HomeMy WebLinkAbout09-1490SUSAN LYNNE SHEEHAN,
PLAINTIFF
VS.
WILLIAM TERRENCE SHEEHAN,
DEFENDANT
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYLVANIA
NO. 0 9 - N 6 CIVIL TERM
: CIVIL ACTION -LAW
: 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
following pages, you must take action within twenty (20) days after this complaint and notice are
served, by entering a written appearance personally or by attorney and filing in writing with the
court your defenses or objections to the claims set forth against you. You are warned that if you
fail to do so the case may proceed without you and a judgment may be entered against you by the
court without further notice for any money claimed in the complaint or for any other claim or
relief requested by the Plaintiff. You may lose money, property or other rights important to you.
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
2 Liberty Avenue
Carlisle PA 17013
(717) 249-3166
1-800-990-9108
SUSAN LYNNE SHEEHAN,
PLAINTIFF
vs.
WILLIAM TERRENCE SHEERAN,
DEFENDANT
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYLVANIA
NO. CIVIL TERM
: CIVIL ACTION -LAW
: IN CUSTODY
COMPLAINT FOR CUSTODY
AND NOW, comes the Plaintiff, SUSAN LYNNE SHEEHAN, by and through her
counsel, Susan Kay Candiello, Esquire, of the Law Firm of Susan Kay Candiello, P.C., and files
this Complaint for Custody upon a cause of action of which the following is a statement:
1. The Plaintiff (hereinafter sometimes referred to as "Mother") is SUSAN LYNNE
SHEEHAN, who currently resides at 5 Hickory Court, Boiling Springs, Cumberland County,
Pennsylvania, 17007.
2. The Defendant (hereinafter sometimes referred to as "Father") is WILLIAM
TERRENCE SHEEHAN, who currently resides at 1532 Holly Pike, Carlisle, Cumberland
County, Pennsylvania, 17013.
3. Plaintiff seeks Shared Legal and Primary Physical Custody of the following child:
Name Pr_ Dxte of phlb
KEVIN JOSEPH SHEEHAN 5 Hickory Court November 18, 1992
Boiling Springs, PA
4. The child was born during the parties' marriage.
5. Physical custody of the child is primarily with Plaintiff, who resides at 5 Hickory
Court, Boiling Springs, Cumberland County, Pennsylvania, 17007.
6. For the past five (5) years the child has resided with the following persons at the
following addresses:
PERSONS ADDRESS DATES
Plaintiff 5 Hickory Court 2004 to Present
Boiling Springs, PA
7. The Mother of the child is the Plaintiff, Susan Lynne Sheehan, who currently resides
at 5 Hickory Court, Boiling Springs, Cumberland County, Pennsylvania, 17007. Father and
Mother are separated.
8. The Father of the child is the Defendant, William Terrence Sheehan, who currently
resides at 1532 Holly Pike, Carlisle Cumberland County, Pennsylvania, 17013.
9. The relationship of the Plaintiff, Susan Lynne Sheehan, to the child is that of the
Natural Mother. Mother resides at 5 Hickory Court, Boiling Springs, PA 17007.
10. The relationship of the Defendant, William Terrence Sheehan, to the child is that of
the Natural Father. Father resides at 1532 Holly Pike, Carlisle, PA 17013.
11. 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.
12. Plaintiff has not participated as a party in any prior custody agreement concerning
the custody of the child in any other court in Pennsylvania.
13. Plaintiff has no information of a custody proceeding concerning the child pending
in a court of this Commonwealth at this time.
14. The best interests and permanent welfare of the child will be served by granting
the relief requested because:
A. Mother has great love and concern for the child and would like a
legal custody agreement to insure the child does not get caught in the
disagreements of the parents.
15. 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 a party to this
action.
WHEREFORE, Plaintiff, SUSAN LYNNE SHEEHAN, requests this Honorable Court
award the Plaintiff, SUSAN LYNNE SHEEHAN and the Defendant, WILLIAM TERRENCE
SHEEHAN, SHARED LEGAL CUSTODY and the Plaintiff, SUSAN LYNNE SHEEHAN,
PRIMARY PHYSICAL CUSTODY and the Defendant, WILLIAM TERRENCE
SHEEHAN, PARTIAL PHYSICAL CUSTODY, of the parties' minor child, KEVIN
JOSEPH SHEEHAN.
Respectfully submitted,
LAW FIRM OF SUSAN KAY CANDIELLO, P.C.
Dated: March 9, 2009
Susan Kay I
Counsel for
PAI.D.#&
4010 Glenfi
Mechanicsburg PA 17055
(717) 724-2278
VERIFICATION
The undersigned hereby verifies that the facts averred in the foregoing document are true
and correct to the best of his knowledge, information, and belief This verification is made
subject to the penalties of IS Pa. C.S.A. §4904 relating to unworn falsification to authorities.
DATED: 3 5 "J?6 Q 2 1'4-? S&d--4?
SUSAN LYNNE EHAN
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SUSAN LYNNE SHEEHAN IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND, COUNTY, PENNSYLVANIA
V.
WILLIAM TERRENCE SHEEHAN
DEFENDANT
2009-1490 CIVIL ACTION LAW
. IN CUSTODY
ORDER OF COURT
AND NOW, Tuesday, March 17, 2009 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Monday, April 20, 2009 at 8:30 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/ jacguc ne M. Verney, Es am-/
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
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APR 2 0 2009,,
SUSAN LYNNE SHEERAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2009-1490 CIVIL ACTION - LAW
WILLIAM TERRENCE SHEEHAN, :
Defendant : IN CUSTODY
ORDER OF COURT
AND NOW, this 20th day of April, 2009, being advised that the plaintiff wishes
to withdraw the complaint, the Conciliator hereby relinquishes jurisdiction in this matter.
FOR THE COURT,
A -L?-4
acq line M. Verney, Esquire, tody Conciliator
CAF THEE € l"
2009 APR 21 AN 10: 15