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Home My WebLink About05-4718 MICHAEL L. EPPERSON and CAROL A. EPPERSON, and ALBERT EPPERSON, Plaintiffs v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO.O.s-</1/f'CIVIL TERM CARMEN LANCASTER, Defendant : IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff Michael L. Epperson, natural father, whose legal address is 26 Cobblestone Drive, Carlisle, Pennsylvania. 2. Plaintiffs Carol A. Epperson and Albert Epperson, paternal grandparents, reside at 26 Cobblestone Drive, Carlisle, Pennsylvania. 2. Defendant Carmen Lancaster, natural mother, resides at 1003 South Center Street, Grove City, Pennslvania. 3. Plaintiffs seek clarification of custody of the following child: Name Present Residence Aae Alexis V. Epperson with Paternal Granolparents 7 The child was born out of wedlock. The child is presently in the custody of paternal grandparents. 4. Father currently resides with the following persons: Name Relationship Melissa Epperson Wife 5. Mother currently resides with the following persons: Name Relationship Not known Her stepfather 6. Plaintiffs have not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another COLlrt. Plaintiffs have no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiffs do not know of a person not a party to the procee'dings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because Plaintiffs need assurance that paternal grandA'lElt"'W will have the authority to meet the child's health, welfare, and educational needs. P"'" Wherefore, Plaintiffs request the court to grant legal clJstody of the child to Father, Mother and Paternal Grandparents and that Paternal Grandparents have primary physical custody and Father and Mother have liberal periods of partial custody while Father is away on military service. ~ ! 21)a~~~ \1 i I'd, Esq uife 37 South Ha elr Carlisle, PA 1701:3 Attorney for Plaintiff I verify that to best of my knowledge and belief, the stallements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.~4904 relating to unsworn falsification to authorities. I verify that to best of my knowledge and belief, 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.C.S.~4904 relating to unsworn falsification t,o authorities. ca~~on,~ainti~~ I verify that to best of my knowledge and belief, 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.C.S.~4904 relating to unsworn falsification to authorities. Api ~- Albert Epperson, Plaintiff C) "-.) l~ 0 ,-. <::::.c, "" -q ~ C,> 5! f'''-l ~ -U r/l:!J ~ r- j - ~;~tg f'\) JC) ..... ..... .:to.::. r_~'-: "- "" .. -)(')' ~ ...... Co '.~j l'fJ 0<1 v..... ..... :;:1 ~ ...... c.- "0 ;or-iJ ~ d Cf) ." --t> MICHAEL L. EPPERSON and CAROL A. EPPERSON, and ALBERT EPPERSON, Plaintiffs v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. OJ- '1711 CIVIL TERM CARMEN LANCASTER, Defendant : IN CUSTODY STIPULATION FOR CUSTODY 'C)/~ ~ STIPULATION made this - day of 2005, between Carmen Lancaster, hereinafter referred to as Mother, and Michael L. Epperso ,hereinafter referred to as Father and Carol A. and Albert Epperson, hereinafter referred to as Paternal Grandparents. WHEREAS, the above-named Mother and Father had born to them the fOllowing child on the fOllowing date: NAME Alexis V. Epperson BIRTH DATE August 6, 1998 AND WHEREAS, the above-named Mother and Father desire to enter into a Stipulation as to the custody of the above-said child and to the partial custody rights of the non-custodial parents while Father is away on military service: NOW, THEREFORE, in order to effectuate the above purpose, the above-named Mother, Father and Paternal Grandparents hereby stipulate that: 1. Mother, Father and Paternal Grandparents shall share legal custody of the child. 2. Paternal Grand shall have primary physical custody of the child. 3. Mother and Father shall have liberal periods of partial custody as agreed upon by the parties. TO THIS PURPOSE, The parties hereto intend to be legally bound by the terms of this Stipulation and desire to have the Stipulation entered as an Order of Court. <t rr- , IJ;i ~ ~ . armen Lancaster, Moth r ~ / Mx{~~ c~fd;ers~<Iteft:t:;:o~ Witness: CI~ Ii, Lindsay Dare Baird, Esq. Aid-- ~(Ur Albert Epperson, aternal Grandfather p (- rv '-J - r--., /5; <::'J-l c~., t) ,~ o -'1 MICHAEL L. EPPERSON AND CAROL A. EPPERSON AND ALBERT EPPERSON IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 05-4718 CIVIL ACTION LA W CARMEN LANCASTER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, September 15, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, October 13, 2005 at 8:30/1, rY\, 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 the conciliator 48 hours prior to scheduled hearing, FOR THE COURT. By: Isl facqueline M. Verney. Esq. ~ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with DisabiIites 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. Y Oll mllst 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 17013 Telephone (717) 249-3166 .~~~ -- ~4l ~>o"J/b *$ ~ ~~ 3cJ./}I/! ~ fv ~ ~~? n 5t?'9/6 YINl:/A1ASNN3d ,UNncO n~,~'..'l'l~8;i'lna at :01 WI 91 d3S snnz AtJV1ONOHlOl.:ld 3H1 :10 30I:J.:lO-Cl31l.:l MICHAEL L EPPERSON and CAROL A. EPPERSON, and ALBERT EPPERSON, Plaintiffs v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA J : 5RECEIVED SEP 15 200~ : NO. 05-4718 CIVIL TERM CARMEN LANCASTER, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 'Jo~ day of ~ 2005, upon consideration of the attached custody stipulation with respect to the child, Alexis V. Epperson, born August 6, 1998, the terms of the stipulation are entered as an order of court. J. cc: ~ay Dare Baird, Esquire . ~~armen Lancaster ~ . ,(t; "- ?\C"(r o V!N1!\lJ,St,jj{jd I "I'n'~"\ n -,,-' '''''''In'' !\..jJ",j '"I.; ,_:., \,' '}~,=-!-,";/". ....1 Sf: : II WV OZ d3S SOOl .' Ai:fv'lONOHlOod 3Hl. ::10 30I::l.:\O-G3lI:l RECE!'fEl ~=? 2 ~ :005 ~ MICHAEL L. EPPERSON and CAROL : IN THE COURT OF COMMON PLEAS OF A. EPPERSON and ALBERT EPPERSON: CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. : NO. 2005-4718 CIVIL TERM CARMEN LANCSTER, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 27th day of September, 2005, the Conciliator being notified that the parties have reached an agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, L.-. ine M. Verney, Esquire, Custod)' onciliator ~\ V~-Z< ("";, -,.- "::~;;: ~ 'i}. q, ';..->> ~ \~;. /-'':1 ::L q" ~\ ~ '-;:' .p ,,\~ -00 -'}2., ~) '-.-:-:_\v,.. .(~~\ ~t? ~ .....,:1 -::? u' " .- .p