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Home My WebLink About09-0492Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 KRISTINE A. LEIB, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. Q . ?? a- c tv MARK S. LEIB, CIVIL ACTION -LAW Defendant CUSTODY COMPLAINT 1. The Plaintiff is Kristine A. Leib (hereinafter referred to as "Mother"), who currently resides at 142 Fifteenth Street, Apt. Q, New Cumberland, Cumberland County, Pennsylvania 17070. 2. The Defendant is Mark S. Leib (hereinafter referred to as "Father"), who currently resides at 500 Eighth Street, New Cumberland, Cumberland County, Pennsylvania 17070. 3. Plaintiff seeks an order of shared legal and shared equal physical custody of the following children: NAME PRESENT RESIDENCE Derek E. Leib 142 Fifteenth Street, Apt. Q New Cumberland, PA 17070 Jenelle M. Leib and Derek E. Leib 142 Fifteenth Street, Apt. Q New Cumberland, PA 17070 500 Eighth Street New Cumberland, PA 17070 DATE OF BIRTH September 22, 1995 December 20, 1999 September 22, 1995 Jenelle M. Leib 500 Eighth Street December 20, 1999 New Cumberland, PA 17070 4. but separated. 5. The children are presently in the custody of both parents who are currently married During the past five years the children have resided with the following persons at the following addresses: DATES 1/19/2004 to 1/19/2009 1/19/2009 to present ADDRESSES 500 Eighth Street New Cumberland, PA 17070 142 Fifteenth Street, Apt. Q New Cumberland, PA 17070 NAMES OFPERSONS IN HOUSEHOLD Father, mother, children Mother and children and 1/19/2009 to present 500 Eighth Street Father and children New Cumberland, PA 17070 6. The Father of the children is Mark S. Leib, currently residing at 500 Eighth Street, New Cumberland, Cumberland County, Pennsylvania 17070. 7. The Mother of the children is Kristine A. Leib, currently residing at 142 Fifteenth Street, Apt. Q, New Cumberland, Cumberland County, Pennsylvania 17070. The parties are currently separated and divorce is pending. 8. The relationship of the Plaintiff to that of the children is that of Mother. The Plaintiff currently resides with the following persons: 2 NAME Derek E. Leib Jenelle M. Leib RELATIONSHIP Son Daughter 9. The relationship of the Defendant to the children is that of Father. The Defendant currently resides with the following persons: NAME Derek E. Leib RELATIONSHIP Son Jenelle M. Leib Daughter 10. 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. 11. The Plaintiff has no information of a custody proceeding concerning the children pending in any court of this Commonwealth. 12. 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 13. The best interest and permanent welfare of the children will be served by granting the relief requested because the parties desire to formalize a parenting plan to establish stability and avoid conflict between them. 14. 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. WHEREFORE, the Plaintiffrequests the Court to grant shared legal and physical custody of the children to the Plaintiff. DATE: January 30, 2009 (717) 774-1445 Supreme Court I.D. 32317 4 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 KRISTINE A. LEIB, : IN THE COURT OF COMMON PLEAS Plaintiff V. MARK S. LEIB, Defendant CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-4(q.1- CIVIL ACTION - LAW VERIFICATION I, Kristine A. Leib, hereby certify that the facts set-forth in the foregoing CUSTODY COMPLAINT are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Dated: -\)a(-1 2009 KRIST E A. LEI r-a a _71 1 ? ?il ?l ? V p r ?y Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 KRISTINE A. LEIB, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09-492 MARK S. LEIB, CIVIL ACTION -LAW Defendant CUSTODY AFFIDAVIT OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that I served a copy of the Custody Complaint in the above-captioned matter by United States Mail, Restricted Delivery, Certified No. 7008 0150 0002 5290 0344, Return Receipt Requested, on the above-named Defendant, Mr. Mark S. Leib, on January 31, 2009 at Defendant's last known address: 500 Eighth Street, New Cumberland, PA 17070. A copy of the receipt and return receipt card are attached hereto as Exhibit "A". I hereby certify that the facts set forth above are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Dated: February 3, 2009 G Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID #32317 Attorney for Plaintiff -.. Postal 1"I S. CERTIFIED MAI L RECEip-r : (Domestic Mail Only; No I nsurance Coverage Providea m o For deliverv information visit our website at www.usps.com C3 'IM I'A L US PE 'I Q' ru U1 Postage $ rU Certified Fee - C3 Return Receipt Fee (Endorsement Required) s .yj Postmark Here-, C3 ` Restricted Delivery Fee O (Endorsement Required) VI Total Postage & Fees i C3 CEI t? M O M \ /? O sheer, Apt No.; ... - a ??'1 r%_ or PO Box No. ?? ll T . `i1 !rf X1.1- n ?f ¦ Complete Items 1, 2, and 3. Also complete a Signature Own 4 If Restricted Delivery Is desired. ? Agent ¦ Print your name and address on the reverse X l 69 Addresses so tfrat we can return the card to you. B. Pfcolved by( pd C. a of Dekwy ¦ Attach this card to the back of the mailpiece, ? ' ' 73 t or on the front If space pemtits. 1. Alrtfcis Addressed to: D. Is delivery address dNwr i wiTi rom 1? ? Yes If YES, enter delivery address below: U No YY (- S&L) 1 ?o?b 3. Service Type i Cwttfled Mail ? epess Mail ? Registered ? Return Receipt for Metc wKfte ? Insured MaN ? C.O.D. 2, ArWe umber mwww 7008 0150 0002 5290 0344 ?rrtssrrAwn awelto slrs? PS Form 3811, Fabrtiary 2004 Domaatic ftulr Moeipt lowee-oe-M•IM EXHIBIT "A" t-11 9 i KRISTINE A. LEIB PLAINTIFF V. MARK S. LEIB DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2009-492 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, February 04, 2009 , 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 Tuesday, March 03, 2009 at 9:00 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 e.Telephone (717) 249-3166 'N 1!`v`iA A,SNNIII]d I Z :I I WV S- 833 6002 AMONG loud =,Hi 10