HomeMy WebLinkAbout94-04973
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The mother of the child Is RACHEL L. SEBERS, currently residing at 88 Cave HIli
Drive, Carlisle, PA 17013. She Is not married.
The father of the child Is MERL A. NEIL, currently residing at 178 Rustic Drl'le,
Shlppensburg, PA 17257. He Is not married,
4. The relationship of the Plaintiffs to the child Is that of maternal grandparents.
The Plaintiffs currently reside with the natural mother, RACHEL L. SEBERS and the child In
question.
5. The relationship of the Defendant, RACHEL L. SEBERS to the child Is that
of naturEll mother.
The relationship of the Defendant, MERL A. NEIL to the child Is that of natural
father. The Defendant currently resides with his mother, MARY E. NEIL, at 178 Rustic Drive,
Shlppensburg, PA 17257,
6. Plaintiffs have not participated as a party or witness, or In any other capacity
in any other litigation concerning the custody of the child in this or another jurisdiction.
7. The Plaintiff has no information of a custody proceeding concerning the child
pending in a Court of the Commonwealth.
8. The 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,
4
111,."......._.-
9. The best Interest and permanent welfare of the child will be served by
granting the relief requested because: The child Is In need of health Insurance, and can be
Included under Plaintiffs' Health America health Insurance, if they formally have legal custody of
the child. Neither RACHEL L. SEBERS, the natural mother, nor MERL A. NEIL, the natural
father, are In a position to purchase health Insurance for the child.
10. Each parent whose parental rights to the child have not been terminated and
the persons who have physical custody of the child have been named as parties to this action.
No othor persons are know to have or claim a right to custody or visitation of the child.
11. Attached as exhibit "A" is Defendant RACHEL L. SEBERS acceptance of
service of this Complaint, and Joinder in request that the relief sought by Plaintiffs be granted.
12, Attached as exhibit "A" Is Defendant MERL A. NEIL acceptance of service
of this Complaint, and joinder in request that the relief sought by Plaintiffs be granted,
WHEREFORE, the Plaintiffs request this Court to grant primary physical custody
of the child, JAKE AMOS SEBERS, to the Plaintiffs.
FLOWER, MORGENTHAL, FLOWER & LINDSAY
Attorneys for Plaintiff
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Date: .' ~,~ ())
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By (~7r Ii ( _ l (://1 )!ry\,ytml" J\ .
JamllS D. Flower, Jr. I,'" . I ," / .
11 East Hfgh Street / </';'lfiI1.,j' 7
Carlisle, PA 17013 ,
(717) 243-5513
1.0, No. 27742
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CHARLBS SBBBRS AND NANCY L.
SBBBRS,
: IN THE COURT OF COMMON PL8AS OF
:CUMBERLANn cOUNTY, PENNSYLVANIA
:
:NO. 4973 - CIVIL - 1994
:
:
:CIVIL ACTION - CUSTODY
Plaintiffs
v
RACHEL L. SEBENS AND MERI, A.
NEIL,
Defendants
PRIOR JUDGE: JUDGE J. WESLEY OLER, JR.
CONCILIATION CONFERENC1J1 SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the
following report:
1. The pertinent information pertaining to the child who is
the subject of this litigation is as follows:
Jake Amos Sebers, born August 24, 1994.
2. A Conciliation Conference was held November 10, 1994, with
the following individuals in attendance:
The Maternal Grandparents, Charles and Nancy Sebers, with
their counsel, James D. Flower, Jr., Esquire. Also present
was the Mother. The i'ather was not present but had been
notified of this conference.
3. The child in question is currently in the custody of the
Maternal Grandparents pursuant to an Order of Court. The
natural Father and Mother agree with this custody arrangement
primarily to insure that the child has medical insurance.
The Mother resides with her parents. Father visits the child
as the parties agree.
4. The Conciliator recommends an Order in the form as attached.
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Hubert x. Gilroy, Es
Custody Conciliator