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HomeMy WebLinkAbout02-6027SANDRA M. LONG, Plaintiff Ve CHRISTOPHER DEICHMAN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA .. : CIVIL ACTION - LAW : IN CUSTODY ..COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, SANDRA M. LONG, by and through her attorney, ROBERT B. LIEBERMAN, ESQUIRE and respectfully represent as follows: 1. The Plaintiff is SANDRA M. LONG, residing at 1095 Nanroc Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is CHRISTOPHER DEICHMAN, residing 285 CartrefRoad, Etters, York County, Pennsylvania. Shawn Christopher Long Plaimiff seeks custody of the following child: Residence .Age 1095 Nanroc Drive 2 months Mechanicsburg, Pennsylvania The child was bom out of wedlock to the Plaintiff and Defendant. The child is presently in the custody of the Plaintiff, Sandra M. Long, who resides at 1095 Nanroc Drive, Mechanicsburg, Cumberland County, Pennsylvania. The child has always resided with the Plaintiff, SANDRA M. LONG. The mother of the child is SANDRA M. LONG, currently residing at 1095 Nanroc Drive, Mechanicsburg, Cumberland County, Pennsylvania. She is single. The father of the child is CHRISTOPHER DEICHMAN, currently residing at 285 Cartref Road, Etters, York County, Pennsylvania. He is single. 4. The relationship of Plaintiff to the child is that of Mother. The Plaintiff resides alone. 5. The relationship of Defendant to the child is that of Father. The Defendant resides with his parents: Joyce Koon and Marty Koon. 6. Plaintiffhas 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. Plaintiffhas no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. Plaintiffdoes not know ora 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. 7. The best interests and permanent welfare of the child will be served by granting the relief requested because Plaintiff is ready, willing and able to provide a stable home environment for the child. 8. Each party 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 this Honorable Court to grant him legal and primary physical custody of the subject minor child. Respectfully submitted, DATED:] h ~ ~_} - o~ ROBERT B. ~-~EBE--RMA~, ~S~-~p~~'~ 500 North 3ra Street, 12th Floor P.O. Box 1004 Harrisburg, PA 17108-1004 (717) 236-1485 Attorney for Plaintiff -3- VERIFICATION I verify that the statements made in the foregoing Complaint for Custody are true and correct based upon my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Plaint~f~4. Long, ' SANDRA M. LONG PLAINTIFF CHRISTOPHER DEICHMAN DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-6027 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, December 23, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, January 21, 2003 at 8:30 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. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sunday. Esa. ~ Custody Concil'i~tor ' [3 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 171) 13 Telephone (717) 249-3166 SANDRA M. LONG, Plaintiff, V, CHRISTOPHER DEICHMAN Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-6027 IN CUSTODY PRAEClPE. TO THE PROTHONOTARY: Please enter our appearance on behalf of Christopher Deichman in the above- captioned matter. q Dated: January ~, 2003 Respectfully submitted, WIX, WENGER & WEIDNER By: ¢' ' uavid R. Getz, Esquire / Supreme Ct. I.D. No. 34838 508 North Second Street Post Office Box 845 Harrisburg, PA 17101 (717) 234-4182 SANDRA M. LONG, Vo Plaintiff, CHRISTOPHER DEICHMAN Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-6027 IN CUSTODY CERTIFICATE OF SERVICF I hereby certify that the foregoing Notice of Intervention was served upon the following by placing the same in the U.S. mail, first class, postage prepaid mail this day to the following: Robert B. Leiberman, Esquire Five Hundred North Third Street Twelfth Floor P.O. Box 1004 Harrisburg, PA 17108-1004 WIX, WENGER & WEIDNER Dated: January,~, 2003 By: David R. Getz~ Esquire / Supreme Ct. I.D. No. 34838 508 North Second Street Post Office Box 845 Harrisburg, PA 17101 (717) 234-4182 F:\drg\1830 - Deitchrnan, Christopher,12077 - Child Custody\Documents\Praecipe to Enter Appearance.doc SANDRA M. LONG, Plaintiff CHRISTOPH1 ;R DEICHMAN, Deft adant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 02-6027 : IN CUSTODY ACCEPTANCE OF SERVICE AND NOW this ffAOv~, day of~'~',-~J~ ,2(103, the undersigned, DAVID R. GETZ, Esquire attorney for Defendant, CHRISTOPHER DEICHMAN, hereby accepts service of the Complaiht for Custody and Order of Court in connection with the above case. David R. G-~Z, Esqui-r-e ,fi" WIX WENGER & WEIDNER PC 508 N Second Street Harrisburg, PA 17101 Attorney tsar Defendant SANDRA M. LONG, Plaintiff VS. CHRISTOPHER DEICHMAN Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-6027 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this -:; r~ ~[, day of '3~2J~,a 29-? , 2003, upon consideration of the attached CUsto~l~-Conciliation Report, it is ord&ed and directed as follows: 1. The Mother, Sandra M. Long, and the Father, Christopher Deichman, shall have shared legal custody of Shawn Christopher Long, bom October 7, 2002. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 2. The Mother shall have primary physical custody of the Child. 3. The Father shall have periods of custody with the Child every Saturday and Sunday from 4:00 pm until 8:00 pm, beginning January 25, 2003. For the first four weekends, the Father's periods of custody shall take place at the Mother's residence, unless otherwise agreed between the parties. The Father may also have additional periods of custody with the Child as arranged by agreement. The parties agree to cooperate in adjusting the times for the Father's periods of custody as necessary to meet the needs of the Child's schedule. 4. After the Father has had ongoing periods of weekend custody not restricted to the Mother's residence, the parties agree to cooperate in discussing further expansion of the partial custody schedule to longer periods and eventually to overnights as developmentally appropriate for the Child. 5. Each party shall be entitled to have an extended period of custody with the Child on Easter, Christmas, Thanksgiving, Memorial Day, July 4th, and Labor Day. The Father shall have an extended period of custody on Father's Day and the Mother shall have an extended period on Mother's Day. All specific times for exchanges of custody on holidays shall be arranged by agreement between the parties. 6. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Child comply with this provision. 7. Within six months of the date of the Conciliation Conference, counsel for either party may contact the conciliator to schedule an additional Custody Conciliation Conference, if necessary to address the issue of expanding or adjusting the partial custody schedule. 8. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, Jo cc.~obert B. Lieberman, Esquire, Counsel for Mother ,,/David R. Getz, Esquire, Counsel for Father 0t-.30-o3 SANDRA M. LONG, Plaintiff VS. CHRISTOPHER DEICHMAN Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-6027 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME Shawn Christopher Long DATE OF BIRTH CURRENTLY IN CUSTODY OF October 7, 2002 Mother 2. A Conciliation Conference was held on January 21, 2003, with the following individuals in attendance: The Mother, Sandra M. Long, with her counsel, Robert B. Lieberman, Esquire, and the Father, Christopher Deichman, with his counsel, David R. Getz, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquire / Custody Conciliator