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HomeMy WebLinkAbout01-0348 FXJohnson, Duftie, Stewart & Weidner By: Keirsten W. Davidson I.D. No. 78243 By: Mark C. Duffie I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff KATHERINE E. RYNARD, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 2001- 3y~ CIVIL TERM v. CIVIL ACTION -LAW JOEL D. SHEFFIELD, JR., IN CUSTODY Defendant COMPLAINT FOR CUSTODY 1. The Plaintiff is Katherine E. Rynard, hereinafter referred to as "MOTHER," who resides at 13 S. Filbert Street, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is Joel D. Sheffield, Jr., hereinafter referred to as "FATHER," who resides at 1161 Baish Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. MOTHER seeks custody of the following child: ALEXIS CARROLL RYNARD, age three months, whose date of birth is September 27, 2000. 4. The child was born out of wedlock. 5. The child is presently in the custody of MOTHER at 13 S. Filbert Street, Mechanicsburg, Cumberland County, Pennsylvania. 6. Since birth, the child has resided with the following persons at the following addresses: From birth until present -with MOTHER and Grandparents at 13 S. Filbert Street, Mechanicsburg, Pennsylvania. 7. The mother of the child is Plaintiff, Katherine E. Rynard. She is single. 8. The father of the child is Defendant, Joel D. Sheffield, Jr. He is single. 9. The relationship of Plaintiff to the child is that of natural mother. Plaintiff currently resides with the following persons: Plaintiff's parents and the minor child. 10. The relationship of Defendant to the child is that natural father. The Defendant currently resides with the following persons: Terry and Eve Smith, stepfather and mother; Carly Smith, half-sister. 11. MOTHER has not participated as a party or witness, or in any other capacity, in any other litigation concerning the custody of the child in this or another court. 12. MOTHER has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 13. MOTHER does 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. 14. The best interest and permanent welfare of the child will be served by granting the relief requested because: A. The child has resided with MOTHER since birth; B. MOTHER has been the child's primary caretaker since birth; C. The child has developed a close emotional bond with MOTHER; and D. MOTHER has the desire and the flexibility to care for the child on a primary basis. 15. 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. WJiEREFORE, MOTHER requests that the Court grant primary physical custody to MOTHER, subject to liberal periods of partial custody to FATHER. Respectfully submitted, JOHNSON, DUFFIE, STEW/~Ri~& WEIDNER C. Duffie :142129 :~ VERIFICATION I, Katherine E. Rynard, verify that the statements made in the foregoing Complaint for Custody are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. KOl.~1,tp rC.cic Q ~ l~ U`1~,'~ ~ Katherine E. Rynard Dated: 1- ~ ~ - (~ N ~' ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ T~ t~~r d 4 0 ~ %_ r ~ ~ ^~~ y F~ _~ r. ~, r °~ __ (~ _.. ,: \ :.;~ _:,. _~~ i b KATHERINE E. RYNARD IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JOEL D. SHEFFIELD, JR. DEFENDANT 01-348 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 18th day of January , 2001, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear beforeMelissa P. Greevy, Esq. ,the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on the 22nd day of February , 2001, at 1:00 p.m. for aPre-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: /s/ Melissa P Greev~, Es Custody Conciliatof--- 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 anangements 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 .~ ~..~ ~ ~ ~ ~'° ~~ i ~6 ~ ~ ~ ~ Ia ~~~/ t/h~!lilJtS~UN~d A1Nf?C}~J ^rd`~`1N~aAi~~O ~'~ ~ 1 ~1~1 ~~ f~'~i 10 ,~a~~~rac ~~~~a -, ~ ~Ea ~~!~~ ~-a3~u ~~~ KATHERINE E. RYNARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. JOEL. D. SHEFFIELD, JR. Defendant NO. 01-348 CIVIL ACTION -LAW CUSTODY ORDER OF COURT AND NOW, this 21st day of February, 2001, the Conciliator, having received notification from counsel for the Plaintiff that the parties have reached an agreement, hereby relinquishes jurisdiction of this matter. FOR THE COURT, Melissa Peel Greevy, Esquire Custody Conciliator F_ .r e KATHERINE E. RYNARD, Plaintiff v. JOEL D. SHEFFIELD, JR., Defendant NO. 2001-348 CIVIL TERM CIVIL ACTION -LAW IN CUSTODY ORDER AND NOW, this 13~~day of ~z, ~ ~-, , 2001, the attached Custody Agreement is hereby made into an Order of Court. ~A~ x ~ zo IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BY THE COURT: c~ 03-1 ~-01 R~s ~flNd,~IASN~~~f ~N(1~ ~;~f~'3 ~1,_,~,; .. ~~,~ ~~d ~tI L;~~~ ICS ,.. i Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson I.D. No. 78243 By: Mark C. Duffie I.D. No. 75906 301 Market Street P. O. $ox 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 KATHERINE E. RYNARD, Plaintiff v. JOEL D. SHEFFIELD, JR., Defendant CUSTODYAGREEMENT IN CUSTODY 1. MOTHER is Katherine E. Rynard, who presently resides at 13 South Filbert Street, Mechanicsburg, Cumberland County, Pennsylvania. 2. FATHER is Joel D. Sheffield, Jr., who presently resides at 1161 Baish Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. MOTHER and FATHER are the natural parents of one minor child, ALEXIS CARROLL RYNARD, age five (5) months, whose date of birth is September 27, 2000. 4. MOTHER shall have primary custody of the child. 5. FATHER shall enjoy liberal periods of partial custody pursuant to the agreement of the parties. FATHER shall be entitled to exercise his periods of partial custody each and every Monday from Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.2001-348 CIVIL TERM CIVIL ACTION -LAW 9:00 a.m. until 5:00 p.m., and each and every Saturday from 3:00 p.m. until 10:00 p.m. 6. The parties intend that this Agreement shall be made into an Order of Court. ~- I-Q1 ~CLt~~nlwLa 1 ~~~- Date Katherine E. Rynar Da e i ~~ ' Joel D. S iel r. :143757 ~' G? ~ ~ f 1 ~ ..{ ~'y; ~ j ~ ; ZF^"- 1 fi :~" ~ G ~ ~~ (,~~ "L JAW ~ 8 2001 KATHERINE E. RYNARD, Plaintiff v. JOEL D. SHEFFIELD, JR., Defendant ORDER OF COURT CIVIL ACTION -LAW IN CUSTODY You, JOEL D. SHEFFIELD, JR., Defendant, have been sued in court to obtain custody, partial custody or visitation of the minor child: ALEXIS CARROLL RYNARD. You are ordered to appear in person at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania on , 2001, at , - M., for ^ a conciliation or mediation conference. ^ a pretrial conference. ^ a hearing before the court. If you fail to appear as provided by this Order, an Order for custody, partial custody or visitation may be entered against you or the Court may issue a warrant for your arrest. 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 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 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. FOR THE COURT, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001- 3Y~ CIVIL TERM J.