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Home My WebLink About09-4798GORDON A. MOATZ, JR., Plaintiffs V. TAMAR R. MOATZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CUSTODYNISITATION :NO. 09- y7 7 Q' CIVIL TERM COMPLAINT FOR CUSTODY 1. The Plaintiff is Gordon A. Moatz, Jr., 157 Rustic Drive, Shippensburg, Cumberland County, Pennsylvania 17257. 2. The Defendant is Tamar R. Moatz, last known residing at 4689 Railroad Rd., Chambersburg, Franklin County, Pennsylvania 17201. 3. Co-Plaintiff's seeks custody of the following children: NAME RESIDENCE Kelsey Ann Moatz 157 Rustic Drive, Shippensburg, PA Katelyn Marie Moatz 157 Rustic Drive, Shippensburg, PA 4. The children were not born out of wedlock. DOB AGE 09/09/1997 11 09/09/1997 11 5. The children are presently in the custody of Gordon A. Moatz, Jr. 6. During their life, the children have resided with the following persons and at the following addresses: NAME Gordon A. Moatz, Jr Tamar R. Moatz Gordon A. Moatz, Jr., & Tamar R. Moatz ADDRESS 157 Rustic Drive, Shippensburg 4689 Railroad Rd., Chambersburg 157 Rustic Dr., Shippensburg, PA DATES 05/23/2009-Present 08/28/2008-05/23/2009 04/2006-08/28/2008 Gordon A. Moatz, Jr., & Wyrick Avenue, Shippensburg, PA 2004-2006 approx. Tamar R. Moatz Gordon A. Moatz, Jr., & Mickey Inn Mobile Home Park, Scotland 1997-2004 Tamar R. Moatz 7. The mother of the children is Tamar R. Moatz, last known residing at 4689 Railroad Rd., Chambersburg, Pennsylvania 17201. She is married. 8. The father of the child is Gordon A. Moatz, Jr., currently residing at 157 Rustic Drive, Shippensburg, Pennsylvania 17257. He is married. 9. The relationship of the Plaintiff to the children is that of Natural Father. The Plaintiff currently resides with the following persons: a. Kelsey Ann Moatz b. Katelyn Marie Moatz 10. The relationship of the Defendant to the children is that of Natural Mother. The Defendant currently resides with the following persons: a. UNKNOWN 11. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of these children in this or another court. 12. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 13. 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. 14. Plaintiff has had Primary Physical Custody of the children since May 23, 2009, at which time Natural Mother dropped the children off with Natural Father and told him to keep the children as she was not mentally or physically able to care for them. WHEREFORE, Plaintiff requests the Court to grant Primary Physical Custody of the children to Plaintiff subject to structured Partial Visitation Periods by the Defendant pending the hearing. By: Respectfully submitted, Paul Bradford Orr, Esquire Attorney for Plaintiff 50 East High Street Carlisle, PA 17013 Telephone: (717) 258-8558 Supreme Court ID No. 71786 VERIFICATION I verify that the statements made in the foregoing Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. DATE: 10q ; '6' Ng2r Gordon A. Moatz, Jr., Petitione C M. C??f?: J: ? `Uh lz? ek .2 .7G r/ GORDON A. MOATZ, JR. IN THE ('OUR"1- (_)F COMMON PLFAS OF PL;IINTIIT CUMBERLAND ('Ol!N'I Y. PF: NNSYI V,'\NIA TAMAR R. MOATZ DID FFINDANT 2009-4798 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT :1ND \OW. Monday, July 27, 2009 upon consideration ofthe attached Complaint, it is herehv directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, August 20, 2009 at 10:30 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 entrv ol'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 hearinLy. FOR THE COURT, Fay: is/ Hubert X. Gilroy,Esq., Custody Conciliator 'I'hr CotnFt ofCOmrnon Pleas ofCumherland County is required by law to comply with the Americans with Disabihte, Act of 1990. For intormation about accessible facilities and reasonable accommodations availahlc ti) disabled individuals having husincss before the Court, please contact our office. All arran?(Tements must he made at least 72 horn"s prior to any hearing: Or husiness 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 11AVI A\ AT'IORNF.Y OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SI_,T FORT] 1 13110W TO FIND OUT WI--IERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle. Pennsylvania 17013 Telephone (717) 249-3166 FILED-', i'Fl U: 2009 JUL 27 PM 3: 56 1lVElEr `, :. t 'l.j;JO AUG ? A 2009 GORDON A. MOATZ, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW TAMAR R. MOATZ, NO. 2009-4798 Defendant IN CUSTODY ORDER AND NOW, this day of August, 2009, the Conciliator being advised the parties have reached an agreement, the Conciliator relinquishes jurisdiction. At- zo Hubert X. Gilroy, E., Custody Conciliator OE THE Pl'. 2009 AUG 21.4 Ail 1, -- 2 3 ABOM CSZ' j~LITLILAKIS Michelle L Sommer, Esquire Attorney LD. No.: 93034 2 Wert High Street Carlisle, Perrnsylvaraia 17013 (717) 249-0900 GORDON A. MOATZ, JR. Plaintiff v. TAMAR R. MOATZ, Defendant ,, ZC10 ~i~{W C~ ~~i J' ~..1 ~~^^ a ~~I`; LTV ~ ~ `~` .. ~ 1 - t ~• ;' ~ ~ , t" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO 09-4798 CIVIL ACTION-LAW IN CUSTODY PRAECIPE TO WITHDRAW APPEARAN~ Please withdraw my appearance on behalf of the Plaintiff, Gordon A. Moatz, Jr., in the above-captioned matter. R e full ubmi , Paul Orr, Esquire Paul Bradford Orr Law Offices 50 East High Street Carlisle, PA 17013 (717) 258-8558 PRAECIPE OF ENTRY OF APPEARANCE Please enter my appearance on behalf of the Plaintiff, Gordon A. Moatz, Jr., in the above- captioned matter. Respectfully submitted, AsoNr&KUTULAKIS, L.L.P. Michelle L. Somme , squire 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney ID No. 93034 MAR. ~I U ZULU T ~BOM ~' uTULAKIs Michelle L. Sommer, Esquire Attorney LD. No.: 93034 2 West High Street Carlisle, Pennsylvania 17013 (717) 249-0900 GORDON A. MOATZ, JR. Plaintiff v. TAMAR R. MOATZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO 09-4798 CIVIL ACTION-LAW IN CUSTODY ORDER OF O TRT AND NOW this ~_ day of ~ ar ~.~ , 2010, the attached Custody Stipulation and Agreement is hereby made an Order of Court. BY THE COURT, J. D~istribution• / Michelle L. Sommer, Esquire Attorney for the Plaint ~.,~ ~.~, Abom & Kutulakis, L.L.P. ~~°- 2 West High Street -r,~ ~ ?''r , Carlisle, PA, 17013 ' ' =a '~~~ -v `r' r'~ Harold S. Irwin, III, Esquire ' ~- a~ =~-Trt Attorney for the Defendant ~ ~ =~= ~y'C- ~ i~~ 64 South Pitt Street ~~ ..~ Carlisle, PA 17013 ~ .. ~.~~C~C ~ ~Q~~v ~~ LAW OFFICES OF JEFFREY S. EVANS 2025 East Main Street Waynesboro PA 17268 Phone 717-762-1415 Fax 717-765.0172 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA GORDON A. MOATZ, JR., Plaintiff TAMAR R. MOATZ, Defendant : Civil Action -Law No. 2009 - 4798 IN CUSTODY PRAECIPE FOR ENTRY OF APPEARANCE r'n a ;rrn C a CD q C ) zc . Please enter my appearance in the above-captioned matter as attorney for Defendant, Tamar R. Moatz. Date: B _ squire J Weendant Atto 2025 East Main Street Waynesboro, PA 17268 717-762-1415 Pa Atty. ID No. 55654 GORDON A. MOATZ, JR., Plaintiffs vs. TAMAR R. MOATZ, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYI:VANIA NO. 2009-479$ CIVIL ACTION - L.AW IN CUSTODY ORDER L"0 AND NOW, this ~~ day of May, 2012, the above case being previously assigned to the Conciliator and there being no activity on this case for a period. of six months or more, the Conciliator relinquishes jurisdiction. ~4 ~ J -i ~ ~ ,d Hubert X. Gilroy, esquire Custody Conciliator ~.__ ,' J ~ ~. ~! `~ -1 GJ ':?