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Home My WebLink About94-06353 " , , , I , , , ., , " , , " , . , , v' I I , -, " .~ ,'I' ~I , '. , " , " I' a' , , I , .', 1 ., , , " '-1 1 " 'I': , i I '.' r , '. , to,,' " , i' , " "il, .. , , ~' 1 , , " F,' ,.. I.' ' , 'i, 1," I'" .,' I, ,;I', .i,1' Hl\ {(~;'; , " ..~'\' , Lr:, ;I'i' , , ~'i; , , , K .' l" {'i , " 1 , "L' , " " " -l ~ I ,. - J 'I'f) V) tt). ~ .' . (} " . * 'IN 'J'HB COUR'J' OF COHHON PLEAS OF ,CUMBBRLAND COUN'l'Y, PENNSYLVANIA , 'CIVIL AC'l'ION - LAW . ;NO.'1y-\..,z,S-"3CIVIL 19 , CUS'l'ODY / VISITATION M~I,-\'!>"" '(0,\/1) . Plainti.ff V * M\(le.L" \ tklfJI1trDefendant ORDER OF COUR'l' (\\0 v. 10 (C1 C, '{ AND NOW, this (date) , upon consideration of the attached complaint, it is hereby directed that the parti~ aQd their respective counsel appear before, c,,,,,I..<<'( [. I)'l(t~... t-~I , the cone liator, at ',,' (\l, I- ,~ ). '" 11(- on the 0 h day of , ......" , 19 5 , at 'M., or a Prehearing Custo y Con erence. At such confer nee, an effort mll 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. Bither party lIIay bring the child who is the subject of this custody action to the conference, but the child/children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THB COURT: !'ri YOU SHOULD 'J'AICE THIS PAPER 7'0 YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO 7'0 OR TELEPHONE THE OFFICE SE'J' FORTH BELOW 7'0 FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADHINISTRA'l'OR COURTHOUSE, 1i'OURTH FLOOR CARLISLE PA 170H (717)240-6200 LAW omcu YOfFE. YO"E, P.C. . SlItTl! 103 . nUllNA11I AYINUIl CAMP HILL. PA 17011 (111) 975-1131 N~! ~_~~':~t~!( MELISSA YOUNG. IN THE COURT OF COMMON PLEAS OF plaintiff CUMBERLAND COUNTY. NO. 14- (P353 PENNSYLVANIA 't' ,II j. I . .{. .lk-L:, A.~ ve. MICHEAL DANNER. Defendant CIVIL ACTION . CUSTODY QRDER OF COURT ":(ou, Micheal Danner, defendant, he,ve been sued in Court to obtain custody of the child Dalton Danner. You are ordered to appear in person at . on . at , _om., for a conciliation or mediation conference. a pretrial conference. a hearing before the Court. If you fail to appear as provided by this order, an order for custody, partial custody or visitation may be enter~d against you or the Court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER .:JR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Court Administrator Cumberland County Courthouse Fourth Floor Carlisle, PA 17013 B'i THE COURT: J. MELISSA YOUNG, IN THE COURT OF COMMON PLEAS OF plaintiff CUMBERLAND COUNTY, PENNSYLVANB VS. NO. MICHEAL DANNER, Def endant CIVIL ACTION - CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Melissa Young, residing at Lot 416 Mountainview Terrace, Dover, pennsylvania 17315, York County. 2. The defendant is Micheal Danner, residing at 5950 Blue Mountain Trail, Eno1a, Pennsylvania 17025, cumberland County. 3. plaintiff seeks custody of the following child: ~ Present Residence Lot 416 Mountainview Terrace, Dover, pennsylvania 17315, York County. The child was born out of wedlock, ~ 3 Dalton Danner The child is presently in the custody of Melisaa Young, who residee at Lot 416 Mountainview Terrace, Dover, penney1vania 17315, York County. During the past five yoars, the chile has resided with the following persons and at the following addresses: ~ Address ~ Melissa Young Scott Beers Marcus Beers Lot 416 Mountainview Terrace, Dover, Pennsyl vania Late June 1994 to Present Michea1 Danner Julia Weaver 4415 valley Road, Enola, pennsylvania December 1993 to Late June 1994 Micheal Danner Melisaa Youn'l Julia Weaver 4415 valley Road, Enola, pennsylvania Mayor June of 1993 until December 1993 . . . VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made lubject to the pena1tiel of l8 Pa.C.S. 54904 re1atinq to unsworn falsification to authoritiel. ~ ~. -:"1- I' \() ~ r;, , >:"l.. ~~~ .'" ~ I'; ~ ' . '''*' '. . r--j , j , ~ .") ~~ ~ J~ ~ ............ i.... ........ ...... .'- ~ It; , ~ ,_:1,',; ~~ ~ ~~ -- \~ o - .. ," " , II ;\;~I' '.\.1.',' i:"t'J'll 1n.:fJ. ~ ,)1 ,I ,." i";!I" " '.., It I. .. .. .... .. , ;.\ ~ ! 11 ., " "f-c' ' 'n'6 "-"';'",1,,/ Ur: . Ii ~. ..',1 ,. . ',;I", .' . ~ . .. LAWOPII'ICU' YaFFE. YaFFe, P.C. IUITl20S . 2!-UII'lATI AVINUI CAMP HILL. PA 17011 (717) 975.113. .;;~: "1"1 MOTION FOR ENTRY OF CUSTODY ORDER 1. In the above captioned action, the parties have aqreed to the' entry of a Custody Order. The Stipulation between the parties as well as the aqreed to CUBtody Order are attached hereto as Exhibit "A". 2. A copy of the Complaint in this matter was served upon the defendant. A copy of the Accsptance of Service siqned by the defendant is attached hereto as Exhibit "B". WHEREFORE, Counsel requests that the Courl: enter an Order identical to the aqreed to Custody Order attached hereto as part of Exhibit "A". Respectfully Submi t ted, YOFFE ''fOFFE, F .C. B ), :,L' .)J d~ i~dEFFRE N. YOFFE, ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, FA 17011 (717) 975-1838 Attorney ID No. 52933 . CUSTODY ORDER <"'{II AND NOW, tl.J.s ,,:> . \ " I \. day of,~,.('(J.,,\,-. . 1994. in reference to the custody riqhts of the parties to the minor child, Dalton Danner (D,O.B. 1/5/91), IInd in consideration of the stipulation attached hereto. the fol1owinq ORDER is entered: 1. Melissa Younq, hereafter Mother, shall have primary physical custody of Dalton Danner. 2. Michea1 Danner, hereafter Father, shall have partial physical custody of Dalton Danner. 3. Leqa1 custody of Dalton Danner shall be shared equally by Mother and Father. 4. Father shall have partial physical custody of Dalton Danner at such times that are mutually aqreed upon between Mother and Father. BY THE COURT: / I I ~- / -- c ( ,'-f'". , '\ '/u (d J. EXHI81T "A" DEe 9 IU ;.4 "I '9y .iI' ,. I ! !,j;r " " f,: ., , "y " II,', , , , , , ," ,', .' i'J ;l-t ,', . ,. MELISSA YOUNG. I IN.THE COURT OF COMMON PLEAS OP plaintiff I I CUMBERLAND COUNTY, PENNSYLVANIA VI. I I NO. 94.6353 MtCHEAL DANNER, I Defendant I CIVIL ACTION . CUSTODY A~CEPTANCE OF SERVICE I accept service of the Custody Complaint filed in the above captioned action. Dater lI/lH/ 'N , , I I.. . / -- MIe~~ ~~E;--- 5950 Blue Mountain Trail Eno1a, PA 17025 EX;;;:rr "B" . " CERTIFICATE OF SERVICE The undersigned certifies that on the ~~day of ~~~, 1994 it served by first claB8 mail, postalJe prepaid, a copy of the Motion for Entry of Custody Order on the fo11owinq' Michea1 Danner 5950 Blue Mountain Trail Eno~a, PA 17025 YCFFE , YOFFE. P.C. :;;03 . . NO. J d)Ul~ I: MELISSA BEERS (fonncrly Mclissa Young). Plaintill' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v NO, 94.6353 MICHEAL DANNER, Detendant CIVIL ACTION. CUSTODY ORDER OF COURT AND NOW. this Jb~ day of ~~ . 2001 upon review and consideration of thc Stipulation and Agreement for Appointment of Guardian of Minor Child. a copy of which is attached hereto. said Stipulation and Agreement is hereby APPROVED, ADOPTED, MERGED and INCORPORATED herein as the Order of this Court, BY~ J. cc: . Melissa L. Van Eck, Esquire ,(<"fQ..... .~ . · ~J.. I 1/_,;)0.01 y..... . (Iq I(-~O -"'l, 11rJal....' '.' l11111J.J \1 i1:'r:1. ',,)fAIlY (I:. 01 "ClIJ 20 Ilillq: 57 CUMUl:.!lu'I,L) CUUNTY PENNSYLVANIA , . " ,"il ~ .." ,; I,' ,iI'. I 6. Plaintill', Melissa Bccrs, shall cxcrcisc physical custody of the minor child during all holidays, including but not limited to, Thanksgiving. Christmas and Eastcr, 7, The parties will kecp cach other adviscd immcdiately relative to any emcrgencics concemingthe child and shall furthcr take allY necessary stcps to insure that the hcalth, welfare. and well being of the child is protected, 8, Plaintiff and Defendant shall have reasonable telephone contact with the minor child during periods when the minor child is in the care and custody of Marlene Danner. 9. The parties agree that in making this Agreement the best interest of the minor child is the primary concem, and all parties shall have the right to modify this Agreement if the interests of the minor child will be better served through modification of same, 10, The parties agrce that in making this Agrcemcnt that there has been no fraud, concealment, overreaching, coercion, or unfair dealing on the part of the other, all parties have consulted with counselor have had the opportunity to consult with counsel, and all parties understand the tenns of this Agreement. 11. The parties desire that this Agreement be made an Order of Court through the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberlancl County has jurisdiction over the issue of the guardianship and custody of the minor child and shall retain suchjurisdiction should circumstances change. lk><.....,. 111111J I .. . 12, This Agreement shall become nullllnd void on June 3, 2002 and the prior Order of December 8, 1994, shall be in full fon,e and e1Tect, 13. The parties agree that this Agreement shall be etlcctive immediately upon signature of all parties and its validity is not contingent upon Court approval, 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 above set forth, 1/1d~(:I/~if!!l JI 1, ~l Witness ~ ~dt!l..tJ4L '- c";I tjdJ'____ Witness . ///'i/.., D;de / 1/!tJ!/}~ (y' /i;/( fai 11!r J(j Witness Die I ' _.._ I1f111J I Mlfl!/V)P ~ "'1t-/_~'::';'f MfCheal Danner ---/r7a_d~" 4---. Marlene Danner "'- L. , '