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HomeMy WebLinkAbout01-0654STEVEN A. TRAYER, Plaintiff TAMMY L. TRAYER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO, o J- 65~c/ IN CUSTODY CIVIL TERM COMPLAINT FOR CUSTODY Plaintiff is Steven A. Trayer, an adult individual currently residing at 87 East Yellow Breeches, Carlisle, Cumberland County, Pennsylvania. Defendant is Tammy L. Trayer, an adult individual currently residing at 141 Trayer Lane, Carlisle, Cumberland County, Pennsylvania. The parties are the natural parents of two (2) children, namely, Megan Marie Trayer, bom May 9, 1989, and Bethany Ann Trayer, bom July 7, 1991. The children were not bom out of wedlock. For the past five (5) years, or since the children's birth, the children have resided with the following persons at the following addresses for the following periods of time: NAME Steven A. Trayer Tammy L. Trayer Tammy L. Trayer ADDRESS 141 Trayer Lane Carlisle, PA 17013 141 Trayer Lane Carlisle, PA 17013 DATES 1993 to January20,2001 January20,2001,to Present The natural mother of the children is Tammy L. Trayer who resides as aforesaid. She is married. The natural father of the children is Steven A. Trayer who resides as aforesaid. He is married. The relationship of the Plaintiff to the children is that of natural father. The Plaintiff currently resides with his parents. The relationship of the Defendant to the children is that of natural mother. Defendant currently resides with the children at issue. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning custody of the children. Plaintiff has no information of any custody proceedings concerning the children pending in any Court of this Commonwealth. It is in the best interest and permanent welfare of the children to grant the relief requested because: a) Plaintiff is better capable to provide for the children's moral, spiritual, and physical well-being; b) Defendant recently has demonstrated emotional instability culminating in verbal abuse of the parties youngest daughter; 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 Custody Conciliation Conference followed by a hearing at which time he should be granted primary physical custody of the children. Respectfully submitted, Mar~ot~jlatas, Esquire Attorney'for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. STEVEN A. TRAYER, Plaintiff STEVEN A. TRAYER PLAINTIFF V. TAMMY L. TRAX/ER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-654 CIVIL ACTION LAW IN CUSTODY ORDER OFCOURT AND NOW, this 5th day of February , 2001, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear beforeJacqueline M. Verney, Esq. , the conciliat at 4th Floor, Cumberland County Courthouse, Carlisle on the 7th day of March ,2001, at 8:30 a.m. 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. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THECOURT, By: /s/ ]acqueline M. Verney. Esqt,.~ 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 F1ND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 STEVEN A. TRAYER, Plaintiff V. TAMMY L. TRAYER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA : : NO. 2001-654 CIVIL ACTION - LAW : : IN CUSTODY : ORDER OF COURT AND NOW, this ay of Z) consideration of the attached Custody Conciliation Report, it follows: ,2001, upon is ordered and directed as 1. The Father, Steven a. Trayer, and the Mother, Tammy L. Trayer, shall have shared legal custody of Megan Marie Trayer, born May 8, 1989 and Bethany Ann Trayer, born July 7, 1992. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. 2. Pending a resolution of the occupancy of the marital home and either party requesting to return to the Conciliator within sixty days of March 14, 2001, the parties agree to the following interim shared physical custody schedule of the children: A. Father shall have physical custody of the children on alternating weekends from Friday at 5:00 p.m. to Sunday at 9:00 p.m. B. Father shall have physical custody of the children every Tuesday and Thursday from 5:00 p.m. to 9:00 p.m. C. Mother shall have physical custody of the children all other times. otherwise. Father shall be responsible for all transportation, unless the parties agree 4. 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. cc: Marylou Matas, Esquire - Counsel for Father Carol J. Lindsay, Esquire - Counsel for Mother BY THE COURT, STEVEN A. TRAYER, Plaintiff V. TAMMY L. TRAYER, Defendant ] 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA 2001-654 CIVIL ACTION - LAW 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 Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY 1N CUSTODY OF Megan Marie Trayer Bethany Ann Trayer May 8, 1989 Mother July 7, 1992 Mother 2. A Conciliation Conference was held in this matter on March 14, 2001. Father, Steven A. Trayer, was present with counsel, Marylou Matas, Esquire, and Mother, Tammy L. Trayer, was present with counsel, Carol J. Lindsay, Esquire. 3. The parties agreed to an interim Order in the form attached pending a resolution of the occupancy of the marital home by Father. The Conciliator shall retain jurisdiction for sixty days. If neither party contacts the conciliator within 60 days from today's date, the Conciliator shall relinquish jurisdiction. Date Custody Conciliator