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custody
Conference.
At
such
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. ,
ERIC LYBRAND,
IN THE COURT OF COMMON PLEAS OF
plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
v.
KRISTY MANNING,
Defendant
NO. 95. (..(,13
CUSTODY
CIVIL TERM
ORDER OF COURT
AND NOW, upon consideration of the attached complaint, it is
hereby directed that the
appear before
~1\' tloo' (...Jt,.l.."r"'~~ the
/O:.?iJ(1..m., for a pre-Hearing
parties and their respective counsel
.
I.J- /;It.the
~ntl day of
conciliator, at
11,. ( (-n.btr t
~ , 1995, a
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. Failure to appear at the conference may provide grounds for
entry of a temporary or permanent order.
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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 FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
COURT ADMINISTRATOR, 4th FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 240-6200
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.
Noy 29 3 17 PH '95
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Koleen Marie Manning 26 South Hanover st.
Carlisle, PA
The child was born out of wedlock.
The child is presently in the custody of KRISTY MANNING, who
8 months old
.
ERIC LYBRAND, I IN THE COURT OF COMMON PLEAS OF
plaintiff .
.
. CUMBERLAND COUNTY, PENNSYLVANIA
.
v. I
.. . NO. 95 CIVIL TERM
.
KRISTY MANNING, .
.
. CUSTODY
.
Defendant .
.
COMPLAINT FOR CUSTODY
1. The plaintiff is ERIC LYBRAND residing at 504 West south
street, Carlisle, cumberland county, Pennsylvania 17013.
2. The defendant is KRISTY MANNING, residing at 26 South
Hanover street, CUmberland county, pennsylvania 17013.
3. The plaintiff seeks custody of the following child:
~ Present Residence
bml.
resides at 26 South Hanover street, Carlisle, Cumberland county,
pennsylvania.
During the child'S lifetime, she has resided with the
following persons and at the following addresses:
~ Address
Kristy Manning; 26 South Hanover st.
Pat, George, Carlisle, PA
Michael, Kandy,
and Sherrie Manning
The mother of the child is KRISTY MANNING, currently residing
DWl
Birth -
present
at 26 South Hanover street, carlisle, cumberland county,
Pennsylvania.
.
.
.
She is single.
The father of the child is ERIC LYBRAND, currently residing at
504 West south strest, Carlisle, Cumberland county, Pennsylvania.
He is single.
4. The relationship of plaintiff to the child is that of
father.
The plaintiff currently is residing at 504 West South street,
Carlisle, CUmberland county, Pennsylvania.
5. The relationship of defendant to the child is that of
mother.
The defendant currently resides with the fOllowing persons:
liAU
RelationshiD
Koleen Harie Hanning
Pat Hanning
George Hanning
Sherrie Manning
Hichael Hanning
Kandy Hanning
Daughter
Hother
Father
sister
Brother
sister
6. The 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.
7. The plaintiff has no information of a custody proceeding
concerning the child pending in a court of this Commonwealth.
8. The plaintiff is aware that George Manning, the
defendant's father, claims to have custody or visitation rights
with respect to the child, and he has been served with a copy of
this action.
9. The best interest and permanent welfare of the child will
~.,...,.."',.-... .......,
.
. .
be served by qrantinq the relief requested for reasons includinq
the followinq:
a. It is in the best interest of the child to form and
maintain a relationship with her father.
b. The father is able to provide for the physical and
emotional nseds of the child.
10. Each parent whose parental riqhts to the child have not
been terminated and the person who has physical custody of the
child have been named as parties to this action.
WHEREFORE, the plaintiff requests this Court to qrant him
custody of the child.
The plaintiff requests any other relief which is just and
proper.
Respectfully submitted,
~~,J~hh/
an Carey
Attorney for Pl<<{ntiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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.
The above-named Plaintiff, ERIC LYBRAND, verifies that the
statemente made in the above Complaint are true and correct.
Plaintiff understands that false statements herein are made
subject to the penalties of 18 Pa, C.S. 54904, relatinq to
unsworn falsification to authorities.
Date: ~ Iqr;
&U<, ~~
Eric Lybrand, aintiff
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ERIC LYBRAND,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-&(,0 CIVIL TERM
CUSTODY
plaintiff
v.
KRISTY MANNING,
Defendant
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the prothonotary:
Kindly allow, Eric Lybrand, plaintiff, to proceed in forma
DZlUDeris.
I, Joan carey or Philip Briganti, attorney for the party
proceeding in forma DauDeris, certify that I believe the party is
unable to pay the costs and that I am providing free legal
services to the party. The party's affidavit showing inability
to pay the costs of litigation is attached hereto.
~~.:1(
Attorneys for Plaintiff
LEGAL SERVICES, INC.
a Irvine Row
carlisle, PA 17013
(717) 243-9400
..
.
ERIC LYBRAND,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintitt
v.
NO. 95-
CUS'l'ODY
CIVIL TERM
KRISTY MANNING,
Detendant
AFFIDAVIT IN SUPPORT OF PETITION
FOR LEAVE TO PROCEED IN FORMA PAUPERIS
1. I am the plaintiff in the above matter and because ot my
tinancial condition am unable to pay the tees and costs ot
prosecuting, defending, or appealing the action or proceeding.
2. I am unable to obtain funds from anyone, including my
tamily and associates, to pay the costs of litigation.
3. I represent that the information below relating to my
ability to pay the fees and costs is true and correct.
(a) Name: Eric Lvbrand
Address: 504 West South street
Carlisle. PA 17013
Social Security Number: 197-66-2203
(b) If you are presently emplo~~d, state
Employer: pvrotech Inc. .
Address: Claremont Road
Carlisle. PA 17013
Salary or wages per month: $312.00
Type of work: Laborer
If you are presently unemployed, state
Date of last employment: NIA
Salary or wages per month: NIA
Type of work: NIA
(c) Other income within the past twelve months
Business or profession: Giant - 221.00/mo. for 6 mos.
Other selt-employment: None
~ .'
Cash:
$10.00
Checking Account: $0.00
Savings Account: None
Certificates of Deposit: None
Real Estate (including home): None
Motor vehicle: Make None
Year
Cost
Amount owed
stocks; bonds: $400.00 Savinas bonds
other: None
-.
(f) Debts and obliqations
Mortqaq8: None
Rent: None
Loans: Gordon's Jewelers - SlD.DO/mo.
Monthly Expenses: Phone-S70.00. Gas-S32.00.
Clothina-S30.00. car insurance-SlOO.DO
(q) Persons dependent upon you for support
(Wife) (Husband) Name: None
Children, if any:
Name:
Colleen Mannina
Aqe:
9 mos.
4. I understand that I have a continuinq obliqation to
inform the court of improvement in my financial circumstances
which would permit me to pay the costs incurred herein.
5. I verify that the statements made in this affidavit
are true and correct. I understand that false statements herein
are made subject to the penalties of 18 Pa, C.S. 4904, relatinq
to unsworn falsification to authorities.
Date:
~~it,~~\'\
Eric Lybrand, laintiff \
,
ERIC LYBRAND,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95 -6613 CIVIL TERM
CUSTODY
Plaint iff
v.
KRISTY MANNINO,
Defendant
AFFIDAVIT OF SERVICE
I, Traci Lederer, on this 30th day of November, 1995, served
a true and correct copy of a Custody Complaint and an Order for a
Conciliation Conference in the above-captioned case upon the
defendant's attorney, Thomas Devlin at 1802 Market Street, Camp
Hill, Pennsylvania, by certified mail, return receipt requested,
restricted delivery.
I verify that the statements made in this Affidavit of
Service are true and correct. I understand that faise statements
herein are made subject to the penalties of 18 Pa. C.S. 84904
relating to unsworn falsification to authorities.
nlY30 11?
;~
Traci Le erer
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ERIC LYBRAND,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-6613 CIVIL TERM
CUSTODY
KRISTY MANNING,
GEORGE A. MANNING,
PATRICIA MANNING,
Defendants
CUSTODY ORDER
AND NOW, this ~ day of April, 1996 upon consideration
of the parties' Consent Agreement, the following Order is entered
with regard Koleen Marie Manning, hereinafter referred to as the
child.
1. The plaintiff, Eric Lybrand, hereinafter referred to as
the father, and the defendant, Kristy Manning, hereinafter
referred to as the mother, shall share legal custody of the
child.
2. The mother shall have primary physical custody of the
chil d.
3. The father shall have partial physical custody of the
child according to the following schedule:
a. Every other Friday from 5:30 p,m, until
Sunday at 4:00 p.m, beginning Friday, March 8, 1996.
b. Other times mutually agreed upon by the parties.
4. The father and mother shall alternate Christmas Eve and
Christmas Day each year, one parent having the child from
Christmas Eve at noon until Christmas Day at noon and the other
parent having the child from Christmas Day at noon until December
~." ",'-",,,,
.
26th at noon.
6. The father and mother shall alternate the following
holidays: Easter, Memorial Day, the Fourth of July, Labor Day,
and Thanksgiving.
6. The father shall have the right to see the child on her
birthday at a time to be agreed upon by the mother and father.
7. The father shall have the right to partial custody of
the child for one week in the summer of 1996, and for two weeks
each summer thereafter. These weeks do not have to be taken
consecutively. The father shall give the mother two weeks notice
as to when his period of summer custody will take place, or if he
proposes to take the child out of state. The mother shall have
the right to have the child on weekends during that time unless
the father takes the child on a vacation trip including weekends.
The mother also has the right to take the child on a summer
vacation including n maximum of 2 weekends.
8. The mother and father, by mutual agreement, may vary
from this schedule at any time, but the Order shall remain in
effect until further Order of Court.
9. Each parent shall notify the other immediately of
medical emergencies which arise while the child is in that
parent's care.
10. The mother and father shall not move out of state
without having this Order modified.
11. The mother and father shall keep each other informed of
their current addresses and phone numbers.
12. Neither parent shall do anything which may estrange the
child from the other parent, or injure the opinion of the
child as to the other parent or which may hamper the free
and natural development of the child's love or respect for the
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other parent.
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.
.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-8813 CIVIL TERM
CUSTODY
ERIC LYBRAND,
Plaintiff
KRISTY MANNING,
GEORGE A. MANNING,
PATRICIA MANNING,
Defendants
This Agreement is
CONSENT AGREEMENT
entered on this ;L/
day
,4pr'~
of Mareh,
1998, by the plaintiff, Eric Lybrand, and the defendant, Kristy
Manning, and her parents, George A. Manning, and Patricia
Manning. The plaintiff is represented by Joan Carey of Legal
Services, Inc.; the defendants are represented by Thomas Devlin.
The plaintiff, hereinafter referred to as the father, and
the defendant, Kristy Manning, hereinafter referred to as the
mother, agree to the entry of the following Custody Order
regarding Ko1een Marie Manning, hereinafter referred to as the
child.
1. The father and mother will share legal custody of the
ch il d.
2. The mother will have primary physical custody of the
ch il d.
3. The father will have partial physical custody of the
child according to the following schedule:
a. Every other Friday from 8:30 p.m. until
Sundays at 4:00 p.m. beginning Friday, March 8, 1998.
b. Other times mutually agreed upon by the parties.
.-, -... "".. -.~' -.
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4. The father and mother will alternate Christmas Eve and
Christmas Day each year, one parent having the child from
Christmas Eve at noon until Christmas Day at noon and the other
parent having the child from Christmas Day at noon until December
26th at noon.
5. The father and mother will alternate the following
holidays: Easter, Memorial Day, the Fourth of July, Labor Day,
and Thanksgiving.
6. The father will have the right to see the child on her
birthday at a time to be agreed upon by the mother and father.
7. The father will have the right to partial custody of
the child for one week in the summer of 1996, and for two weeks
each summer thereafter. These weeks do not have to be taken
consecutively. The father will give the mother two weeks notice
as to when his period of summer custody will take place, 01' if he
proposes to take the child out of state. The mother will have
the right to have the child on weekends during that time unless
the father takes the child on a vacation trip including weekends.
The mother also has the right to take the child on a summer
vacation including a maximum of two weekends.
8. The mother and father, by mutual agreement, may vary
from this schedule at any time, but the Order shall remain in
effect until further order of court.
9. Each parent will notify the other immediately of medical
emergencies which arise while the child is in that parent's care.
. .'_'V"'H__"._'~"'.""."_"
10. The mother and father will not move out of state
without having this Order modified.
11. The mother and father will keep each other informed of
their current addresses and phone numbers.
12. Neither parent will do anything which may estrange the
child from the other parent, or injure the opinion of the
child as to the other parent or which msy hamper the free
and natural development of the child's love or respect for the
other parent.
WHEREFORE, the parties request that an Order of Court be
entered to reflect the above terms.
~l?il'~W\i7JN\~
ERIC LYBRA ,Plalntiff
&~U@~.
AN CAREY
Attorney for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
-11-'74 ~<?'~ 9t.,
GEORG A. MANNING, ~efendant
.
PATRICIA MA N NG,
~A.
THOMAS DEVLIN
Attorney for Defendant
1802 Market Street
Camp Hill, PA 17011
(717)730-9878
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BRIC LYBRAND,
PlaintiU
v.
lCRIS'l'Y HANNING,
GBORGB A. HANNING,
PA'l'RICIA HANNING,
Defendants
.tY
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IN 'l'HB COUR'l' OF CONNON PLUS OF
CUMBBRLAND COUN'l'Y, PBNNSYLVANIA
CIVIL AC'l'ION - LAW
NO. 95-6613 CIVIL 'l'BRH
CIVIL AC'l'ION - CUS'l'ODY
.,.&.
AND NOW, this"]~ day of 1996, the Conciliator
being advised that the partie in the above case have reached an
agreement, the Conciliator relinquishes jurisdiction.
eel Joan Carey, Esquire
'l'homas Devlin, Esquire
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