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HomeMy WebLinkAbout05-1917 TARAN R. BRANDT, Plaintiff IN THE COURT OF COMMON PLE S CUMBERLAND COUNTY, PENNSYL ANIA vs. NO. oS; - /917 C"u~l MICHAEL T. VanBILLIARD, Defendant IN CUSTODY CIVIL ACTION - LAW COMPLAINT FOR CUSTODY NOW COMES Plaintiff, Taran R. Brandt, by her attorneys, Purcell, Krug & Haller, and files the following Custody Complaint: 1. The Plaintiff is Taran R. Brandt, an adult individu 1 who currently resides at 645 Mallard Way, Etters, York Count, Pennsylvania. 2. The Defendant is Michael T. VanBilliard, an adult individual who currently resides at 1312 F Mallard Road, Cam Hill, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following child: Name Present Residence Date of Bir h A e Aidan M. VanBilliard 645 Mallard Way Etters, PA 2/14/05-Age 2 Months 4. The child was born out of wedlock. 5. The child is are presently in the primary custody of Plaintiff, Taran R. Brandt, who currently resides at 645 Mall rd Way, Etters, Pennsylvania. ~ 6. During the past five (5) years, the children have es ided with the following persons at the following addresses: Name Address Dates Taran R. Brandt 1198 Twin Lakes Dr. 3/28/05 - resent Taran R. Brandt & 1312 Mallard Road Birth to 3 28/05 Michael T. VanBilliard Camp Hill, PA 7. The mother of the child is Plaintiff, Taran R. Bran t, who currently resides at 645 Mallard Way, Etters, Pennsylvania. She is single. 8. The father of the child is Defendant, Michael T. VanBilliard, who currently resides at 1312 F Mallard Road, Ca p Hill, Pennsylvania. He is single. 9. The relationship of Plaintiff to the child is that 0 Mother. Plaintiff currently resides with the following persons: Name Relationship Aidan M. VanBilliard Jason Skrinak Son Uncle 10. The relationship of Defendant to the children is that of Father. Defendant currently resides with the following persons: Name Relationship None known 2 11. Plaintiff has not participated as a party or witn ss, or in another capacity, in other litigation concerning the cus ody of the child in this or another court. 12. Plaintiff has no information of a custody proceedin concerning the child pending in a court of this Commonwealth or any other state. 13. Plaintiff does not know of a person not a party to he proceedings who has physical custody of the child or claims 0 have custody or visitation rights with respect to the child. 14. The best interests and permanent welfare of the chil ren will be served by granting the relief requested. WHEREFORE, Plaintiff requests the court to grant her custody of Aidan M. VanBilliard. / Date: ~'I']:O'1 ichole M. S al 719 North F on arrisburg, PA . D. No. 79866 717) 234-4178 Attorney for Plaintiff By 3 VERIFICATION I, Taran R. Brandt , Plaintiff in the within acti n, hereby verify that the facts contained in the foregoing Complaint for CllRtnrly. are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa c.S. Section 49D4, relating to unsworn falsification to authorities. ? V~--:'( ;y;iAM r~ Ii v~,~ V{j~ DATE: Ol(!Oi filS (0 if:). ~ --- AJ ~ -- --- \L r-' 0 = V( <:;:> ....., cf< ::2..,-, C> :r~ B -0 rnp --- -~ :;:0 -r;rn \ - :,~Jc;) ~ --() ~ ;;:- ',~ ~~{ -..() t -u !0 ~ .-'" ~ " <!? ..-1 ~ f.~.:~ ~:6 .;-- .< - TARAN R. BRANDT PJ.AINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA V. 05-1917 ClVIL ACTION LAW MICHAEL T. VANBlLLlARD IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, VVednesday,A~120,2005 " upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at DJ Manlove's, 1901 State St" Camp Hill, PA 1701t on Friday, May 13,2005 at It :00 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 mav provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Ahuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing, FOR THE COURT. By: Isl Melissa P. Greevy, Esq'--.:L__ Custody Conciliator The Court of Common Pleas of Cumberland County is required hy law to comply with the Americans with Disabilites Act of 1990. For infonnation about accessible facilities and reasonable accommodations available to disabled individuals having business before the COUl1, 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) 249-3 166 ~ 'irf' q ~ IJ,J,J . 1ft 1 /'0,,-.1 01" ll, Iirp f" '{ ~ tJ.! "" "'1 ,\ i';Y,:) l6"2. ~. " ,...1 :'l\,::\7 l:.\~ \ t., ,'1(',\1 ':,,jIJ'''' , ' ~ 'jo!th 50 Ie '/7 SOft!; ----------.' . ~ , TARAN R. BRANDT, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-1917 MICHAEL T. VanBILLlARD, Defendant IN CUSTODY CIVIL ACTION - LAW AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I, Nichole M. Staley O'Gorman, Esquire, Attorney for the Plaintiff, Taran R. Brandt, in the above action, hereby swear and affirm that on the 25th day of April, 2005, I sent, by certified mail, return receipt requested, restricted delivery, a Complaint in Custody to the Defendant, Michael 1. Van Billiard. The Return Receipt Card signed by the Defendant on May 9, 2005, is attached hereto as Exhibit "A". Sworn and subscribed to before me this I~ day ~2005 Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Michele L. Pntchard, Notary Public Deny Twp., Dauphin County I My Commission Expires Mar. 22. 2OIl8 . Member, Pennsylvania ASSOCiation Of Notanes . . Complete items 1, 2, and 3~ Also complete ~em 4 ~ Restricted Delivery Is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space pennits. 1. Article Addressed to: , MJcha.tl T Van 8', Jl lOrd J3/ ~ F Ncdlcvd f':<d. CCtmp ~I!t PA }701J 2. Article Number (Transfer from service Isbef) PS Form 3811, August 2001 3,\S,rvice Type Ji'J Certified Mail D Express Mail Cl Registered ~ Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) as 7001 1140 0000 9826 8391 eon-tIc Return Receipt 10259S-<J2-M-1540 EXHIBIT "A" ':"1 -" ,-;':' cJ; f'..) I' ' -; . Plaintiff RECEIVED MAY 2 7 2005~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-1917 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY TARAN R. BRANDT, v. MICHAEL T. VANBILLlARD, Defendant ORDER OF COURT AND NOW, this -t...,.. day of Yl-.14., , 2005, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Leaal Custody. The parties, Taran R. Brandt and Michael T. VanBilliard shall have shared legal custody of the minor child, Aidan M. VanBilliard, born February 14, 2005. 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. Pursuant to the terms of 23 Pa. C. S. 95309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Phvsical Custodv. Physical custody of the minor child shall be with Father on Thursdays, Fridays, and Saturdays from the time Mother drops him off in the morning until 8:00 p.m. each day. At such time when Father does not have custody, Mother shall have custody. In the event Father needs to change the custodial schedule due to his work arrangements, Father shall notify Mother by Saturday of the week prior to the change that he requests so that the parties are able to have time to discuss how they will rearrange the custodial schedule for the fOllOWing week. 3. The parties shall consult with each other in the selection of any babysitter or daycare provider outside of the immediate family. 4. Holidavs. The parties will share custodial time during the holidays by mutual agreement. 5. Vacation. The parties will share custody for purposes of vacation by mutual agreement. '-/;'.no 6 I ;9 WI IS} ill sauz :JO . NO, 05-1917 CIVIL TERM 6. Transportation. Transportation shall be provided by Mother during that period of time while Father does not have his driver's license. After Father regains his driver's license, which is anticipated to occur in approximately July 2006, the parties will share responsibility of transportation to custodial exchanges equally. 7. In the event that either party intends to be away from home with the child overnight, that parent will notify the other parent of the location at which they intend to be and a telephone number where they can reached. BY THE COURT: Ois!: Anole M. Staley O'Gorman, Esquire, 1719 North Front Street, Harrisburg, PA 17102 ~chael T. VanBilliard, 1312 Mailard Road, Camp Hili, PA 17011 4- J. RECEIVED MAY 27 2rJlJ( Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-1917 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY T ARAN R. BRANDT, v. MICHAEL T. VANBILLlARD, Defendant 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 DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Aidan M. VanBilliard February 14, 2005 Mother 2. A Custody Conciliation Conference was held on May 13, 2005 following Mother's filing of a Complaint for Custody on April 14, 2005. Present for the conference were: the Mother, Taran R. Brandt, and her counsel, Nichole M. Staley O'Gorman, Esquire; the Father, Michael T. VanBilliard, pro se. 3. parties reached an agreement in the form of an Order as attached. -( C) (L Melissa Peel Greevy, Esquir Custody Conciliator :250888 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION—LAW TARAN R. BRANDT, ) �.-C zz; �. Plaintiff ) NO: 05-1917 '10 c— _ vs. ) IN CUSTODY= MICHAEL.VANBILLIARD, z ` Defendant =c STIPULATION OF COUNSEL s4 The undersigned counsel, for and on behalf of their respective parties, hereby stipulate and agree that jurisdiction of the above captioned matter should be transferred to the Court of Common Pleas of Centre County, Pennsylvania. The parties acknowledge that the minor child has resided with Taran R. Brandt in Beech Creek, Centre County, Pennsylvania for the past five (5) years. The parties further agree that the Cumberland County matter should be transferred to the proceedings commenced in the Court of Common Pleas in Centre County, Pennsylvania under the caption Michael VanBilliard v. Taran R. Brandt indexed at Centre County Case No. 1182-2013 with any costs of transfer to be paid by Michael VanBilliard. �a to *YveWillson, Esquire Attorney for Taran R. Brandt Z� l3 Date Fra S. Miceli, Esquire Attorney for Michael VanBilliard IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION—LAW TARAN R. BRANDT, ) y Plaintiff ) NO: 05-1917 .tea MCo VS. ) IN CUSTODY:�En C= =-"' i. MICHAEL VANBILLIARD, ) g-<--M 4 Defendant ) � - -, ENTRY OF APPEARANCE I, Frank S. Miceli, Esquire, hereby enter my appearance on behalf of Defendant Michael VanBilliard in the above captioned matter. ROBERTS, MICELI & BOILEAU, LLP 2 q l3 BY: 91to�wxo�e/ Date 16ank S.Miceli, Esquire Attorney for Defendant 146 East Water Street Lock Haven, PA 17745 (570) 748-4059 ID #39830 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION—LAW c r-n i" ro n7t:7 TARAN R. BRANDT, Plaintiff ) NO: 05-1917 - vs. ) IN CUSTODY a) MICHAEL VANBILLIARD, Defendant ) ENTRY OF APPEARANCE I, Yvette L. Willson, Esquire, hereby enter my appearance on behalf of Plaintiff Taran R. Brandt in the above captioned matter. Centre County Women's Resource Center Civil Legal Representation Project r I L�� V Y tte L. Willson, Esquire ttorney for Plaintiff PO Box 59 122 N. Allegheny Street Bellefonte. PA 16823 (814) 355-0301 ywillson @ccwrc.org PA I.D. # 202691 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — LAW TARAN R. BRANDT, ) Plaintiff ) NO: 05-1917 vs. ) IN CUSTODY MICHAEL VANBILLIARD, Defendant ) ORDER AND NOW,this,4"V y of �,� y , 2013, upon stipulation of the parties though counsel, it is HEREBY ORDERED and DECREED that the above captioned matter be transferred to the Court of Common Pleas of Centre County, Pennsylvania in the matter of Michael VanBilliard v. Taran R. Brandt indexed to Centre County Civil Action No. 1182-2013. Any costs associated with the transfer of this matter shall be paid by Defendant. BY 1`- �) co Z 1"ec t7z-.-2 t LJL Z'7 08/13/2013 12:39 FAX 570 748 6790 ROBERTS, MICELI& BOILEAU Z004/004 c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA =' CIVIL ACTION—LAW TARAN R. BRANDT, ) Plaintiff ) NO: 05-1917 vs. ) IN CUSTODY ) MICHAEL VANBILLIARD, ) Defendant ) AMENDED STIPULATION OF COUNSEL The undersigned counsel, for and on behalf of their respective parties, hereby stipulate and agree that jurisdiction of the above captioned matter should be transferred to the Court of Common Pleas of Centre County, Pennsylvania, The parties acknowledge that the minor child has resided with Taran R. Brandt in Beech Creek, Centre County, Pennsylvania for the past five (5) years. The parties further agree that the Cumberland County matter should be transferred to the proceedings commenced in the Court of Common Pleas in Centre County, Pennsylvania under the caption Michael VanBilliard v. Taran R. Brandt indexed at Centre County Case No. 1181-2013 with any costs of transfer to be paid by Michael VanBilliard. Date - tte . Wilson, Esquire orney for Taran R. Brandt er)/(6//3 Date Fr. S. Miceli, Esquire Attorney for Michael VanBilliard Z ORIGINAL - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION—LAW TARAN R. BRANDT, ) Plaintiff ) NO: 05-1917 VS. ) IN CUSTODY MICHAEL VANBILLIARD, ) Defendant ) AMENDED ORDER AND NOW, this 7 day of , 2013, upon stipulation of the parties through counsel, it is HEREBY ORDERED and DECREED that the above captioned matter be transferred to the Court of Common Pleas of Centre County, Pennsylvania in the matter of Michael VanBilliard v. Taran R. Brandt indexed to Centre County Civil Action No. 1181-2013. Any costs associated with the transfer of this matter shall be paid by Defendant. BY THE T J. Lo'asex') �l �� e•�Cm mom(. •�rLd`�t�,�d�� `4 ` `