The URL can be used to link to this page

Home My WebLink About06-3150 STACY B. WOLF, ESQUIRE ATTORNEY In NO. 88732 10 WEST HIGH STREET CARLISLE P A 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF LYNETTE J. MEREDITH, Plaintiff : IN THE COURT OF CO MON PLEAS OF : CUMBERLAND CO , PENNSYLVANIA : CML ACTION - LAW v. . : NO. 06- 31 /,7:> CML BRIAN K. MEREDITH, Defendant : IN CUSTODY COMPLAINT FOR CUSTODY NOW COMES the plaintiff, Lynette J. Meredith, by her attome Stacy B. Wolf, Esquire, and presents the following complaint for custody, representing as follows: 1. The plaintiff is Lynette J. Meredith, the natural mother of the hild who is the subject of this action (hereinafter referred to as ""Mother"), an adult individual resi' at 145 SME, Shippensburg, G.unberland County, Pennsylvania 17257. 2. The defendant is Brian K. Meredith, the natural father of the c . d who is the subject of this action (hereinafter referred to as "Father"), an adult individual residing at 300 Links Circle, Apt. 1, Jonesboro, AIKansas 72404. 3. Plaintiff Mother seeks primary physical custody of the folio child: Name Present Residence Age Keith M Meredith 145 SME Shippensburg, P A 17257 10 years D.0.B.2/2/1996 4. "Mother and Father are the natural parents of the child. 5. The child was bom during the marriage of the parties. 6. The child is presently in the custody of Mother but has resid d with the following parties for the following specified periods: a. WIth Mother and Father between the child's birth an Januazy 5, 2006 when Pather moved to Amansas. b. WIth Mother between Januazy 5, 2006 until the prese t. 7. The parties are manied. 8. Plaintiff has not participated as a party or witness, or in ano r capacity, in other 1itigation concerning the custody of the child in this or another court. 9. Plaintiff has no reliable information of any other custody pro eeding concerning the child pending in a court of this Commonwealth or any other state. 10. Plaintiff does not know of a person not a party to the procee' s who has physical custody of the child or claims to have custody or visitation rights with respect to 11. The best interests and permanent welfare of the child will be erved by granting the relief requested herein because Mother has been the sole and primary caregive for the child for his whole life and because Father has informed Mother that he intends to remove the hild from the jurisdiction and take the child to Amansas, where Father now resides. 12. Mother and the child have always lived in this area and Mo r's family resides in this area. 13. Mother and the child have friends and strong ties to the area 14. Plaintiff believes and therefore avers that it is in the child's b st interests to remain in the primary custody of his Mother and to limit Father's rights to visitation to a set schedule in Pennsylvania that may be incorporated into an Order issued by this Honorable Court. 15. Mother believes that the best interests of the child would be est served by an award of primary physical custody, that the child must continue to have a relatio hip with his Father, which she will encour.lge and facilitate with all reasonable efforts, and agrees that ather should be permitted reasonable visitation and contact with the child. WHEREFORE, Plaintiff Lynette J. Meredith, respectfully req sts that this Honorable Court enter an order granting primary physical and shared legal custody of the hild to her. Plaintiff furthermore requests that this Coun enter an Order awarding Father, B' K. Meredith, rights to visitation of the child in Pennsylvania. Respectfully submitted, June a. 2006 STACY B. OLF, ESQ Attorney for Plaintiff 10 West High Street Carlisle, Pennsylvania 1 013 (717) 241-4436 Supreme Court I.D. No 88732 VERIFICATION I do hereby verify that the facts set forth in this complaint for c tody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.CS. Section 4904, relating to unsworn falsification to authorities. /7u/lll2 / .2006 STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF LYNETTE J. MEREDITH, Plaintiff : IN THE COURT OF CO MON PLEAS OF : CUMBERLAND CO , PENNSYLVANIA : CIVIL ACTION -LAW v. : NO. 06- CIVIL BRIAN K. MEREDITH, Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Stacy B. Wolf, Esquire, have served a true and correct copy of Olrnplaint for OJstody upon the following person and in the matter indicated: SERVICE BY U.S. MAIL: Brian K. Meredith 1300 Links Circle, Apt. 1 Jonesboro, AR 72404 WOLF & WOLF June .d...., 2006 By: r5.W STACY B. WOLF, ES Attorney for Plaintiff 10 West High Street Carlisle, Pennsylvania 1 013 (717) 241-4436 Supreme Court I.D. No 88732 (> ~C'"" ..;. """ c- c:- v ~ o .... "i2 ~ 01' t-:> ~ Q c, 'CS ,.;;::> v-' (--"" C-.: -;.:.- , N R. ..... :"f"'1:!!: r. h, 'CQ "~\~j\l., '~-.:{~(~::(" L;C') ~7 r<' .') S ....;r ,.0;..0 ::<:. ~ ::\: .- -- .' .- - -' STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF : IN THE COURT OF C MON PLEAS OF : CUMBERLAND COU , PENNSYLVANIA : CIVIL ACTION -LAW LYNETTE J. MEREDITH, Plaintiff v. : NO. 06- 3/51> CIVIL BRIAN K. MEREDITH, Defendant : IN CUSTODY AND NOW comes the Petitioner, Lynette J. Meredith, by her a mey, Stacy B. Wolf, Esquire, and files this petition for special relief respectfully representing as follows 1. The plaintiff is Lynette J. Meredith, an adult individual resi . Ounberland County, Pennsylvania 17257. 3. The plaintiff and defendant are the natural parents of two Name Present Residence Kevin D. Meredith 145 SME Shippensburg, P A 17257 2. The defendant is Brian K. Meredith, an adult individual resi . 1, Jonesboro, AtKansas 72404. Keith M Meredith same at 145 SME, Shippensburg, at 1300 Links Circle, Apt. r children, namely: Age 14 years D.O.B.7/17/1991 10 years D.O.B.2/2/1996 4. The children are presently in the custody of plaintiff but reside -with both parents from the time of their births until on or about January 5, 2006 when the parties sepa red. 5. Father informed Mother that he intends to come to PeIUlSJ'\vania on June 9, 2006 and will take the children back to Arkansas with him. 6. Mother believes and therefore avers that it would be in the est interests of the youngest child, Keith M Meredith, for this Court to issue an Order for Special lief, directing Father not to remove the child from the jurisdiction without the express written cons t of the mother, to prevent the child from being removed from the jurisdiction before a conciliation conference can be held on this matter. 7. Mother has, this date, initiated an action in G1stody by the f of a complaint with the Court. WHEREFORE, Petitioner, Lynette J. Meredith prays this Bono G.lstody Order directing Respondent, Brian K. Meredith, not to remove e youngest child, Keith M Meredith, from this jurisdiction in excess of 72 hours without the express written consent of the Petitioner, pending fUrther Order of Court, and directing the Court . . trator's office to schedule an expedited custody conciliation conference to address the issues raised' this matter. Dated: June ;;[, 2006 .-WmJJJ Stacy B. Wo , Esq . e =="'7)'" 10 West High Stte t Carlisle, PA 17013 Supreme Court I. . No. 88732 (717) 241-4436 Attorney for Plainti VERIFICATION I, the undersigned, do hereby verify that the facts set forth in . petition are true and correct to the best of my knowledge and belief. I understand that false stateme ts herein are made subject to the penalties of 18 Pa.CS. Section 4904, relating to unsworn falsificatio to authorities. ., June ..2L,2006 ,- STACY B. 'WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF LYNETTE J. MEREDITH, Plaintiff : IN THE COURT OF C MON PLEAS OF : CUMBERLAND CO , PENNSYLVANIA : CML ACTION - LAW v. : NO. 06- CIVIL BRIAN K. MEREDITH, Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Stacy B. Wolf, Esquire, have seIVed a true and correct copy of etition for Special Relief upon the following person and in the matter indicated: SERVICE BY U.S. MAIL: Brian K. Meredith 1300 Links Cin:le, Apt. 1 Jonesboro, AR 72404 WOLF & WOLF June B. 2006 By: ~. (3t . STACYB. LF,ESQU RE Attorney for Plaintiff 10 West High Street Carlisle, Pennsylvania 170 (717) 241-4436 Supreme Court I.D. No.8 732 ( ;9 ~f ' ~ _ l' ~ "" ("- r;- -.c:. ...) .J:) "'" ... ~ 'a C) c- [f,~/;~ ~ (;::::;, "" <.... r;:,7 ~,>*~ fi? ?if rni!l -r::!11j ::.cJC:; <;> (L ,~-d:i:' :,;; ("5 (~jiif ~ -J.J '-C I "> ~ - - cry f'v ~ ~ LYNETTE J. MEREDITH, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN CUSTODY BRIAN K. MEREDITH, DEFENDANT 06-3150 CIVIL ORDER OF COURT AND NOW, this 2nd day of June, 2006, upon consideration of the Petition for Special Relief, IT IS HEREBY ORDERED AND DIRECTED that: 1. A rule is issued upon the defendant to show cause why the plaintiff is not entitled to the relief requested; 2. The defendant will file an answer to this petition on or before June 9, 2006; 3. The petition shall be decided under Pa.R.C.P. No. 206.7; 4. The Rule is returnable and a hearing shall be held on Friday, June 9, 2006, at 3:00 p.m. in Courtroom NO.5 of the Cumberland County Courthouse, Carlisle, PA. 5. Pending further Order of Court, the Defendant is not to remove Keith M. Meredith from the jurisdiction of this Court without express written Order of Court. By the Court, 'l J. M. L. Ebert, Jr., 9 I :6 ~IV s- ~mr gaDl I ....".r' , r),J:-;. ,,. ".i(' ::!Hl -10 ^uv..l,u~ 11......,11...'..,\..1.,.......]....# .:J :1~)l:!.!O-{f31l.::J . Stacy B. Wolf, Esquire Attorney for Plaintiff Brian K. Meredith Defendant bas LYNETTE J. MEREDITH PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 06-3150 CIVIL ACTION LAW BRIAN K. MEREDITH DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, June 05, 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, Carlisle on Thursday, July 06, 2006 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 Custody orders to the conciliator 48 hours prior to scheduled hearinjZ. FOR THE COURT. By: Isl ac ueline M. Veme 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. 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 ] 7013 Telephone (717) 249-3166 . ~ ~ fr ~ ~ ~ 1(7-'1-'1 -~ Z. ~ ~ 9V'-?-? ~ .~ -!L ~ ~ -~ '1(l-')-'1 ';l] f<\//\"ll\ S' \\~ t'~'3 d AlNflC('; '~~',:'(!"ln8 8 S:2 Hd 9- tmr quOl ^b~ilC)[\~,AL.L.0G-::J. 3Hl :JO 3JH:1G~(Ijllj ".......' STACY B. WOLF, ESQUIRE ATTORNEY In NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINfIFF LYNETTE J. MEREDITH, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. : NO. 06-3150 CIVIL BRIAN K. MEREDITH, Defendant : IN CUSTODY STIPULATION AND-AGREEMENT THIS STIPULATION AND AGREEMENT entered into this 9th day of June, 2006, by and between LYNETTE J. MEREDITH (hereinafter referred to as "Mother") and BRIAN K. MEREDITH (hereinafter referred to as "Father"). NOW THIS AGREEMENT WITNESSETH THAT: WHEREAS, the Mother and Father are the parents of two minor children, namely, KEVIN D. MEREDI1H (age 14 years, born July 17, 1991) and KEI1HM MEREDI1H (age 10 years, born February2, 1996); and, WHEREAS, the parties wish to enter into a custody agreement relative to the custody of the parties' youngest child, Keith M Meredith. NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as follows: 1. The parties shall retain shared legal custody of the child. 2. Mother shall have primary physical custody of the child. 3. Father shall have partial physical custody of the child as follows: a. For thirty (30) days during the summer of 2006 and for the entire summer of 2007 and every summer thereafter. b. Father shall be entided to enjoy periods of custody with the child at other times, as per the mutual agreement of the parties. Absent the mutual agreement of the parties, the terms of this Order shall control. 4. The custodial parent shall ensure that the non-custodial parent has reasonable access to the child by telephone. 5. The parties shall share custody of the child on holidays by mutual agreement. 6. The parties shall keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to insure that the health, welfare and well being of the child is protected. 7. The parties shall do nothing that may estrange the child from either party or hinder the natural development of the child's love or affection for the other party. 8. Any modification or waiver of any of the provisions of this agreement shall be effective only if made in writing. 9. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 10. In the event of the breach of the agreement of the parties by any party, the nonbreaching party shall have the right to file a petition for contempt of court and to seek specific perlorrnance of the terms of the agreement of the parties. 11. The parties desire that this agreement be made an Order of Court through the Court of Common Pleas of G.unberland County, and further acknowledge that the Court of Common Pleas of G.unberland County has jurisdiction over the issue of custody of the parties' minor child. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound by the terms hereof, set forth their hands and seals the day and year herein set forth. WITNESSETH: 1/ ~(3.(J~ CUv~4-if- ~~ (SEAL) '~A/ ~.#d# (SEAL) RIAN K. MEREDITH COMMONWEALTH OF PENNSYLVANIA : :SS: COUNTY OF CUMBERLAND On this, the L day of JiJrvi:- , 2006, before, the undersigned officer, appeared L YNETfE J. MEREDIlH !mown to me ( or satisfactorily proven ) to be the same person whose name is subscribed to the within instrument, and ac!mowledged that he executed this agreement for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my COMMONWEALTH OF PENNSYLVANIA NolariaJ Seal Nathan C. Wolf, Notary PubIlc Carlisle Boro, Cl.mJerlMd County My Commission EJcpi"es Apr. 19, 200B Member, Pennsylvania Association Of Notaries COMMONWEALTH OF PENNSYLV d official seal. (SEAL) :SS: COUNTY OF CUMBERLAND On this, the L day of XtU!-- , 2006, before, the undersigned officer, appeared BRIAN K. MEREDI'TIf, !mown to me (or satisfactorily proven) to be the same person whose name is subscribed to the within instrument, and ac!mowledged that she executed this agreement for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my han official seal. ....90MMONWEA L TH OF PENNSYlVANIA Notarial Seal c::::n c. ~af, Notaty Public My~ vtJl'lOeI1and County M Expi-es Apr. 19 ~ ember, Pennsyrv . ,- arna Association Of Notaries (SEAL) (') c ..~ .......... '" = c';:) c,;.-" c_ c: ;;~~: I I.D w N U1 OJ ......,.j --I "".. :iJ -< o '-r " LYNETTE J. MEREDITH, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION-LAW v. : NO. 06- 3150 CIVIL BRIAN K. MEREDITH, Defendant : IN CUSTODY ORDER OF COURT "'\ NOW, this ~ day of J \) "e, , 2006, upon presentation and consideration of the attached Stipulation and Agreement and upon agreement of the parties, it is hereby ordered and decreed that the attached agreement is made an Order of Court. BY THE COURT, \tU4/J. Distribution: A'tacy B. Wolf, Esquire For the Plaintiff \ lI'Brian K. Meredith Pro S e Defendant '" J~l\:n8 LO ;8 ~~d 21 ~mr 900l ^B\;jlCi'~OrU,OUd 3H1 :\0 381::U()-03l\::1 R E eEl V E [) .! U L a 6 "ora V LYNETTE J. MEREDITH, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : NO. 2006-3150 CIVIL ACTION - LAW BRIAN K. MEREDITH, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 6th day of July, 2006, being advised that the parties have reached a stipulated Order, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, A,~ ~p :.. (, :!, ! c';,_ Ii