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Home My WebLink About04-3971MATTHEW HARTMAN, Plaintiff VS. MELISSA MUMPER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :No. Oq- 29'71 ;. : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY The Plaimiff, Matthew I-Iaxtman, through his attorney's, The Law Offices of Patrick Lauer, Jr., Esquire, seeks to obtain custody of his minor child and makes the following averments in support thereof: 1. Plaintiff is "Father," an adult individual who currently resides at 505 South 32nd Street, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. Defendant is "Mother," an adult individual, who currently resides at 225 South Enola Drive, Enola, Cumberland County, and State of Pennsylvania, 17025. 3. Plaintiff seeks custody of the following minor child: Name: Address: Age: Wimer Mumper 225 South Enola Drive Two Years Enola, PA 17025 The child was bom out of wedlock. The child is presently in the custody of Mother, whose address is 225 South Enola Drive, Enola, Cumberland County, and State of Pannsylvania, 17025. 6. During the past five years, the child has resided with the following persons at the following address: Persons: Address: Dates Mother 225 South Enola Drive May, 2002- Father Enola, PA 17025 June 2002. Judith Mumper Amanda Mumper Marlin Mumper Mother Father Matt Hartman, Jr. Damion Hartman Mother Judith Mumper Marlin Mumper Amanda Mumper 501 Windy Hill Road, Lot 94 Shiremans Dale, PA 17090 June 2002 - November 2003 225 South Enola Drive Enola, PA 17025 November 2003 - Present Fred Snow Noreen Snow Rebecca Hartman Names: with the following people: 32~d Street, Camp Hill, Cumberland County, Pennsylvania, 17011. He is Married. 9. The relationship of Plaintiffto the child is that of Father. Plaintiff currently resides Relationship: Step Father Mother Sister 10. The relationship of Defendant to the child is that of Mother. Defendant currently resides with the following people: Names: Relationship: Judith Mumper Marlin Mumper Amanda Mumper Winter Mumper Mother Father Sister Daughter 8. The Father of the child is Matthew Hartman, who currently resides at 505 South She is Not Married. Enola Drive, Enola, Cumberland County, and State of Pennsylvania, 17025. 7. The Mother of the child is Melissa Mumper, who currently resides at 225 South 11. 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. 12. Plaintiffhas no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 13. 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 fights with respect to the child 14. The best interests and permanent welfare of the child will be served by granting thc relief requested because Plaintiff is in a better position to take care of the child, both emotionally and financially, and has the support system in place to support the best interests of thc child. 15. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order granting him custody of the child. Date: Respectfullyos~'~. Cara submi~ J ciolo,';'Esquire 21p8 Market Street, Aztec Building CEmp Hill, Pennsylvania 17011-4706 I~ 90919 Tel. (717) 763-1800 MATTHEW HARTMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. MELISSA MUMPER, Defendant No. CIVIL ACTION - LAW IN CUSTODY VERIFICATION I verify that the statemems made in this Complaim for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom falsification to authorities. MATTHEW HARTMAN, Plaintiff VS. MEL1SSA MUMPER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. : CIVIL ACTION - LAW : IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Complaint for Custody upon the person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by mailing a copy of the same, certified mail, return receipt requested, to the person named as follows: Melissa Mumper 225 S. Enola Drive Enola, PA 17025 Date: CT~/D/~, vi Respect.fully submitted, ~ Jos~h DX2araciolo, Esquire 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 170114706 II~ 90919 Tel. (717) 763-1800 MATTHEW HARTMAN PLAINTIFF V. MELISSA MUMPER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 04-3971 CIVIL ACTION LAW : : IN CUSTODY ORDER OF COURT AND NOW, Thursday, August 19, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear betbre Melissa P. Gree~. , the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Tuesday, October 05, 2004 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. All children age five or older may also be present at the conference. Failure to avl~ear 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 hearinl~. FOR THE COURT, By: /s/ Melissa P. Greevy, Esq, mhc Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply w/th 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. Ail 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 MATTHEW HARTMAN Plaintiff, VS. MELISSA MUMPER Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-3971 CIVIL TERM : : IN CUSTODY ; PRAEC1PE FOR ENTRY OF APPEARANc~ ,; To Curtis R. Long, Prothonotary: Please enter my appearance on behalf of the Defendant, Melissa Mumper, in the above captioned case. Date:~ Respectfully submitted, 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 MATTHEW HARTMAN Plaintiff, VS. MELISSA MUMPER Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA .. : NO. 04-3971 CIVIL TERM : : IN CUSTODY : CE-__~RTIFICATE OF SERVICE I, Jessica Diamondstone, Esquire, of MidPenn Legal Services, attorney for the Defendant, Melissa Mumper, hereby certify that I have served a copy of the foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following date and in the manner indicated below: ~ail Post-~!gg~Pre-Paid oseph D. Caraciolo, Esquire-- 2108 Market Street Aztec Building Camp Hill, PA 17011-4706 MidPenn Legal Services, Inc. Date: MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 MATTHEw HARTMAN, Plaintiff VS. MELISSAMT3MPER, Defendant IN THE COURT OF COMMON PLEAs OF CU~{BERLAND COUNTY, PENNSYLVANIA No. 04-3971 CIVIL ACTION - LAW IN CUSTODY PRA~CIPE WITHDRAWING CUSTODy COMPLAINT To Prothonotary: Kindly withdraw the Complaint for Custody for the captioned civil action on behalf of my clien~ ~ _.~ above ~, ~aEtnew Hartman. Date~~ Respeg~full, ~ub~ted' f/ow Market Street. ~, aZtec Buildin ~amp Hilj., Penns,,] ....... g ~v=a±a 17011-4706 ID# 90919 Tel. (717) 763-1800 MATTHEw HARTMAN, Plaintiff : MELISSA MUMPER, : Defendant : IN THE COURT OF COMMON PLEAs OF CUMBERLAND COUNTY, PENNSYLVANIA No. 04-3971 CIVIL ACTION _ LAW IN CUSTODy CERTIFICATE OF S~__~CE I hereby Certify that I am this day Serving a Copy of the foregoing Praecipe to Withdraw Custody Complaint Upon the person and in the manner indicated below, which Service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by mailing a Copy of the same via first Class mail, to the Defendant,s representative named as follows: Jessica Diamondstone, Esq. MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 ~o ~arket q ire CaRp Hill.' ~tree~, Aztec Buildinc ..... , r=nnsylvania 17011-470~ iu~ 90919 Tel. (717) 763-1800 MATTHEW HARTMAN, Plaintiff MELISSA MUMPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-3971 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER TO RELINQUISH JURISDICTIO:.' AND NOW, this 7th day of October, 2004, counsel for the Plaintiff having filed a Praecipe to Withdraw Custody Count on September 30, 2004 in this action, the Conciliator hereby relinquishes jurisdiction of the above captioned matter. FOR THE CO~.' ~'~ /'~ Melissa Peel ,Greevy, Esquire Custody Conciliator :237024