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Home My WebLink About07-7006NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, you may lose rights and visitation of your child. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford St. Carlisle, PA 17013 (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. TIFFANY N. MAYFIELD, Plaintiff V. SHAWNDELL WATTS, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : IN CUSTODY :NO. 10 7- 7 610 1?0 CIVIL TERM COMPLAINT IN CUSTODY The Plaintiff, TIFFANY N. MAYFIELD, by her attorneys, the Family Law Clinic, sets forth the following cause of action in custody: 1.The Plaintiff is TIFFANY N. MAYFIELD, residing at 500 Geneva Drive, Apartment E-4, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The Defendant is SHAWNDELL WATTS, residing at 25 Sprague Street, West Springfield, Massachusetts, 01089. 3. Plaintiff seeks primary custody of: Name Present Residence Age Date of Birth Danayiah Watts 500 Geneva Drive 11 5/18/1996 Mechanicsburg, PA 17055 4. The child was born out of wedlock. 5. The child is presently in the custody of TIFFANY N. MAYFIELD, who resides at 500 Geneva Drive, Apartment E-4, Mechanicsburg, Cumberland County, Pennsylvania. 6. During the past five years the child has resided with the following persons at the following addresses: Persons 1. Tiffany Mayfield (Mother) Trevon Williams (Brother) Demarcus Williams (Brother) Jaymond Bratcher (Brother) Regina Bratcher (Sister) 2. Tiffany Mayfield (Mother) Trevon Williams (Brother) Demarcus Williams (Brother) Jaymond Bratcher (Brother) Address Dates 500 Geneva Dr. Aug. 2006- Mechanicsburg, PA Present Cumberland County 4 Genesis Court Dec. 2000- Middletown, PA Aug. 2006 Dauphin County Regina Bratcher (Sister) 7. The mother of the child is Tiffany N. Mayfield. 8. She is not married. 9.The father of the child is Shawndell Watts. 10. It is not believed that Father is currently married. 11. The relationship of Plaintiff to the child is that of Mother. The Plaintiff currently resides with the following persons: Name Relationship Danayiah Watts Daughter Trevon Williams Son Demarcus Williams Son Jaymond Bratcher Son Regina Bratcher Daughter 12. The relationship of Defendant to the child is that of Father. The Defendant currently resides with the following persons: Name Unknown Relationship 13. 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. 14. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth, or any other state. 15. 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. 16. The best interest and permanent welfare of the child will be served by granting the relief requested because: a. Plaintiff has been the child's primary caretaker for all of the child's life; b. Plaintiff provides the child with a stable home and environment with adequate moral, emotional, and physical surroundings as required to meet the child's needs; c. Plaintiff has permitted contact between Defendant and the child and will continue to do so; d. Plaintiff is willing to accept custody of the child. 17. Each parent whose parental rights to the children have not been terminated and the person who has physical custody to the child have been named as parties to this action. WHEREFORE, plaintiff requests the Court to grant her shared legal custody and to grant her primary physical custody of the minor child, with father having periods of partial custody. Respectfully submitted, Date: 111q/0 Meg . Mic el Certified Legal Intern I ROBERT E. RAINS THOMAS M. PLACE LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 Verification I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. ?I TIFFANY N. MAYFIELw j C? I '"T'{ r'? ?•• P C?3 -.C TIFFANY N. MAYFIELD, Plaintiff V. SHAWNDELL WATTS Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY : NO. 01. CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow TIFFANY N. MAYFIELD, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date 0 f7 Medan M. Mich el Certified Legal Intern r 9 aur, 4? - ROBERT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 c- c -g I n3 TIFFANY N. MAYFIELD IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2007-7006 CIVIL ACTION LAW SHAWNDELL WATTS IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, December 04, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, Januarv 02, 2008 at 9:30 AM for a Pre-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. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sunda Es q. Custody Conciliator 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 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. 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 '4' "cS - `' x'37 ?`? w.' ?c! 1 C :1 u'd ?- 320 LUUZ Serratelli, Schiffman, Brown & Calhoon, P.C. Paige Macdonald-Matthes, Esquire 2080 Linglestown Road, Suite 201 Harrisburg, PA 17110 (717) 540-9170 (717) 540-5481 Attorneys for Defendant DO-ALL DRYWALL, INC. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, V. : DOCKET NO. 2007-7066 : CIVIL ACTION - LAW BARRETT COMPANY, INC. DEFENDANT NOTICE TO PLEAD To: Do-All Drywall, Inc. c/o Craig A. Diehl, Esquire LAW OFFICES OF CRAIG DIEHL 3464 Trindle Road Camp Hill, PA 17011 You are hereby notified to file a written response to the enclosed Preliminary Objections to Plaintiffs Complaint within twenty (20) days from service hereof or a judgment may be entered against you. Respectfully submitted, Paige Macdonald-Matthes, Esquire Attorney ID No. 66266 SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road, Suite 201 Harrisburg, PA 17110 (717) 540-9170 Date: December 17, 2007 L ? Serratelli, Schiffnan, Brown & Calhoon, P. C. Paige Macdonald-Matthes, Esquire 2080 Linglestown Road, Suite 201 Harrisburg, PA 17110 (717) 540-9170 (717) 540-5481 Attorneys for Defendant DO-ALL DRYWALL, INC. PLAINTIFF, V. BARRETT COMPANY, INC. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : DOCKET NO. 2007-7066 : CIVIL ACTION - LAW DEFENDANT DEFENDANT'S PRELIMINARY OBJECTIONS TO PLAINTIFF'S COMPLAINT AND NOW, comes Defendant, Barrett Company (hereinafter "Barrett"), by and through their counsel, Serratelli, Schiffnan, Brown & Calhoon, P. C., and files their Preliminary Objections to Plaintiff s Complaint, and in support thereof aver as follows: PRELIMINARY OBJECTION TO PLAINTIFF'S COMPLAINT- LEGAL INSUFFICIENCY (DEMURRER), Pa. R. Civ. P. 1028(a)(4) 1. Cousins Bennington Hotel, LLC ("COUSINS") is the legal owner of the Hampton Inn, Bennington, Vermont. 2. COUSINS hired Defendant to serve as the General Contractor for the construction of the Hampton Inn, Bennington, Vermont (hereinafter the "PROJECT"). 3. During the PROJECT, communications between COUSINS and Defendant broke down due to unexecuted change orders and a disagreement between COUSINS and Defendant concerning the PROJECT ensued. Y 4. As part of the resolution of their disagreement regarding the PROJECT, COUSINS determined to hire its own dry-wall contractor, which was Plaintiff. 5. COUSINS hired Plaintiff to provide framing, sheetrock and taping (hereinafter collectively "Drywall Services") for the PROJECT. Defendant is without knowledge sufficient to form a belief as to whether the contract between COUSINS and Plaintiff was subsequently reduced to writing however, there was at least one (1) other witness to the oral contract between COUSINS and Plaintiff, to wit, the PROJECT Superintendent. (Defendant believes and therefore avers that if there is a written contract between Plaintiff and COUSINS, a copy of the written contract is in the possession of Plaintiff and/or COUSINS). 6. Pursuant to the terms of the contract between COUSINS and Plaintiff, COUSINS was obligated to pay Plaintiff for services rendered conditioned on Defendant's review and approval of the work performed by Plaintiff that was described in each payment authorization form submitted by Plaintiff to Defendant. 7. All payment authorization requests that were properly submitted by Plaintiff and authorized by Defendant up to and including Plaintiff's Invoice dated October 13, 2005 were paid, as evidenced by the following documents: Plaintiff's Exhibit "A" attached to its Complaint; Plaintiff's Invoice dated October 3, 2005 (with supporting authorizations), together with a copy of the Treasurer's Check made payable to Plaintiff and Defendant in the amount of $20,778.00, copies of which are attached hereto and collectively marked as Exhibit "A"; and Plaintiffs Invoice dated October 13, 2005, (together with supporting authorizations) which is attached hereto and collectively marked as Exhibit "B." 8. No contract, either written or oral, exists between Plaintiff and Defendant that would in any way obligate Defendant to pay the amount claimed to be due and owing by Plaintiff in its Complaint. WHEREFORE, Defendant, Barrett Company jointly and severally respectfully requests that this Honorable Court sustain its Preliminary Objection to Plaintiff's Complaint, dismiss Plaintiff's Complaint with prejudice and further award Defendant all such other relief as is proper and just. PRELIMINARY OBJECTION TO PLAINTIFF'S COMPLAINT- FAILURE TO JOIN NECESSARY PARTY, Pa. R. Civ. P. 1028(a)(5) 9. The averments set forth in paragraphs 1 through 8 are incorporated by reference as if more fully set forth at length herein. 10. As previously stated herein, COUSINS is the legal owner of the Hampton Inn, Bennington, Vermont. 11. As previously stated herein, COUSINS entered into a contractual agreement with Plaintiff to perform dry-wall services for the PROJECT. 12. COUSINS affirmatively represented to Plaintiff that COUSINS was responsible to pay Plaintiff for services rendered on the PROJECT. 13. All payments issued to Plaintiff for the PROJECT were issued to Plaintiff by COUSINS. 14. The payments claimed to be due and owing by Plaintiff in its Complaint are payments for which COUSINS is contractually liable. 15. COUSINS has a joint interest in the subject matter of this action and must be joined by Plaintiff as a necessary, indispensible party to this action. WHEREFORE, Defendant, Barrett Company jointly and severally respectfully requests that this Honorable Court sustain its Preliminary Objection to Plaintiff's Complaint, dismiss Plaintiff's Complaint with prejudice and further award Defendant all such other relief as is proper and just. Respectfully submitted, Date: December 17, 2007 Paige Macdonald-Matthes, Esquire Pa. Attorney I.D. No. 66266 SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road, Suite 201 Harrisburg, PA 17110 (717) 540-9170 VERIFICATION I, Michael Barrett, verify that the statements made in the foregoing Preliminary Objections to Plaintiff's Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. I Date: ? ?? - (3-7 Michael Barrett Member FDIC 1 0 117 0 O .Q REMITTER: COUSINS BENNINGTON HOTEL, LLC DATE 11/15/05 DO-IT-ALL.DRYWALL, BARRETT CO INC & COUSINS BENN HOTEL LLC 20,778.00 DISB #14 CUSTOMER. FILE COPY TREASRRERQS CHECK NOT NEGOTIABLE Received Fax Oct 03 2005 4:29PM Fax Station : BARRETT COMPANY 2 10/03/2005' 03:35 8607457860 DD ALL DRYWALL PAGE 02 Do-All Drywall, Tnc. 9 Laughlin Rd. Enfield, CT 06082 BILL TO Barrett Company, Inc. 1429 South 18th St. Camp Ai)1 PA 17011 Attn: Michael Barrett Invoice DATE INVOICE # 10/3/2005 ##I6hamp PROJECT Hampton Inn,Ben QUANTITY DESCRIPTION RATE AMOUNT 09/26/05 60x$48 2,880.00 2,880.00 09127/05 30x$48 1,440.00 1,440.00 40x$48 1,920.00 1,920.00 09/28/05 38x$48 1,824.00 1,824.00 45x$48 2,160.00 2060.00 09/29/05 80x$48 3,840.00 3.840.00 09130/05 80xS48 3,840.00 3,840.00 14x$48 672.00 672.00 Overtime 1.0x$24 240.00 240.00 Mcals 37x$35 L,295.00 1,295.00 4xS 15 60.00 60.00 gas 200.00 200.00 Rooms 205.79 205.79 Home Depot Misc. 201.76 201.76 Total $20,778.55 DO ALL DRYWALL 8607457860 ap,?TT WMPAW 1,0/03/2005 03:35 14:47 18024409641 09/27/2005 00 AUI. 6- Qf?2712085 27'24 g01497"'S PAGE. 03 PAGE 01 , M 01 I n M ? A al.l s t7Cll+1? ;; pt _ ?.?,° tea? ,? ? 10/ r VAT14--l" Oz PAGE 04 + DO ALL DRYWALL PAGE 01 10/03/2005 03:35 8607457850 BARRETT COWANY 09!2912005 16:23 18024409641 FAS pp t.L R(4A-1. 0'1r 2T128: 23:24 56874570" D IJIIMMM 110- Acr '8745.74 TA](r W7454M Is xcrATM. ?r, rn`n 'n TO. & T65CSANftt7IM MOOKUMTOPAVDIK WMATO VaWfMJtiCG 3aX'=vocujuNr,AfldY1iN3NTxMcwAxoftAm DATA ? 7-Z-9""Ob dl??- ?. o ®m- 8607457$60 0312005 03:35 10024409041 09/29/2005 16;23 g?t27t2d55 33.24 DAM, TM WW=TM p68T?? vsLow; , car ..... . V-A J IA ..? ?? ?- 1 ' Q r? Comm p Cam . ?'9r ! T'A, Kr NL CXR? ZEN, ? ? FAQ 05 ALL DRYWRL?- pA? 02 DD BARE TT to OLJ- WmMPLL 1 8607457860 DO ALL DRYWALL 1'0/.03/2005 03:35 PAGE 06 DO ALL WVWAI..L PA'x 81 97/27/2899 23:24 868707"9 •- DU.A?t.DIrYWAts,?liC, . 4 LAIA$A.II?I3tD. zmpm.clrosm FA7CM7iMSM DAmr. ' a??rA???zaaasa??ar?eeaa?e4eavw: I (:e) )s{m Tai awM PAwrc rAwwC?'0 nom'wmm PR14'fOB. DATE4 DAT& """'CMR GE'N1?At ANVdWM 113AMS TOB600VZOST 88 :9T gppT. /DIF it a TO 39bd _• 1 1 11 t • 1.0/03/2065 03:35 8607457860 DO ALL DRYWALL PAGE 07 M 27/2095 23.24 068707969 DO All DRYWALL FAGS 31 9XAVm Xm nowD. MUSJ"w PAX'1NS-0eA r7. 'hD.? ? p41 _l . 2MWrA p n?? • "lorl • WZ t&eYA?88D'lD1KA7?E' ?gFANC? Ipmum. ' ?{ ' •r •i' t. .J DATP-4a ts 1 1.8.-: VATAL- d V LA 39%$d ANbdW00 113tkM 108600ozoal 80:91 500b/0E/60 CA ,NO ;WC c .$z Imo 2 n 10/13/2005 01:21 8607457860 Do-AM Drywall, Inc. 9 Laughlin Rd. Enfield, CT 06082 BILL TO Barrett Company, Inc. 429 South 18th St. Camp Hill PA 17011 Attn: Michael Barrett DO ALL DRYWALL PAGE 02 Invoice DATE INVOICE # 1011312005 #17hamp PROJECT Hampton 1nn,Ben QUANTITY DESCRIPTION RATE AMOUNT 10/03/05 65X$48 3,120.00 3,120.00 25x$48 1,200.00 1,200.00 10104105 75xS48 3,600.00 3,600.00 25x$48 1,200.00 1,200.00 9x$48 432.00 432.00 10/05105 60x$48 2,880.00 2,880.00 29x$48 1,392.00 1,392.00 10/06/05 19x$48 912.00 912.00 20048 960.00 960.00 60x$48 2,880.00 2,880.00 10/07/05 59x$48 2,832.00 2,832.00 40x$48 1,920.00 1,920.00 10/08/05 15x$48 720.00 720.00 15x$48 720.00 720.00 Overtime 14024 336.00 336.00 Meals 47x$35 1,645.00 1,645.00 10x$15 150.00 150.00 Rooms 1 220.001 220.00 gas 228.14 228.14 Home Dcpot Miscclaneous 354.04 354.04 Kamco Inv. 9797834 3,176.42 3,176.42 Total 10/13/2005 01:21 8607457860 DO ALL DRYWALL PAGE 03 Do-All Drywall, Inc. 9 Laughlin Rd. Enfield, CT 06082 BILL TO Barrett Company, Inc. 429 South 18th St. Camp Hill PA 17011 Attn: Michael Banat Invoice DATE INVOICE # 10/13/2005 #17hamp -U- PAGE 04 81:21 8687457860 10/1312805 e?? t ??, ae Za: 24 OW46786e DO ALL D"WALL M PU_ rKYAWWL cwwaAct"m 006.7"J" m -Ar z<. tkS ,rooa WAxPW.?pnr?. ?n ?t r + 1 ? ?5 ' M C'$AtiIiS+MUM BDOO&MPAST bF AID JN C%4VO UA" WEL TO SMIM TIDBbOG ',AmM MENTOM )b AND t S7 Ste. '?'?? ??GON'?1ACTt? '' t3tALCAC':?R ?„ T,b866VOZ08 t ?? 1tNb? i1321? 1/ -l 0E:80 seallost0L E0 3Vd / 11 • 1 • 10/13/2005 01:21 8607457860 DD ALL DRYWALL PAGE 05 07/27/2065 23,24 0607457860 DO ALL DRYWALL PASE 01. MALL PAYWALt, M, MOM A, cr 06068 8"745.7&t0 P.4.'"?86Q-743-y860 DAIS: %^ (? TO., ???/ W Nn?+ n ?oh WE YA J ., . ? TO MAKE'2ER MANC3E SPOCOrMgMOW; ' V r V . plodr HHCOIM PAJKr OF AM IN iR AND DA YE: O DAM ` IJI3C -- ? ?. LEV RU, imlit ?'l'OR 10/13/2005 01:21 8607457860 DO ALL DRYWALL PAGE 06 F 8-,/ 27/2005 23:24 6697457968 DO ALL DRYWALL PASS O i, DO ??IM DRYwALL, M BNpmw, CT06062 FAX400-743 7860 yb 9 r. DATE. pro: c?! oS" r?s zvcnrtor?: ??nvK h WE HMMY TO MAM TIM CHANM sFaMSasarow: Merl - 14 ?1r? ,? ?" ? nyy , 6+ ? loo r ? "q-A lo V, c V?y N b fQ BRAB WftatM ?M PAn OF AM W PR[C"n?OBb . D 1 T•A? ? AM DATBJ DAM- AD . ¢b?RAt" C?'?.fiOlt PAGE 07 ® $607 q57 p,60 312005 01 21 860 ? 4?g80 07/2712085 23'24 ?c DO ALL DpvWALL vo a-L 'AI'L x ",`' ?,,pfs,lyR rte,. .. _ , ? ., e -,' J?(?'?'?/,?/~r` • ! ???? ` 1 ?` C ?? JjY (400C ?r s p?,t? ? wTB. ?. fo ?LE -- flp'1'E: d Iz Z ?Cp?P.1i?,?"GQR PAGE 08 DO ALL DRYWALL 01:21 8607457860 1/13/2005 DO OLL f?t'FtiA4L / 29:24 0697457988 F v0.41yDsXwA24m- . .F?a, C! 060d'Z F,I?jrBW?? 7860 PASS 6S. pR.n. u 5 ; ?d'AE8 p?,qW. LA q??h t a? ,bra ?Q :9? ?gOL JZi tQT "''? t,90bZgbZ08 MOO 53-idGlS 50 "d v p y ADULT-r a 4 /1312005 01:21 8607457660 10/11/2005 10:40 18024409841 e68 im x7/2Ee3 29:21 9E0'7497 DD ALL DRYWALL BARRETT COMPANY -OLMXKWNL a vw amFi?M74&7 PAGE 09 PAGE 03 ti 7)A1ia: 7178 L0CAI QOM ?• W MMYAGIM 'tV MUM TEMOWM U,Q _3 r r P 1' A? p ?Jll? 2? o - ooltrf ,r,"''-M- VA • CERTIFICATE OF SERVICE I, Paige Macdonald-Matthes, Esquire, do hereby certify that on this 17th day of December, 2007, I served a copy of Defendant's Preliminary Objections to Plaintiff's Complaint via United States Mail, First Class, postage pre-paid, to the following person(s): Craig A. Diehl, Esquire LAW OFFICES OF CRAIG DIEHL 3464 Trindle Road Camp Hill, PA 17011 Attorney for Plaintiff, Do-All Drywall, Inc. Paige Macdonald-Matthes, Esquire 7 i ? ?-G K 1 k TIFFANY N. MAYFIELD IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :2007-7006 CIVIL ACTION LAW SHAWNDELL WATTS , Defendant. : IN CUSTODY CERTIFICATE OF SERVICE I, Megan M. Michael, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Custody Complaint on Shawndell Watts, residing at 25 Sprague Street, West Springfield, Massachusetts, 01089 by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt on December 12, 2007 as evidenced by the attached green card. Ce ifi d Legal Inte Supe sing Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 r ¦ Complete items 1, 2, and 3. Also complete a gre 13 Agent item 4 If Restricted Delivery is desired. Addressee ¦ Print your name and address on the reverse so that we can return the card to you. g, ad by f Name) " C. of iver? ¦ Attach this card to the back of the mailpiece Me or on the front If space permits. is delivery add Hferent from Kom 1 ? Yes 1. Article Addressed to: IYES, enter defier ?address.below: oi [3 No ?a,-t,t ? l Q .'t- J L' l r ?v l) ,M /r 1? v1 ? I??T r ? Express Mail ) ? Registered { Return Receipt f or Merchandise L ? Insured mail ? C.O.D. V O 4. Restricted Delivery? (Extra Fee) es 2. AticleNurrl-- 7005 0390 0003 2632 6147 (Panster In PS Form 3811, February 2004 Domestic Return Receipt 102595-02-WI 540 Y UNITED STATES POSTAL SERVICE I 111111 • Sender: Please print your name, address, and ZIP+4 !nW)K boo A44 it,?lii„tliltt:F?,li„lip},i?li?i?t?it}i,?li?,i?,i,i,i;??,Jil c? .. : OD ? ? (Dvn 91 s TIFFANY N. MAYFIELD, Plaintiff V. SHAWNDELL WATTS, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2007-7006 CIVIL ACTION LAW IN CUSTODY CERTIFICATE OF SERVICE I, Megan M. Michael, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Custody Complaint and Court Order scheduling a hearing on Shawndell Watts, residing at 25 Sprague Street, West Springfield, Massachusetts, 01089 by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt on December 12, 2007 as evidenced by the attached green card. C s I M ganM. Mic ael Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 I A. q Agent by D. Is delivery ad I S, enter `OF ?r from item 1? 0 Yes below: ? No ? 114) ? ?,dr ? Express Mall ? Registered -A Return Receipt for Merohandis v/n / o o ? insured Mail ? C.O.D. J 4. Restricted Delivery? (Extra Feel es 2. Article 7005 0390 0003 2632 6147 (Transferr fn fi PS Form 3811, February 2004 Domestic Return Receipt 102595-02.M.i& ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front If space permits. 1. Article Addressed to: ?1 G?XX. ? hew ? uQ :Z A e UNITED STATES POSTAL SERVICE F CVN o" U 9 p 1( • Sender. Please print your name, address, and ZIP+4 in bof3 vs- )91 A-44 r? ' i11)IIl1If fill) 11)1IIII l1111)1»111111111$) 1111!)1I1if1fi11111 71 Mir; - rn Man Fn C'"' ?m W M TIFFANY N. MAYFIELD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY SHAWNDELL WATTS, Defendant. : NO. 2oo`7 " 7 00(o CIVIL TERM CUSTODY AGREEMENT THIS AGREEMENT, made this L day of -be-Centibe-r , 2007, between TIFFANY N. MAYFIELD, hereinafter Mother, and SHAWNDELL WATTS, hereinafter Father, concerns the custody of their child: DANAYIAH WATTS, born May 18, 1996. Mother and father desire to enter into an agreement as to the custody of the child. Mother and father agree to the following. 1. Mother and Father shall share legal custody of the child. 2. Mother shall have primary physical custody of the child. 3. Father shall have partial custody of the minor child during a period in the summertime. This period shall begin on the Saturday following the child's last day of school. Father shall return the child to her Mother on July 1St 4. Father shall be responsible for transporting the child both to and from Mother's residence. 5. Father shall notify Mother one week in advance if he is going to exercise his period of partial custody. 6. Father understands that if he is late in picking up the child, Father will still return the child on July 1 St M ? 7. Father shall have such other periods of partial physical custody as the parties may agree. 8. Mother and Father will agree upon drop off and pick up times. 9. Mother and Father will notify each other of all medical care the child receives while in the parent's care. Mother and Father will notify the other immediately of medical emergencies which arise while the child is in that parent's care. 10. Neither parent will do anything which may estrange the child from the other party, 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 and respect for the other parent. 11. Regarding the child, Mother and Father shall communicate with one another in a respectable manner. 12. Father shall be permitted to engage in reasonable telephone contact with the minor child. 13. Father acknowledges that the Family Law Clinic represents only Mother's interest in this matter and has given him no legal advice other than that he should seek the advice of legal counsel. 14. The parties intend to be bound by the terms of this Agreement and intend for this Agreement to be made an Order of Court. w. a. l TIF A N. Y IE Plaintiff 1?Ig1?a Date 11 Megan M. Michaeq ' Certified Legal Intern Counsel for Plaintiff r ROBERT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Counsel for Plaintiff Fax (717)243-3639 _% ? * &K FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 C SHAWNDELL WATTS Defendant / 7:1 ,gig / 1? z 7 Date r-I C 71 j TIFFANY N. MAYFIELD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. .2007-7006 CIVIL ACTION LAW SHAWNDELL WATTS, Defendant. : IN CUSTODY CERTIFICATE OF SERVICE I, Megan M. Michael, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving a true and correct copy of the Proposed Court Order on Shawndell Watts, residing at 25 Sprague Street, West Springfield, Massachusetts, 01089 by depositing a copy of the same in the United States mail, postage prepaid on December 21, 2007. j, I I)A Gw(? I Megan M. Mich el Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 Fri '' r rrt DEC S 82001 TIFFANY N. MAYFIELD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :2007-7006 CIVIL ACTION LAW SHAWNDELL WATTS, Defendant. : IN CUSTODY ORDER OF COURT AND NOW, this st day of December, 2007 per the attached signed Custody Agreement regarding the child, Danayiah Watts, born May 18, 1996, the following terms are approved and entered as an Order of Court and shall become effective immediately: 1. Tiffany N. Mayfield (hereinafter "Mother") and Shawndell Watts (hereinafter "Father") shall share legal custody of Danayiah Watts (hereinafter "child") 2. Mother shall have primary physical custody of the child. 3. Father shall have partial custody of the minor child during a period in the summertime. This period shall begin on the Saturday following the child's last day of school. Father shall return the child to Mother on July I". 4. Father shall be responsible for transporting the child both to and from Mother's residence. 5. Father shall notify Mother one week in advance if he is going to exercise his period of partial custody. 6. Father understands that if he is late in picking up the child, Father will still return the child on July 1St 7. Father shall have such other periods of partial physical custody as the parties may agree. 8. Mother and Father will agree upon drop off and pick up times. 9. Mother and Father will notify each other of all medical care the child receives while in the parent's care. Mother and Father will notify each other immediately of medical emergencies which arise while the child is in that parent's care. 10. Neither parent will do anything which may estrange the child from the other party, 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 and respect for the other parent. 11. Regarding the child, Mother and Father shall communicate with one another in a respectable manner. 12. Father shall be permitted to engage in reasonable telephone contact with the minor child. J. cc: The Family Law Clinic, for Mother cc: Mr. Shawndell Watts, pro se 10 ,Z yid Z° Nvr goon Ate IC tiu G' d 3HI 3a.. 3;;.:': 0-Q3-m-- TIFFANY N. MAYFIELD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :2007-7006 CIVIL ACTION LAW SHAWNDELL WATTS, Defendant. : IN CUSTODY CERTIFICATE OF SERVICE I, Megan M. Michael, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Court Order dated December 31, 2007 on Mr. Shawndell Watts, residing at 25 Sprague Street, West Springfield, Massachusetts, 01089 by depositing a copy of the same in the United States mail, postage prepaid on January 4, 2007. Date: `OU g Mean . Mic el Certified Legal me FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 C ? o°v { } r r ? te? ?" f ? r ; - co