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Home My WebLink About99-06598 C1 -19 Q> Zl- i i >e, DONALD L MECK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99- CIVIL TERM CATHY MECK, Defendant : CIVILACTION -LAW : IN CUSTODY ORDER OF COURT AND NOW, t \ 1 1 `, , 1999, upon consideration of the attached petition, it is hereby directed that the parties and their respective counsel appear before h? ch nc'1 1 ??? _ th iliator,at 1\'? \?.Cnti,•o 11i\1.t?\ on the I? day of , at 11'. t)p R m., for a Pre-tlearitig Custody Conference. At such conference, an ort 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: 1II,i i" '1 Custody Conciliator- -? C t?l,) 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 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. .1 J ?461-lkl( /11- 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 TIME 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 cc: i DONALD L MECK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99- 6.S-'2J' CIVIL TERM CATHY MECK, Defendant : CIVIL ACTION -LAW IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes Plaintiff Donald L. Meck, by his attorneys, Rupp and Meikle, and Richard C. Rupp and files this Complaint for full custody of the parties' minor children as follows: 1. The Plaintiff is Donald L. Meek who resides at 52 Sussex Road, Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is Cathy Meek who resides at 518 Schuylkill Street, Schuylkill Haven, Schuylkill County, Pennsylvania. 3. Plaintiff Donald L. Meek seeks custody of the following minor children: Name Present Residence Age Crystal A. Meek 52 Sussex Road, Camp hill, PA 16 Yrs. Christopher D. Meek, 52 Sussex Road, Camp llill, l'A 15 Yrs. 4. The children were not born out of wedlock. 5. The children are presently in the custody of the Plaintiff, the father who resod -at) 52 Sussex Road, Camp Hill, PA. 6. During the past five years, the children have resided with the following persons at the following addres't! Person Address Dates Father 52 Sussex Road, Camp Hill, PA July 1999-Present Mother and Father 52 Sussex Road, Camp Hill, PA 1994- July 1999 7. The father of the children is Donald L. Meek, the Plaintiff, who currently resides at 52 Sussex Road, Camp flill, PA. I-le is married to the Defendant. 1) 8. The mother of the children is Cathy Meek, the Defendant, who currently resides at 518 Schuylkill Street Apt Nl, Schuylkill Haven, PA 17972. She is married to the Plaintiff. 9. The relationship of the Plaintiff to the children is that of their father. The Plaintiff's household includes: Name Relationship Donald Meek - Plaintiff Father Crystal A. Meek Daughter Christopher D. Meek Son 10. The relationship of the Defendant to the children is that of their mother. The Defendant's household is believed to be as follows: Cathy Meek - Plaintiff George Moyer - boyfriend 11. The Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 12. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 13. The Plaintiff does not 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. 3 I Fivn?1 14. The best interest and the permanent welfare of the parties' minor children will be served by granting the relief requested by the Plaintiff because: a. The Plaintiff can provide the parties' minor children with a home with adequate moral, emotional and physical surroundings to meet the children's needs; b. The Plaintiff is willing to accept custody of the children; c. The Plaintiff continues to exercise parental duties and enjoys the love and affection of the parties' minor children. d. The Plaintiff beleives and therefore avers that the Defendant has been suffering from some mental problems which would be detrimental to the custody and care of the parties' minor children. e. The Plaintiff has been the primary caretaker during the raising of the parties' minor children. f. The Plaintiff has been the only caretaker of the parties' minor children since the Defendant left the family. g. The Defendant has moved in with a male adult who is unknown to the Plaintiff except that he was a patient of the Veterans Administration Mental Hospital, Lebanon County, Pennsylvania, and Plaintiff is concerned for the welfare of the parties' minor children. h. The parties' minor children prefer full custody with the Plaintiff, their father. 4 S XA 16. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim NONE WHEREFORE, the Plaintiff respectfully requests this Honorable Court to grant full custody of the parties' minor children to the Plaintiff, the father of the parties' minor children. RUPP AND MEI I.E By' ic- Ric and C. Rupp Attorney for Defendant Attorney I.D. #34832 355 North 21st Street, Suite 303 Camp Hill, PA 17011 (717) 761-3459 5 VERIFICATION I verify the statements made in this -ANNEEft Plaintiff's Complaint For Custody and Counterclaim for Custody Against Plaintiff are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa C.S. 4909 relating to unsworn falsification to authorities. Date: /D11. ?/?„?(o{r Donald L. Meck, Pla?ff \^ M ? n C1 C.. .n ?? 1 Y ? i If v O n (7-_ J IJl T ? r ?f J ?n a M n? ti >- r' ?_ c:. .? ' % . i c I ;-, v . __ Ct, r.. r- ? , L_' `? - 1- L C,' 4 -- SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1999-06598 P COP4MONPIEALTH OiF PENNSYLVANTA: COUNTY OF CUMDPRLP:ND MECR DONALD L vs. MECK CATHY R. Thomas Kline 5i:eri.;-i, :;'},o bci.^.y duly s:vorn according to law, savs, that he made a diligent search and inquiry for tine within named defendant. to wit: MECK CATHY but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of SCHUYLKILL County, Pennsylvania. to serve the within COIIPr: T*4T - CUSTODY On December 2nd, 1999 this office was in receipt of the attached return from SCHUYLKILL County, Pennsylvania. Sheriff's Costs: So answers: Docketing 10 .00 Out of County 9 .00 Surcharge Dep. ScFiuvl}-ill C 8 26 .00 .50 R? homers rTi`nErif- ?TS B RUPP & MEIKLE 12/02/1999 Sworn and subscribed to before me this day of"; 19-2? A. D. rrotnonoC«ry r s?FE 1; N-,... ..,,. ,-.. ---------------- --------------------- ------ t 7 ------------------- ---------------- '. -------------------------------------------------- -------------------------- ------------ --- --- ._ __ __________ ____________________ ___ _________________ __ ___ ------ D 17E 7- . SEG --- -------- ---- --------------- --- - ------------- ------ -------------------- -------------------- -- ----- ----- - ::. :.or 1 I ------------------------------------------------------------------------------------------ _.]i_ __________ ______________________________ ------------------ _----------------------- ------- ______________________________ t?a E 2? ] D ?.rr,„a<a,f a x+Hf • H-+N af++x Hr•H++ x Ato;o' :?ii . cj?aec? 140.00 a O'ic ...................i3?0 + +xif+sa+x+sexa?,.r+fa+ra+.fsx{xxx+x+x+ 1995 ! il:°_ a7,4 ,,'.;4 - _eh _ aaND ; S- ? 3 6 5?? `?ty of U? ltr;']ber o`` l?i R. THOMAS KLINEi "! .. ,...'?. I ° RONNYR.ANDERSON Sheriff > . .;; ,.'.:-•: Chief Deputy EDWARD L. SCHORPP PATRICIA A. SHATTO Solicitor OFFICE OF THE SHERIFF Real Estate Deputy One Courthouse Square Carlisle, Pennsylvania 17013 TO: Hon. Francis V. McAndrew RE: Donald L. Mock Sheriff of Schuylkill Co vs Cathy Meck Order of Court, Complaint for Custody Dear Sir: 99-6598 Civil Enclosed please find _Order of CO , . r•mmPl a i n t F,.,. Custody Ha o to be served upon Cathy Mock, 518 Schuylkill St. Schuytk; 11 r''ven PA in your County. Kindly make service thereof and send us your return of service. Enclosed is the advance payment which you requested. Very truly yours, R. Thomas Kline. Sheriff Cumberland County, Pennsylvania Enclosures: N c j.. r•• ?• r .t 'f s In The Court of Common Plea.- .-f Cumberland County, Pennsylvania Donald L. Meck VS. Cathy Meck No, 99-6598 Civil Now, 11/3/99 , 19_, 1, SHER.IFF OF CUIVIBERLAND COUNTY, PA, do hereby deputize the Sheriff of Schuylkill County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Simi ffof Cumberland County, PA Affidavit of Service Now, 19 , at o'clock M. served the L7 within upon t at •- .r by handing to a copy ofthe original and made known to the contents thereof. So answers. Sheriff of COSTS Sworn and subscribed before SERVICE me this - day of 19- MILEAGE AFFIDAVIT County, PA S S --------------------------------------------- ------------------- S MCN 1'(141 221 I?CI,-. 11:15 Y.. (PAGE 2) f H I.:. 7 t ' .. .? III( fl 1 ':. . CODE ISLAIfiIC° ---------- iY -------- :'I'E -sir i'i !!?! - ------------------------ -------------------------------- Ci731 ElT --------------------------- CPPCM'ET ff.CE1'iU;b. P^?cET?71i .. c1!P•I .^, _-. JPi co?1n.J1 ...:cc _.52 I1.5) CSEW.rCE MM IT G5 S.Op £c:-TC1aI cO.50 i:v r n ii14 <u'u. I- i(S I •Ii 441>4 r0{4{t: • T7.ai [G'.L; of . i5,5l1 4 &a7Ur,! p;rd in F'Ivance : !4O.O?i t .I ..............lli5O 4 aUe;C: Mei4• N i}42 NHf"440 COST 5Pc,?{Oo;:l -- ---- - - - ---- ------- .jUNT'i FEES -------- 24.:9 P9OTtV'e3TARY i.[0 1! mm ;1N 2?, m; It: s5 ;c' rcgjc 31 or -- l ] LUt.? Lti iZ ! 1 J_ i? 1_n _ r.` F .d- --------- ------ ---- ------------------------ - ___._ _ --- --- -- - -- - _= __....---- ---- , 1. _ f :- ? L M ? • 1' J ? li .- i I ..ai(.- 1 y?f t' D i. F.' ._ 1 I _.__._-_.-.-__--_.__----- _I DONALD L. HECK. PlaintilT IN THE COURT OF COMMON PLEAS 01: CUMBERLAND COUNTY, PENNSYLVANIA VS. CATI-IY MECK. Defendant ) NO. 1999-6598 CIVIL "TERM CUSTODY/VISITATION ORDER OF COURT AND NOW this ? day of ? , 2000, having not heard From the panics for some time, the undersigned Conciliator assumes the matter has been resolved and hereby rclinquishesjurisdiclion of the case. I f either ol'the parties wishes t'urther proceedings in this action, they should petition the Court anew. POR'ri IE COURT, 4AEL L. BANGS Custody Conciliator