HomeMy WebLinkAbout99-04579
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P. C. .
OF ILLINOIS COUNTY OF LAKE
IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT
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ORDER
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File Stamp Here
LEADS p
Respondent's Date of Birth:
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The Court Finds that
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on Ex Parts Dprpesilc VipIs rdir ?Q?Wion was Issued
O A Domestic Violence Order of Protection was Issued
on
THE COURT HAVING JURISDICTION OF THE SUBJECT MATTER, IT IS HEREBY ORDERED THAT:
O 1. An extension of the ex parts Order of Protection is granted and is hereby extended to - 19
at m.
O 2. A hearing on the ex parts Order of Protection is set for m., on 19 -
In Courtroom No.
3. The ex parts Order of Protection is vacated.
O 4. The Or or o } Pr tt tioP r igpsly Issued Is extended to n 19 _,
5. A he? g o77n 1 OWeer cUPrioteation is set for r4 m., on 19
In Courtroom No ('- 7 I1
O 6. The Order of Protection is vacated.
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Attorney for JEnter:
/? 0L? JUDGE
Address ?J p pip
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Telephone Number
171-42 2183
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STATE OF ILLINOIS )
SS
COUNTY OF L A K E )
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I, SALLY D. COFFELT,•Clerk of the Circuit Court of the
NINETEENTH'J'UDICIAL CIRCUIT, LAKE COUNTY, in and for the State of
Illinois, and the keeper of the records, files,and seals thereof,
do hereby certify the above and foregoing to be a true, perfect and
complete copy of a certain ORDER
filed in my office on
19 99 in a certain cause
JEFFREY SHIFLET
, General Number 99 OP 890
JULY 19th
NOW pending in said Court, wherein
Plaintiff
and AMY SHIFLET Defendant.
IN WITNESS WHEREOF, I have hereunto set my hand, and
affixed the seal of said Court, at
Waukegan, Illinois
JULY 20th 19 99
BY:
D. CO' EL
of t0 i ui Court
Clerk.
17147! 0M
Certified Copy
from
Circuit Court of THE NINETEENTH JUDICIAL CIRCUIT;,
Lake County, Illinois
A
e
STATE OF ILLINOIS )
LAKE COUNTY ) SS
I> HENRY C. TONIGA N Judge of the Nineteenth Judicial
Circuit of Illinois, do hereby certify that
SALLY D. COFFELT , whose name is subscribed to the foregoing Certificate
of Attestation, now is, and was at the time of signing and sealing the same,
Clerk of the Circuit Court of Lake County aforesaid, and keeper of the Records
and Seal thereof, duly elected and qualified to office; that full faith and
credit are, and of right ought to be given to all. her official acts as such,
in all courts of record and elsewhere; and that her said attestation is in
due form of law, and by the proper officer.
GIVEN under my hand and seal this 20th day of
JULY _ A. D. 19 99 .
SEAL)
r
STATE OF ILLINOIS )
LAKE COUNTY ) SS
I, Sally D. Coffelt , Clerk of the Circuit Court, in and
for said County in the State aforesaid, and keeper of the Records and Seal
thereof, do hereby certify that HENRY C. TONIGAN
signature appears to the foregoing certificate, was at the,timesofgsigning
the same, Judge of the Nineteenth Judicial Circuit of Illinois, duly commissioned
and qualified; that full faith and credit are, and of right ought to be given
to all his official acts as such, in all courts of record and elsewhere.
IN TESTIMONY WHEREOF, I have hereunto
171-34 Rev. 1/a1
set my hand and affixed the Seal of
said Court, at my office in Waukegan,
in said County, this --2_Q_t_hday of
JULY _ A. D.
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IN THE CIRCUIT COURT OF TH 19TH JUDICIAL CIRCUIT
LANE COUNTY, ILLINOIS
IN RE THE MARRIAGE OF: )
Amy Jo Shiflet, )
Petitioner,
AND
Jeffrey Shiflet, )
Respondent. )
To: Amy Jo Shiflet
616 BloserbWe Road
Newville, PA 17241
No. 99 OP 890
NOTICE OF MOTION
JU1.191999
'41"
CIRCUIT CK
On July 19, 1999 at 9:00 A.M. or as soon thereafter as counsel may be heard, I
shall appear before the Honorable Judge Smoker presiding in room C-220 of the Lake
County Courthouse in Waukegan, Illinois and present R ndent's Emergency Petition
to Re-open a copy of which is attached hereto 717/3- /
R er, mey for Petitioner
Y R-1 ROD R & ASSOCIATES
PROOF OF SERVICE BY OVERNIGHT DELIVERY
I, Jay R Grodner, an attorney, state that on July 16, 1999 I served this Notice and
attached motion by overnight delivery to the above-referenced address by depositing the
same with the Overnight Carrier located at 130 East Randolph, Chicago, Illinois 60601,
before the hour of 5:00 p.m.
J G er
JAY R. GRODNER & ASSOCIATES
One Prudential Plaza - Suite 1200
130 East Randolph Drive
Chicago, Illinois 60601
(312) 236-1142
#3123771
IN THE CIRCUIT COURT OF THE 19TH JUDICIAL CIRCUIT
LAKE COUNTY, ILLINOIS
IN RE THE MARRIAGE OF: )
AMY JO SHIE LET, )
Petitioner, )
and )
JEFFREY C. SHIFLLET, )
Respondent. )
No. 99 OP 890
? lu
EMERGENCY PETITION FOR RETURN OF
CHILDREN TO ILLINOIS
AND TEMPORARY CUSTODY
NOW COMES Jeffrey C. Shillet, by and through his attorney, Jay R. Grodner of Jay R. Grodner
& Associlttes, pursuant to 28 U.S.C.A. § 1738A, the Parental Kidnapping Act, 750 ILCS 51501, 750
I LCS 51601, et g-%, 750 I LCS 3511 et sea.. Illinois Supreme Court Rule 104(c), and Circuit Court Rule
2.05 on his Emergency Petition for Return of Children to Illinois and Temporary Custody and states as
follows:
1. Jeffrey has filed a Petition for Dissolution of Marriage pursuant to 750 ILCS 51101, et
ss. pending in this Court.
2. Jeffrey C. Shiflet, and Amy Jo Shiflet, are the parents of Stephanie Diane Shiflet, bom
July 19, 1984 and Joshua Cain Shiflet, born July 19, 1990, (hereinafter "children").
3. Jeffrey, bom September 15, 1964, is thirty-four (34) years old, resides in Fort Sheridan,
Illinois and is currently a United States Marine stationed at Great Lakes Training Center, Great Lakes,
Illinois.
4. Amy Jo Shiflet, born October 27, 1965, is thirty-three (33) years old, and upon
information and belie!; is currently located at 616 Bloserbille Road, Newville, PA 17241, but has listed
her address in court documents as Petitioner's address. Upon information and belief Respondent is
currently employed.
5. The parties and their child have resided in Lake County Winois since October 1998.
The Petitioner adopted Stephanie in 1993.
6. Over past five (5) years the children and the parties have resided at 225 Bullock Drive,
Apartment C, Fort Sheridan, Lake County Illinois, from October 1998 to present; Kingsland,
Georgia from June 1990 through November 1994, and in Kingston, Washington from
December 1994 until October 1998.
7. There is currently pending before this Honorable Court, Judge Smoker presiding, an
Emergency Order of Protection, 99 OP 890. Petitioner knows of no other legal actions that are
pending in Illinois or any other state or country that involve the custody of the children named herein.
8. Jeffrey knows of no other person not a party to these proceedings who has who has
physical custody of the children or claims to have custody or visitation rights with respect to the
children.
9. Petitioner is a fit and proper person to have temporary custody of the children named
herein.
10. On or about June 16, 1999, Respondent removed herself and children from the marital
residence for a "vacation" to West Virginia. She has not returned the children.
11. On July 13, 1999, Respondent returned to the marital residence without the children and
removed valuables and the majority of the childrens' possessions from the parties' home. She said to
Petitioner that she has no intention of returning to Illinois.
12. Amy Jo petitioned for and was granted an emergency order of protection agsihM
Respondent on July 13, 1999. In her petition, Respondent did not inform the couPAM she had
removed the children from the state of Illinois or that she was not living in the marital residence.
Nevertheless, Respondent prayed for and was granted exclusive possession of the marital residence
and possession of the minor children.
13. For the last nine (9) months the children have lived in Illinois. The children completed
the 1998-99 school year in Lake County. They are enrolled to attend school in Lake County in Fall
1999.
14. Over past three (3) months, Amy Jo has been engaging in increasingly aggressive and
bizarre behavior toward Petitioner, including but not limited to:
a. Raging at Petitioner and blaming him for the affair that Respondent is having.
b. Berating, screaming at, and yelling at Petitioner about her affair and marital
difficulties in front of the children.
c. Removing the children from the state.
d. Slapping and punching Petitioner.
15. Amy Jo has demonstrated a propensity for erratic mood swings and extreme anger in
front of the children, often resulting in Amy Jo cursing at, striking and/or threatening Petitioner.
16. Amy Jo has demonstrated utter disregard for the father-child relationship of Petitioner
and his children. Such disregard is demonstrated by Petitioner's unilateral removal of the children
from Illinois.
17. Amy Jo has shown utter disregard for the children's' emotional well being. Amy Jo
unilaterally removed the children and most of the children's belongings from the marital home. At no
time did Amy Jo attempt to discuss the move or discuss the best way to inform the children of the
current marital difficulties and impending divorce. Instead, Amy Jo has exposed the children to her
extra-marital affair in a direct an obvious manner and had told the parties' daughter to keep it secret
from Petitioner. Amy Jo has screamed about her boyfriend's sexual prowess in the house with the
children present.
18. Amy Jo's use of self-help and flagrant extra-marital behavior is indicative of her
propensity to place her own needs above those of her children despite the emotional and psychological
strain on them
19. Petitioner is in a better position to provide the children with a calm, peaceful, and stable
environment during the course of these proceedings, because:
A. is in a better position to provide a safe and healthy environment for
the children;
B. Petitioner is a responsible adult who is gainfully employed;
C. has attempted to protect the children from Amy Jo's extra-marital
activities and violent out bursts;
D. has always encouraged a strong relationship between his children and
their mother;
E. will sacrifice his own emotional needs if it will keep his children free
from-unnecessary mental anguish; and,
F. will not discuss the litigation with the children or use the children as
tool by which to gamer information regarding Amy Jo.
21. Amy Jo cannot provide a stable environment during this litigation and has shown that
by moving the children to another state.
22. This cause is an emergency because the children were wrongfully removed from their
home state and deprived of their established home environment with their father. The children are
subject to the jurisdiction of this Court as it is their home state pursuant to the UCCJA and because the
Amy Jo submitted them and herself to the jurisdiction of this Court in the Order of Protection
proceeding before Judge Smoker. Amy Jo's actions have shown a complete disregard for the
children's relationships with their father. Continued estrangement from their father is detrimental to
the parent-child relationship. The children need to be in the safe and secure surroundings that they are
most familiar with during the pendency of this matter. Petitioner's affidavit is attached and
incorporated as though fully herein set forth.
23. This cause should be heard as an ex-parte matter. Amy Jo has unilaterally removed the
children from Illinois and the custody, care, and control of Petitioner. Obtained an Emergency Order
of Protection from this Circuit Court without informing Judge Smoker that she had removed the
children from the State. Given her lack of candor before a legal tribunal, Petitioner believes that notice
of this proceeding would cause Amy Jo to further sequester the children from him Amy Jo has
indicated that she is not going to return to Illinois.
24. Alternatively, Amy Jo has sent notice of this Petition to Amy Jo by Certified Overnight
U.S. Mail at the address he believes Amy Jo is located, however, for the reasons cited above, Petitioner
believes that Amy Jo will not respond to said notice.
WHEREFORE, Jeffrey C. Shitlet, Petitioner, respectfully pray that this Honorable
Court:
A. Grant his Emergency Petition for Temporary Custody.
B. Award Petitioner temporary sole custody, care, and control of parties' minor chidlren.
C. Set this cause for hearing on the issue of temporary custody on an expedited basis.
D. Grant Amy Jo supervised visitation with the children in Petitioner's home.
E. Order Amy Jo to pay reasonable temporary child support as defined by statute and continue
to maintain health insurance for the minor children.
F. Enter any and all other orders necessary to secure the well being of Petitioner's children
and that the Court deems just, equitable and/or warranted under existing law.
Jeffrey C. Shifiet, Petitioner
/ Say R. Grodner,
JAY R. GRODNER & ASSOCIATES, P.C.
Attorney for Petitioner
AFFIDAVIT OF JEFFREY SMLET
1 • Amy Jo and I started having marital difficulties during or about March 1999. We were
having disputes over the amount of time that Amy in was spending with a male companion.
2. The arguments progressed and Amy Jo began spending more time with her male
companion and requested that she be transferred to the same store in which her companion
worked.
3. On June 14, 1999, I had fixed Amy Jo a romantic dinner with balloons and cards in an
effort to mend our marital difficulties. During dinner we discussed our difficulties. We
discussed reconciliation and possible counseling.
4. On June 15, 1999, I asked Amy Jo to stay home from work to talk and try to work things
out. Amy Jo said that she had important inventories to do at work. She left for work taking
items for a tanning appointment
5. Amy Jo did not return from work at her usual time, between 4:30 and 5:00 p.m. At 6:00
p.m., I went to the tanning salon and discovered Amy Jo and her male companion kissing in the
parking lot. Amy Jo did not know that I was there.
6. I returned home. Amy arrived home at 6:30 p.m. We left together to pick-up a friend's
car to take it to him at O'Hare. 1 asked Amy Jo why she was so late and she told me that the
traffic was bad due to the Ravinia Festival. She said she was stuck in traffic.
7. I touched her arm and noted aloud that her skin was hot for being out of the tanning bed
so long. She said that she had to run the defroster in the car while she was stuck in traffic to
keep it from over heating.
S. I told her that I had just returned from the tanning salon and did not notice any traffic.
Amy Jo burst into a rage about her male companion's wife. She was yelling and screaming and
cursing about the wife and demanding to know what the wife had told me.
9. Amy Jo dropped me off at my friend's car. I drove the car home.
10. Upon my return, I heard Amy Jo screaming at the wife of her male companion, they are
our next door neighbors, demanding to know what the wife had told me.
11. I went into our home and Amy Jo came in and began screaming and yelling at me and
blaming me for her affair. This entire episode took place in front of our son.
12. During her tirade, during which I was also yelling, Amy Jo threatened to take the children
to West Virginia.
13. About 8:00 p.m. I left to pick-up my friend at the airport, I returned home between
midnight and 1:00 a.m. I was late because someone had picked up my friend's bag in
Charleston, South Carolina and we had to report it, the process took longer than expected.
14. Upon my return to the house, I went upstairs to go to bed. I got some clothes and was
going to sleep on the couch. Amy Jo got up and began arguing again.
15. She was telling me to prove it, prove it and referred to a video that she had erased that
showed her kissing her male companion. I had taken the videotape that afternoon.
16. My daughter came home from a movie shortly after that. Amy Jo said shut-up because I
was involving the children. I told Amy Jo that I just wanted the kids to know the truth. During
this part of the argument my daughter blurted out, "I swear to god, mom, I didn't tell hire. I
swear to god, mom, I didn't say anything. You told me that the only reason you were with him
was because dad wasn't treetin' you right; but, dad's treating you right and you're still with
him.
17. I was shocked that my wife had made my daughter keep such a secret.
18. My son got up.
mother, should My daughter was crying and screaming. Amy Jo said, "If I'm such a bad
ther, maybe I should just go kill myself then." She then left the house. The kids took off
after their mother. I got the kids back inside and into bed.
19. About an hour later, I was in the bedroom holding my son, who had been crying. Amy Jo
came back in flipped-on all of the lights and began piling up suitcase in the hallway. I got up
shut the door to keep the bedroom dark so my son could sleep.
20. Amy Jo came into the room, turned on the lights and started yelling again. My son woke
up and started crying. Amy Jo left the room. 1 turned off the lights and shut the door. Amy Jo
opened the door again, turned on the lights, but did not enter the room. She started taking the
wedding pictures off the wall and throwing them away. She was screaming the entire time.
21. I asked her to go downstairs so the children could sleep. She went downstairs. She
immediately started berating me and said she was going to go outside and beat herself up and
call security.
22. She calmed down after a while and said she wanted to talk. I went downstairs and she
acted as though she was attempting to apologize. She did apologize. I did not respond light
away. So, she stood up and smacked me in the face - twice. She then punched me. I turned to
walk away. She burst into a rage again.
23. I hied to call security and Amy Jo ripped the phone off the wall. I went upstairs to use
the other phone and she left again.
.IL.,,
24. On June 16, 1999, in the morning, Amy Jo returned with the military police. She said she
wanted take the kids and go to West Virginia for two (2) weeks. I gave her my consent and she
went to West Virginia with the children.
25. 1 have not seen my children since June 16, 1999. I had spoken to them frequently until
Amy Jo got the pending Order of Protection.
26. On June 30,1999, Amy Jo returned without the children. She said she was coming back
to work things out. I asked my brother and my sister to be present.
27. 1 returned from base on June 30, 1999, and my brother and my sister were at the house.
Amy Jo was leaving when I got there. She was talking to her boyfriend in the parking lot of our
residence.
28. She left and said nothing to me.
29. On July 1, 1999, Amy Jo returned with security to get some clothes for the children. I
did not see her again until July 13, 1999.
30. On July 13, 1999, Amy Jo returned to the house upon agreement to get more clothes for
the children. I went to work. My friends, who I had stay at the house while she was there, called
and said that Amy In had brought a U-Haul. I called security to prevent her from removing
major items from the house.
31. Security arrived and said that there was nothing they could do to stop her. However, they
requested that Amy Jo inventory the things that she was removing from the residence. She,
removed the children's bedroom sets, except for the beds, her clothes, the Play Station, two (2)
televisions, two (2) V.C.R., and without telling the military police, the 35 run camera and the
camcorder.
32. She left the residence. Gave me the keys to the house. I was served with the Emergency
Order of Protection that evening.
33. Amy Jo is currently living in Pennsylvania with her sister. The address is 616 Bloserbille
Road, Newville, PA 17241. Her parents live at 1605 Avery Street, Parkersburg, WV 26101.
34. I have never abused, harassed, or stalked Amy Jo.
FURTHER AFFIANT SAYETH NOT
All/
Jeffery Shiflet
Signed and sworn before me this day of , 1999
NOTARY
#3123771
IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT
LAKE COUNTY, ILLINOIS
IN RE THE MARRIAGE OF: )
JEFFREY C. SHIFLET, )
Petitioner, ) No. 99 OP 890 f r
and ; I tt L?
)
AMY JO SHIFLET, ) a'?F) ? '.'s5
Respondent. )
2
EMERGENCY PETITION TO RE-OPEN C c`t1:T r::_crt
NOW COMES the Petitioner, JEFFREY C. SHIFLET, by and through his attorney, Jay R.
Grodner of Jay R Grodner & Associates, pursuant to 750 ILCS 60/224(b) and (d) on his
Emergency Petition to Reopen and states as follows:
On July 13, 1999, this Honorable Court granted Petitioner herein an Ex-parte
Emergency Order of Protection. Under Illinois law, upon two (2) days notice or less as may be
prescnbed by a court, a Court may hear a Petition to Reopen an Emergency Order of Protection
if the Respondent alleges no actual notice and a meritorious defense. 750 MCS 60/224(d).
Respondent herein now petitions this Honorable Court to re-open the proofs and rehear
Petitioner's petition.
2. The Emergency Order was granted without any notice to Respondent.
3. The Emergency Petition underlying the Emergency Order alleges nothing that
rises to the level of abuse as contemplated by the Illinois Domestic Violence Act. Further, upon
information and belief Respondent is attempting to manipulate the court system in such a way as
to allow her to remove the children form this state and leave Respondent with no recourse.
NO EMERGENCY AND NO DOMESTIC ABUSE OR VIOLENCE AS
CONTEMPLATED BY THE ILLINOIS DOMESTIC VIOLENCE ACC
4. The Petition itself states alleges only that Respondent pushed Petitioner and
Petitioner hit Respondent on June 15, 1999, during an extended argument between the parties.
Said argument occurred almost one (1) month prior to the alleged emergency.
5. The Petition further alleges that after Petitioner slapped the Respondent,
Respondent called the military police, not Petitioner.
6. The Petition further states that Respondent left town with the children and
returned almost one (1) month later to pick-up their valuables.
7. The Petition further alleges that Respondent called the military police.
Respondent called the military Police to prevent Petitioner from removing items from their home.
8. The Petition does not allege that Respondent struck, pushed, and/or kicked
Petitioner on July 13, 1999, the date of the entry of the Ex-parse order.
MANIPULATION OF COURT SYSTEM TO IN ORDER TO REMOVE CHILDREN
FROM THE STATE AND LEAVE RESPONDENT NO RECOURSE
9. On June 15, 1999, the military police removed Petitioner from the marital
residence because she had hit Respondent.
10. Upon her return on June 16, 1999, Petitioner unilaterally removed the children
from the marital residence for a vacation to West Virginia. She has not returned the children to
Illinois. The children are now in Newville, Pennsylvania.
11. - The Petitioner came to the marital residence on July 13, 1999, to remove the
children's personal items. Respondent, necessarily upset, but not abusive or harassing, called the
military police in order to prevent Petitioner from removing the children's things.
WHEREFORE the Respondent, Jeffrey Shiflet prays that this Honorable Court Dismiss the
Emergency Petition for an Order of Protection, award him attorney fees and costs and grant any
and all relief that in necessary and just.
Jeffrey C. Shiflet, Respondent
Jay R. Grodner, Attorney for Respondent
JAY R. GRODNER & ASSOCIATES
One Prudential Plaza - Suite 1200
130 East Randolph
Chicago, Illinois 60601
(312) 236-1142
STATE OF ILLINOIS )
COUNTY OF L A K E j SS
IN TEE CIRCUIT COURT OF THE NINETEENTE
JUDICIAL CIRCUIT, LAKE COUNTY, ILLINOIS
A ti V -P,)Y>n66-r
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at Waukegan, Illinois this
day of 19
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JEFFREY C. SHIFLET,
PETITIONER
V.
AMY JO SHIFLET,
RESPONDENT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-4579 CIVIL TERM
ORDER OF COURT
AND NOW, this 2q 4? day of July, 1999, upon petition filed
containing certified copy of the 19th Judicial Circuit in Lake County, Illinois order for
custody providing: "Amy Shiflet is ordered to return the minor children Stephanie Diane
Shiflet, born 7/19/84, and Joshua Cain Shiflet, born 7/19/90 to Lake County, Illinois.
Jeffrey Shiflet is awarded temporary custody of Stephanie and Joshua," the Sheriff of
Cumberland County is authorized and directed to serve a certified copy of the out-of-
state order of the circuit court together with a certified copy of this order and petition
upon the respondent Amy Shiflet at address set forth in the petition or wherever she
may be found, and to seize the children from any person and to facilitate the transfer of
the children to petitioner or his agent in Cumberland County.
By the Court, , /1
Edgar B.
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Qtb.;nuaos
JEFFREY C. SHIFLET
Petitioner
V.
AMY JO SHIFLET
Respondent
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO.99-g519 ?y s.:OTe
ENFORCEMENT OF OUT-OF-STATE
CUSTODY DECREE
CIVIL AC TION - LAW
EMERGENCY PETITION FOR ENFORCEMENT OF
OUT-OF-STATE. CUSTODY DECREE
Jeffrey C. Shiflet through his Attorneys John H. Broujos of Broujos & Gilroy, P.C. and Jay R.
Grodner of Jay R. Grodner and Associates, set forth the following:
Petitioner Jeffrey C. Shiflet is an adult individual residing 225 C Bullock Drive, Fort
Sheridan, Illinois, active duty regular member of the United States Navy, as an E-6.
2. Respondent is Amy Jo Shiflet an adult individual residing at 619 Bloserville Road,
V,--
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Plitto s, believed to be residing with her sister. Julie Bay. She is believed to be working at Home
Depot, 6000 Carlisle Pike, Mechanicsburg, PA. 17055, in garden department.
3. On July 19, 1999, the Circuit Court of the 19'h Judicial Circuit in Lake County, Illinois
upon hearing entered an order directing Respondent to return the minor children Stephanie Diane
Shiflet, bom 7/19/84 and Joshua Cain Shiflet, born 7/19/90 to Lake County Illinois. Jeffrey
Shiflet is awarded temporary custody of Stephanie and Joshua. Amy's visitation is reserved.
4. Certified copy of the Order has been tiled in the Prothonotary's Office in accordance with
the Uniform Child Custody Jurisdiction Act. incorporated in 23 PaCS 5354, which provides:
"The courts of this Commonwealth shall recognize and enforce an initial or modification
decree of a court of another state which had assumed jurisdiction under statutory provisions
r
substantially in accordance with this subchapter or which was made under factual circumstances
meeting the jurisdictional standards of this subchapter, so long as the decree has not been
modified in accordance with jurisdictional standards substantially similar to those of this
subchapter.
"The court shall treat that decree in the same manner as a regular custody decree of a court of
this jurisdiction, which decree shall have the same effect and shall be enforced in the same
manner as a current custody decree."
UCCJA clearly intends that Pennsylvania courts enforce the foreign decree. Com ex rel Zaubi
v Zaubi, 418 A2d 729, 275 PaSuper 294, 1980, affirmed 423 A2d 492 Pa 183
5. Illinois has enacted the Uniform Child Custody Jurisdiction Act, SHA, 750 ILCS 35/1 TO
35/26.
6. Petitioner requests the Court to issue an order directing and authorizing the Sheriff of
Cumberland County to serve a certified copy of the order upon Respondent Amy Shiflet
wherever he shall find her and to facilitate the transfer of custody of the children to Petitioner in
accordance with the Order.
AND HE SHALL EVER PRAY. \ ,.1?\ \ lC
John fl. Broujos, Esquire
B ujos & Gilroy, P.C.
4 North Hanover Street
Carlisle. PA 17013
717 243 4574 Fax 243 8227
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-04579 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
JEFFREY C SHIFLET
VS.
SHIFLET AMY JO
KATHY CLARKE , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within ORDER OF COURT -ENFORCMENT OF was served
upon SHIFLET AMY the
defendant, at 12:00 HOURS, on the 29th day of July
1999 at 616 BLOSERVILLE ROAD
NEWVILLE, PA 17241 CUMBERLAND
County, Pennsylvania, by handing to AMY JO SHIFLET
a true and attested copy of the ORDER OF COURT -ENFORCMENT OF
together with OUT OF STATE CUSTODY DECREE, EMERGENCY PETITION
FOR ENFORCEMENT, OUT OF STATE CUSTODY ORDER
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing 18.00
Service 7.44
Affidavit .00 .,.,...???/
Surcharge 8.00 $ S9s T3
? 4 JEFFREY999 SHIFLET
07/29/1
by LLLk
epu y eri
Sworn and subscribe to before me
this a day of
19get A.D.
CLtiC. ?h
rocnonotar