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Home My WebLink About09-1019McNEES WALLACE & NURICK LLC By: DEBRA D. CANTOR Attorney ID No. 66378 100 Pine Street Harrisburg, PA 17108-1166 (717) 237-5297 (717) 237-5300 facsimile dcantorO-mwn.com Attorneys for Plaintiff CRAIG R. HARMON, Plaintiff V. TARA J. FISHER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION NO. 09- 1019 CIVIL TERM IN CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the foregoing pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. 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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 McNEES WALLACE & NURICK LLC B ' Y r on Can Attorney I.D. No. 66378 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorneys for Plaintiff Dated: February 17, 2009 McNEES WALLACE & NURICK LLC By: DEBRA D. CANTOR Attorney ID No. 66378 100 Pine Street Harrisburg, PA 17108-1166 (717) 237-5297 (717) 237-5300 facsimile dcantor -mwn.com Attorneys for Plaintiff CRAIG R. HARMON, Plaintiff V. TARA J. FISHER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION NO. 6?-W q CIVIL TERM IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, Plaintiff, by and through his attorneys, McNees Wallace & Nurick LLC, files a Complaint for Custody against Defendant, and in support thereof, avers the following: 1. Plaintiff is Craig R. Harmon, ("Father"), who currently resides at 16 Mary Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Tara J. Fisher ("Mother"), who currently resides at 254 Ridge Hill Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. Plaintiff seeks shared physical and legal custody of the following child: Names Present Address(es) Age(s) Connor Alexander Harmon 254 Ridge Hill Road Approx. 7 months Mechanicsburg, PA 17050 (DOB: 7/30/08) The child was born out of wedlock. The child is presently in the custody of Mother, who currently resides at 254 Ridge Hill Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. During the past five years, the child resided with the following persons and at the following addresses: Persons Address(es) Date (s Michael Strohl & 254 Ridge Hill Road 11/08-present Melissa Strohl Mechanicsburg, PA 17050 Michael Strohl & 1 Melwood Lane until 11/08 Melissa Strohl Mechanicsburg, PA 17050 The mother of the child is Tara J. Fisher, who currently resides at 254 Ridge HIII Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. She is single. The father of the child is Craig R. Harmon, who currently resides at 16 Mary Avenue, Mechanicsburg, Cumberland County, PA 17055. He is single. 4. The relationship of Plaintiff to the child is that of Father. Plaintiff currently resides with the following person(s): Name(s) Richard C. Harmon Relationship Paternal Grandparent Phyllis J. Harmon Paternal Grandparent -2- 5. The relationship of Defendant to the child is that of Mother. Defendant currently resides with the following persons: Name(s) Relationship Connor Alexander Harmon Son Melissa Strohl Maternal Grandparent Michael Strohl Maternal Grandparent 6. 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. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth, or any other state. 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. 7. The best interests and permanent welfare of the child will be served by granting Plaintiff shared physical and legal custody of the child. 8. 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. -3- WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order granting Plaintiff shared physical and legal custody of the child. Respectfully submitted, McNEES WALLACE & NURICK LLC r By D for 04 Attome No. 66378 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 Phone: 717 237-5297 Attorneys for Plaintiff Dated: February 17, 2009 -4- VERIFICATION I 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 are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. C ig Har o Dated: 13- 4 JA. •'if rh V 1 Ica -c i ?Y-S N ? ?V! tl'S Q ? CRAIG R. HARMON, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : CIVIL ACTION NO. 09-1019 CIVIL TERM TARA J. FISHER, IN CUSTODY Defendant AGREEMENT OF THE PARTIES AND NOW, this 447\ day of , 2009, comes the above-named parties, having been advised by counsel and intending to be legally bound, do hereby agree as follows: 1. Plaintiff, Craig R. Harmon, hereby agrees and simultaneously with the execution of this Agreement, will withdraw his action for custody docketed to the above term and number. 2. Simultaneously with the execution of this document, Defendant, Tara J. Fisher, hereby agrees to withdraw the support matter entered into the Court of Common Pleas of Cumberland County, Domestic Relations Office, Docket No. 00702 S 2008, PACSES Case No. 193110248, and waive all arrears. 3. It is the intention of the Defendant, Tara J. Fisher, to terminate the support action currently against the Plaintiff, Craig R. Harmon, and to waive any and all arrearages due and owing as of the date of the execution of this Agreement. 4. The parties hereto acknowledge that the termination of the custody action and the termination of the support action shall occur simultaneously with the execution of this Agreement, and shall remain in full force and effect. r 5. The parties hereto acknowledge that should Defendant commence or reinstate the support action, Plaintiff may immediately file for custody, partial custody or visitation of the minor child. Should Plaintiff file to reinstate custody, partial custody or visitation of the minor child, Defendant may immediately file to reinstate the support action. 6. The parties hereto believe that it is in the best interest of the minor child that Plaintiff waive his custodial rights and Defendant terminate the support action. 7. Presentation of this Agreement to the Cumberland County Domestic Relations Office shall be sufficient for an Order to be entered terminating the support action against the Plaintiff, Craig R. Harmon, including any and all arrearages due and owing. IN WITNESS WHEREOF, the parties hereto intending to be legally bound do hereby execute this Agreement by signing their hands and seals the day and year first above written. VA,-Q J6 fitness t aig R. on f , ? j. Tara J. Fisher, FILE - =i i E OF THE PRCTHC?NOTARY 2009 MAY -7 PM 3: 53 ?"y PENNSYLVANIA u MAY 0 8 2000 G CRAIG R. HARMON, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : CIVIL ACTION NO. 09-1019 CIVIL TERM TARA J. FISHER, Defendant IN CUSTODY COURT ORDER AND NOW, this day of , 2009, upon consideration of the attached Agreement of the Parties, it is ordered and directed that: Pursuant to an executed private agreement and representations of counsel, Plaintiffs custody complaint is hereby WITHDRAWN and the instant matter is hereby DISMISSED without prejudice. /Distribution: Debra D. Cantor, Esquire, McNees Wallace & Nurick LLC, 100 Pine Street, P.O. Box 1166, Harrisburg, Pa., 17108-1166, (717) 237-5297 (phone); (717) 260-1667 (fax); dcantor _mwn.com / caJessica C.D. Hoist, Esquire, MidPenn Legal Services, 401 East Louther Street, Carlisle, Pa., 17013, (717) 243-9400 (phone), (717) 243-8026 (fax); jholstCa?midpenn.org F'.S m5.c LScL IS??r`7 BY THE COURT: C'C .C Wd ZI AvW6g41 3HU 1V