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Home My WebLink About09-37010 Margaret M. Simok SCARING & SCARING, P.C. 2000 Linglestown Road; Suite 106 Harrisburg, PA 17110 717-657-7770 Attorneys for Plaintiff ANDREW ROBERT SHEETS, Plaintiff V. JILL KIMBERLY SHEETS, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :No. CA-.3701 ?iviITerm :Civil Action - CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Andrew Robert Sheets, residing at 106 Sholly Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant is Jill Kimberly Sheets, who's current address is unknown to Plaintiff. 3. Plaintiff seeks custody of the following children: Name Present Residence Alisha Marie Sheets unknown . William Andrew Sheets unknown Madison Brianne Sheets unknown Age 17 9 7 Madison and William were not born out of wedlock. Alisha is the biological child of Plaintiff and was adopted by Defendant in 1998. The three children are presently in the custody of Defendant, who's current residence is unknown to Plaintiff. During the past five years, the three children have all resided with Plaintiff and Defendant at 106 Sholly Drive, Mechanicsburg, Cumberland County, Pennsylvania. The mother of the children is Jill Kimberly Sheets who's current residence is unknown to Defendant. She is married. The father of the children is Andrew Robert Sheets, currently residing at 106 Sholly Drive, Mechanicsburg, Cumberland County, Pennsylvania. He is married. 4. The relationship of Plaintiff to the children is that of father. Plaintiff currently resides alone. 5. The relationship of Defendant to the children is that of mother. Plaintiff has no information regarding with whom Defendant may be residing. 6. Plaintiff has participated as a party in other litigation concerning the custody of the children in this Court. The Court, term and number, and its relationship to this action is: Cumberland County Court of Common Pleas, Protection from Abuse Temporary Order, Docket Number 2009-3579, wherein Defendant named all three children as protected parties. Plaintiff has no information of a custody'proceeding concerning the children 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 children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because the children have a loving relationship with Plaintiff. Defendant abruptly removed them from their Father and family home to suit her own needs. 8. 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, Plaintiff requests the Honorable Court to grant the parties shared legal custody and shared physical custody of the children. Respectfully submitted: hA?,za,t i/h. &? Marga M. Simok, Esquire SCARING & SCARING, P.C. 2000 Linglestown Road; Suite 106 Harrisburg, PA 17110 Supreme Court No. 89633 717-657-7770 Attorneys for Plaintiff 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 unsworn falsification to authorities. Date: Andrew Robert Sheets OF THE q pry ,?M My 2oug juM -4 PP1 1: 02 CUMBE; tom;;u Pe' YLWA 4b66-50 PO any (x.* 519? R. T* a39 ANDREW ROBERT SHEETS PLAINTIFF V. JILL KIMBERLY SHEETS DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2009-3701 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, June 08, 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 Thursday, June 25, 2009 at 10:30 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/ ac ueline M. Verne Es . 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 CAF Tl-?,fOTARY TDD9 JUN _g ptf 2: 4 9 F? ?1%?'S LVAJN1IA, tom' .r , JUN 0.5 2000 cn ANDREW ROBERT SHEETS, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : No. - 3101 04 viITerk JILL KIMBERLY SHEETS, Defendant :Civil Action - CUSTODY ORDER OF COURT AND NOW, , upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before the Custody Conciliator, at on , at _M 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 forty-eight (48) hours prior to the scheduled conference. FOR THE COURT: By: Custody Conciliator 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. 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, PA 17013 717-249-3166 e RECEIVED JUN 1 2 2009 ANDREW ROBERT SHEETS, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 2009 - 3701 JILL KIMBERLY SHEETS, Defendant :Civil Action - CUSTODY ACCEPTANCE OF SERVICE I, Debra Denison Cantor, Esquire, do hereby accept service of the Complaint for Custody in the above-captioned matter, on behalf of Defendant, Jill Kimberly Sheets, and certify that 1 am authorized to do so. Date: ? Re ectfully Submitted: d",/ De a Denison Cantor McNees Wallace and Nurick, LLC 100 Pine Street P 0 Box 1166 Harrisburg, PA 17108 Attorney for Defendant fil U- }--1. lpy _r 2009 JUN 19 k I I : 4 2 JUN 2 6 2009G ANDREW ROBERT SHEETS, Plaintiff V. JILL KIMBERLY SHEETS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-3701 : IN CUSTODY ORDER OF COURT CIVIL ACTION - LAW AND NOW, this 62670 day of ins , 2009, upon consideration of the attached Custody Conci ation Report, it is ordered and directed as follows: The custody provisions in the PFA Order dated June 9, 2009 are hereby vacated. 2. The Father, Andrew Robert Sheets and the Mother, Jill Kimberly Sheets, shall have shared legal custody of Alisha Marie Sheets, born March 14, 1992, William Andrew Sheets, born October 14, 1999 and Madison Brianne Sheets, born June 29, 2001. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to medical, dental, religious or school records, the residence address of the children and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor children. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 3. Mother shall have primary physical custody of the children 4. Father shall have the following periods of partial physical custody: A. During the summer of 2009, Father shall have physical custody of the children two overnights per week on the following alternating week schedule: the first week from Friday after work to Sunday either to 1:30 p.m. (if Father has to work) or 7:00 p.m., and the second week from Tuesday at 10:00 a.m. to Thursday at 2:00 p.m. B. During the school year, alternating weekends from Friday after school to Sunday at 1:30 p.m. (if Father has to work) or 7:00 p.m., and on the off week, one evening per week from after school to 7:00 p.m. Father shall give Mother two weeks notice of which evening it shall be. Father shall take the children to their extra-curricular activities to which he has agreed to permit them to participate in. 5. Holidays. The following holidays shall be alternated from 10:00 a.m. to 8:00 p.m.: July 4t", Labor Day, Thanksgiving, Easter, and Memorial Day, with Father having July 4t . 6. Christmas shall be divided into two blocks. Mother shall always have from 12:00 noon on Christmas Eve to 2:00 p.m. on Christmas Day. Father shall always have from 2:00 p.m. Christmas Day to December 29 at 7:00 p.m. 7. Mother shall cooperate with therapeutic family counseling between Alisha and Father at Innerworks. Father shall be responsible for any cost associated with the counseling with Alisha and Father. In the event that the counselor wants Mother and the other children to join in the counseling, then Father shall also be responsible for those costs. Father does not object if Mother wishes to take the younger children to counseling but Mother shall be responsible for the cost. 8. Transportation shall be shared such that the receiving party shall transport, except for Father's evening during the off week during school, he will be responsible for all transportation. 9. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Another Custody Conciliation Conference is scheduled for September 29, 2009 at 9:30 a.m. BY THE COURT, cc` argaret M. Simok, Esquire, Counsel fo!` Father Debra Denison Cantor, Esquire, Counsel for Mother (20?1 'es P?la J. ANDREW ROBERT SHEETS, Plaintiff V. JILL KIMBERLY SHEETS, Defendant PRIOR JUDGE: Kevin A. Hess, J. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-3701 CIVIL ACTION - LAW : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Alisha Marie Sheets March 14, 1992 Mother William Andrew Sheets October 14, 1999 Mother Madison Brianne Sheets June 29, 2001 Mother 2. A Conciliation Conference was held in this matter on June 25, 2009, with the following in attendance: The Father, Andrew Robert Sheets, with his counsel, Margaret M. Simok, Esquire, and the Mother, Jill Kimberly Sheets, with her counsel, Debra Denison Cantor, Esquire. 3. The Honorable Kevin A. Hess previously entered an Order of Court dated June 9, 2009 in a PFA matter at Docket No. 2009-3579 providing for Father to have one overnight per week and telephone contact. 4. The parties agreed to an Order in the form as attached. Date ac ine M. Verney, Esquire Custody Conciliator FILED-OFFICE 07 T =" PROTHONOTARY 0 S F P 20 PIN I : 2 "!.1C° EiL k"ND C 0 U N T r' r: ", 1,53 ,}r 11 A 1?, 11 1 A Debra R. Mehaffie, Equire SCARINGI & SCARINGI, P.C. 2000 Linglestown Road, Suite 106 Harrisburg, PA 17110 717-657-7770 debraLa?scaringilaw.com Attorneys for Plaintiff ANDREW ROBERT SHEETS Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. JILL KIMBERLY SHEETS Defendant NO. 2009-3701 CIVIL ACTION IN CUSTODY PRAECIPE TO WITHDRAW APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of Margaret M. Simok, Esquire, as attorney in the above-captioned action for Plaintiff, Andrew R. Sheets, per his request. Respectfully submitted, Date: 7 - r7 " (0 / a /! MargareOV1. Simok Attorney I.D. No. 89633 Cognetti & Associates 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Debra R. Mehaffie, Esquire, as attorney in the above-captioned action for Plaintiff, Andrev*'R.)Sheets, per his request. e pectfully submitted, Date: n / I ebra R. ehaffie. Eso attorney I.D. No. 90951 (7 Scaringi & Scaringi, P.C. 2000 Linglestown Road, Suite 106 Harrisburg, PA 17110 (717) 657-7770 CERTIFICATE OF SERVICE I hereby certify that I served the foregoing Praecipe to Withdraw and Praecipe to Enter to Defendant by United States Postal Service, regular mail, postage prepaid, addressed as follows: Debra Denison Cantor, Esquire McNees Wallace & Nurick, LLC 100 Pine Street Harrisburg, PA 17108-1166 Attorney for Defendant y submitted, Date: J affie, Esquire Meh ®raR. ev I.D. No. 90951 ?caringi & Scaringi, P.C. 2000 Linglestown Road, Suite 106 Harrisburg, PA 17110 (717) 657-7770 ANDREW ROBERT SHEETS IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA _~_ N0.2009-3701 JILL KIMBERLY SHEETS CIVIL ACTION -LAW Defendant IN CUSTODY PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly withdraw the appeazance of Debra R. Mehaffie, Esquire on behalf of Scaringi & Scaringi, P.C. and enter the appearance of Debra R. Mehaffie, Esquire on behalf of Hynum Law, as attorneys in the above-captioned action for Plaintiff, Andrew R. Sheets, per his request and authorization. Date: ~ ~ b 'Debra R. Mehaffie, E~ I.D. No. 90951 Hynum Law 2608 N. Third Street Harrisburg, PA 17110 Tele: (717) 774-1357 Fax: (717) 774-0788 ~,,~ ~.~ c',. ~'? ; .,'.,Y o..,a ..tea ~ ~ .'_.,' ::r~ ~ ~ ~ ,y[.. l ~9t' Y ....?~.+•.~ aw :.. „,/ 1 ~""" y~~b-~~ p"1 . i.++~ ~ ~_-d^^~. ~~ ~ ~~~~ ai5-~~~- ~ -../~3 1f~ wJ ~ CERTIFICATE OF SERVICE I hereby certify that served the foregoing Praecipe to Enter Appearance upon the individual indicated below via United States Postal Service, first class mail, postage prepaid, addressed as follows: Debra Denison Cantor, Esquire McNees Wallace & Nurick, LLC 100 Pine Street Harrisburg, PA 17108-1166 Attorney for Defendant i1 Date: v ra R. Mehaffie, E~ r~ .D. No. 90951 ynum Law 608 N. Third Street Harrisburg, PA 17110 Tele: (717) 774-1357 Fax: (717) 774-0788