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Home My WebLink About06-4706 Q ANDREA L. BRYER, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 0" - 470& (...I,ll ..ft.n- SCOTT R. BRYER, Defendant : CIVIL ACTION - LAW : IN DIVORCE AND 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 on the _ day of , 2006 at .m., at Carlisle, Pennsylvania, for a 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. FOR THE COURT, Date of Order: BY: Custody Conciliator 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 FROTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE P A 17013 (717) 249-3166 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 scheduled conference or hearing. v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA . ; NO. Cl"- t..{70~ c.J"d hr... ANDREA L. BRYER, Plaintiff SCOTT R. BRYER, Defendant : CIVIL ACTION - LAW : IN DIVORCE AND 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 may 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 rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOUW 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 32 SOUTH BEDFORD STREET CARLISLE PA 17013 (717) 249-3166 Le ban demandado a usted en la corte. Si usted qui ere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y pueda entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE P AGAR TAL SERVICIO. VA Y A EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENC1JENTRA ESCRITA ABAJO PARA A VERlGUAR DONnE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE PA 17013 (717) 249-3166 ANDREA L. BRYER, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ~ NO. O(,-J..I'lD!... (2'(J~LJ~ . SCOTT R. BRYER, Defendant : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY COMPLAINT FOR DIVORCE UNDER SECTION 33011C)OR (0) OF THE DIVORCE CODE AND FOR CUSTODY AND NOW, comes the above-named Plaintiff, Andrea L. Bryer, by her attorney, Mark A. Mateya, Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant upon the grounds hereinafter more fully set forth as well as full custody of MATTHEW BRYER. DIVORCE UNDER SECTION 33011 CI OF THE DIVORCE CODE 1. Plaintiff is ANDREA L. BRYER., an adult individual who currently resides at 1610 Longs Gap Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. All legal papers may be served on Plaintiff by service on her Attorney, Mark A. Mateya, Esquire with a mailing address of P.O. Box 127, Boiling Springs, Pennsylvania 17007. 3. Defendant is SCOTT R. BRYER, an adult individual who currently resides at 216 Garland Drive, Carlisle, Cumberland County, Pennsylvania 17013. 4. Plaintiff and Defendant are bona fide residents of the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 5. The Plaintiff and Defendant were married on January 25,1989, in Greenville, South Carolina. 6. There have been no prior actions of divorce or for annulment of marriage between the Parties in this or any other jurisdiction. 7. The marriage is irretrievably broken. 8. Plaintiff is a member of the anned services of the United States; Defendant is not a member of the anned services of the United States or any of its allies. 9. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. 10. Plaintiff requests the Court to enter a Decree of Divorce. COMPLAINT FOR CUSTODY II. Paragraphs I through 10 above are incorporated herein by reference as if set forth completely herein. 12. Plaintiff seeks primary physical custody of Matthew Bryer, (hereinafter referred to as "Child"), born February 10,1990, who currently resides at 1610 Longs Gap Road, Carlisle, Cumberland County, Peunsylvania 17013. 13. The child Matthew Bryer was born in wedlock. 14. The child is presently in the custody of Plaintiff, Andrea Bryer, at 1610 Longs Gap Road, Carlisle, Cumberland County, Pennsylvania 17013; Plaintiff and Defendant are sharing custody evenly. 15. During the past five years the child has resided with the following persons at the following addresses: A. At 216 Garland Drive, Carlisle, Cumberland County, Pennsylvania with Scott R. Bryer and Andrea L. Bryer. B. At 1610 Longs Gap Road, Carlisle, Cumberland County, Pennsylvania with Andrea L. Bryer. 16. The Mother of the child, Andrea L. Bryer, is currently residing at 1610 Longs Gap Road, Carlisle, Cumberland County, Pennsylvania, and she is married. 17. The Father of the child, Scott R. Bryer, is currently residing at 216 Garland Drive, Carlisle, Cumberland County, Pennsylvania, and he is married. 18. The relationship of the Plaintiff to Matthew Bryer is that ofnatural Mother. 19. The relationship of the Defendant to Matthew Bryer is that of natural Father. L.1C~ .':'-"'...~' 20. The Plaintiff has not participated as a party or a witness, or in any other capacity, in other litigation concerning the custody of the child in this or another Court. 21. Plaintiff has no infonnation of a custody proceeding concerning the child pending in a Court of this Commonwealth or any other state. 22. Plaintiff does not know of a person not a party to this custody proceeding who has physical custody of the child or claims to have custody or visitation rights with re~ect to the child. TIllS SPACE LEFT INTENTIONALLY BLANK 23. The best interests and pennanent welfare of the child will be served by granting the relief requested because: a. Plaintiff is the Mother of the child. b. Plaintiff is presently seeking a divorce. c. Plaintiff has been the primary caregiver of the child since his birth. d. Plaintiff can continue to provide a stable home for the child. e. Defendant has been domineering to the child. WHEREFORE, the Plaintiff requests this Honorable Court to grant primary physical custody of the child to Plaintiff pending a custody conciliation. Respectfully submitted, ~.;.,~ Attorney I.D. No. 78931 P.O. Box 127 Boiling Springs, P A 17007 (717) 241-6500 Dated: <8//-; If) ~ { { Attorney for Plaintiff VERIFICATION I, ANDREA L. BRYER, verify that the facts set forth in the foregoing Complaint for Divorce and Custody are true and correct to the best of my knowledge, infonnation, and belief. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. ~ 4904, relating to unsworn falsification to authorities. DATED: 15-po;.~ ~~- ~ (") ...., .l& s; = ~ ~ (> ~ = -0 fr'~ C7' \\- 7':. G"- lJl (t' :1>0 ~:!l - L"~I <= *" ...j ~ ZS G") ~ (o.'~ :oF;; -- .(;:) r:-<;;"::-- 0"1 e3'? ~ Vl , ~t) Q ~ P --IU ~ ~ 20 "'" a~ - D ~C) :x c ?( ~ 2; 'f? Om l' =< N 35 - -.:> c:, N -< ~ v. t:>-. d ~ a .; .t- ? I" :>. ~ l+. ..:t ~ t 1- ? ANDREA L. BRYER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, 06-4706 CIVIL ACTION LA W SCOTT R. BRYER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, August 22, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. . the eonciliator, at 4th Floor, Cumberland County Courthouse, Carlisl~,_ on .._TII....~s,<l.ll.y,September 21, 2006 at 10:30 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 aecomplished, to de line and narrow the issues to be heard by the court, and to enter into a temporary order. All children age live or older may also be present at the conference. Failure to appear at the conferenee may provide grounds for entry of a temporary or penn anent 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 ac 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 individuals having business before the court, please eontaet our oftiee, All arrangements must be made at least 72 hours prior to any hearing or business before the court, You must attend the seheduled eonference 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 Assoeiation 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 - # ~ ~ """j,~,tI ~ 9tl,(p . #pp~ ~ 1'c1./-6 ~W P ~~ ~ -A 1<7./-6 \/lNV/\lASi\I!\.:Id "Nn~r, no ',,'.C '.-~'^'n'"' I\.i.. j j~.", ,'. "',:~.'dVI/! v 2 S :0I11V 1- d3S 90al Al:lVlOj\iOHlOUd 3Hl :10 38H'!O-0311:l ANDREA L. BRYER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 06-4706 SCOTT R. BRYER, Defendant CIVIL ACTION - LAW IN DIVORCE AND CUSTODY AFFIDAVIT OF SERVICE AND NOW, this 8th day of September. 2006, comes Mark A. Mateya, Esquire, Attorney for Plaintiff, who, being duly sworn according to law, deposes and says that: 1. A Complaint for Divorce and Custody was filed to the above term and number on August 16, 2006. 2. On August 16, 2006, a certified copy of the Complaint in Divorce was sent to the Defendant via certified mail, restricted delivery, return receipt requested pursuant to Pa. R.C.P. 1920.4. A copy ofthe Certified Mail Receipt is attached hereto as Exhibit "A" and is incorporated herein. 3. On August 16, 2006, a certified copy of the Complaint was sent to the Defendant via first class mail, postage prepaid. A copy of the Certificate of Mailing is attached hereto as Exhibit 'B' and is incorporated herein by reference. 4. On or about September 8, 2006, undersigned counsel for Plaintiff received the Certified Mail which had been previously sent to the Defendant which was refused by the Defendant. Attempts were made to deliver the Complaint on August 17th, August 25th, and September 1 st. A copy of the envelope returned to Plaintiff's counsel is attached hereto as Exhibit "C" and is incorporated herein by reference. Respectfully submitted, ~:t~wre Attorney J.D. No. 78931 P.O. Box 127 Boiling Springs, P A 17007 (717) 241-6500 (717) 241-3099 Fax Attorney for Plaintiff ... . . U.s. Postal Service)'" CERTIFIED MAILM RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) IT" U1 IT" <0 U1 ru rn ru =r- CJ CJ Return Reclept Fee CJ (Endorsement Required) CJ Restricted Delivery Fee CJ (Endorsement Required) U1 CJ Total Postage & Fees Certlfled Fee *.2:; ~::i=j ~.111g5 ~3.70 $ rn ~ to .scali j' 'UR.. I'- ~"APiNO:-'"''-'''---''''.''' ___._..._J.2..~..____........__._.. t':;:;;'.~*~Ii5 t-f~PA--1?-!o1Y}L ~.B" ~SP, .... . . U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: JY)1=lR.1< A. ~ ~ I !SS~. p.O. 13o'X )~1 ~lllAJG :5Pt<..\Nl7S PA J 700'1 One piece of ordinary mail addressed to: 5 c.o71 R. ."Bt?y J:/c' ~)~ 1/ AIGLAJJb 1)R.1 V E CAltLI5LE PA ]10)3 PS Form 3817. Mar. 1989 a: a... u.J III t:l t:l a: z w I- ..... 0 III ocr,. f- CJ':JQ..I~ ..:z 0.......(/)1;:)(,(1:::) <I: 1"-'0 .'I..t:l'- :E: III Z (.;I<I: . ~ =, ::J d <I: o en rQtle ..;;: ~~ ~.. i~ ~~ } Lfl L.n'i' al~ .~ c:::J~ -f:A-:5 o o o o o -- ... ~ ~ ~ ?,~ t '~"f- %~~? ~.~~~ ~~?,~ '"" ~ ~ ';.L. '7 ~ '7 -:j .- % ~ b ~ ~ ~ o~~ ~~~, ~~~.p ~T~~ . ~~\~ 00 w ~;p ~'1 ,. <3. ~ ~'h\ ~ ~.\ .... "". U' ~\. P \" ..h\ "". ~;\ 4~"l" ~\ ~, t' \ ~ / ----, ~~'I\\\\ . . "\ . ~ ~ /....~'..,.... \, .<'\ '~~ ';" \ .-I ..~t;~; . \ \,.. \. ' .. "~'" ' .... , .'" . v\ ~lo-,~ <. .... , ~,\, ~ t 'li> ~ % \' ""'d \ ~ ~. ~.....' ,~~C ., '<it~,.....,\:: . ~", ~ ' '~\. -' ,,\,. r" , ~- ~ ':'"y; \ ~. .~ \' \ - 0 __ , ,. , '<' 0 11... Sl >~ " _~ ' ~ 1. ~ ~ ~ ~ ,-,,,,. \ \ ~ ,'. ~ .. ~ ~~ ~ ~1\\ ~\ \'J~~-\' '} ~\~,oQ '\, " "t'~ ..... _^ ./. ~~.... ~ . - ... "'...... d' ~. ~ , \~ i,\,,,, ;;':~~.~ ~ \\~"'f:" l1.) '<' " .:. \'\ <.; '" " , ..- -:- ~ "9 1\ (if> \ tn \ \J\ _ 'f "\ '>>0 . \ (:) -:- 0 ", \ I J ~ , \. -:- (\) -:- ~ ~ \)\ 0, ":.,...; \ .....' ~~ ~ ~\ \ .----- .' - 1'; C,) ~,-l MAR 0 .2 2007 )7 <j ANDREA L. BRYER, Plaintiff : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-4706 CIVIL ACTION - LAW SCOTT R. BRYER, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 2nd day of March, 2007, being advised that the parties hare reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, A~ ~ r-) ~ ~ -..J ::m: :P' :;;0 , N c_ z ':::2 -0 3 ~ ~ rn'fd -0\:3 -:D, i.:) (:'J =2'~1 (:~r") :~rn 9 ~ :.< - ., o \D