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Home My WebLink About00-04694 NILE H. & MARY LOU LEWIS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF V. JENNIFER LEE LEWIS 00-4694 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 6TH day of JULY ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicshurg, PA 17055 on the 31ST day of AUGUST ,2000, at 3:00 PM for a Pre-Heanng Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to defme 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 Dawn S. Sunday. EsqrP 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 "''; ~.." '-'. - ~;, ,~ ," ''1!>~II!ll~li1,iti~!1>i<l~fi~'''WilMMi>.Mif'~~iiIt:\IoIlJllt1ill'-~' -~<-"""'"!liilIil"'.- ~ ,. ,~"~,..-' IO'~~"'_I!I~~~" . ():FjCr:: .-- -1 I '~,: 1/--/ R'{ ", :'i"':'\;\...-H,rJ, 00 1'lJL ....] D':' 2' 07 "'..' . I I. _" J CUMI-3r.:riLA\D COUNTY PENNSYLVANIA ?7.otJd~~$4~ ?-)4J ~ ~ ~ d;/I' ")'/'C1t1 ~ /U~ ~ 4 ~,. - ... , - .. ~~"~'^"~~'=-~"-'-'"~ ,., , NILE H. LEWIS and MARY LOU LEWIS, PLAINTIFFS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs NO. 00 - J.jf.p 9'f (t~l~ JENNIFER LEE LEWIS, DEFENDANT CIVIL - CUSTODY ORDER AND NOW, this_dayof ,2000, upon consideration of the attached motion, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at , on the day of 2000, at _o'clock _,m., for the 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 shall 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: Custody Conciliator 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 the Court Administrator at (717) 240-6200. 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. T,. .. r:lfru: . NILE H. LEWIS and MARY LOU LEWIS, PLAINTIFFS : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs NO. JENNIFER LEE LEWIS, DEFENDANT CIVIL - CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you, You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB 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 Fourth Floor Cumberland County Courthouse Carlisle P A 17013 (717) 240-6200 ~-- 'c ~~ NILE H. LEWIS and MARY LOU LEWIS, PLAINTIFFS vs : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. #0- </(,,9<( ~ I~ JENNIFER LEE LEWIS, DEFENDANT CIVIL - CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiffs are NILE H. LEWIS and MARY LOU LEWIS, husband and wife, residing at 101 Second Street, West Fairview, Cumberland County, Pennsylvania, 17025. 2. The Defendant is JENNIFER LEE LEWIS, residing at 101 Second Street, West Fairview, Cumberland County, Pennsylvania, 17025. 3. Plaintiffs seeks Primary Physical Custody of the following child: Name Present Residence Date of Birth Spencer Harvey Lewis 101 Second Street West Fairview, PA 17025 June 19,2000 4. The child was born out of wedlock. 5. The child is presently in the custody of the Plaintiffs, who reside at 101 Second Street, West Fairview, Pennsylvania, 17025, 6. The child has resided with the following persons at the following address since his birth: Name(s) Address Dates Nile E. Lewis, Mary Lou Lewis, and Jennifer Lee Lewis 101 Second Street West Fairview, PA June 19, 2000 to Present 7. The mother ofthe child is Jennifer Lee Lewis, currently residing at 101 Second Street, West Fairview, Pennsylvania, 17025. She is single. ,"' _ ~ ~ ~ -- "' " ~ ~ 8. The father ofthe child is unknown. 9. The maternal grandparents of the child are Nile H. Lewis and Mary Lou Lewis. They currently reside at 101 Second Street, West Fairview, Pennsylvania, 17025. They are married and reside at the same residence. 10. The relationship of the Plaintiffs to the child is that of maternal grandparents. The Plaintiffs currently reside with the following persons: Name Relationshio Jennifer Lee Lewis Daughter 11. The relationship of the Defendant to the child is that of natural mother. The Defendant currently resides with the following persons: Name Nile H. Lewis Relationshio Father Mary Lou Lewis Mother 12. Plaintiffs have not participated, as a party or witness, in another litigation concerning the custody of the child in this or another court, 13. Plaintiffs have no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 14. Plaintiffs do not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 15. The best interest and permanent welfare of the child will be served by granting the relief requested because: a. Plaintiffs have great love and concern for their grandson, Spencer -~" t"C . ,,' Harvey Lewis; b. The Plaintiffs have been an integral part of their grandson's life, even before he was born; c. The Defendant lives with the Plaintiffs, is not married, is not employed, does not have an automobile, and is not able to support and care for herself; , d. Plaintiffs have an established, stable family home, where they can accommodate, without any difficulty, both the Defendant and the child; e. Plaintiffs are financially stable and can meet the financial needs of both the Defendant and the child; f Defendant believes it is in the best interest of her child for the Plaintiffs to have Shared Legal and Primary Physical Custody of her child; 16. 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, Plaintiffs, NILE H. LEWIS and MARY LOU LEWIS, request this Honorable Court to grant Shared Legal Custody and Primary Physical Custody of the minor child, SPENCER HARVEY LEWIS, to the Plaintiffs, NILE H. LEWIS and MARY LOU LEWIS. Respectfully submitted, GATES & ASSOCIATES, P.c. Dated: Jun~ ,2000 Susan Kay Candi Counselfor Plai PA I.D. # 64998 10 13 Mumma Road, Suite 100 Lemoyne, PA 17043 (717) 731-9600 ,,~ ' ., VERlFICA nON The undersigned hereby verifies that the facts averred in the foregoing document are true and correct to the best oftheir knowledge, information, and belief. This verification is made subject to the penalties of 18 Pa. C.S,k 94904 relating to unswOI;n falsification to authorities. DATED: ~.2..-\ ,2000 iJ ct- ',6~tP~ Nile HLewis ..... . ", . DATED: ~~, ,2000 m~~c&L~I1~ Mary Lou ewis ',,,11 ",'~ ~" w "1 -"'................~, ~~ ~ ~ -.c ~ (j t ^' -lq -fq ~h""'~ 9~8~ ~w ~~ "-<..:t:- . ~', " ' . ^" J , 0 (:::> () C c::> -n s: c.._ ,,,--I -Of!) c: :c.~~J~~ 1T!r'J T -,- G 2:r:.1 tiit;: U) _-"~r""l 0"".. 0 (~~;;'~~} ~. > ~e:' --0 -'f^' ,', >- ~??~ zc~ >~ ,~ r~~=Sin -; z '1> ::2 <:0 5:J -< ~I!!!I!MtI, "~_,~ IP,\irl1m~" ."'~~ '''",""r~''1'i!~''*!!!'l~'i$(''l1l'iWl>f:;;~,,!~~j,o;j)''r.m;r}:mJI$~.-'ll!!'!iI!~~~.!IP0~J:~l\i!ifffl-,~~ft!II~ NILE H. LEWIS and MARY LOU LEWIS, PLAINTIFFS : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA vs NO. 00-4694 CIVIL ACTION LAW JENNIFER LEE LEWIS, DEFENDANT IN CUSTODY AFFIDAVIT OF SERVICE CERTIFIED MAIL COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF CUMBERLAND Be it known, that on the ID1:/.1 day of August, 2000, before me, the subscriber, a Notary Public, personally appeared SUSAN KAY CANDIELLO, who, being duly sworn according to law, did depose and state as follows: 1. I am an attorney licensed to practice law in the Commonwealth of Pennsylvania, and 1 am employed by the law firm of Gates & Associates, P.C., Lemoyne, Pennsylvania. 2, My law firm represents Nile H. Lewis and Mary Lou Lewis, Plaintiffs in the above-captioned matter. 3. On July 19, 2000 a true and correct copy of the Complaint for Custody was deposited for delivery with the U.S. Postal Service in Camp Hill, Pennsylvania, being Certified/First Class Mail, restricted delivery, return receipt requested, Article No. 7099 3400 00060353 1802, and addressed to the Defendant, Jennifer Lee Lewis, at 101 Second Street, West Fairview, PA 17025. 4. A copy ofthe return receipt card signed by the Defendant, Jennifer Lewis, "'-<~,,.,.,~;:-, '^ '-- ' showing a date of service of July 26, 2000, is attached hereto as Exhibit" A". 5. Service by certified mail meets the requirements ofPa.R.C.P. 404(2) and Pa.R.C.P.403. LLO, SWORN TO AND SUBSCRIBED before me, a Notary Public, this ID-tlt day of August, 2000. dwfufuO Notary Public Notarial Seal Terl L. Walker, Notary Public Lemayne BOlO, Cumberfand County My Commission Expires Jan. 20, 2003 Member, PennsylVania Association at Notaries My Commission Expires: _-':))1,,,,_,,.,", , '. , SENDER: COMPLETE THIS SECTION . Complete items 1, 2. and :j, Arso complete item 4 if Restricted Detiver9 Is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailplece. or on the front if space permits. 1. Article Addressed to: J"e.nn:;Jj e., Lee LewlS lDl 5e.<-0'0..6.. :'JtC€G\ . 10e"5t Fo.is'ul€L0 p.!f 1'10;>5 "~ 3. ServJce'TYpe ~rtifled Mail o Registered o Insured Mail , t , ~ , g, {, o ~ wi ~ )i( Return Receipt for MerchandIse : 1:;19.0.0. J 4. Restricted ~Jivery1 (Extra Fee) Yes i. f i 10259S-S9.M.1789 t . 2. Article Number (Copy from service label) fJO<tq 3\.[)[) ()OClo D3S:~ 18D;::) PS Form 3811. July 1999 Domestic Return Receipt UNITED STATES POSTAL SERVICE 11\\1 - '---t ~ t First-Class Mail . Postage & Fees Paid USPS . Permit No. G-10 [. , , 1 . Sender: Please print your name, address. and ZIP-+-4 in this box' .-;(- Law Offices..of' \\\'\\ L. ... Gates & Associates, 'p.em\. 1013 Mumma Rd., Suite 100" Lemoyne, PI'.. 17043 :\ILC ?lInn ~ "'. \," III", Ill, ",I" \, ,H,,,!.l,, !.11I",1I1111111.11,1",.1I.1 06 EXHIBIT I l(A-" . ,...t....J~ rr:~l!JIIIlIIfilit!_~~(,l1lll.'l(!IWrlll!'1'l~~-:'iI'V' ..~JTflJi!!t:l!w.J.- "^' '& "'."';"" --,-, , 'of" <',C' () c: <- "'1Jf:1': rnfT-: z:ij "7C' 0,,;: ""'1:'. ~-;: "" ~~'8 ;:t-,.c: :;:..: =<! ,;.c- _,,,,,-,~ ",---~"", ,1"''''' ,"',0, ",." '~.i'\:l"iitl '3r o Cl "'" '-' G=5 o --0' :11# -~'-!Tr ".;~Jb '~,~~6 ','- ---1'"; Q~~ 6cn b' :0 -< " ..Ji. c- eo """F'~(l'J!I!lli1"1mi$j!lwg~'_~,m~~'!!I""'i"'''''?l'l:r~",!'tr,_t~!!~m~m.<:ijf;j'ffi~iMmr,:;';;:".~ ~^,,~ J,I!Ii NILE H. LEWIS and MARY LOU LEWIS, PLAINTIFFS : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA vs NO. 00-4694 JENNIFER LEE LEWIS, DEFENDANT CIVIL - CUSTODY ORDER OF COURT AND NOW, this 11t\. day of ~ 2000, after presentation and consideration of the attached Stipulation For Agreed Order of Cusotdy, it is hereby ORDERED AND DECREED that said Stipulation, as submitted and executed by Plaintiffs, NILE H. LEWIS and MARY LOU LEWIS and Defendant, JENNIFER LEE LEWIS, shall be incorporated into and made a part of this Order, thereby giving said Stipulation the full force and effect as an Order of this Court. 1. {;p1ipJ 9-g-00 R}{.3 <, ~ ~, ,'~- ~ , 'r. ,. ~ -- .~'"~.~;, ~ ~,.....!t<t~Il~'Ilft~l<~..iWitll!i"Mml'il~liiit~lffi!;-.iI,\'.j~ ""'(,37. ,", ,~,,"'" '.' ~ ~ ~~.". """ ",,_", "h 4l' '.l.~" ~.~. ~~, '"""""""~ Ii -",> F", C'!) \'/'.. "</J C /? I - t', _'h, f', '; 'lIi{" 'I / ~ , P,,":::;;"'I../,:,; , ''-' ,(, ;".. (:/W\I"" i-V (., 1,.' , \') iZ k~f ,;-<':t/1 ?l ~1/~i?1 ii, y . """"'1iiI1I111 ~ .l1 NILE H. LEWIS and MARY LOU LEWIS, PLAINTIFFS : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA vs NO. 00-4694 JENNIFER LEE LEWIS, DEFENDANT CIVIL - CUSTODY STIPULATION FOR AGREED ORDER OF CUSTODY Plaintiffs are NILE H. LEWIS and MARY LOU LEWIS, who currently reside at 101 Second Street, West Fairview, Cumberland County, Pennsylvania, 17025. Defendant is JENNIFER LEE LEWIS, who currently resides at 101 Second Street, West Fairview, Cumberland County, Pennsylvania, 17025. SPENCER HARVEY LEWIS, who is the subject of this Stipulation for Agreed Order of Custody, is the child of the Defendant. Spencer Harvey Lewis was born on June 19, 2000. It is the Defendant's belief it is in the best interests of her minor child to be in the custody of her Mother and Father. The Defendant does not know the biological father of the child. As a result, the biological father is not a part of this agreement. WHEREFORE, Plaintiffs, NILE H. LEWIS and MARY LOU LEWIS, and Defendant, JENNIFER LEE LEWIS, have entered into a mutual agreement regarding the custody of the Defendant's child and respectfully request that this Honorable Court enter the following Order: 1. Plaintiffs and Defendant shall share Legal Custody (as defined in 23 Pa.C.SA Section 5302) of the minor child, Spencer Harvey Lewis. 2. Primary Physical Custody of Spencer Harvey Lewis shall be with the Plaintiffs, Nile H. ''I. ^>,"'"f" ' ~ ~ -~- - , ~ Lewis and Mary Lou Lewis. Defendant, Jennifer Lee Lewis, shall enjoy Partial Physical Custody of Spencer Harvey Lewis. 3. Plaintiffs and Defendant have mutually agreed to communicate, cooperate, and work together in scheduling visitation with and care ofthe child. 4. Plaintiffs shall have Spencer Harvey Lewis as an Income Tax Deduction. 5. The parties shall be free to mutually agree to alter any of the above visitation, and/or schedule other visitation. DATE: September ~ , 2000 /Ja II ~t NILE H. LEWIS v DATE: September ~, 2000 /J'ltUq4 ~/~ MARY LOU LEWIS DATE: SePtember~,2000 ~n'& ~ljl?~ FERrEE LEWIS COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF CUMBERLAND On this, the Ijr/l.; day of September, 2000, before me, a Notary Public for the Commonwealth of Pennsylvania, the undersigned officer, personally appeared NILE H. LEWIS known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I have set my hand and notarial seal. ~(t-ti~<HJ~~-J otary Public My Commission Expires: Notarial Seal Traci l. Sepkovie, Notary Publie Lemoyne Boro, Cumberland County My Commission expires Julv 7, 2003 Member, PennsylvanlaAssoolallonofNolaooo ":~i.'""", ' ~'\t ~,'" COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF CUMBERLAND On this, the ~ day of September, 2000, before me, a Notary Public for the Commonwealth of Pennsylvania, the undersigned officer, personally appeared MARY LOU LEWIS known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, 1 have set my hand and notarial seal, ~jt/A t4rW(G tary Pub My Commission Expires: Notarial Seal Traci L. Sepkovic, Notary Public Lemoyne Bora, Cumberland County My Commission Expires July 7, 2003 Member, Pennsj/!\'an:aAc;scdatiLn ofNotanes COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF CUMBERLAND On this, the ~day of September, 2000, before me, a Notary Public for the Commonwealth of Pennsylvania, the undersigned officer, personally appeared JENNIFER LEE LEWIS known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I have set my hand and notarial seal. ~/~~~CG Notary Public My Commission Expires: Notarial Seal Traei L. Sepkovie, Notary Public Lemoyne Boro. Cumberland County My Commission Expires July 7, 2003 MflI'nher, Pennsylvania Association of Notaries . -~ ,~ . ",~~' ~.$'lll!lfli~._ ,~.....".-~" ," "" r ~,,.,_. '.~ W-!M!I;f-W ~ ,-~,'" , ~ .'~.C'__ ~,_~ --<~-"'-,~. "-0.."."" ". '''' 'j" 0 C~ (j ~ C:J ~ :/') .'0 L. '-'1 m r', , '~~.J :Z "i Z ,-, (l~ C '. ''', t"l ~\ i [-j c.- .. " ~::--- '. ,.--'" ;..' :~) ;~ '->', >, c_' l-:- , Tl ,- .J c_ :;;---= '::'J ;f~ ...; -< .r:- _U -< 'P~~~!." """"""'.....'''''"'''''.. ~-,. r~"""-:". ,."",$; SEP 11 2~ NILE H. & MARY LOU LEWIS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . . vs. : NO. 00-4694 CIVIL TERM : : CIVIL ACTION - LAW JENNIFER LEE LEWIS, Defendant . . : IN CUSTODY ORDER OF <XXlRT AND NOW, this 31st day of August, 2000, the Conciliator, being advised by counsel for the Plaintiffs (who were present at the time of the Conference) that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction. The Custody Conciliation Conference scheduled for today, August 31, 2000 is canceled. FOR THE COURT, o~~ Dawn S. Sunday, Esquire Custody Conciliator ;-~ ,. "'~ _^ .w , "'''''''''''''''''~"'--';:;'OIti",'lilI;l!iJ~~!Mll\;jli<4'~~'[',"!1.n-,,",!ill,iio>.l1M;ilih,,*M:l'.>O;~lIlBi~~P. ~fAillISll'Nli- r C~'-i ,. sr~p 'J b;;-i <"i. ':' n ,;. t_, .Iv (': I', ", .,', "'U"J"f'Y' Vwll~ll.,,,._: ,L.! " ""/\) 11' PENN"YI \!A'I\!IA \.. ...~,,", 1. - .~ ~"' ~......""'-....... "'""""'" " --.is,,"'' -