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HomeMy WebLinkAbout00-04327 ,...' ,.j~ ~ , JEFFREY A. SHENCK IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF V. LISA K. SHENCK 00-4327 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 30th day of June ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on the 25th day of July ,2000, at 11:15 AM for a Pre-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. FOR THE COURT, By: Isl 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 TillS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VB 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 " F" ~I').. Ill" ""F'/'/'r' Or- - _1. ...;/ \,c ...I~ !~'!F F';YY!"f.'!r'~'C)"'\nY . "',,;, I )1'1 1/1..11 00 JUl-3 P1112: 36 CUMBERLAND COUNTY PENNSYLVANIA ' )'3 -00 ')'3.txJ 7JCJtP w~~~ 7l~ ~ 4; < ~~~ 'r gl!1~""'1lII~~III\IilI!lf!!!llll!". !\!mIlII,,4 ~ '-'!'-' ,~ ~ -~ ;l:>'W!~"1j1"'''''F''''''''"'''''''''':''''''';''illWn'1'O\",:%,m,*-,*,''(Il'W\!'-'W~....."," _$!!I ITJllI ~ _," _~~: - ,--" .' -~ - " ,- - ~-,~ , -,,'" ->~'~-..>,", .'. '.',",,', ,-~~"~~,- ~ ~,=' 'I "- --' 1,-.,,,--,,,-,::.",' ..""" ""M_ '''-'" ""~ -. '.''';1 JEFFREY A. SHENCK, Plain tiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. LISA K. SHENCK, Defendant NUMBER :tX:>-.l./JJ...7 CIVIL TERM CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at , on the _ day of , 2000, at _ _.M., for a Pre-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. BY THE COURT: 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 Il;o-~. ~ ~.>>~d" - ,,,~,, . 'lL ~"I "'-"";;'~'. ;';:'1 I I JEFFREY A. SHENCK, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NUMBER: ro- '-I.J..l 7 (l.l.,;./ -r:h. _ LISA K. SHENCK, Defendant CUSTODY COMPLAINT FOR CUSTODY NOW COMES the Plaintiff, JEFFREY A. SHENCK, by his attorney, Charles E. Petrie, and respectfully represents as follows: 1. Plaintiff is JEFFREY A. SHENCK, who currently resides at 1702 Locust Street, New Cumberland, County of Cumberland, Pennsylvania. 2. Defendant is LISA K. SHENCK, who currently resides at 258-B West Main Street, Hummelstown, County of Dauphin, Pennsylvania. 3. Plaintiff seeks to have rights of primary physical and shared legal custody with respect to TRISHA KAY SHENCK, born November 8, 1992. The child was born out of wedlock. The child is presently in the custody of Plaintiff, JEFFREY A. SHENCK. During the past five years, the child have resided with the following persons and at the following addresses: From June, 1995, until July, 1997, with both parents in Hershey, Pennsylvania; from July, 1997, until August, 1999, with both parents at 1702 Locust Street, New Cumberland, Pennsylvania; from August, 1999, until June 14, 2000, with Plaintiff at 1702 Locust Street, New Cumberland, Pennsylvania; from June 14,2000, until the -\ '~~', ' ~~ ~ " - n ,'"j,_"",- _I ,. Cd'_ ~ .;;__,.. e 'I I I present with Defendant at 258-B West Main Street, Hummelstown, Pennsylvania. The mother of the child is LISA K. SHENCK, who currently resides at 258-B West Main Street, Hummelstown, Pennsylvania. She is married. The father of the child is JEFFREY A. SHENCK, who currently resides at 1702 Locust Street, New Cumberland, Pennsylvania. He is married. 4. The relationship of the Plaintiff to the child is that of father. The Plaintiff currently resides with the child. 5. The relationship of the Defendant to the child is that of mother. She currently resides alone. 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 in another court. The Plaintiff has no information of a custody proceeding concerning the custody of the child in this or in another court. Plaintiff does not know of a person not a party to these proceedings who has physical custody of the child or who claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by confirming rights of primary physical and shared legal custody in Plaintiff ~&i because Plaintiff has been the primary caretaker of the child since Defendant's relocation to Humme1stown, Pennsylvania. 8. Each parent whose parental rights 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, Plaintiff requests that Your Honorable Court enter an Order confirming rights of primary physical and shared legal custody in Plain tiff. Respectfully submitted, /'9~ J -<. &_ ~ .., CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiff 411 ~. , ~~., -, - ','," ~ . -, - COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I verify that the statements in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ~..... \~,;!OW ATE _fu~ " () C~ 0 C C -n ;g: <:- '-' ~W r:= t-i~;n rn ;,e .:.n N -~,i71 2,> ~~ ~2~ 0'> ~C ." ~8 ::JI:' >c S~ ,~ -~ -2 55 ::;! '0 -" e k, . ,~ ""', JUL 1 8 20~~ JEFFREY A. SHENCK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000-4327 LISA K. SHENCK, Defendant CIVIL ACTION - LAW CUSTODY ~l ~, ORDER OF COURT AND NOW, This 13th day of July, 2000, Plaintiff in this matter, haVing filed a Custody Complaint on July 3, 2000, subsequent to the Defendant filing a Custody Complaint on June 19,2000 docketed at 2000-3737, it is hereby directed that this matter be consolidated into one Action, to resolve the custody dispute and docketed at 2000-3737. Therefore, the Conciliation Conference presently scheduled for July 25, 2000, at 11:15 AM, is hereby CANCELED. FOR THE COURT,