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Home My WebLink About10-3669 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 prompt action. You are warned that if you fail to do so, you may lose rights and visitation of your child. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER A'C ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford St. Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 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. ra ~ --; r. a =~, `' -C' Cf. ; ~ - ~ ~ F`" t ~ _ ) . ~ =~ ~ C'3 b `'~ ~ ~ ~~ ~~ ~ VANESSA K. DATTOLI, : IN THE COURT OF COMMON PLEAS OF Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN CUSTODY MICHAEL E. HEMPERLY JR., Defendant. : NO. CIVIL TERM COMPLAINT FOR CUSTODY The plaintiff, Vanessa K. Dattoli, by her attorneys, the Family Law Clinic, sets forth the following cause of action in custody. 1. The plaintiff is Vanessa K. Dattoli ,residing at 1550 Williams Grove Rd. Lot 104, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The defendant is Michael E. Hemperly, Jr., residing at 300 Ridge Rd., Trailer 60, Etters Pennsylvania, 17319. 3. Plaintiff seeks shared custody of: Name Present Residence Age Makayla Hemperly With Mother: 3 D.O.B. 1/19/07 1550 Williams Grove Rd., Lot 104 Mechanicsburg, PA 17055 With Father: 300 Ridge Rd, Trailer 60 Etters, PA 17319 AND 518 Saw Mill Road Mechanicsburg, PA 17055 The child was born out of wedlock. The child presently resides in the custody of Mother and Father at the three listed addresses above on a week on/ week off basis. During the past five years the child has resided with the following persons at the following addresses: Persons Address Dates Vanessa Dattoli, 4519 Rollo Court, Jan. 07 -April 07 Michael Hemperly, Jr. Mechanicsburg, PA 17055 Vanessa Dattoli, 1550 Williams Grove Rd. April 07 -Jan. 09 Michael Hemperly, Jr. Mechanicsburg, PA 17055 Vanessa Dattoli 1550 Williams Grove Rd. Jan. 09 -present Mechanicsburg, PA 17055 Michael Hemperly, Jr. 300 Ridge Rd. Trailer 60 Jan. 09 -Present Kristyn Hummel Etters, PA, 17319 Shawna Hemperly 518 Saw Mill Rd. Jan. 09 -Present Michael Hemperly, Jr. Mechanicsburg, PA, 17055 The mother of the child is Vanessa Dattoli. She is single. The father of the child is Michael Hemperly, Jr. He is single. 4. The relationship of Plaintiff to the child is that of mother. Plaintiff currently resides with the following persons: Name Relationship Makayla Hemperly Daughter 5. The relationship of Defendant to the child is that of father. Defendant currently resides with the following persons: Name Relationship Kristyn Hummel Girlfriend Makayla Hemperly Daughter Shawna Hemperly Paternal Grandmother 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 interest and permanent welfare of the child will be served by granting the relief requested because: a. Plaintiff and Defendant are willing to share custody of the child and have signed a custody agreement detailing such. 8. Each parent whose parental rights to the child have not been terniinated and the person who has physical custody to the child have been named as parties to this action. WHEREFORE, Plaintiff requests the court to grant her shared legal custody and shared physical custody of the child. Respectfully submitted, Date: June 4, 2010 ~'~ =---_ Patrick Scha er Certified Legal Intern THO M. PLACE ROBERT E. RAINS ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 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. ~, ~- ~~ Vanessa K. Dattoli, Plaintiff VANESSA K. DATTOLI, Plaintiff, v. MICHAEL E. HEMPERLY JR., Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IN CUSTODY NO. /~- ~(~~ CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Vanessa K. Dattoli, Plaintiff, to proceed in forma pauperis. n ~ ,>> c. -~ ~ ~ ~:~ ~ ~ ~ ~ ~i - ' '--- ~ __. r ~ , + ,~ ~?~' r _.,, 'y c`r `'•: r r ~ L;., -~ -< c The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date: June 4, 2010 >~-- -~~- Patrick Schaeffer Certified Legal Intern ROBER E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX MEGAN RIESMEYF,R Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 Vanessa K: Dattoli, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA v :CIVIL ACTION-LAW Michael E. Hemperly, Jr., : IN CUSTODY ~. ; Defendant n N Q . No. 10-3669 CIVIL TERM .~,, ~ ~ -, { . ., -- . ; , ~ tV -::-7;_n PRAECIPE TO REINSTATE COMPLAINT ~~ '~- -- -_ ~ , c_- r.: To The Prothonotary: ca Please reinstate the Custody Complaint at the above-captioned docket. Date: ~'/21 / Zo ro ~,,,,~,~ Patrick Schaeffer Certified Legal Intern THO S M. PLACE ROBERT E. RAINS ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 Vanessa K. Dattoli, Plaintiff v. Michael E. Hemperly, Jr., Defendant I accept service of Date ~ 9' D IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION -LAW IN CUSTODY NO. 10-3669 CIVIL TERM e? ~ ; c_ _ ~ - t - `- -t s= _ ~' _