HomeMy WebLinkAbout05-6703
,
STEVIE KRAMER,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, P A
NO. bs- (,,70 3 G;",~ f~
MATTHEW WEARY,
Defendant
CIVIL ACTION -LAW
IN CUSTODY
COMPUUNTFORCUSTODY
1. The Plaintiff is Stevie Kramer, who currenrly resides at 28 Maple Avenue, Camp Hill,
Cumberland County, Pennsylvania 17011.
2. The Defendant is Marthew Weary, who currenrly resides at 71 Hope Road, New
Bloomfield, Perry County, Pennsylvania.
3. The Plaintiff seeks custody of the following children:
Name
Address
DOB
Madison Weary
28 Maple Avenue
Camp Hill, PA 17011
02/13/2004
4. The child was born out of wedlock.
5. The child is presenrly in the primary custody of Stevie Kramer, 28 Maple A venue,
Camp Hill, Cumberland County, Pennsylvania.
6. During the child's lifetime, she has resided with the following persons and at the
following addresses:
Name
Address
Date
Stevie Kramer and Shannon
Devine
28 Maple Avenue,
Camp Hill, P A
Birth to June 2004
Stevie ](ramer
Weary
and Matthew 24 South Apple Street, June 2004 to May 2005
New Bloomfield, PA
Stevie l(ramer and Richard Sutch 164 North 4'h Street, May 2005 to September 2005
Newport, PA
Stevie ](ramer and
Devine
Shannon 28 Maple
Camp Hill, PA
Avenue, September 2005 to Present
7. The mother of the child is Stevie Kramer, who currendy resides at 28 Maple Avenue,
Camp Hill, Cumberland County, Pennsylvania. Mother currendy resides with her mother,
Shannon Devine, her step-father, Dennis Devine, and her son, Dylan Kramer, as well as the
subject minor child.
8. The father of the child is Matthew Weary, who currendy resides at 71 Hope Road,
New Bloomfield, Perry County, Pennsylvania. Father currendy resides with his parents,
Shari and Merle Weary.
9. The mother of the child is currendy married, but separated, from Rory ](ramer.
10. The father of the child is not currendy married.
11. The relationship of Plaintiff to the children is that of Mothet.
12. The relationship of Defendant to the children is that of Father.
13. The 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 any other court.
14. The Plaintiff has no information of a custody proceeding concerrung the child
pending in a court of this Commonwealth.
15. The Plaintiff does not know of a person not a party to the proceedings who has
physical custody of the child or claims to have custody or visitation rights with respect to the
child.
16. The best interest and permanent welfare of the child will be served by granting the
relief requested for reasons including the following:
a. The Mother has been the primary caregiver of the minor child smce her
birth. She has:
1. Planned and prepared meals;
11. Bathed, groomed and dressed the child;
111. Purchased, cleaned and cared for the child's clothing;
IV. Arranged medical care, including trips to physicians;
v. Arranged alternative daycare;
vI. Put the child to bed nighrly, attended the child in the middle of the
night, and awakened the child in the morning.
b. The child has a psychological bond with the Mother.
c. Mother is able to provide a stable environment for the child.
d. Father has retained custody of the child since Tuesday, December 13, 2005,
and has refused to allow Mother any contact with the child.
17. Each parent whose parental rights to the children have not been terminated has been
named as parties to this action.
WHEREFORE, the Plaintiff requests that This Honorable Court grant primary physical
custody of the child to the Plaintiff/Mother.
Respectfully submitted,
MOM & KUTULAKlS, L.L.P.
nUE
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i~Llkl [i)' ~I~ ( ")~fL
Kara W. Haggerty
ID No. 86914
36 South Hanover Street
Carlisle, P A 17013
(717) 249-0900
Attorney for Plaintiff
-I
VERIFICATION
I, Stevie Kramer, verify that the statements made in this Custody Complaint are true and
correct to the best of my knowledge, information, and belief. I understand that false statements
herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to
authorities.
Date:
/ :2../9 7/tJ5-
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Stevie Kramer
CERTIFICATE OF SERVICE
AND NOW, this 22nd day of December, 2005, I, Kara W. Haggerty, Esquire, of Abom &
Kutulakis, L.L.I', hereby certify that I did serve a true and correct copy of the foregoing Custody
Complaint, upon the Defendant by depositing, or causing to be deposited, same in the United States
Mail, First -class mail, postage prepaid addressed to the following:
Matthew Wea.ry
71 Hope Road
New Bloomfield, PA 17068
Respectfully submitted,
ABOM & KUTULAKIS, L.L.P.
~I(gJi\ I~(L~
Kara W. Haggerty
ID No. 86914
36 South Hanover Street
Carlisle,I'A 17013
(717) 249-0900
Attorney.for Plaintiff'
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STEVIE KRAMER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
v.
NO. D5 -1.c103 [.,'vI11c..rm
MATfHEWWEARY,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
TO THE HONORABLE JUDGE OF SAID COURT:
PETITION FOR SPECIAL RELIEF
AND NOW, this 22ND day of December, 2005, comes the Petitioner, Stevie
Kramer, by and through her attorney, Kara W. Haggerty, Esquire, of ABOM &
KUTULAKlS, L.L.P., and respectfully petitions This Honorable Court to grant
Petitioner special relief, and in support thereof avers the following:
1. The petition of Stevie Ivamer, Mother, respectfully represents that on
December 22, 2005, simultaneously with this Petition, Mother has filed a
Custody Complaint requesting primary physical custody ...ith her and for
Father to be granted partial physical custody. (Copy attached as Exhibit "A").
2. Prior to the within Petition and Custody Complaint being f1!ed, Mother and
Father had shared custody of the minor child, Madison Weary, born February
13,2004, by agreement with Mother exercising primary physical custody and
Father enjoying partial physical custody at such times as the parties could agree.
3
3. On Tuesday, December 13, 2005, Father obtained custody of the child with
the understanding that he would return her to the babysitter on Thursday,
December 15, 2005, in the morning.
4. On Thursday, December 15, 2005, Father refused to return the child, and
Father's parents prohibited Mother from entering their property to obtain
custody of the child.
5. It was previously agreed that Father would retain custody of the minor child
on Friday, December 16, 2005, through Sunday, December 18, 2005.
6. Father refused to return the child to Mother on Sunday, December 18,
2005.
7. On Monday, December 19, 2005, Mother drove to Father's house to pick
up the child and Father and his parents refused to allow Mother to take the
child.
8. On Tuesday, December 20, 2005, Father initially advised Mother that she
could have custody of the child and later changed his mind and refused to
return the child to Mother.
9. On Wednesday, December 21, 2005, Father advised Mother that he would
not return the child to her unless and until he was court-ordered to do so.
4
10. Paternal Grandparents refuse to allow Father to have any contact at all with
Mother as long as Father is living at their residence.
11. It is believed and therefore averred that Paternal Grandparents interfere
with custody of the minor child and Father and Mother's contact regarding the
minor child.
12. Father has been physically and verbally abusive to Mother.
13. Father has been previously diagnosed with a rage disorder.
14. Since the time Father has withheld custody of the minor child, he has been
extremely verbally abusive to Mother.
15. It is believed and therefore averred that Father's verbal abuse toward
Mother has taken place in the presence of the minor child.
16. Father has been inconsistent with exercising custody of the minor child in
the past.
17. Mother believes that it would be in the child's best interest to have a
consistent and regular custody schedule imposed by the Court.
18. Mother believes it would be in the child's best interests if Mother were
granted primary physical custody and Father partial physical custody of the
minor child.
5
19. Mother believes it would be in the child's best interest for a Christmas
custody arrangement to be ordered.
WHEREFORE, Petitioner prays that This Honorable Court grant her
Petition for Special Relief and order the following relief:
a. Grant Mother primary physical custody of the minor child;
b. Grant Father partial physical custody of the minor child on an every
other weekend basis, to commence Friday,]anuary 6, 2005;
c. Grant Father partial physical custody of the minor child over the
Christmas Holiday from December 25, 2005, at 6:00 PM through
December 26, 2005, at 6:00 PM;
d. Order a conciliation conference to be scheduled at the earliest
available date;
e. Grant such other relief as the Court deems appropriate.
Respectfully submitted,
MOM & KUTULAKIS, L.L.P.
/.la,lcl ~U.I~{LCt( ~1l '
Kara W. Haggerty, sire
Attorney ID No. 86914
36 South Hanover Street
Carlisle, P A 17013
(717) 249-0900
Attorney for Petitioner
DATE 12 17- D
6
VERIFICATION
I, Stevie Kramer, verify that the statements made in this Petition for Special
Relief are true and correct to the best of my knowledge, information, and belief. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
~ 4904 relating to unsworn falsification to authorities.
DATE
IJ /-;',}./05
(
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Stevie Kramer
8
STEVIE KRAMER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
v.
NO.
MATTHEW WEARY,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NOW, upon consideration of the attached Complaint, it is hereby directed that the
parties and their respective counsel appear before , the conciliator,
at , on the day of
200_, at .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. 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 hours prior to
the scheduled Hearing.
BY THE COURT,
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 A LAWYER 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
CARLISLE, PA 17013
(717) 249-3166 OR (800)990-9108
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STEVIE KRAMER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
v.
NO.
MA TIHEW WEARY,
Defendant
CIVIL ACTION -LAW
IN CUSTODY
COMPLAINT FOR CUSTODY
1. The Plaintiff is Stevie Kramer, who currendy resides at 28 Maple Avenue, Camp Hill,
Cumberland County, Pennsylvania 17011.
2. The Defendant is Matthew Weary, who currendy resides at 71 Hope Road, New
Bloomfield, Perry County, Pennsylvania.
3. The Plaintiff seeks custody of the following children:
Name
Address
DOB
Madison Weary
28 Maple Avenue
Camp Hill, PA 17011
02/13/2004
4. The child was born out of wedlock.
S. The child is presendy in the primary custody of Stevie Kramer, 28 Maple A venue,
Camp Hill, Cumberland County, Pennsylvania.
6. During the child's lifetime, she has resided witli the following persons and at the
following addresses:
Name
Address
Date
Stevie I<ramer and Shannon
Devine
28 Maple Avenue,
Camp Hill, PA
Birth to June 2004
Stevie I<ramer and
Weal)'
Matthew 24 South Apple Street, June 2004 to May 2005
New Bloomfield, PA
Stevie I<ramer and Richard Sutch 164 North 4'h Street, May 2005 to September 2005
Newport, PA
Stevie Kramer and
Devine
Shannon 28 Maple
Camp Hill, P A
A venue, September 2005 to Present
7. The mother of the child is Stevie Kramer, who currently resides at 28 Maple Avenue,
Camp Hill, Cumberland County, Pennsylvania. Mother currently resides with her mother,
Shannon Devine, her step-father, Dennis Devine, and her son, Dylan l<ramer, as well as the
subject minor child.
8. The father of the child is Matthew Weary, who currently resides at 71 Hope Road,
New Bloomfield, Perry County, Pennsylvania. Father currently resides with his parents,
Shari and Merle Weary.
9. The mother of the child is currently married, but separated, from Rory l<ramer.
10, The father of the child is not currently married.
11. The relationship of Plaintiff to the children is that of Mother,
12. The relationship of Defendant to the children is that of Father.
13. The Plaintiff has not participated as a party or wimess, or in another capacity, in
other litigation concerning the custody of the child in this or any other court.
14. The Plaintiff has no information of a custody proceeding concerrung the child
pending in a court of this Commonwealth.
15. The Plaintiff does not know of a person not a party to the proceedings who has
physical custody of the child or claims to have custody or visitation rights with respect to the
child.
16. The best interest and permanent welfare of the child will be served by granting the
relief requested for reasons including the following:
a. The Mother has been the primary caregiver of the l11l11or child since her
birth. She has:
1. Planned and prepared meals;
11. Bathed, groomed and dressed the child;
ill. Purchased, cleaned and cared for the child's clothing;
lV. Arranged medical care, including trips to physicians;
v. Arranged alternative daycare;
Vl. Put the child to bed nighdy, attended the child in the middle of the
night, and awakened the child in the morning.
b. The child has a psychological bond with the Mother.
c. Mother is able to provide a stable environment for the child.
d. Father has retained custody of the child since Tuesday, December 13, 2005,
and has refused to allow Mother any contact with dle child.
17, Each parent whose parental rights to the children have not been terminated has been
named as parties to this action.
WHEREFORE, the Plaintiff requests that This Honorable Court grant primary physical
custody of the child to the Plaintiff/Mother.
nm [1\2.2) OS
Respectfully submitted,
ABOM & KUTULAKIS, L.L.P.
~
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Kara W. Haggerty
ID No. 86914
36 South Hanover Street
Carlisle, P A 17013
(717) 249-0900
Attorneylor Plaintiff
VERIFICATION
I, Stevie Kramer, verify that the statements made in dus Custody Complaint are true and
correct to the best of my knowledge, information, and belief. I understand that false statements
herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to
authorities.
Date:
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CERTIFICATE OF SERVICE
AND NOW, this 22nd day of December, 2005, I, Kara W. Haggerty, Esquire, of Abom &
Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Custody
Complaint, upon the Defendant by depositing, or causing to be deposited, same in the United States
Mail, First-class mail, postage prepaid addressed to the following:
Matthew Weal)'
71 Hope Road
New Bloomfield, PA 17068
Respectfully submitted,
ABOM & KUTULAKIS, L.L.P.
kdULIJ. ~t{( (, ( L 12
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Kara W. Haggerty
ID No. 86914 - ~
36 South Hanover Street
Carlisle, P A 17013
(717) 249-0900
Attorneyfor Plaintiff
CERTIFICATE OF SERVICE
AND NOW, this 22nJ day of December, 2005, I, Kara W. Haggerty, Esquire,
of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of
the foregoing Petition for Special Relief, upon the Defendant by depositing, or
causing to be deposited, same in the United States Mail, First-class mail, postage
prepaid addressed to the following:
Matthew WealY
71 Hope Road
New Bloomfield, PA 17
Respectfully submitted,
Abom & Kutulakis, L.L.P.
idlU( U'J.
Kara W. Haggerty, , re
Attorney ID No. 86914
36 South Hanover Street
Carlisle, PA 17013
(717) 249-0900
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STEVIE KRAMER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, P A
v.
NO. 05 - iP 1D.5 CJvlllc.rrn
MATTHEW WEARY,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this ~2.-;ray of December, 2005, upon consideration of the
attached Petition for Special Relief, it is ORDERED and DECREED that the
Petitioner shall immediately ta~=~l custody of the subject minor child.
It is further ORDERED and DECREED that, pending a custody conciliation
conference, Father shall have partial physical custody every other weekend from
Friday at 5:00 PM through Monday morning when he drops the child off at the
babysitter, commencing Friday, January 6, 2006. For the Christmas Holiday, Father
shall have partial physical custody from Christmas Day at 6:00 PM through December
26, 2005, at 6:00 PM.
IN jAE ALTE~A TIVE/t j{ Ordered !n<;pej'feed that the J?Pties, 2' nd eir
respe~f counsel appear b;!/fJ This Ho;6rable Court, on ~:n/ . ' y of
I / ' 00_, at '{' .m., foy a H nng on Said
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~tition. ? /"', /
BY THE c:ouj9'>// .' /
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Kara W. Haggerty, Esquire - CoP'! p~CMJ'2LLy c( JV~,
Matthew Weary, 71 Hope Road, New Bloomfield, P A 17068 - tJof Y Yn.~ (!.u:(
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STEVIE KRAMER
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V,
05-6703
CIVIL ACTION LA W
MATTHEW WEARY
IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW,
FridaY",December 30,,2005 _
, upon consideration of the attached Complaint,
it is hereby directed that pm1ies and their respective counsel appear before Hubert X. Gilroy, Esq.
at 4th FI()or'_<=_llmherland County Courthonse, Carlisle. on Friday, Jannary 20, 2006
, the conciliator,
at 8:30 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 Custodv orders to the conciliator 48 hours prior to scheduled hearinv;.
FOR THE COURT,
By: /s/
Hubert X Gilrov, Esq.
Custody Conciliator
~
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 indi,iduals 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 A TTORNEY 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
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STEVIE KRAMER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, P A
v.
NO. 05-6703
MATTHEW WEARY,
Defendant
CIVIL ACTION - LA W
IN CUSTODY
PETITION TO WITHDRAW AS COUNSEL
AND NOW, this ~ day of August, 2006, comes the Petitioner, ABOM &
KUTULAKIS, LLP, by Kara W. Haggerty, Esquire, and files this Petition to Withdraw
As Counsel, and represents as follows:
1. Petitioner is Kara W. Haggerty, Esquire, attorney for Plaintiff, with offices
at 36 South Hanover Street, Carlisle, Cumberland County, Pennsylvania 17013.
2. The Respondents are the Plaintiff, Stevie Kramer, residing at 28 Maple
Avenue, Camp Hill, Pennsylvania 17011, and the Pro Se Defendant, Matthew Weary, 71
Hope Road, New Bloomfield, Pennsylvania 17068.
3. Petitioner was retained on or about December 22, 2005, to represent
Plaintiff in the above-captioned custody action.
4. The parties are presently engaged in a custody proceeding.
5. Petitioner drafted various pleadings in relation to the above-referenced
custody matter, as well as attended various conferences on Plaintiff's behalf, and engaged
in correspondence with the Plaintiff.
6. The Plaintiff has not paid Petitioner in full for services rendered by her
law firm to date. Although Petitioner, by and through the partners of the law firm, have
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attempted to correspond with Plaintiff about her account and additional proceedings,
those efforts have been unsuccessful.
8. Petitioner believes and therefore avers that Plaintiff has adequate time to
find substitute counsel and that neither party will be prejudiced should the court grant
Petitioner's request herein
WHEREFORE, Petitioner respectfully requests This Honorable Court enter a
Rule upon the Respondents to show cause why Petitioner should not be permitted to
withdraw from this case as counsel for Plaintiff.
Respectfully Submitted,
ABOM & KUTULAKIS, L. L. P.
Date: O~IOlj- ~!J
Kara W. Haggerty,
Attorney ID #86914
36 South Hanover Street
Carlisle, Pennsylvania 17013
Petitioner
.,
....
CERTIFICATE OF SERVICE
AND NOW, this ~ day of ~ 2006, I, Tracy Finkenbinder, of
Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the
foregoing Petition to Withdraw as Counsel, upon the Plaintiff and Pro Se Defendant by
depositing, or causing to be deposited, same in the United States Mail, First-class mail,
postage prepaid addressed to the following:
V'" Certified Mail- Return Receipt Requested:
Matthew Weary
71 Hope Road, New Bloomfield
Pennsylvania 17068
Stevie Kramer
28 Maple Avenue
Camp Hill, PA 17011
~c~~
. Tracy Fi nbinder
.,
-.
VERIFICATION
I, Kara W. Haggerty, Esquire, verify that the statements made in foregoing
Petition to Withdraw as Counsel are true and correct to the best of my knowledge,
information, and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities.
DATE
Kara W. Haggerty,
Attorney ID #86914
..
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RECEiVED NJG 072006 r>1
STEVIE KRAMER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 05-6703
v.
MATTHEW WEARY,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this ~
day of ~~
, 2006, upon
petition of Kara W. Haggerty, Esquire, a Rule is hereby issued upon the parties to show
cause why the Law Offices of Abom & KutuIakis, L.L.P., should not be permitted to
withdraw as counsel for Plaintiff.
Rule returnable '7.
days after the date of service of this Order. Service to
be by certified mail upon Plaintiff and upon the Pro Se Defendant.
J.
Distribution:
A'a W. Haggerty, Esquire
~atthew Weary, 71 Hope Road, New Bloomfield, Pennsylvania 17068
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STEVIE KRAMER,
Plaintift'
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO.05-6703 CIVIL ACTION . LAW
MATIHEWWEARY,
Defendant
IN CUSTODY
ORDER
~
AND NOW, this r;: day of September, 2006, the above case being previously
assigned to the Conciliator and there being no activity on this case for a period of six
months or more, the Conciliator relinquishes jurisdiction.
OAL
Hubert X. Gilroy, squire
Custody Concilia or
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STEVIE KRAMER,
Respondent
v.
MATTHEW WEARY,
Petitioner
NO. 05-6703 CIVIL TERM
IN RE: PETITION FOR SPECIAL RELIEF
ORDER OF COURT
AND NOW, this 17 day of February 2012, upon consideration of Petitioner's
Petition for Special Relief, a hearing is scheduled for 21 February 2012 at 1:30 p.m.
in Courtroom Number 6 of the Cumberland County Courthouse, 1 Courthouse
Square, Carlisle, Pennsylvania 17013.
PETITIONER shall effectuate service upon Respondent and her described but
unidentified parents. Proof of service shall be filed prior to the time of the hearing.
The sole issue of the conference is the current and immediate health and well-
being of the child, Madison Weary, who SHALL be present at the hearing. All other
custody issues shall be referred to a Custody Conciliator.
Thomas L 1, cey C.P.J.
Distribution List:
VJason M. Weinstock, Esq.
-
800 North Second Street C
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Harrisburg, PA 17102 rnca =
For Petitioner
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( via first class mail and emal? o°
Stevie Kramer, C'
Respondent Pro Se
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Parents of Stevie Kramer
L* ft? t 42
IN THE COURT OF COMMON PLEAS OF
THE NINTH JUDICIAL DISTRICT
LED-OFFICE
OF THE PROTHONOTARY
Jason M. Weinstock, Esquire
Supreme Court I.D. No. 69272
IRA H. WEINSTOCK, P.C.
800 North Second Street
Harrisburg, PA 17102
Telephone: 717-238-1657
Facsimile: 717-238-6691
STEVIE KRAMER,
Respondent,
V.
MATTHEW WEARY,
Petitioner
2012 FEB 21 PM I : 10
CUMBERLAND COUNTY
PENNSYLVANIA
Attorney for:
Petitioner
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 05-6703
CIVIL ACTION-LAW
IN-CUSTODY
ACCEPTANCE OF SERVICE
I, Shannon Devine, of Cumberland County, and Mother of Stevie Kramer,
Respondent, in the above-captioned action, acknowledge receipt of the Order of Court dated
February 17, 2012, and the Petition for Special Relief filed on February 17, 2012 in the above
captioned matter
Dated: ?f h
Shannon 15evine
STEVIE KRAMER, IN THE COURT OF COMMON PLEAS OF
Respofdent THE NINTH JUDICIAL DISTRICT
{
v CIVIL ACTION - LAW cv? ;z
NO. 05-6703 CIVIL TERM zmj
MATTHEW WEARY, m
Petitioner
CCJ ?•. r?
C"? IN RE: PETITION FOR SPECIAL RELIEF -?'
ORDER OF COURT
AND NOW, this 21st day of February, 2012, upon
consideration of the Petition for Special Relief and a conference
at which Matthew Weary, Madison Weary, and Shannon Devine were
present, along with counsel for Petitioner, Jason M. Weinstock,
Esquire, the following interim order is entered:
1. Father shall have primary physical custody of
Madison until further Order of Court.
2. Grandmother, Shannon Devine, shall have
liberal periods of visitation at the parties' discretion,
together with the input of Madison, until further notice.
3. If mother is aggrieved by this order, in
addition to any other appeal remedies she may have, a petition to
modify this order would be considered by the Court at any time
during the future of this custody matter.
By the Court
Thom Placey C.P.J.
V Jason M. Weinstock, Esquire
800 N. Second Street
Harrisburg, PA 17102
For Petitioner
y-'Shannon Devine
28 Maple Avenue
Camp Hill, PA 17011
Maternal Grandmother
?Stevie Kramer
r?
72 or 74 Pine Hill Road
Shermans Dale, PA 17090
STEVIE KRAMER N/K/A STEVIE IN THE COURT OF COMMON PLEAS OF
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OPPERMAN ~" ~'
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVAN~~ a rn-
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• 2005-6703 CIVIL ACTION LAW ~-~:;
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"- C.-J
MATTHEW WEARY "
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IN CUSTODY ~.n ~`
DEFENDANT _
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ORDER OF COURT
AND NOW, Wednesday, November 21, 2012 ,upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. ,the conciliator,
at 4th Floor ,Cumberland County Courthouse, Carlisle on Thursday, December 06, 2012 at 9:30 AM
for aPre-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. 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 hours prior to scheduled hearing.
FOR THE COURT,
By: _/s/ Hubert X. Grlro Es .
Custody Conciliator
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 before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. TF 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
Sh a nr~ ~~ ~~ vin ~ Telephone (717) 249-3166
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STEVIE KRAMER (n/k/a
STEVIE OPPERMAN),
Petitioner
v.
MATTHEW WEARY,
Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO. 2005-6703 CIVIL, ACTION
IN CUSTODY
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Stevie Kramer (n/k/a Stevie Opperman), Petitioner, to proceed in forma
ap uperis.
I, Jessica ~Holst, attorney for the party proceeding in forma ap uperis, certify that I believe
the party is unable to pay the costs and that I am providing free legal services to the party.
Jessi 1st, Esquire
MidPenn egal Services
401 East Louther Street
Carlisle, PA 17013
(717)243-9400
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