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HomeMy WebLinkAbout06-5823 - .' STEPHANIE L. EBY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO. 01-- Sf;)3 {!'v;LY~ : CIVIL ACTION - LAW : CUSTODY v. CHRISTOPHER L. EBY, Defendant COMPLAINT FOR CUSTODY 1. The Plaintiff is Stephanie L. Eby, residing at 1011 Harriet Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Christopher L. Eby, residing at 906 North Calvert Street, Apt. 3R, Baltimore, Maryland 21202. 3. Plaintiff seeks custody of the following child: NAME PRESENT RESIDENCE AGE DOB David Eby 1011 Harriet Street Carlisle, PA 17013 1 9/18/05 The child was not born out of wedlock. The child is presently in the custody of Plaintiff/Mother, Stephanie L. Eby, who resides at 1011 Harriet Street, Carlisle, PA 17013. During the past five (5) years, the child has resided with the following persons and at the following addresses: NAME RESIDENCE DATE Stephanie L. Eby 634 Melvin Dr. Baltimore, MD 21230 Date of birth - 12/15/05 Stephanie L. Eby, Kelly Jester, and David & Cynthia Jester 10 11 Harriet St. Carlisle, PA 17013 12/15/05 - Present .- The mother of the child is Plaintiff, Stephanie L. Eby, currently residing at 1011 Harriet St., Carlisle, PA 17013. She is married to Defendant. The father of the child is Defendant, Christopher L. Eby, currently residing at 906 North Calvert Street, Apt. 3R, Baltimore, MD 21202. He is married to Plaintiff. 4. The relationship of the Plaintiff to the child is that of Mother. The Plaintiff currently resides with the following persons: NAME David Eby RELATIONSffiP Son Kelly Jester Sister David & Cynthia Jester Parents 5. The relationship of the Defendant to the child is that of Father. The Defendant currently resides with the following persons: NAME RELATIONSffiP Unknown Unknown 6. 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. However, Defendant/Husband, on September 8, 2006, did file a "Complaint for Absolute Divorce" in Baltimore City, Maryland. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. However, Defendant/Husband, on September 8, 2006, did file a "Complaint for Absolute Divorce" in Baltimore City, Maryland. . 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: A. Plaintiff/Mother has been the sole care giver to the child since the date of birth. B. It is believed, and therefore averred, that Defendant/Father's employment requires extended periods of overseas habitation. 8. Each parent whose parental rights to the child have not been terminated, and the person who has physical custody of the child, have been named a party to this action. WHEREFORE, Plaintiff requests the Court to grant custody of the child. Respectfully submitted, FRIEDMAN & KING, P.C. DateO crd~ Y-: ;)1jp J Attorney for Plaintiff .,' VERIFICATION I, Stephanie L. Eby, hereby acknowledge that I am the Plaintiff in the foregoing action; that I have read the foregoing Complaint for Custody; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. ~rY~ Stephanie L. Eby DatedO~ Y-: ~ ~ ~ ~ ~ ~ !v w R.J C' ~ ~ l) ~f it! ':f5 ~ o :"" ~;- ;::.~:; .r:.__ c)""'t. , ~:,; ~~ .) -"-1 ! ~- ..r:" ~,.) ::,.t C') - :~ ~ STEPHANIE L. EBY PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 06-5823 CIVIL ACTION LAW CHRISTOPHER L. EBY DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, October 11, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, November 14, 2006 , the conciliator, at 9:00 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 hearinl!. FOR THE COURT. By: Isl Dawn S. Sunday. Esq. (fJi 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 17013 Telephone (717) 249-3166 ~fp ~ ~ ~ W-I/-W . w.z. ~ ~u, 1t?'JI' 0/ ~I Y ~ ~ ~ -~ ~",'II-",I \i\i\JV'\l ft, S\J'I' 1';3 ,J II~in.~'-,' ;..',.'-:.: 'UC:J I\J,J\,,', f." ' ;:" :"'j' :). :'....,..(1U\U''\t''\ ".J'.~:/ Vl h..J 8 S :01 t'Jij II 1:10 900Z NOV 15 2006 rl Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEPHANIE L. EBY vs. 06-5823 CNIL ACTION LAW CHRISTOPHER L. EBY Defendant IN CUSTODY ORDER AND NOW, this 14th day of November , the conciliator, being advised by plaintiffs counsel that all custody issues have been resolved by agreement ofthe parties, hereby relinquishes jurisdiction. The custody conciliation conference scheduled for today, November 14,2006, is cancelled. FOR THE COURT, Dawn S. Sunday, Esquire Custody Conciliator BS :6 l'l~ 91 AON 9DOl AtIV10i\!ij;.LtUtJd 3Hl :JO 38U:jO-D3lt1