The URL can be used to link to this page

Home My WebLink About09-7813 JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff KELLY M. MYERS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND, PENNSYLVANIA V No d 9- `I S'i? eiP T SHAWN MYERS, CIVIL ACTION - LAW Defendant CUSTODY COMPLAINT IN CUSTODY AND NOW, comes Plaintiff, Kelly M. Myers, by and through her attorney, Jeann6 B. Costopoulos, Esquire, and avers the following in support of this Complaint in Custody: 1. Plaintiff, Kelly M. Myers, is an adult individual currently residing at 615 Somerset Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant, Shawn Myers, is an adult individual currently residing at 233 E. Locust Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. There is one child born from the marriage of Plaintiff and Defendant, namely Ryan Lyle Myers, born January 30, 2009. 4. The parties are married. The child was not born out of wedlock. The parties separated from each other on September 1, 2009. 5. The child is currently in the custody of Plaintiff, Kelly M. Myers, residing at 615 Somerset Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 6. Since birth, the child resided with the following people at the following addresses: 1 Residents Address Plaintiff 615 Somerset Drive Laurel Shaffer (Plaintiff's mom) Mechanicsburg, PA 17055 Twila Perry (Plaintiff's grandmother) Michael Shaffer (Plaintiff's brother) Plaintiff 615 Somerset Drive Defendant Mechanicsburg, PA 17055 Laurel Shaffer (Plaintiff s mom) Twila Perry (Plaintiff s grandmother) Michael Shaffer (Plaintiff s brother) Plaintiff 615 Somerset Drive Laurel Shaffer (Plaintiffs mom) Mechanicsburg, PA 17055 Twila Perry (Plaintiff s grandmother) Michael Shaffer (Plaintiff s brother) Plaintiff Laurel Shaffer (Plaintiff s mom) Twila Perry (Plaintiffs grandmother) Michael Shaffer (Plaintiff s brother) Plaintiff 3205 Brookfield Road Defendant Harrisburg, PA 17109 Laurel Shaffer (Plaintiffs mom) Michael Shaffer (Plaintiffs brother) Dates September 1, 2009 to prsent August 1, 2009 to September 1, 2009 June 26, 2009 to August 1, 2009 May 26, 2009 to June 26, 2009 January 30, 2009 to May 26, 2009 7. Plaintiff is the natural mother of the child and she currently resides with her mother, Laurel Shaffer, her grandmother, Twila Perry, her brother, Michael Shaffer, and the subject child at 615 Somerset Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 8. Defendant is the natural father of the child and he currently resides with his friend Richie and Richie's girlfriend (more specific names are unknown by Plaintiff) at 233 E. Locust 2803 Oakwood Drive Harrisburg, PA 17110 2 Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 9. Plaintiff has not participated as a party or a witness, or in any other capacity in other litigation concerning the custody of the child in this or any other Court. 10. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 11. 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. 12. The best interest and permanent welfare of the child will be served by granting Plaintiff primary physical and shared legal custody of the parties' son. 13. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff, Kelly M. Myers, respectfully requests this Honorable Court to grant her primary physical and shared legal custody of the parties' son. Respectfully Submitted: By: E B. COSTOPOULOS, IRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 j/ Attorney for Plaintiff Date: 3 VERIFICATION I, Kelly M. Myers, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. Date: 6q Y?&' R. n I a .1 Kelly M. 101 ers J F LEC CE TPT Zv?J9 c?TV 10 l i'1 12: G, .. ..? x.,.41'. .? $1105. 5o po Alit (',?.? 5319 p. a3531o KELLY M. MYERS IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. SHAWN MYERS DEFENDANT 2009-7813 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, November 17, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Monday, December 21, 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/ ohn . Mangan, r. 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 CUMP ?- `;`tL?t A!w t?l? JOA