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Home My WebLink About07-3975Jeffrey B. Engle, Esquire SHAFFER & ENGLE LAW OFFICES 129 Market Street Millersburg, PA 17061 717-692-2345 * phone 717-692-3554 * faz jeffengl@epix.net MELISSA O. MCCONCHIE, Petitioner vs. JONATHAN R. SEELE, Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV~AN~IA CIVIL ACTION -LAW IN CUSTODY CUSTODY COMPLAINT & STIPULATION 1. Plaintiff is Melissa O. McConchie, an adult individual currently residing at 4704 Courtland Street, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. Defendant is Jonathan R. Seele, an adult individual currently residing at 60 Bryon Nelson Circle, Etters, York County, Pennsylvania, 17319. 3. Plaintiff seeks custody of the following children: Name Present Residence Age Mia Deanna Seele 4704 Courtland Street 4 (DOB 10/1/02) Jaden David Owen Seele Camp Hill, PA 17011 2 (DOB 4/16/05) The child Mia was born out of wedlock, the child Jaden was born in wedlock. The children aze presently in the custody of Petitioner, Melissa McConchie, who resides at 4704 Courtland Street, Camp Hill, PA 17011. During the past four (4) years the children have resided with the following persons at the following addresses: Name Melissa McConchie Jaden David Owen Seele Mia Deanna Seele Melissa McConchie Jonathan R. Seele Jaden David Owen Seele Mia Deanna Seele Address Date 4704 Courtland Street ' 4/07 to present Camp Hill, PA 17011 y ' 4704 Court treet Birth to 4/07 Cam i 1, PA 17011 ~ ~yr~, ~~~~r CX The mother of the children is Melissa McConchie who currently resides at 4704 Courtland Street, Camp Hill, Cumberland County, Pennsylvania. The father of the children is Jonathan R. Seele, who currently resides at 60 Bryon Nelson Circle, Etters, York County, Pennsylvania. 4. The relationship of Petitioner to the children is that of natural mother; the Petitioner currently resides with the children.. 5. The relationship of Respondent to the children is that of natural father; the Defendant currently resides alone. 6. Petitioner 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. Petitioner has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 7. Petitioner does not know of a person not a party to the proceeding who has physical custody of the children, or claims to have custody or visitation rights with respect to the children. 8. The Petitioner and Respondent have agreed upon custody of the children and have executed the original attached Stipulation for consideration by the Court for entry of an Order. 9. The best interest and permanent welfare of the children will be served by granting the relief requested. WHEREFORE, Petitioner seeks entry of the attached Stipulation as an Order of Court. Respectfully Dated: e . Et o. 7. & EnTGLL LAW OFFICES 129 Milldrrsburg, P2~ 17061 (717)692-2345 Attorney for Petitioner d. The parties shall shaze Christmas on an A/B schedule. Father shall have Segment B in odd years, and Mom shall have Segment A in odd years. The parties shall then alternate, with Father having Segment A in even yeazs and Mom having Segment B in even years. A Segment consists of physical custody from December 20~' until December 26d'. B Se ent consists of physical custody from December 26`~ until January 2nd 4. The parties agree to share transportation requa~l3~, meeting at an agreeable ~ point between the parties residences. Z~3 MeL~~~ ,~3 '~'~G~-(„ o,n cs 5. Mother also agrees to reduce the current amount of child support she is receiving from Father to $600.00 per month effective January 1, 2008. 6. Mother shall not relocate until after December 1, 2007, after which time Mother may relocate but not in excess ot:~miles from Camp Hill, Pennsylvania. . c K S ,23 v ~v`' 7. Both parties are directed to encourage the children to love and respect the other party and aze prohibited from making any derogatory remazks about the other party in the presence of the children or permitting anyone else to make such remarks about the other party while the children aze their custody. 8. Each party shall be afforded reasonable telephone contact with the children during the other party's period of physical custody. 9. The parties agree to provide each other with school records and reports, medical records and reports, and notification of appointments the children have with any treating professionals, as well as information, concerning extracurriculaz activities, interests and hobbies. Each party also agrees to provide the other party with phone numbers and contact information including cell phone numbers where the children can be reached when any party travels or vacations with the children, or spends periods of overnights .away from home. 10. Neither pazent shall use illegal drugs or alcohol to the point of intoxication while in the presence of the children and shall encourage others not to do so in the presence of the children. Page 2 of 3 ~? ~ o _., ti ~} 5".. ~. r~~ -~ ~ k~ . ~, 1~ Ca ~1 ' .'.... _.t r-- 1.d _. ~,.Yl (~J ti _ ~i ~ ~~ ~. `~ it _.aCJ ~'x-~ ~~ iV %~~ ~ t_/'1 MELISSA O. MCCONCHIE, Petitioner vs. JONATHAN R. SEELE, Respondent I~~E20~,y~-" N' /~, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IIV CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint and Stipulation, the attached Stipulation is made an Order of Court this ~ day of , 2007. Date OO J. Distribution: Jeffrey B. Engle, Esquire, 129 Market Street, Millersburg, PA 17061 ,; ~,,~...._,~,~t~ Jonathan R. Seele, 60 Bryon Nelson Circle, Etters, PA 17319 ~- ro - o ~ P fi ~,~ ~€ ~~I ~~~.~ ~ f ~~~' tG~~