HomeMy WebLinkAbout01-2040 ~'~ti~ · t~ ~ corer o~ co~t~oN ~'t.s~s o~
' C~~~ CO~y, PE~S~v~
VS.
' C~ ACTION. LAW
~~ M. ~ . NO.~/.~o
C~ ~~
Defend~t ' ~ CUSTODY
CO~~~T FOR CUSTODY
1. Pl~tiffis Bfi~ L. H~, ~ adult indi~du~ c~ently resi~g at 1328 P~e Road, Lot
6, C~lisle, C~berl~d Co~~, Pe~sylv~a.
2. Defender is 2~e M. H~, ~ ad~t ~di~du~ ~ently resid~g at 592 L~e M~de
Drive, E~t Berli~ Cumberlmd Count, Pe~sylv~a.
3. The p~ies ~e the namr~ p~ents of one c~ld, ~ely, ~1~ ~i~ H~, bo~ 2~y
~0, =000.
4. The c~ld w~ bom out of w~lock.
Sin~ the c~ld's bi~ the c~ld h~ resid~ ~th the follo~ng per, ns at the
follo~g addresses:
NAME ADDRESS
DATE
Sane Hair Lake Meade Drive
Bailey ($ane's daughter) Hanover, PA Birth to
Sane and Barry McDermitt sept. 2000
($ane's parents)
Sane Hair
Brian Hair 1328 Pine Road
Bailey Carlisle, PA Sept. 2000-
Feb. 10, 2001
Jane Hair Lake Meade Drive
Bailey Feb. 10, 200 l-
Hanover, PA
Jane & Barry McDermitt Present
5. The relationship of the Plaintiff to the child is that of natural father. Plaintiff is married
and resides alone.
6. The relationship of the Defendant to the child is that of natural mother. Defendant is
married and resides with her parents, Jane and Barry McDermitt, her daughter, Bailey,
and the child at issue in these proceedings, Dylan.
7. Plaintiff has not participated as a party or witness, or in any other capacity in other
litigation, concerning custody of the child.
8. Plaintiff has no information of a custody proceeding concerning the child pending in
any Court of this Commonwealth.
9. The best interest and permanent welfare of the child will be served by granting Plaintiff
shared legal and physical custody ofthe chi/d for the following reasons:
(a) Sine the time of the parties' separation on February 14, 2001, Father has not seen
his son because Mother refuses to let him see him;
(b) Mother will agree to Father spending time with his son only at her parents' house
under their supervision, which is unacceptable to Father;
(c) Plaintiff is equally capable to provide for the child's moral, spiritual and physical
well-being;
(d) Plaintiff is capable of providing for and meeting the day-to-day needs of the child;
and
(e) Plaintiff desires to be an equal parent and remain involved in his son's life.
10. Plaintiff does not know of any person not a party to the proceedings who claims to
have custody or visitation rights with resp~t to the child.
WHEREFORE, Plaintiff rextuests your Honorabl~ Court to sche.,dul~ a custody
Conciliation conference followed by a heating, at which time he should be granted shared
physical custody of the child.
Respectfully submitted,
GRIFFIn & ASSOCIATES
Attorney for'Plaintiff
200 North Hanover Street
Carlisle, PA 17013
(717) :~4~-SSS 1
(800) 34'7-5552
_VERIFICATION
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section
4904, relating to unswom falsifications to authorities.
BRIAN L. HAIR, Plaintiff
BRIAN L. HAIR
' IN THE COURT OF COMMON PLEAS OF
PLAINTIFF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
JANE M. HAIR '
DEFENDANT ' 01-2040 CIVIL ACTION LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, Tuesday, April 17, 2001
_, upon consideration of thc attached Complaint,
it is hereby directed that parties and their respective counsel appear bct~rc Jacqueline M. Verney, Esq. _, thc conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, M.__~ay 02, 2001
at 3:30 p.m.
for a Pre-Hearing Custody Conference. At such conference, an effort will bc 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 thc conference. 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 ali 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/ ac ueline M. Verne Es .
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
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
BRIAN L. HAIR, · IN THE COURT OF COMMON PLEAS OF
Plaintiff · CUMBERLAND COUNTY, PENNSYLVANIA
v. · CIVIL ACTION- LAW
JANE M. HAIR, · NO. 2001-2040 CIVIL TERM
Defendant · IN CUSTODY
CERTIFICATE OF SERVICE
I, Marylou Matas, Esquire, hereby certify that I did, the 24th day of April, 2001, cause a
tree and attested copy of the Complaint for Custody and related Order of Court dated April 17,
2001, to be served upon the Defendant, Jane M. Hair, by serving her attorney of record, Mark T.
Silliker, Esquire, at 5922 Linglestown Road, Harrisburg, Pennsylvania, 17112, by first class
mail, postage pre-paid on April 24, 2001.
Marylou'MatfiS, Esquire
Attorney for Plaintiff
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717)243-5551
(800) 347-5552
BRIAN L. HAIR, · IN THE COURT OF COMMON PLEAS OF
Plaintiff ' CUMBERLAND COUNTY, PENNSYLVANIA
V. · NO. 2001-2040 CIVIL TERM
JANE M. HAIR, · CIVIL ACTION- LAW
Defendant .
· IN CUSTODY
ORDER OF COURT
AND NOW, this 8th day of January, 2003, being advised that a custody complaint
was filed by the within defendant at Docket No. 2001-2104 and the parties have
proceeded under that docket number, the Conciliator hereby relinquishes jurisdiction in
this matter.
FOR THE COURT,
·
~/acq~line M. Ve~e3), Esquire~Custo~y Conciliator