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Home My WebLink About96-06960 I' '~ " . . 'I 'I 'I 'i " ,I I' I (;::) ~ '-Q \ ~ ;1 SHANIil MEHAFFIJi:i P aintitf vs, IN THE COURT OF COMMON Ii'~EAB CUMBERLAND COUNTY, PBNNSY~VANIA No, (1 ~ - 6 96 0 ('u';.d Tt -l-w...., HBIDI-JO MJi:HAFFIB, Defendant IN CUS'l'ODY gJlDn QP oQIlU ANO NOW, J) (, ( .<u , 199~, upon conside/:'ation of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before i L L<l' . ",' 'l\< , the Conc ator, at _~ L' ~ I b \" '.1 ('"" r' /1J.L. i , on~e .J,1h day of i'b'''''':! , 199 ,at ,', ___,M., for a Pre-Hearing custody Conference. At suc confer nce,' ~ an effort will be n~de to r~solve the issues in dispute, or if this cannot be aocomplished, to define and narrow the issues to be heard by the Court, and to enter into a Temporary Order, All children age five or alder may also be present at the Conference, Failure to applJar at the Conference may provide grounds for entry of a temporary or permanent Order. FOR 'rHE COURT I BYI '~;J 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 acoommodations 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 SHOU~D TAKB THIS PAPBR TO YOUR ~AWYER AT ONCE. IF YOU DO NOT HAVB A ~AWYBR OR CANNOT AFFORD ONB, GO TO OR TE~EPHONE THE OFF1CE SET FORTH BB~OW TO FIND UUT WHERB YOU CAN GET ~EGA~ HE~P, OFFICB OF THB COURT ADMINISTRATOR COURTHOUSE, 4TH F~OOR CAR~IS~Ji:, PA 17013 (717) 240-6200 . SHANB MBHAPPIBi P aintite IN ~Hm COUR~ 0' COMMON P~BAB CUMBBRLAND COUNTY, PBMNSY~VAN1A vs, No, HIII01-':)O MSHAPPIB, Oetendant IN CUS~OOY COMPLAItII'r FOR CU.IU'.Q.O.X AND NOW, comes Shane Mehattie, by his attorneys, Caldwell & Kearns, P.C., and respecttully represents as folloWSI 1. ~he Plaintiff, Shane Mehaefie, is an adult individual, presently residing at 5317 Oxford Circle, Apartment 73 (Lower Allen ~ownship, Cumberland County), Mechanicsburg, pennsylvania, 17055. 2. ~he Oetendant, Heidi -Jo Mehaffie, is an adult individtJal, whose last known place of residence was 14 South Second Street, Apartmenl: 1, Wormleysburg, ['ennsyl vania (Cwnl:>erland County), 17043, and who is presently believed to be residing at the home of her mother, Mildred Quayle, 19 Eisenhower Boulevard, Duncannon, pennsylvania, 17020. 3. ~he following minor children are the subject of this Complaint I 1iAIllIl .EJ;:esent Address Birth Date Amber Lee Mehaffie 5317 Oxford Circle, Apt. 73 11/18/90 Mechanicsburg, PA 17055 Sara Michelle Mehaffie 5317 Oxford Circle, Apt, 73 2/12/93 Mechanicsburg, PA 17055 ~he aforementioned minor children were not born out of wedlock. The parties have no other children, The dorementioned children are llresently in the llhysioal oustody of their father, the Plaintiff, Shane Mehaffie, who resides at 5317 Oxford Circle, Apartment 73, Mechaniosburg, Pennsylvania, 17055. 4. During the llast five years, the subject minor ohild, Amber/ has resided with her natural parents/ the Plaintiff and the Defendant, at variQus looations, hereinafter enumerated. Beginning with the date of her birth on February 12, 1993/ th~ minor child, Sara, has resided with both of her natural llarents, the Plaintiff and Defendant at the addresses hereinafter enumerated. The child or children have resided with their natural parents during the past five years, at the following lQcationsr From January/ 1991, until January, 1992, the children resided at Riverhouse Apartments, 2311 North Front Street / Harrisburg, Pennsylvania, from January/ 1992, until April or May/ 1992, the children resided at 3598 Green Streett Harrisburg, Pennsylvania, from Allril or May, 1992, until February or March, 1994, the children resided at 2600-B Green Street, Italian Lake Apartments, Harrisburg / Pennsylvania, from February or March, 1994, until March, 1995/ the children resided at 36 Beacon Drive, Williamsburg Estates, Harrisburg, Pennsylvania, from March, 1995/ until May, 1995, the children resided in the 2600 block of Market Street, Camp Hill, Pennsylvania, from May, 1995, until May, 1996/ th~ children resided at 1105 Yverdon Drive / Apartment 7, Bunker lIill Apartments, Camp Hill, Pennsylvania, from May, 1996/ until Deceml:ler 7, 1996, the children resided at 14 South Seoond Street, Apartment 1, Wormleysburg, Pennsylvania. Prom Deoeml:ler 7, 1996, to the present date, the minor children have resided with their father, the ~laintiff herein, at 5317 Oxford CirCle, Mechanic.burg, Pennsylvania, 17055. 5. The Plaintiff and the Defendant have lived separate and apart since on or about Oeoeml:ler 7, 1996, when the Pl~intiff moved to his present address, and when, simultaneously, it is believed and averred that the Oefendant moved to the home of her mother, Mildred Quayle, 19 8isenhower aoulevard, Ouncannon, Pennsylvania, 17020. 6. The relatiomJhip of the Plaintiff to the subject minor children is that of natural father. 7, The relationship of the Oefendant to the subj ect minor children is that of natural mother, 8. The Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the minor children in chis or any other Court. Plaintiff has no information of a custody proceeding concerning the children pending in a Court of thia Commonwealth. Plaintiff does nClt know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 9. The best interests and permanent welfare of the minor children will be served by granting the relief requested herein, to wit I shared legal custody in both parents, primary physical ~ SHJ\NE MIllHAFFII!:, Plal.ntift Viii. HEIDI-JO MEHAFFIE, Detendant . ..,.......... '~ ~ ~ IN THE COURT OF COMMON P~EAB CUMaER~J\ND COUNTY, PENNSYINJ\NIA No, 96-6960 CIVI~ TERM IN CUS'l'ODY ~FFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVJ\Nr.A COUNTY OF DAUPHIN SSI Personally appeared betore me, a Notary Public in and for said ConU1\onweal th and County, CARL (l, WASS, ESQUIRE, who being duly Bworn according to law, states that he served a certified copy of the Complaint For C1lstody and attached Order of Court, upon the Defendant, Heidi-Jo Mehaffie, pursuant to Pennsylvania Rules of Civil Procedure 1930.4 by mailing to the said Defendant at her residence, 14 South Second Street, Apartment 1, Wormleysburg, Pennsylvania, 17043, by certified mail, return receipt requested, said certified mail piece being No, P 511 155 225r that setvice of the foregoing was made on January 15, 1997r and that attached hereto and incorporated herein by reference is the return receipt, bearing the signature of the Defendant, acknowledging receipt of the aforementioned documents by the Defendant. Sworn to and subscribed befor, me this ~ day of ",' ( , 1997. ", ~( , ) I) -1. L. ,'p ~,'I H"( eta c 92583-1 NOTARIAl5EAl NANCY l, aRE6~1, NOla!'{ Public Harrisburg Dauphlo County My Commission tlplr!S March 16,2000 ""-~-~~ Carl. (l, Wass, Esquire