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Home My WebLink About04-5179PAMELA SUE LEBO, PLAINTIFF RODNEY L. GARNER, DEFENDANT 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04 .,-ffl7q C, IVIL TERM IN CUSTODY COMPLAINT FOR CUSTODY The plaintiff is Pamela Sue Lebo, residing at 154 Fairview Drive, Carlisle, Cumberland County, Pennsylvania 17013. The defendant is Rodney L. Garner, residing at 154 Faiirview Drive, Carlisle, Cumberland County, Pennsylvania 17013 (but will be leaving this residence soon). Plaintiff seeks custody of the following child: Name Present Residence DOB Age Ryan L. Garner 154 Fairview Drive 06/04/97 7 yrs 4 months Carlisle, PA 17013 The child was bom out of wedlock The child is presently in the custody of both parents at 154 Fairview Drive, Carlisle, Cumberland County, Pennsylvania 17013. During the past five years, the child has resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Pamela Sue Lebo & 154 Fairview Drive Birth to Present Rodney L. Garner Carlisle, PA 17103 The mother of the child is Pamela Sue Lebo, residing at 154 Fairview Drive, Carlisle, Cumberland County, Pennsylvania 17013. She is unmarried. The father of the child is Rodney L. Garner, residing aI 154 Fairview Drive, Carlisle, Cumberland County, Pennsylvania 17013 (but will be leaving this residence soon). He is unmarried. The relationship of plaintiff to the child is that of Moth er. The plaintiff currently resides with the following persons. Name Ryan L. Garner Rodney L. Garner Relationship Son Father (will be leaving residence soon) The relationship of defendant to the child is that of Father. The defendant currently resides with the following persons. Name Relationship Ryan L. Garner Son Pamela Sue Lebo Mother Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the ]proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. The best interest and permanent welfare of the child will be served by granting the relief request because: A Court Order of custody and structured visitation is desired so that the Plaintiff and the child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion. Plaintiff desires to maintain the family household which has been established, and the continued stability of the household is in the best interest of the child. A Court Ordered determination of custody is required to avoid continuing conflict between the parties regarding responsibility for custody. Plaintiff continues to maintain the same family household for the child that has been maintained since June 4, 1994. Plaintiff and Defendant are separating and the Defendant will be moving from the family residence to an unknown address in the near future. WHEREFORE, Plaintiff requests this Court grant Plaintiff primary physical custody subject to structured partial physical custody for Defendant. Respectfully submitted, Date: 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 87663 Attorney for Plaintiff VERIFICATION I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unswom falsification to authorities. .~-~ Pamela Su~ Lel~o, Plaintiff PAMELA SUE LEBO PLAINTIFF V. RODNEY L. GARNER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-5179 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, October 20, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear heft>re Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, November 04, 2004 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. 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. 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 horn's I~rior to scheduled hearing. FORTHECOURT, By: /s/ .[acqueliae M. Veraeg, Esq. Custody Conciliator mhc 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 befbre 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 PAMELA SUE LEBO, Plaintiff V. RODNEY L. GARNER, Defendant NOV : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2004-5179 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT .L AND NOW, this Z[5[ day of ~1 o t/ ,2004, upon consideration of the attached Custody Conciliation Rei~ort, it is ordered and directed as follows: 1. The Mother, Pamela Sue Lebo, and the Father, Rodney L. Garner, shall have shared legal custody ofRyan L. Garner, bom June 4, 1997. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. Mother shall have primary physical custody of the Child. 3. Father shall have periods of partial physical custody as follows: A. Alternating weekends, from Friday to Smaday at times agreed by the parties. B. Every Monday evening at times agreed by the parties. C. Such other times as the parties agree. 4. Mother shall have physical custody of the Child on Mother's Day. Father shall have physical custody of the Child on Father's Day at times agreed by the parties. 5. The parties shall share holidays as agreed. 6. Transportation shall be shared as agreed. 7. This Order is entered pursuant to an agreement of the parties at 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. N/tNYAq,~SNN]d BY THE COURT, Mark F Ba le Es rove Counsel forMot~er/ cc: Paul BradftoYrd~rr, ~squ~re, Counsel for Father PAMELA SUE LEBO, Plaintiff V. RODNEY L. GARNER, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 2004-5179 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY 2004~ 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 Ryan L. Gamer DATE OF BIRTH June 4, 1997 CURRENTLY IN CUSTODY OF Mother 2. A Conciliation Conference was held in this matter on November 12, 2004, with the following individuals in attendance: The Mother, Pamela Sue Lebo, with her counsel, Mark F. Bayley, Esquire and Father, Rodney L. Garner, with his counsel, Paul Bradford Orr, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. j l - t ;z. -o q Date Custody Conciliator