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Home My WebLink About06-1525 AMERICANS WITH DISABILITIES ACT OF 1990 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 scheduling conference or hearing. 2 GARY D. KUHN, BRENDA K. KUHN, and TRACY L. BROWNA WELL Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2006- /502:) CIVIL TERM IN CUSTODY ZACHARY PRYOR Defendant COMPLAINT FOR CUSTODY AND NOW, this 15th day of March 2006, comes the Plaintiffs, Gary D. Kuhn, Brenda K. Kuhn, and Tracy L. Brownawell, by their attorneys, Irwin & McKnight, and presents the following Complaint for Custody. 1. The Plaintiffs are Gary D. Kuhn and Brenda K. Kuhn, his wife, adult individuals who reside at 202 Garfield Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Plaintiff is Tracy Lynn Brownawell, an adult individual who resides at 3 Terry Drive, Carlisle, Cumberland County, Pennsylvania 17013 and is the natural mother of Taylor Lynn Pryor, born January 20, 1996. 3. The Defendant, Zachary Pryor, an adult individual resides at 11423 South 9th Street, Apartment 3, Philadelphia, Pennsylvania 19147, and is the natural father of the minor child, Taylor Lynn Pryor. 3 4. The Plaintiffs, Gary D. Kuhn and Brenda K. Kuhn, are the maternal grandparents of said minor child. 5. The Defendant, Zachary Pryor, has not contacted his son, Taylor L. Pryor, for a period in excess of seven (7) years. 6. The Plaintiffs, Gary D. Kuhn and Brenda K. Kuhn, desire to share equally joint physical custody and joint legal custody of Taylor Lawton Pryor with Plaintiff, Tracy L. Brownawell. 7. The best interest of Taylor Lawton Pryor requires that the court grant the Plaintiffs' request as set forth above. WHEREFORE, Plaintiffs respectfully seek the entry of an Order of Court as follows: The Plaintiffs, Gary D. Kuhn and Brenda K. Kuhn, desire to share equally joint physical custody and joint legal custody of Taylor Lawton Pryor with Plaintiff, Tracy L. Brownawell. Respectfully submitted, By: Date: March 15,2006 4 ~ .J EXHIBIT "A" TRACY LYNN PRYOR, Plaintiff : IN THE COURT OF COMMON PLEAS OF v. : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 98-2168 CIVIL TERM ZACHARY LAWTON PRYOR, Defendant IN CUSTODY ORDER OF COURT f11.cl . AND NOW, this ;?;;l. day of September, 1998, in consideration of the stipulation of the parties the following Order is hereby entered: 1. The mother, Tracy Lynn Pryor, and the father, Zachary Lawton Pryor, shall have shared legal custody of Taylor Lynn Pryor, born January 20,1996. 2. The mother shall have primary physical custody of the child. 3. The parties agree that a custody evaluation is not necessary. 4. The father will have temporary periods of physical custody of Taylor Lynn Pryor as follows: a. Every Thursday from 10:00 a.m. to 6:00 p.m. b. The holiday schedule will be as follows each year: 1. Father's Day from 9:00 a.m. to 1 :00 p.m. 2. Thanksgiving Day from 3:00 p.m. to 7:00 p.m. 3. Christmas Day from 3;00 p.m. to 7:00 p.m. 4. Taylor's Birthday as the parties agree. 5. Easter as the parties agree. c. Any other time as the parties agree is in the best interest of Taylor Lynn Pryor. By The Court; Ire" . (1 '-,., 13 ..........t'LL-.......-r.::u:L C ~,w::<.~- Edward E. Guido, Judge cc; Marcus A. McKnight, III, Esquire Attomey for Plaintiff Michael J. Hanft, Esquire Attorney for Defendant -.,'"T r~;r,).1 ^"\, 7~D >:nd " '. ...1 .,~ ;, "_; ',' ') //,.( lfli.;) _..;:t;,~p,,,,,,, uuY L-f .;j fi.. ,.C . C. ....-........................J........ cxi';' ' .-.:. .-1:J.l 17.'1{ ,;>. _l!~::(..~rf2(.{.~ ,.,.....n PrOtliOnotary TRACY LYNN PRYOR, Plaintiff : IN THE COURT OF COMMON PLEAS OF v, : CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW 98-2168 CIVIL TERM ZACHARY LAWTON PRYOR, Defendant IN CUSTODY CUSTODY STIPULATION ..,.I, AND NOW, this 13 day of August, 1998, the parties agree to the following Custody Stipulation: 1. The mother, Tracy Lynn Pryor, and the father, Zachary Lawton Pryor, shall have shared legal custody of Taylor Lynn Pryor, born January 20, 1996. 2. The mother shall have primary physical custody of the child. 3. The parties agree that a custody evaluation is not necessary. 4. The father will have temporary periods of physical custody of Taylor Lynn Pryor as follows: a. Every Thursday from 10:00 a.m. to 6:00 p.m. b. The holiday schedule will be as follows each year: 1. Father's Day from 9:00 a.m. to 1 :00 p.m. 2. Thanksgiving Day from 3:00 p.m. to 7:00 p.m. 3. Christmas Day from 3:00 p.m. to 7:00 p.m. 4. Taylor's Birthday as the parties agree. 5. Easter as the parties agree. c. Any other time as the parties agree is in the best interest of Taylor Lynn Pryor. WITNESSETH: 0?I.a.vx- cr?ld.L~ , i I I "\-..(" '- V '~) /'''L:~/{: ; 'j, . ).." ,-' '.. .-' Z~~~A*YLA*;;~PRYOR '/ (SEAL) (SEAL) VERIFICATION The foregoing document is based upon information which has been gathered by counsel and us in the preparation ofthis action. We have read the statements made in this document and they are true and correct to the best of our knowledge, information and belief. We understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Ju . ~~ A': ,)(hA BRENDA K. KUHN //) ,../ I _:, /<L~ I~'" ~ ( ~ARY , KUHN /'J . / T~~l;ca<fUr Date: March 15, 2006 5 (') ~ ~~ t f ?' 'K:.- }\ -~ ...0 "" v, ~ ... c' 0 v. )oJ r. 0 -ell)' rnr' ;:."- ",~. .." ~,~ (') C~ :;~ ,.", f3 <:1-- ~ ":="" -, /~ ':::'; ::" .....~. 0' (J '-fi -1~ \;11-:"'< -'n~ .'f_) \:7' (.-\j;'~ -'1', ();::\, ':,:"'171'1 ::-\ -'7 ',;-"1, .~<.. ~:J ~ (-:.? 1',' G'''' GARY D. KUHN, BRENDA K. KUHN AND TRACY L. BROWN A WELL IN THE COURT OF COMMON PLEAS OF PLAINTIFf CUMBERLAND COUNTY, PENNSYLVANIA v. 06-1525 CIVIL ACTION LAW ZACHARY PRYOR IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, March 23, 2006 , 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,Carlis~ on" __-"'hursday,~priI20, 20~.__." at }:3~~M for a Pre-Hearing Custody Confercnee. At such conference, an effort will be made to resolve the issues in dispute: or ifthis cannot be accomplished, to define and nanow the issues to be heard by the court, and to enter iJ1lo 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 herehy 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 hearin!:. FOR THE COURT. By:_/sl Tacqyeline M. .Vem~EEL___t+j'\ 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 disahled individuals having business before the court, please contact our office. All anangements must be made at least 72 hours prior to any hearing or business before thc court. You \TILlst 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 FlND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717)249-3166 . vi' ~'11 fr' ..... t'mr'!.b; 1<1 U' r . 'M fJ I11'm~' 1ill.N ~JW,;;I, ~ ~.f''1 ,'vucI 7 \\"1\ ."(:,C'1 S, \ ,~\\(I Lv ,,;" ,;\.j'~ .J~-\\ ~o ~, ~ /.\"::{'-\j - "---------- APR 2 0 2006 {J1l / . GARY D. KUHN, BRENDA K, KUHN: IN THE COURT OF COMMON PLEAS OF AND TRACY L. BROWNA WELL, : CUMBERLAND COUNTY, PENNSYL VANIA Plaintiffs V, : NO. 2006-1525 CIVIL ACTION - LAW ZACHARY PRYOR, Defendant IN CUSTODY ORDER OF COURT f"~ AND NOW, this ;;V day of , 2006, upon consideration of the attached Custody Concil atlOn Report, it is ordered and duected as follows: I. The prior Order of Court dated September 22, 1998 is hereby vacated. 2. The Mother, Tracy L. Brownawell, and the maternal grandparents, Gary D. Kuhn and Brenda K. Kuhn shall have shared legal custody of Taylor Lynn Pryor, born January 20, 1996. Mother and maternal grandparents shall have an equal right, to be exercised jointly with the other, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. 3. Mother and maternal grandparents shall have shared physical custody of the child as agreed. 4. Father shall have periods of visitation as agreed by the parties. 5. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. --~_.-.- / ! BY THE COD " J. cc: Marcus A. McKnight, III, Esquire, Counsel for Mother and maternal grandparents , 'I ',\". "I .~ '.' . ~ APE? 2 0 200r GARY D, KUHN, BRENDA K,KUHN: IN THE COURT OF COMMON PLEAS OF And TRACY L. BROWNA WELL, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V, : NO. 2006-1525 CIVIL ACTION - LAW ZACHARY PRYOR, Defendant : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J, 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 CUSTODY OF Taylor Lynn Pryor January 20, 1996 Mother and maternal grandparents 2. A Conciliation Conference was held in this matter on April 20, 2006, with the following in attendance: The Mother, Tracy L. Brownawell, and the maternal grandparents, Gary K. Kuhn and Brenda K. Kuhn, with their counsel, Marcus A. McKnight, 1lI, Esquire. Fathe~ although served with notice, did not appear. 3. The Honorable Edward E. Guido entered an Order upon Stipulation of the parties dated September 22, 1998 providing for shared legal by Mother and Father, Mother primary physical custody, and Father periods of partial physical custody. 4. The child has lived with the grandparents for 10 years. Father has not had contact with the child for 7 years. 5. Mother and grandparents requested an Order in the form as attached. [1- Lv /o? Date fL1~, acq line M. Verney, Esquire Custody Conciliator ...-- APR 2 0 2006 rJII / GARY D. KUHN, BRENDA K. KUHN: IN THE COURT OF COMMON PLEAS OF AND TRACY L. BROWNA WELL, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V, : NO, 2006-1525 CIVIL ACTION - LAW ZACHARY PRYOR, Defendant : IN CUSTODY ORDER OF COURT ~~ AND NOW, this Jif day of , 2006, upon consideration of the attached Custody Conci! atlOn Report, It IS ordered and directed as follows: 1. The prior Order of Court dated September 22, 1998 is hereby vacated. 2. The Mother, Tracy L. Brownawell, and the maternal grandparents, Gary D. Kuhn and Brenda K. Kuhn shall have shared legal custody of Taylor Lynn Pryor, born January 20,1996. Mother and maternal grandparents shall have an equal right, to be exercised jointly with the other, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. 3. Mother and maternal grandparents shall have shared physical custody of the child as agreed. 4. Father shall have periods of visitation as agreed by the parties. ~ This Order is entered pursuant to a Custody Conciliation Conference. The , --___ _.s:' ~RLAND COUNTY COURT ADMINISTRATOR ONE COURTHOUSE SQUARE CARLISLE, PA 17013 ftJV;r b(/p1!-t- B ~~ ~- ,..v. '-;r ()~ - / j-J-S- Zach ryor 3 South 9th Street ApartrT'~' ^ Ph' A 0 INSUFFICIENT ADDRESS Ilad Oc 0 AHEMPTED NOT KNOWN 0 OTHER o NO SUCH NUMBER! STREET S ... NOT DELIVERABLE AS ADDRESSED , UNABLE ro FORWARD ~:.".-:.... ~_.~._. . '",Il/.. ,III"", ,11"11,,, 11." 11" ",',.',./.1,.,,/.,', /.,'