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Home My WebLink About09-5296IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ROGER B. TABER, Plaintiff DOCKET NO.: vs. CIVIL ACTION IN CUSTODY CINDY D. TABER, Defendant COMPLAINT FOR CUSTODY 1. The plaintiff is Roger B. Taber and resides at 28 Ross Avenue, New Cumberland, Cumberland County, Pennsylvania 17070-2610. 2. The defendant is Cindy D. Taber, residing at 817 Hummel Avenue, Cumberland County, Lemoyne, Pennsylvania, 17043-1835 3. Plaintiff seeks physical custody of the following child: Shannon L. Taber Date of Birth: August 27, 1996 Currently Residing at 817 Hummel Avenue, Lemoyne, Pennsylvania 17043-1835 The child was not born out of wedlock. The child is presently in the custody of PlaintifflFather Roger B. Taber. During the past five years, the child has resided with the following persons and at the following addresses: a. July 25, 2009 - Present Roger B. Taber 28 Ross Avenue New Cumberland, PA 17070 b. 2008 - July 25, 2009 Cindy D. Taber 817 Hummel Ave. Lemoyne, PA 17043-1835 C. 2005 - 2007 Roger & Cindy Taber 28 Ross Avenue New Cumberland, Pa 1707-2610 d. 2005 Roger and Cindy Taber c/o Virginia Taber 1930 Carlisle Road Camp Hill, PA 17011 4. The relationship of the plaintiff to the child is that of Father. The Plaintiff currently resides with the following person/s: Joshua R. Taber, son and Shannon Taber, daughter. 5. The relationship of defendant to the child is that of Mother. The Defendant currently resides with the following person/s: self. 6. Plaintiff and Defendant are divorced. 7. The Plaintiff has not participated as a party or witness or in another capacity in other litigation concerning the custody of the child or knows information of a custody proceeding concerning the child in this or another court. 8. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 9. The best interest of the child will be served by granting the relief requested because Mother is no longer employed and is presently suffering from severe substance abuse. 10. Plaintiff requests this court to grant him physical custody WHEREFORE, Plaintiff requests the Court to grant his Petition and other appropriate relief. Date: L) Respectfully submitted, z?? L. Rex ickley, Esquire 114 S th Street H )burg, PA 17101 717/234-0577 717/234-7832, fax VERIFICATION I verify that the statements made in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements made herein are made subject to the penalties of Pa. C.S.A. §4904 relating to unworn falsification to authorities. Date: R?'m.; to fir, .?,? ?r• ?`-; "?i?`.T?]i{-t? 2109 JUL 3 r. 1Y\I CiL.** 3'13{ R,T# 9,2 R& q ? ROGER B. TABER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-5296 CIVIL ACTION LAW CINDY D. TABER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, August 06, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, September 08, 2009 at 9:30 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/ _Jaequeline M. Verney, Esq. 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 i FLED- "V 0-000, SEP 10. 2009 67 li ROGER B. TABER, Plaintiff V. CINDY D. TABER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-5296 : IN CUSTODY ORDER OF COURT CIVIL ACTION - LAW AND NOW, this ?/ " day of 2009, upon consideration of the attached Custody Conci on Report, it is ordered and directed as j follows: 1. Father, Roger B. Taber, shall have sole legal custody of Shannon L. Tali r, born August 27, 1996. Father shall provide all medical and educational information to' Mother, Cindy D. Taber, in a timely fashion. 2. Father shall have primary physical custody of the child. 3. Mother shall have periods of temporary custody upon agreement of the parties. 4. The parties shall have reasonable telephone calling w' privileges with the child while the child is in the custody of the other parent. The parties shall not prevent the parent who may be calling from talking to the child, or preventing the child from calling the other party, provided that the phone calls are not excessively frequent nor too long in duration that they disrupt the child's schedule. 5. Both parents shall refrain from making derogatory comments about the other parent in the presence of the child and to the extent possible shall prevent third parties from making such comments in the presence of the child. 6. Each party is encouraged to accommodate the reasonable requests of th other party for alterations of any agreed upon schedule, as the circumstances and the best interest of their child require. 7. Neither party shall use illegal drugs or permit the use of illegal drugs in their homes. Additionally neither party may consume alcoholic beverages in an excessive manner. 8. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, J cc•. L/Rex Bickley, Esquire, Counsel for Father mdy D. Taber, pro se yes m???c?, 911 ROGER B. TABER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-5296 CIVIL ACTION - LAW CINDY D. TABER, Defendant : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL' PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME Shannon L. Taber DATE OF BIRTH August 27, 1996 CURRENTLY IN CUSTODY OF Father 2. A Conciliation Conference was held in this matter on September 8, 2001 with the following in attendance: The Father, Roger B. Taber, with his counsel, L. Rex''. Bickley, Esquire. Mother, although notified of the Conciliation Conference, did not attend. 3. Father requested an Order in the form as attached. -!? Date Ja eline M. Verney, Esquir Custody Conciliator FILK-OFFICI OF THE PFI,,Tf f^? LITARY 2009 SEP I I Ali : 4 4 Pi NNf' lrANIA