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HomeMy WebLinkAbout06-2770 GREGORY G. SAWYER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. ()I....- C;u~L~0c"l IPANEMA P. SAWYER, Defendant : CIVIL ACTION - CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE PROMPT ACTION. YOU ARE WARNED THAT IF YOU FAIL TO DO SO, THE CASE MAY PROCEED WITHOUT YOU AND A DECREE OF DIVORCE OR ANNULMENT MAYBE ENTERED AGAINST YOU BY THE COURT. A JUDGMENT MAY ALSO BE ENTERED AGAINST YOU FOR ANY OTHER CLAIM OR RELIEF REQUESTED IN THESE PAPERS BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RlGHTS IMPORTANT TO YOU, INCLUDING CUSTODY OR VISITATION OF YOUR CHILDREN. WHEN THE GROUND FOR THE DIVORCE IS INDIGNITIES OR IRRETRlEV ABLE BREAKDOWN OF THE MARRIAGE, YOU MAY REQUEST MARRIAGE COUNSELING. A LIST OF MARRIAGE COUNSELORS IS A V AILABLE IN THE OFFICE OF THE PROTHONOTARY AT THE CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYER=S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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 LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 GREGORY G. SAWYER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01..- - ;)"1'16 C2tu~~~~~ IP ANEMA P. SAWYER, Defendant : CIVIL ACTION - CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes Plaintiff, Gregory G. Sawyer, by and through his attorney, Bradley A. Winnick, Esquire, of Wiley, Lenox, Colgan & Marzzacco, P.C., and files the instant Complaint for Custody, and in support thereof, avers as follows: 1. The Plaintiff is Gregory G. Sawyer, who currently resides at \04 November Drive, Apartment 5, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. The Defendant is Ipanema P. Sawyer, whose address is currently unknown. 3. Plaintiff seeks primary physical custody of the following child: Daniel K. Sawyer, born on February 5, 2001. The child was born out of wedlock. During the past five (5) years, the child has resided with the following persons at the following addresses: A. From May 2001 until January 2002, the child resided with Plaintiff and Defendant in the Phillipines. B. From January 2002 until May 2002, the child resided with Plaintiff and Defendant in Australia. C. From May 2002 until June 2002, the child resided at 1411 Gallant Fox Court, Indianapolis, Indiana, with Plaintiff, Defendant and Plaintiff's sister, Deborah Eckstein. D. From June 2002 until October 2002, the child resided with Plaintiff and Defendant as they traveled the United States in Plaintiff's motor home. E. From October 2002 until May 2003, the child resided with Plaintiff and Defendant in Australia. F. From May 2003 until July 2003, the child resided at 1411 Gallant Fox Court, Indianapolis, Indiana, with Plaintiff, Defendant and Plaintiffs sister, Deborah Eckstein. G. From July 2003 until early May 2006, the child resided at 104 November Drive, Apartment #5, Camp Hill, Pennsylvania, with Plaintiff and Defendant. H. In early May 2006, the Defendant left the marital residence with the child and is residing at an unknown address. The mother of the child is Ipanema P. Sawyer, whose address is currently unknown. She is married. The Father of the child is Gregory G. Sawyer, who is currently residing at 104 November Drive, Apartment 5, Camp Hill, PA 17011. He is married. 16. The relationship of Plaintiff to the child is that of Father. 17. The relationship of Defendant to the child is that of Mother. 18. 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 or any other state. 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. 19. The best interest and permanent welfare of the child will be served by granting Plaintiff primary physical custody. 20. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiff respectfully requests This Honorable Court to grant him primary physical custody of the minor child. Respectfully submitted, WILEY, LENOX, COLGAN &MARZZACCO, P.C. Dated: .s /11 J (; ~ innick, Esquire 130 Wes urch Street DiJlsburg, PA 17019 (717) 432-9666 J.D. # 78413 VERIFICATION I, Gregory G. Sawyer, verify that the statements made in this 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. es. g4904, relating to unsworn falsification to authorities. Date: iVt"Q 10 ,'2-00<e . ~ GREGORY G. SAWYER Plaintiff ;j [") ~ \ - ~ - It) C> 0 ...., t3 = ~ - \) c <=' ;;.:'" <S'" ~ -Ot~'~ ::% ~~ "-.J rP qJL'-' "" .~ -,,-. -' -< ..., ...c (! '::'0 '~':'-.; "'0 ....0 (J1 :n~ I ~C 0::> -- J ;1-'1""1 .;;;, ~ -0 ~~,~ " -,.-,-.," ;~-~ :JJ: ~'4t) .s:- ;;;'5\11 ~ ~ ?D . - \.D '< , GREGORY G. SAWYER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 06-2770 CIVIL ACTION LAW IPANEMA P. SAWYER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, May 24, 2006 , 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 MDJ Manlove, 1901 State St., Camp Hill, PA 17011 on Friday, July 07, 2006 at 12:30 PM 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 Custody orders to the conciliator 48 hours prior to scheduled hearin2. FOR THE COURT. By: /s/ Melissa P. Gree 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 A TTORNEY 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 ~f?5I- ~ ~ ~~7~~U; ~('1 fE~ ~~-P'lJ Z 8 :2 Hd 08), \Jt,~ 900l AtlV10i\J,u.odd 3Hl :10 . :1:.J!..3:{)-(j:J1H tf)(J ~ ~ T ~'1 'jb'. ~:.9 1- ~ dj}--6f'S 1''9 ~b/lb/<~~b ~~:<I 1114~<~4<b IHl:. WILl:.Y (;t.1.)Ut-' t-'A(;l:. ~</~< v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-2770 GREGORY G. SAWYER, Plaintiff IP ANEMA P. SAWYER, Defendant : CIVIL ACTION - CUSTODY ACCEPTANCE OF SERVICE 1, WUliam L. Grubb, Esquire, Attorney for thc Defendant, accept service of the Complaint for Custody filed on May 15, 2006 and Order of Court dated May 24, 2006 scheduling a Pre-Hearing Conference. I certify that I am authorized to accept service on behalf of said, Defendant, Ipanema P. Sawyer. Date: (Q ~ 14 -() (q 10~/?hQll~' William L. Gfubb. Esquire ' LD.# -rz.io& , 3803 Gettysburg Road Camp Hill. P A 170 11 717-763-5580 ~ ~ 'J/, (i::: "","-~ f',) 0) '!?~, -< 0! C,: x.... ::::-"~ '?}q, .... 717/200610:57 AM FROM: (717)975-1912 Yaffe and Yaffe, P.C. TO: 763-6848 PAGE: 002 OF 002 GREGORY G. SAWYER Plaintiff vs. IP ANEMA P. SAWYER, Defendant : IN TIlE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : NO. 06-2770 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY PRAECIPE TO ENTER/WITHDRA W APPEARANCE On behalf of Ipanema P. Sawyer, please enter the appearance of Jeffrey N. Yoffe, Esq. and withdraw the appearance of William L. Grubb, Esq. 1~~O~ByL)Q-N~(1i~ ' William L. Grubb, Esq. LD.# 72661 3803 Gettysburg Road Camp Hill, PA 17011 (717) 763-5580 YOFFE & YOFFE, P.C. By ~J7i tf'e rey . Y , Esquire 214 Senate Avenue, Suite 404 Camp Hill, PA 170ll (717)975-1838 Attorney ID No. 52933 jyoffe@verizon.net ::-'J -n L ~"'.; c ('C"\ GREGORY G. SAWYER, Plaintift' * * IN TIlE COURT OF COMMON PLEAS CUMBERLANDCOUNlY ,PENNSYLVANIA * vs. * * * * * * CIVIL ACI'ION . LAW IN CUSTODY NO. 06-1770 CIVIL TERM IPANEMA P. SAWYER, Defendant PRAECIPE TO DISCONTINUE TO TIlE PROTHONOTARY: On behalf oCthe Plaintiff, Gregory G. Sawyer, kindly discontinue the above-captioned custody action instituted by Complaint filed on May IS, 2006. Respectfully submitted, WILEY, LENOX, COLGAN & MARZZACCO By: Dated: August 1,2006 _.-J~ '-" Plaintiff CEIVEL AUG 0 9 2006 BY: r IN THE COURT OF C OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2770 CIVIL TERM GREGORY G. SAWYER, v. IPANEMA P. SAWYER, CIVIL ACTION - LAW IN CUSTODY Defendant ORDER TO RELINQUISH JURISDICTION AND NOW, this ~ day of August, 2006, the Plaintiff having filed a Praecipe to Discontinue and filed with this Court, the Conciliator hereby relinquishes jurisdiction of the above captioned matter. FOR THE COURT: e issa Peel Greevy, Esqui Custody Conciliator B: :280513 'v'IN'v'^lASNN3d ,UNnm O~,,'1i:!38~ S*1 :01 WY 0 I $flY 900l AtNIONOHlOW 3Hl::lO 3::lI:1:lo-<T:tll:l.