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Home My WebLink About05-1456 WILLIAM C. LOPER SR, and JODI L. LOPER Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. ()~ -I'-I!:b C;o~l ~~ : CIVIL ACTION - CUSTODY ELIANA F. MOORES Respondent COMPLAINT FOR CUSTODY 1. The Plaintiff is WILLIAM C. LOPER SR. and JODI LOPER, a citizen of Pennsylvania, residing at 338 Thorley Road, New Cumberland, Pennsylvania, 17070. 2. The Defendant is ELIANA MOORES, a citizen of Pennsylvania, residing at 427 Arch Street, Mechanicsburg, Pennsylvania, 17055. 3. Plaintiff seeks custody/visitation of the following children: Name Present Residence Age Briana Loper William Loper III 427 Arch Street Mechanicsburg, P A 17055 August 22, 1995 August 2, 1990 The child is presently in the custody of Respondent, EJiana Moores, who resides at 427 Arch Street, Mechanicsburg, Pennsylvania, 17055. During the past five years, the child has resided with the following persons and at the following addresses: From To 2000 - 2002 With Whom Eliana Lopez Address 4723 Tuscarora Street, Harrisburg, PAl 7110 2002 - 2003 Eliana Lopez 19 S. 4th Street, Newport PA,17074 2003 - Present Eliana Moores 427 Arch Street, Mechanicsburg, P A 17055 Briana Loper and William Loper III were born out of wedlock. The mother of the child is Respondent, Eliana Moores, currently residing at 427 Arch Street, Mechanicsburg, Pennsylvania, 17055. She is married. The father of the child is William C. Loper Jr. currently residing at 303 South Broadway Suite 200, Denver, Colorado. He is married. 4. The relationship of Petitioners, to the children is that of grandfather and step- grandmother. 5. The relationship of Respondent to the children is that of mother. 6. Petitioner 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. Petitioner has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Petitioner does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because he has demonstrated that it is the best interests of the minor children that he continues as primary caregiver. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. - WHEREFORE, Petitioner requests the court to grant partial custody/visitation of the children, Briana Loper and William Loper III. Respectfully submitted, DATE: 3\1'2>\o':j :'LLU~~ Sanford A. vsky, Esquire Attorney for Petitioner 1101 North Front Street Harrisburg, Pa 17102 ID # 15560 (717) 234-4583 DATE: ~ --' (f -oS ~ "~~~/L -- rn~ '.. " p~ JODI L ! OPER ,( V WILLIAM C. LOPER SR, and JODI L. LOPER Petitioner : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. ELIANA F. MOORES Respondent : CIVIL ACTION - CUSTODY VERIFICATION We, WILLIAM C. LOPER, SR. and JODI L. LOPER hereby verify that the information contained in the foregoing Complaint is true and correct to the best of our knowledge, information and belief. I also understand that false statements made herein are subject to the penalties of 18 Pa. C.S. S 4904, relating to sworn falsification to authorities. DATE:-l,-- 'i5- G .'-) !1j~Jt/~./ C (~h ~ WILLIAM C. LOPER, SR. fwm. \f\. ( l{~ \YU tv Kami M. Cramer 1101 North Front Street Harrisburg, P A 17102 (717) 234-4583 WILLIAM C. LOPER SR, and JODI L. LOPER Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. ELlANA F. MOORES Respondent : CIVIL ACTION - CUSTODY CERTIFICATE OF SERVICE AND NOW, this \~\.- day of March, 2005, I, Kami M. Cramer, for the Law Firm of Krevsky & Rosen, P.C., attorneys for Petitioner WILLIAM C. LOPER SR. and JODI LOPER, hereby certifY that I have this day served a copy of the Complaint via First Class U.S. Mail, Certified Mail on the following: ELIANA MOORES 427 ARCH STREET MECHANICSBURG, PA 17055 \J ""=\. ~ 1- -- ("~\ Tl - , - ~ VI I,; ."; - 'il ?j ..,.~ , ~ C':) - --Cl r .. ~ - ,.C") ......D !:: r.) . T- --. ~ WILLIAM C. LOPER, SR. AND JODI L. LOPER IN THE COURT OF COMMON PLEAS 0 PLAINTIFF CUMBERLAND COUNTY, PENNSYLV A IA v. 05-1456 CIVIL ACTION LA W ELIANA F. MOORES DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, March 23, 2005 , upon consideration of the attache Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, April 26, 2005 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the iss es in dispute: or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter nto a temporary order. All children age five or older may also be present at the conference. Failure to appear at the mference 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 Ab corders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearin FOR THE COURT. By: Isl Dawn S. Sunday, Esq. Custody Conciliator y The Court of Common Pleas of Cumberland County is required by law to comply with he Americans with Oisabilites Act of 1990. For information about accessible facilities and reasonable accomn dations available to disabled individuals having business before the court, please contact our office. All rrangements must be made at least 72 hOllrs prior to any hearing or business before the court. You must atten the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOl; 0 NOT HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFI ~ 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 4p-f;. r 'I t'O:' ~ '* -I- /I;rf 1- "f''''' "yK ~ ~ 't~. Jq;.('1 ,", ' >0 f/'" C 50/1(" r 5(7 -/J t" . [" "'? ,'\\f') S;}jL I' ';_ '\\~ 6.~ r\ _; CI .,', \\(l (.IV .- ,. .,~.:;\ ::,J . >l\);.u:-,.,\;-::~<:(~~~- ht.P.... .\,-.~;':J' \...(~"") ,\.. :.\-y,).-'." ..------ ------.-- WILLIAM C. LOPER, SR. AND JODI L. LOPER RECEIVED MAY 18 2005 (f1., F IN THE COURT OF COMMON PLEAS OF I Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 05-1456 CIVIL ACTION LAW ELIANA F. MOORES Defendant [N CUSTODY ORDER OF COURT AND NOW, this / 3 ~ day of IYI ~ ' 2005, consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: upon I. The Mother shall have primary physical and legal custody of the Children. 2. The plaintiffs shall have partial physical custody of the Children for one weekend per month from Friday through Sunday, with the specific dates and times to be arranged by agreement between the parties. In addition, the plaintiffs shall have custody of the Children on Christmas Eve from I :00 p.m. until 5:00 p.m. 3. The plaintiffs shall ensure that the Children have no contact of any nature with their biological father, William C. Loper, Jr., during their periods of custody unless otherwise agreed between the parties. J. cc:..sanford A. Krevsky, Esquire - Counsel for Paternal Grandfather ,Jeanne B. Costopoulos, Esquire - Counsel for Mother 0-:'cP 0')' r;}..J r: : (~: " (' ') r ~ ' l U'.' it- j , , WILLIAM C. LOPER, SR. AND JODI L. LOPER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 05-1456 CIVIL ACTION LA W ELIANA F. MOORES Defendant IN CUSTODY Prior Judge: Kevin A. Hess CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: I. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Briana Loper William C. Loper, III August 22, 1995 August 2, 1990 Mother Mother 2. A conciliation conference was held on May II, 2005 with the following individuals in attendance: The paternal Grandfather, William C. Loper, Sr., and his wife, Jodi L. Loper, with their counsel, Sanford A. Krevsky, Esquire, and the Mother, Eliana F. Moores, with her husband and her counsel, Jeanne B. Costopoulos, Esquire. 3. The parties agreed to entry of an Order in the form as attached. 4. The Mother has filed a Petition for Termination of the Father's parental rights which is currently scheduled for hearing before Judge Hess on June 29, 2005. For that reason, Judge Hess has been indicated as the prior Judge on the attached proposed Order although there have been no prior custody proceedings in this matter. m"o I u.( d<x,S' Date Da{d~ Custody Conciliator