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Home My WebLink About05-3354 Megan Oliphant, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 33s''f No. 05 - CIVIL TERM T aisean Harris, Defendant IN CUSTODY ORDER OF COURT AND NOW, ,2004, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before . the conciliator, at day of ,2004, at o'clock, on the _.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 defme 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 THE COURT: By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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 LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER 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 North Bedford Street Carlisle, P A 17013 717-249-3166 VI. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA No. 05 - j35c~ TERM Megan Oliphant, Plaintiff Taisean HarIis, Defendant IN CUSTODY COMPLAINT FOR CUSTODY I. The plaintiff is Megan Oliphant, who is residing at 12 Westminster Court, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is Taisean Harris, who is residing at 3 Coral Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks custody of the following child: Name Akira M. Harris Present Residence 3 Coral Drive Carlisle, PA 17013 DOB 01/13/05 Age 5 months The child was not born out of wedlock The child is presently in the custody of Taisean Harris, who is residing at, 3 Corral 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 Taisean HarIis & Megan Oliphant 3308 Enola Road Carlisle, P A 17103 birth to 03116/05 Taisean HarIis 3 Coral Drive Carlisle, PA 17013 03/16/05 to present 4. The mother of the child is Megan Oliphant, currently residing at 12 Westminster Court, Carlisle, Cumberland County, Pennsylvania 17013. She is unmarIied. The father of the child is T aisean Harris, currently residing at 3 Coral Drive, Carlisle, Pennsylvania 17013. He is unmarried. 5. The relationship of plaintiff to the child is that of mother. The plaintiff currently resides with the following persons. Name Colleen Kemp Harry Kemp Melissa Oliphant Relationship Mother Step-father sister 6. The relationship of defendant to the child is that of father. The defendant currently resides with the following persons. Name Ashley Roberts Kaden Roberts Relationship girlfriend son 7. 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. 8. The best interest and permanent welfare of the child will be served by granting the relief request because: Plaintiff has undertaken and performed the primary parental responsibilities for the child, until June 21,2005. Plaintiff is best able to provide the care and nurture which the child needs for healthy development. A Court Order of primary physical custody to the Plaintiff, subject to structured partial custody to the Defendant, 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 and support. WHEREFORE, Plaintiff requests this Court grant Plaintiff primary physical custody subject to structured partial custody by the Defendant. Respectfully submitted, Date: (p_ 30-0<)- J:1;dsql ~tt 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ill # 89028 Attorney for Plaintiff Megan Oliphant, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA x. No. 05 - CIVIL TERM T aisean Harris, Defendant IN CUSTODY VERIFICA nON 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 unsworn falsification to authorities. ~~~ Me Oliphant, Plai Iff () c ~2!P <~'{'. ~IJ " i-;: }.,.; ~~,~'j\ Pc ~ o en "> ~ "" <- c- =Ii: w o " :J:: J:- ~ :r rn .:0 r- ~~ ,~:d ;;;"0 Om --1 {; -< Megan Oliphant, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IX. No. 05 - CIVIL TERM T aisean Harris, Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Michael 1. Whare, Esquire, attorney for Plaintiff, do hereby certiJy that I this day served a copy of the Custody Complaint upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Taisean Harris 3 Corral Drive Carlisle, PA 17013 Date: r; - 5<>- os fI/l~ IfL~ Michael 1. Whare, E~ire / "- 155 S. Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 89028 Attorney for Plaintiff Q &;; ~ sir: ~~,. ~ ~~ ~~ (\ --- ~ Iv "'Q\ '\l ~ ~ i'" L.I ""'~ ......... .......... v\ o '" g: 0 <on "TI e :;:l z ffi F1 ~ :g~ o -0 ~~. == C-" ::d ;;:<0 .r:- (jrn c.; ~ 0'" ~ ~\ MEGAN OLIPHANT PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. 05-3354 CIVIL ACTION LAW T AISEAN HARRIS DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, July 07, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, AU2ust 18, 2005 , the conciliator, at 9:30 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 mav 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 Abuse orders, Special Relief orders, and Custody orders to tbe conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ Hubert X Gilrov, Esq. Custody Conciliator w The Court of Common Pleas of Cumberland County is required by 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 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 HA VE 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 170 J 3 Telephone (717) 249-3166 ) ~ ~f1<' fp ~ ~Tl'.lI '~I ~ *'7 ~ ~J1, ~ C7~ ~-.P!J ViNv'/il,~SNNjd I I "n'...",....l (l~,lt../~~!..j::::::i,'..tn.1""\ ^-U'l ,....,1.,; -, ',_'.__,' ,.\1...., 8i :8 Wd L - lnr SOOZ AtlV.LONOHlOCld 3H..L :lO 3JI:!~Q-Cl31!:l S'cl- 5'cl Scl -I.. .t- .t... MEGAN OLIPHANT, Plaintiff v T AISEAN HARRIS, Defendant AND NOW, this RECEIVED AUG 22 100y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 05-3354 CIVIL TERM IN CUSTODY CONCILIATION ORDER l'y ( q day of August, 2005, the Conciliator being advised the parties have reached an agreement, the Conciliator relinquishes jurisdiction. 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