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HomeMy WebLinkAbout09-6625 Melanie L. Erb, Esquire 2132 Market Street Camp Hill, PA 17011 717-975-9446 Merbkdcdlaw.net RICHIE D. HARRISON, Plaintiff V. SHANNON L. HARRISON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. () q- 4 G - 5:?. : CIVIL ACTION - LAW : CUSTODY ACTION COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, RICHIE D. HARRISON, by and through his attorney, Melanie L. Erb, Esquire and the Law Office of Darrell C. Dethlefs, who files this Complaint for Custody and avers as follows: 1. The Plaintiff is Richie D. Harrison, an adult individual, currently residing at 473 West Walnut Street, Hanover, York County, Pennsylvania, 17331. 2. The Defendant is Shannon L. Harrison, an adult individual currently residing at 21 Skyport Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3 (a). Plaintiff seeks shared legal and partial physical custody of the minor child Leyla Mae-Richie Harrison, born February 10, 2008. 3(b). The child was not born out of wedlock. The child is presently in the custody of Defendant, Shannon L. Harrison who resides at 21 Skyport Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. Her relationship to the minor child is that of Mother. For the past five years, the child has resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Shannon L. Harrison Shannon L. Harrison Richie D. Harrison Shannon L. Harrison Richie D. Harrison 21 Skyport Road 8/15/09 to present Mechanicsburg, PA 473 West Walnut Street 6/09 - 8/15/09 Hanover, PA Cross Keys Motor Inn 5/26/09 - 6/09 Shannon L. Harrison 21 Skyport Road 1/09 -5/26/09 Mechanicsburg, PA Shannon L. Harrison 1335 English Drive birth-1/09 Richie D. Harrison Mechanicsburg, PA 3(c). The mother of the child is Shannon L. Harrison, currently residing at 21 Skyport Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. She is currently married to, but separated from, the Father of the child. The father of the child is Richie D. Harrison, currently residing at 473 West Walnut Street, Hanover, York County, Pennsylvania, 17331. He is currently married to, but separated from, the Mother of the child. 4. The relationship of Plaintiff to the child is that of Father. The Plaintiff currently resides with the following persons: Name Relationship None 5. The relationship of Defendant to the child is that of Mother. The Defendant currently resides with the following persons: Name Relationship Edwina Harris Mother Lee Harris Father Levi Harris Son Leyla Mae-Richie Harrison Daughter 6(a). 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. 6(b). Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because Defendant/Mother has denied Plaintiff/Father any contact with the minor child and because the bond between Plaintiff/Father and child should be maintained. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as a party to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: NONE. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an Order scheduling a custody conciliation conference. Respectfully Submitted, anie rb, Esquire A MD. No. 84445 The Law Offices of Darrell C. Dethlefs 2132 Market Street Camp Hill, PA 17011 (717) 975-9446 Attorney for Plaintiff VERIFICATION I verify that the statements made in the 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. r Date: 9l30 i\w h/1-11 Richie D. H son OF THE PRCDTHONOTARY 2009 OCT -5 PPS 3: 12 0 Jp $1!©5.50 PON ATJ CO M009 & a I459 RICHIE D. HARRISON IN THE COURT OF COMMON PLEAS OF PL..AINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V' 2009-6625 CIVIL ACTION LAW SHANNON L. HARRISON 1N CUSTODY DEFENDANT ORDF..R OF COUKT AND NOW, Tuesday, October 13, 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, November 12, 2009 at 9:30 AM for aPre-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/ acqueline M. Verney, 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 ;~ ~,~ ',tea i y., ' .. '~- ' (('~~"+ ' -,` r~s=~~~ 2~U9 ~t~ T i 3 F~ ~_ ~ T Cara v: ,, , ;:,.~ JUL 12 2010 RICHIE D. HARRISON, : IN THE COURT OF COMMON PLEAS OF Plaintiff VA1NjA :CUMBERLAND COUNTY, PENNSYL ,. ~„a c_ - ~~ V. : N0.2009-6625 CIVIL ACTION - LA-~== t--- SHANNON L. HARRISON, E:. Defendant : IN CUSTODY ~% ~- - _ ~• t;r,~- - -~ '- E ; ,~ S `~.. ~.. -~ cs ORDER OF COURT AND NOW, this 9~h day of July, 2010, being advised that the parties have reached a settlement agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, '~v t ~` ~~ acq line M. Verney, Esquire, Cu dy Conciliator