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Home My WebLink About09-6704LAW OFFICES OF DILS & DILS DIANE M. DILS, ESQUIRE Attorney I.D. No. 71873 1400 North Second Street Harrisburg, PA 17102 Telephone No. (717) 232-9724 Attorney for Plaintiff, Mary Katherine Hays Mary Katherine Hays Plaintiff vs. Christopher W. VanDenEeden Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. ®9- CIVIL ACTION - LAW :CUSTODY COMPLAINT FOR PRIMARY PHYSICAL CUSTODY AND NOW, this day of October, 2009, comes the Plaintiff, Mary Katherine Hays, by her attorney, Diane M. Dils, Esquire, and respectfully avers the following: 1. The Plaintiff is Mary Katherine Hays, an adult individual currently residing at 10 Mayberry Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Defendant is Christopher W. VanDenEeden, an adult individual currently residing at (p West Main Stree ('Me hamcsburg, Cumberland County Pennsylvania 17050. 1 3. The Plaintiff and Defendant were never married; however, they are the natural parents of one child; namely: Sophia Grace VanDenEeden, born December 13, 2007 in Harrisburg, Pennsylvania. 4. The Plaintiff and Defendant have not resided together since May of 2008. 5. The minor child has been in the primary physical custody of her mother since May of 2008. 6. There has been limited and sporadic contact between the Defendant and the minor child since May of 2008. 7. The Plaintiff believes that it is in the best interest of her daughter that there be a specific schedule set forth to provide for periods of partial custody in the Defendant with the minor child. 8. Previous to the current address of the Plaintiff, the minor child resided on Portland Street in Mechanicsburg, Pennsylvania with both Plaintiff and Defendant. 9. The minor child has resided in Cumberland County, Pennsylvania since her birth on December 13, 2007. 10. The Court of Common Pleas of Cumberland County has jurisdiction in this matter. 2 11. The Plaintiff has not participated as a party or witness in any capacity in other litigation concerning the custody of the minor children in this or any other Court. 12. The Plaintiff has no information of the custody proceedings concerning the children pending in a Court of this Commonwealth or any other state. 13. The 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. 14. The Plaintiff respectfully prays Your Honorable Court to enter and Order for shared legal custody, primary custody in her with partial custody rights in the Defendant. WHEREFORE, the Plaintiff, Mary Katherine Hays, respectfully prays Your Honorable Court to grant her request for primary physical custody. Respeaf y ubmitted, Diane Nje Dils, Esquire 1400 North Second Street First Floor, Front Harrisburg, PA 17102 (717) 232-9724 I.D. No. 71873 Date 3 VERIFICATION I verify that the statements made in this COMPLAINT FOR CUSTODY are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA. C.S. Section 4904 relating to unsworn falsification to authorities. Date: R d d -e r-ILED ? J•wl ZOD9 QL 1 AN ?? ? ? j.. r IF = nGl? t%/S SD f? Di IS 339D Q(C#i d31(?01 MARY KATHERINE HAYS IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 2009-6704 CIVIL ACTION LAW CHRISTOPHER W. VANDENEEDEN IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, October 16, 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 Tuesday, November 10, 2009 at 9:30 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: Is/ 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 THF Zc1Qg OC t 20 Fiq 2: 16 cut,' /o -ao NOV 1 U ZOUy(~ l J MARY KATHERINE HAYS, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V, : N0.2009-6704 CIVIL ACTION -LAW CHRISTOPHER W. VANDENEEDEN, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this ~ ~~~ day of 1V 0 V erm~ c.~[' , 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Mary Katherine Hays shall have sole legal custody of Sophia Grace VanDenEeden born December 13, 2007. 2. Mother shall have primary physical custody of the child. 3. Father shall have the following periods of partial physical custody: A. Beginning, Sunday, November 22, 2009, alternating Sundays from 1:00 p.m. to 6:30 p.m. B. Such other times as the parties agree. 4. Transportation shall be shared such that the receiving party shall transport. 5. Neither party may use illegal drugs or partake in alcoholic beverages to the point of intoxication immediately before or during their periods of physical custody. 6. Telephone calls from Father to Mother are limited to issues regarding the child. 7. Father shall provide his own baby supplies and the child shall sleep in her crib during Father's periods of physical custody. 8. This Order is entered pursuant to 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. Either party may contact the Conciliator within 90 days of the date of this Order to request another conciliation conference. BY THE COURT, J. /. cc: ane M. Dils, Esquire, Counsel for Mother ~ristopher VanDenEeden 16 West Main Street Apt 6 Mechanicsburg, PA 17050 C'orjtes rh~t~ I ~~ t MARY KATHERINE HAYS, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : N0.2009-6704 CIVIL ACTION -LAW CHRISTOPHER W. VANDENEEDEN, Defendant : IN CUSTODY PRIOR JUDGE: None 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 Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Sophia Grace VanDenEeden December 13, 2007 Mother 2. A Conciliation Conference was held in this matter on November 10, 2009, with the following in attendance: The Mother, Mary Katherine Hays, with her counsel, Diane M. Dils, Esquire. Although served with notice of the conference, Father did not appear. 3. Mother requested an Order in the form as attached. Date ac line M. Verney, Esquire Custody Conciliator ~. Z~3~ E~J'~ E 2 ;;~ ~ ~~ ? i .-~,,; ~~~~; ; JUL 12 2010 MARY KATHERINE HAYS, : IN THE COURT OF COMMON PLEAS OF C7 ~_ ~~ Plaintiff :CUMBERLAND COUNTY, PENNSYLVAN~ ° r~~ ~ V. : N0.2009-6704 CIVIL ACTION -LAW ~t r ~ f__ n~ m CHRISTOPHER W. VANDENEEDEN, ~: ~._. Defendant : IN CUSTODY _ ~'' __. ~, .. _. ~~~; c:~ ORDER OF COURT AND NOW, this 9th day of July, 2010, having no contact with the parties for more than ninety days to request another Conciliation Conference, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, ~~~ ~~ acq line M. Verney, Esquire, Custo Conciliator