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Home My WebLink About07-0263Gregory W. Myers, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Tanya Unger, No. C5'~-_~~ CIVIL Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Gregory W. Myers, residing at 1153 Belvedere Street, Carlisle, Cumberland County, Pennsylvania. 2. The defendant is Tanya Unger, residing at 840 Baltimore Pike, Gardners, Cumberland County, Pennsylvania. 3. Plaintiff seeks shared custody of the following children: Name Quentin Myers Jerzee Myers Present Residence 1153 Belvedere Street Carlisle, Pa 17013 840 Baltimore Pike Gardners, Pa 17324 1153 Belvedere Street Carlisle, Pa 17013 840 Baltimore Pike Gardners, Pa 17324 DOB Age 6-13 -00 6 Years 7-14-02 4 Years The children were born out of wedlock The children are presently in the custody of Tanya Unger, residing at 840 Baltimore Pike, Gardners, Cumberland County, Pennsylvania and Gregory W. Myers, residing at 1153 Belvedere Street, Carlisle, Cumberland County, Pennsylvania. During the past five years, the children have resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Tanya Unger & 909 Old York Road 2000-2003 Gregory W. Myers Carlisle, Pa 17013 Tanya Unger 840 Baltimore Pike 2003 to Present Gardners, Pa 17324 Gregory W. Myers 30 Pine Street 2003-2005 Carlisle, Pa 17013 Gregory W. Myers 1153 Belvedere Street 2005 to Present Carlisle, Pa 17013 4. The mother of the children is Tanya Unger, residing at 840 Baltimore Pike, Gardners, Cumberland County, Pennsylvania. She is unmarried. The father of the children is 1153 Belvedere Street, Carlisle, Cumberland County, Pennsylvania. He is unmarried. 5. The relationship of plaintiff to the children is that of Father. The plaintiff currently resides with the following persons. Name Relationship Pat O'Donnell Roommate 6. The relationship of defendant to the children is that of Mother. The defendant currently resides with the following persons. Name Relationship Ron Barnes Boyfriend 7. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children and claims to have custody or visitation rights with respect to the children. The best interest and permanent welfare of the children will be served by granting the relief request because: A Court Order of custody and structured visitation is desired so that the Plaintiff and the children may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that-the children are not used in a manipulative fashion. A Court Ordered determination of custody is required to avoid continuing conflict between the parties regarding responsibility for custody and support. WHEREFORE, Plaintiff requests this Court primary custody of the children to Defendant subject to structured partial custody by the Plaintiff. Respectfully submitted, ROMINGER & WHARF Date: Q Lc-~I~A. Tomeo, l~squire 155 South Hanove Street Carlisle, PA 170 ~ 3 (717) 241-6070 Supreme Court I.D. # 200198 Attorney for Plaintiff Gregory W. Myers, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Tanya Unger, No. CIVIL Defendant IN CUSTODY VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. r y .Myers, Plaintiff Gregory W. Myers, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vi. CIVIL ACTION -LAW Tanya Unger, No. CIVIL Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Leslie A. Tomeo, Esquire, attorney for Plaintiff do hereby certify that I this day mailed a copy of the within Motion upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Tanya Unger 840 Baltimore Pike Gardners, Pa 17324 Date: ! / y o Leslie A. Tome ,Esquire 155 South Hano er Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 200198 Attorney for Plaintiff (J 'sv ~- ~ ~' c v '~ GREGORY W. MYERS IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V' 07-263 CIVIL ACTION LAW TANYA LINGER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, January 24, 2007 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on _ Thursday, February 22, 2007 _____ at 8:30 AM for aPre-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 Kelief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilro Es . 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 HAVE 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 ] 7013 Telephone (717) 249-3166 u.': - .r ~~~r MAR 01 X001 N PLEAS OF GREGORY W. MYERS, IN THE COURT OF COMMO Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. No. off, ~. ~ 3 CIVIL ACTION -LAW TANYA UNGER, IN CUSTODY Defendant COURT ORDER AND NOW, this , / ~~ day of ~/l//~ , 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Courtroom No. 7" of the Cumberland County Courthouse on the ~~day of ~ , 2007, at~~.m. At this hearing, the father shall be a moving party and shall proceed initially with testimony. Counsel for the father, and counsel for the mother, if the mother retains counsel for the hearing, shall file with the Court a Memorandum setting forth the history of custody in this case, the issues currently before the Court, and a summary of each party's position on these issues. This Memorandum shall be filed at least five (5) days prior to the above mentioned hearing date. 2. Pending further Order of this Court, the following temporary Custody Order is entered: (a) The mother, Tanya Unger, and the father, Gregory W. Myers, shall enjoy shared legal custody of Quentin G. Myers, born June 13, 2000, and Jerzee R Myers, born July 14, 2002. (b) The mother shall enjoy primary physical custody of the minor children. (c) The father shall enjoy periods of temporary physical custody of the minor children every Wednesday from 4:00 p.m. until 8:00 p.m., and at such other times as agreed upon by the parties. BY THE COURT, Judge cc: es ie A. Tomeo, Esquire Tanya Unger . Y ~ _ Wi ~p~' , ~,, 'h.i.:]~'~ I'~ /~~rfS~Y :.• J ..1ltt~ J~u! 1 ~'~~ f ~_1 ~{y GREGORY W. MYERS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. CIVIL ACTION -LAW TANYA LINGER, IN CUSTODY Defendant CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Quentin G. Myers, born June 13, 2000, and Jerzee R. Myers, born July 14, 2002. 2. A Conciliation Conference was held on February 22, 2007, with the following individuals in attendance: The father, Gregory W. Myers, with his counsel, Leslie A. Tomeo, Esquire, and the mother, Tanya Unger, who appeared without counsel. The father is seeking a very limited period of time with the minor children and has suggested about four (4) hours per week. The mother insists that she will not agree to that because she feels the father should take the children for a longer period of time. The Conciliator notes that the Courts cannot require the parent to take custody and can only specify visitation rights based upon requests of the parties. The mother will not agree and is requesting a hearing in this case. A hearing should be scheduled, but an interim Custody Order should be entered to see if an arrangement can be worked out between the parties prior to the hearing. 3. The Conciliator recommends an Order and the form is attached. Date: February 23, 2007 Hubert X. `Gilroy squire Custody Conci 'ator GREGORY W. MYERS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW NO. 07-263 CIVIL TANYA LINGER, Defendant IN CUSTODY ORDER AND NOW, this 30th day of April, 2007, hearing in the above captioned matter set for June 28, 2007, is continued to Friday, July 20, 2007, at 9:30 a.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, PA. BY THE COURT, ~~ ~~~ Hess, J. Leslie A. Tomeo, Esquire For the Plaintiff Tanya Unger ~, /h~~d ,~' p / . o ~ 840 Baltimore Pike Gardners, PA 17324 :rlm _~r- +~h+~,t" ~~? ~~~ ~ "' ~~~9 ~~~G ~tii;~~'t 3--. GREGORY W. MYERS, Plaintiff vS. TANYA, LINGER, Defendant IN THE COURT OF COMMON PLE S OF CUMBERLAND COUNTY, PENNSY VANIA CIVIL ACTION -LAW NO. 07-263 CIVIL ORDER AND NOW, this 1 ~ r day of May, 2007, at the request of the defendant, which request is attached hereto and made a part hereof, and with the concurrence of th~ plaintiff, the hearing in the above matter set for July 20, 2007, is cancelled. All other provisions of our order of March 14, 2007, to remain in full force and effect. BY THE COURT, slie Tomeo, Esquire For the Plaintiff ~nya Unger 840 Baltimore Pike Gardners., PA 17324 :rlm J Kevin .Hess, J. ~ •~ ~ ~~~~~ ,;, ,~;.~ 1 Sw~~/~F ~"}i _7 ~ ~ .r. (~-~"~ ~ - ~ ire `~~`-~'Z ~. ~``'.~'t'~~ ~5--~-- ~ ~S~-.~' ~ ~~ , . ~ ` ~'~ ~~ ~ ,~ -et' ~, ~`~ -~ _, r,-~ ~~ 4 -~c' ti--R ~ ~r _ ~~ - a~.~ V r~