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Home My WebLink About03-3949Andrew Patrick Meck, Jr., Plaintiff VS. Danielle Janette Stone, Defendant : IN THE COURT OF COMMON PLEAS OF : : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03- ,~ '~ q c~ CIVIL TERM : CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiffis Andrew Patrick Meck, Jr., residing at 322 Walnut Lane, Carlisle, Cumberland County, PA 17013. 2. The defendant is Danielle Janette Stone, currently residing in Cumberland County, to the best of PlaintifI's knowledge. 3. The plaintiff seeks custody 0fthe following child: Name Andrew Patrick Meck, III The child was bom out of wedlock. Present Residence 322 Walnut Lane Carlisle, PA 17013 D.O.B 4/26/01 The child is presently in the custody of the father, who resides at 322 Walnut Lane, Carlisle, PA 17013. During the child's lifetime, he has resided with the following persons and at the following addresses: Name Andrew Patrick Meck, Jr. Danielle Janette Stone Address 33 N. High St., Apt. 2 Duncannon, PA 17020 Date 4/26/01-7/01 Andrew Patrick Meek, Jr. Danielle Janette Stone Andew Patrick Meek, Jr. Danielle Janette Stone Danielle Janette Stone Debrah Stone (Defendant's mother) Andrew Patrick Meck, Jr. Danielle Janette Stone Danielle Janette Stone Donald Weaver (friend) Andrew Patrick Meek, Jr. Angela Rudy (fianc6) Susan Rudy (fiance's mother) Leonna Williams (fiance's sister) Danielle Janette Stone Andrew Patrick Meek, Jr. Angela Rudy (fianc6) Susan Rudy (fiance's mother) Leonna Williams (fiance's sister) 438 S. 15th St. Harrisburg, PA 17104 5402 Dwight Avenue Harrisburg, PA 17112 443 Delville Road Duncannon, PA 17020 4 Jefferson St. Duncannon, PA 17020' 4 Jefferson St. Duncannon, PA 17020 322 Walnut Lane Carlisle, PA 17013 7/01-1/02 1/02-4/02 4/02-5/02 5/02-3/03 3/03-5/03 5/03-7/03 various residences in Cumberland County 322 Walnut Lane Carlisle, PA 17013 5/03 -7/03 7/03-present The mother of the child is Danielle Janette Stone, currently residing somewhere in Cumberland County. She is single. The father of the child is Andrew Patrick Meek, Jr., currently residing at 322 Walnut Lane, Carlisle, PA 17013. He is single. 4. The relationship of plaintiff to the child is that of father. The plaintiff currently resides with the following persons: Name Andrew Patrick Meck, III Angela Rudy Susan Rudy Leorma Williams Relationship son fianc6 fiance' s mother fiance's sister 5. The relationship of defendant to the children is that of mother. The defendant currently resides with the following persons: Name Relationship Unknown Unknown 6. The plaintiff has 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. 7. The plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commomvealth. 8. The plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or clainrs to have custody or visitation rights with respect to the child. 9. The best interest and pemranent welfare of the child would be served by granting the relief requested because it would be more stabilizing for the child. WHEREFORE, the plaintiff requests this Court to grant him primary physical custody of the child with partial custody in the defendant at times mutually agreed upon by the parties. Plaintiff further requests any other relief that is just and proper. Respectfully submitted, Attorney for Plaintiff Mid Penn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 VERIFICATION I verify that I am the Petitioner as designated in the present action and that the facts and statements contained in the above Petition are tree and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S.§4904, relating to unswom falsification to authorities. ~.~ ..~ Dated: ~//~ ~//~ ~.T '~eck, Jr., Plaintiff Andrew Patrick Meck, Jr., Plaintiff Danielle Janette Stone, Defendant : IN THE COURT OF COMMON PLEAS OF : : CUMBERLAND COUNTY, PENNSYLVANIA NO. 03- .~ '~ ~/~ CIVIL TERM CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Andrew Patrick Meck, Jr., Plaintiff, to proceed in forma pauperis. I, Joan Carey, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 Andrew Patrick Meck, Jr., Plaintiff VS. Danielle Janette Stone, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03- .y */q ct C VIL TER CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiffis Andrew Patrick Meck, Jr., residing at 322 Walnut Lane, Carlisle, Cumberland County, PA 17013. 2. The defendant is Danielle Janette Stone, currently residing in Cumberland County, to the best of Plaintiff's knowledge. 3. The plaintiff seeks custody 0fthe following child: Name Present Residence D.O.B Andrew Patrick Meck, III 322 Walnut Lane 4/26/01 Carlisle, PA 17013 The child was bom out of wedlock. The child is presently in the custody of the father, who resides at 322 Whlnut Lane, Carlisle, PA 17013. During the child's lifetime, he has resided with the following persons and at the following addresses: Name Andrew Patrick Meck, Jr. Danielle Janette Stone Address 33 N. High St., Apt. 2 Duncannon, PA 17020 Date 4126101-7/01 Andrew Patrick Meck, Jr. Danielle Janette Stone Andew Patrick Meck, Jr. Danielle Janette Stone Danielle Janette Stone Debrah Stone (Defendant's mother) Andrew Patrick Meck, Jr. Danielle Janette Stone Danielle Janette Stone Donald Weaver (friend) Andrew Patrick Meck, Jr. Angela Rudy (fianc6) Susan Rudy (fiance's mother) Leonna Williams (fiance's sister) Danielle Janette Stone 438 S. 15th St. Harrisburg, PA 17104 5402 Dwight Avenue Harrisburg, PA 17112 443 Delville Road Duncannon, PA 17020 4 Jefferson St. Duncannon, PA 17020 4 Jefferson St. Duncannon, PA 17020 322 Walnut Lane Carlisle, PA 17013 various residences in Cumberland County 7/01-1/02 1/02-4/02 4/02~5/02 5/02~3/03 3/03.5/03 5/03-7/03 5/03-7/03 322 Walnut Lane Carlisle, PA 17013 7/03-present Andrew Patrick Meck, Jr. Angela Rudy (fianc6) Susan Rudy (fiance's mother) Leonna Williams (fiance's sister) The mother of the child is Danielle Janette Stone, currently residing somewhere in Cumberland County. She is single. The father of the child is Andrew Patrick Meck, Jr., currently residing at 322 Walnut Lane, Carlisle, PA 17013. He is single. 4. The relationship ofplaintiffto the child is that of fa,ther. The plaintiff currently resides with the following persons: Name Andrew Patrick Meck, Ili Angela Rudy Susan Rudy Leonna Williams Relationship son fianc6 fiar[c e ' s mother fiance's sister 5. The relationship of defendant to the children is that of mother. The defendant currently resides with the following persons: Name Relationship Unknown Un.known 6. The plaintiffhas not participated as a party or witness, or in another capaeity, in other litigation concerning the custody of the child in this or another court. 7. The plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 8. The plaintiff 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. 9. The best interest and permanent welfare of the child would be served by granting the relief requested because it would be more stabilizing for the child. WHEREFORE, the plaintiff requests this Court to grant him primary physical custody of the child with partial custody in the defendant at times mutually agreed upon by the parties. Plaintiff further requests any other relief that is just and proper. Respectfully submitted, t~/joan Carey g Attorney for Plaintiff Mid Penn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 VERIFICATION I verify that I am the Petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I tmderstand that any false statements are made subject to the penalties of 18 Pa.C.S.§4904, relating to unswom falsification to authorities. Dated: 7t / ~' - Andre)W~atrick Meck, Jr., Plaintiff Andrew Patrick Meck, Jr., Plaintiff VS. Danielle Janette Stone, Defendant : In the Court of Common Pleas of : : Cumberland County, Pennsylvania : : No. 03- Civil ['erm : : Custody CUSTODY ORDER ANDNOW, this~ayof ~'~0"-'5~[ 2003, the following Order is ~ntered by consent of the parties with regard to custody of the parties' child, Andrew Patrick Mec¢, III, bom April 26, 2001: 1. Plaintiff, Andrew Patrick Meck, Jr., hereinafter referred to as the father, and Defendant, Danielle Janette Stone, hereinafter referred to as the: mother, shall share legal custody of the child. 2. 3. by the parties. 4. The father shall have primary physical custody of the child. The mother shall have partial custody of the child at times mutually ~greed upon The mother and father shall share custody of the child on holidays at times mutually agreed upon by the parties. 5. The mother shall have custody of the child on Mother's Day. The father shall have custody of the child on Father's day. 6. The mother and father agree that each shall notify the other immediately of medical emergencies that arise while the child is in that parent's care. 7. Neither party shall do anything which may estrange the child frOm the other parent, or injure the opinion of the child as to the other parent or which may hamper !the free and natural development of the child's love or respect for the other parent. By the Court, This Order is e!3t~red pur.$~ant to the consent of Plaintifl and DefendanI: Judge Andrew lgatfi~Meck, Jr., Plaintiff l~a-nielle'J~nette Stofle, Pro Se Defendant C~a'n Carey, Attorney for P~intiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 o Andrew Patrick Meck, Jr., Plaintiff Danielle Janette Stone, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03- _3 q't cxwL ,EP.U CUSTODY PRAECIPE TO PROCEED 1N FORMA PAUPER_IS To the Prothonotary: Kindly allow, Andrew Patrick Meck, Jr., Plaintiff, to proceed in forma pauperis~ I, Joan Carey, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400