, 2009, with the following individuals in attendance: The mother, Danielle Beattie, who appeared with her counsel, Karl E. Rominger, Esquire. The father, George Miller, did not appear. Attorney Rominger indicated that Mr. Miller had been served and Miss Beattie indicated that Mr. Miller acknowledged that he was aware of the custody conciliation conference. 3. The history of this case is that the mother has primary custody of the minor child and the father is seeing the child as the parties agree. Mother desires a formal order giving her custody and also a restriction with respect to alcohol consumption. 4. The Conciliator recommends an Order in the form as attached. Date: 'k-,e3i , 2009 Z'41 \ ? Hubert X. Gil y, Esquire Custody Con iliator