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Home My WebLink About05-0225 II vs. ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ERIC W. STONESIFER, Plaintiff JAMIE L. STONESIFER, Defendant CIVIL ACTION - LAW -- -- NO. OJ -- .-i~) IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, ERIC W. STONESIFER, by his attorney, Samuel L. Andes, and makes the following Complaint for Custody: 1. The Plaintiff is ERIC W. STONESIFER, an adult individual who resides at 9 Kevin Road, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is JAMIE L. STONESIFER, an adult individual whose precise residence is not known to Plaintiff. Until recently she was residing at 305-5 Hilltop Circle in Hamburg, Pennsylvania, and Plaintiff believes she recently moved to 223 Hillcrest Drive, Sanford, NC, 27330. Otherwise, her last known address was 9 Kevin Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant are husband and wife, having been married on 30 June 2001 and separated in March of 2003. 4. The Plaintiff and Defendant are the natural parents of one minor child, WYATT J. STONESIFER, age 3 and a half, born 16 March 2001. 5. Plaintiff seeks custody of the minor child, WYATT J. STONESIFER. 1 6. The child was born out of wedlock and is presently in the joint custody of the Plaintiff and Defendant. 7. During the past five years, the minor child has resided with the following persons at the following addresses: March, 2001, through June, 2001 York Springs, PA Both Plaintiff and Defendant June, 2001, through March, 2003 852 Brian Drive Enola, PA Both Plaintiff and Defendant March, 2003, to the present 9 Kevin Road Mechanicsburg, PA Primarily in the physical custody of Plaintiff with occasional overnight stays with Mother 8. The father of the child is the Plaintiff who resides at the address set out above. He is married to the Defendant. 9. The mother of the child is the Defendant who resides at the address set out above. She is married to the Plaintiff. 10. The Plaintiff is the natural father of the child. Plaintiff currently resides with the minor child and with the Defendant's grandparents, Clarence "Sonny" Miller and Nancy Miller. 11. The Defendant is the natural mother of the child. Plaintiff does not know Defendant's present living arrangements but has been advised by her that she plans to move 2 II to Sanford, NC, where she will reside with her mother, Christine Miller, her mother's daughter, Rachel Miller (age 14), and other undisclosed persons. 12. The Plaintiff has not participated as a party or in any other way in any litigation concerning the custody of the child in this or any other court. The Plaintiff has no information of a custody proceeding concerning the child pending in a court of this or any other jurisdiction. Plaintiff knows of no other person not a party to this action already who has physical custody of or claims to have custody or visitation rights with the said child. 13. The Plaintiff believes that an award of primary legal and physical custody of the minor child to him is in the best interests of the child for the following reasons: A. He has been more intimately involved in the child's life since the child was born and has provided the primary care of the child since his birth; and B. Defendant's plans are unsettled and she has demonstrated, by her conduct, that she is not stable and cannot provide a stable home for the child. C. It is in the best interests of the child that he remain in the primary care of Plaintiff and remain close to his family here in Pennsylvania and not be relocated to North Carolina or elsewhere. 3 . II 14. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, ERIC W. STONESIFER requests this Court to grant him custody of the child, WYATf J. STONESIFER. &~Q,~ Attorney for Plaintiff Supreme Court 10 17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 I verify that the statements made in this document are true and correct. I understand that any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). DATE: (7/as- 4 \~ :y. ..::N -{: ~ ~. ~~ ~ c-J ---C'\ -........... ~ - . <--." C'" i ~:' '~ ~;: ~.- ::~ ~:.. 8 ~.', _J -<: ~ >', ...........~,... t--..;) C:-.;J- cO> C,.;'" C- :=-.f!I. z o 11 ::;:l (';1 :n r-- ~J i'T1 ::')v ~-;.J,(:) T-.'~l '~:.;:::l" :/~;~ ~.~~ ~ ;:r:,. U1 o ERIC W. STONESIFER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL Y ANIA v. 05-225 CIVIL ACTION LAW JAMIE L. STONESIFER DEFENDANT IN CUSTODY ORDER OF COURT A]\;D NOW. Friday, January 14, 2005 , upon consideration of the attached Complaint. it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator. at DJ Manlove's, 1901 State St., Camp Hill, PA 17011 on Thursday, February 17,2005 at 11:00 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issucs 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 tive or older may also be present at the conference. Failure to appear at the conference mal' 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: Isl Melissa P. GreeVlV, Esq. -f!1\J 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 coul1, 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 HA YE AN ATTORNEY OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET I_EGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 170 \3 Telephone (717) 249-3166 4'~ f:'.? ~ /P7J111 ~ Y/-ft'/f . ~~. ~~il7 >(7/7// ~V'frv$ ~~.7.~ >1//;/./ I. I ~lVt. ('l'07 I t" "~U,..1 r I rHi ..; '.I" t . \,,0 . "'.~ RECEIVED APR 282005-1 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-225 CIVIL TERM ERIC W. STONESIFER, v. CIVIL ACTION - LAW JAMIE L. STONESIFER, IN CUSTODY Defendant ORDER TO RELINQUISH JURISDICTION AND NOW, this 6th day of April, 2005, counsel for the Plaintiff having advised the Oonciliator on March 31, 2005 of the parties' private arrangement and requesting cancellation of the Custody Conciliation Conference scheduled for April 1, 2005, the Conciliator hereby relinquishes jurisdiction of the above captioned matter. elissa Peel Greevy, Custody Conciliator Dist: Samuel L. Andes. Esquire, PO Box 168, Lemoyne, PA 17043 Jamie L. Stonesifer. clo 1735 Mountain Road, York Springs, PA 17372 :248231 6S : I Wd 62: ~dV SOUZ AtJ\llOiKHCdd 3Hl :JO 38U;:i{}{1:J11:J ~---- --