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Home My WebLink About05-0752 ANNETTE M. GRUBB Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 05- 7 S:2-. Cu;[ Yvu,Y'\ CIVIL ACTION -LAW ANDREW PATRICK MECK, JR. DANIELLE JANETTE STONE Defendants CUSTODY COMPLAINT FOR CUSTODY 1, The plaintiff is Annette M. Grubb , residing at RR 1 Box 58G, Covington, P A 16917. 2, The defendants are Andrew Patrick Meck, Jr., whose last known residence was 322 Walnut Lane, Carlisle, P A 17013; and Danielle Janette Stone, whose last known residence was in Cumberland County, to the best of Plaintiffs knowledge. 3. Plaintiff seeks custody of the following child: Name Present Residence Age Andrew Patrick Meck III RR I Box 58G, Covington, PA 16917 3 The child was born out of wedlock. The child is presently in the custody of the paternal grandmother, Annette M. Grubb, residing at RR 1 Box 58G, Covington, PA ]6917. During the child's lifetime he has resided with the following persons and at the following addresses: List All Persons List All Addresses Date Annette M. Grubb Donald E. Meck (paternal uncle) Thomas C. Meck (paternal uncle) Carolyn R. Grubb (paternal aunt) Dolores J. Grubb (paternal aunt) Gary J, Grubb, Jr. (paternal uncle) Elias J. Grubb (paternal uncle) RR I Box 58G9/02 - present 1/28/05 - present Covington, PA 16917 Andrew Patrick Meck, Jr. 322 Walnut Lane 7103 - 1/28/05 Angela Rudy (his fiance) Carlisle, PA 17013 Susan Rudy (fiance's mother) Leonna Williams (fiance's sister) Zechariah Meck (his son) Danielle Janette Stone various residences in Cumberland County Andrew Patrick Meck, Jr. Angela Rudy (his fiance) Susan Rudy (fiance's mother) Leonna Williams (fiance's sister) 322 Walnut Lane Carlisle, PAl 70 13 Danielle Janette Stone Donald Weaver (friend) 4 Jefferson St. Duncannon, P A 17020 Andrew Patrick Meck, Jr. Danielle Janette Stone 4 Jefferson St. Duncannon, P A 17020 Danielle Janette Stone Deborah Stone (her mother) 443 Dellville Rd. Duncannon, P A 17020 Andrew Patrick Meck, Jr. Danielle Janette Stone S402 Dwight Ave. Harrisburg, PA 17112 Andrew Patrick Meck, Jr. Danielle Janette Stone 438 S. lSth St. Harrisburg, PA 17104 Andrew Patrick Meck, Jr. Danielle Janette Stone 33 N. High St., Apt. 2 Duncannon, P A 17020 5/03 - 7/03 5/03 - 7/03 3/03 - S/03 5/02 - 3/03 4/02 - S/02 1/02 - 4/02 7/01- 1/02 4/26/01 - 1/02 The mother of the child is Danielle Janette Stone, whose last known residence was somewhere in Cumberland County. ' She is single. The father of the child is Andrew Patrick Meck, Jr., whose last known residence was at 322 Walnut Lane, Carlisle, PA 17013 He is single. 4. The relationship of plaintiff to the child is that of pate mal grandmother. The plaintiff currently resides with the following persons: Name Relationship Donald E. Meck Thomas C. Meck Carolyn R. Grubb Dolores J. Grubb Gary J, Grubb, Jr. Elias J. Grubb Andrew Patrick Meck III paternal uncle paternal uncle paternal aunt paternal aunt paternal uncle paternal uncle grandson 5. The relationship of the defendant, Andrew Patrick Meck, Jr., to the child is that of father and the relationship of the defendant, Danielle Janette Stone, to the child is that of mother. The defendants currently reside with the following persons: Name Relationship Unknown Unknown 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 information of a custody proceeding concerning the children pending in a court of this Commonwealth. The court, term and number, and its relationship to this action is: Court of Common Pleas of Cumberland County, Pennsylvania; No 03-3949; current custody order in effect 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 children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: a. Plaintiff, the child's paternal grandmother, has a genuine care and concern for the child. b. The relationship of the plaintiff with the child began with the consent of the child's father, the defendant Andrew Patrick Meck, Jr. c. The plaintiff deems it necessary to assume responsibility for the child because the child is substantially at risk due to parental neglect and/or drug or alcohol abuse. d. Under order entered by the Court of Common Pleas of Cumberland County (civil docket number 03-3949) n August 8, 2003, the defendant father has primary physical custody and both defendant parents have shared legal custody. e. The best interest and permanent welfare of the child would be served by granting the relief requested because it would be more stabilizing for the child 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody ofthe child have been named as parties to this action. No other persons are known to have or claim a right to custody or visitation of the children. tmd 4 le!i" I WHEREFORE, plaintiff respectfully requests this court to grant her sole physical'hslody of the child named herein. Michael E. Schechter1y 2.0 N. ,r"" Attorney for Plaintiff Ne-f~d",fA ,?t>J'j j~rr<...e c.r 10 IJ'IoJ6J (717) 31'1-'17(,0 I verity 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.A. !i 4904 relating to unsworn falsification to authorities. ()MM.tfr/}r)~"_M'G."" ",;ru;ff p ~ '"'\ ~, i ~, , <:,:,:, -n t l;;....i" "- , -,. - -- f71 :- CC' -- "l CJ ~ ~ D -,:1 C> ...c 0 ~ -." t.I) - f:J ., 1'.' G\ ~ ~ ANNETTE M. GRUBB Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. No. OS- 75'2. C;u,L ~\ CIVIL ACTION -- LAW ANDREW PATRICK MECK, JR. DANIELLE JANETTE STONE Defendant CUSTODY PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter my appearance as attorney in the above-mentioned action for the Plaintiff, ANNETTE M. GRUBB Respectfully submitted, // , ( ~~ Supreme Court LD. No. 90163 20 N. 6th Street Newport, P A 17074 (717) 567-0157 or (717) 379-4760 DATE: l. - /0 -CJ.5 c -c\ c> ------ v\. ANNETTE M. GRUBB Plaintiff fEB 1 1 2005 ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. No. o5-7S~ C;o~l~~ CIVIL ACTION - LAW ANDREW PATRICK MECK, JR. DANIELLE JANETTE STONE Defendants CUSTODY ORDER OF COURT AND NOW, this R day of February, 2005, upon consideration of Plaintiffs attached Emergency Petition for Custody, it is hereby ORDERED and DECREED that the plaintiff Annette M. Grubb i5 grante~~l~d legal custody of the child Andrew Patrick Meck III pending a resolution to the custody action initiated by the plaintiff in the above-referenced docket number. The defendants may have supervised visits with the child as mutually agreed upon by the parties. .....- t~~~O~d~. _ tT)~ ~ ~ 2/tw oJ' fYl a:.w -P11 'f- "y IJ ~ "" dl../I<I/?>} ~ ("\ J (';' -1':;- t,C' ANNETTE M. GRUBB IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYL VANIA vs. No. 05- CIVIL ACTION - LAW ANDREW PATRICK MECK, JR. DANIELLE JANETTE STONE Defendants CUSTODY EMERGENCY PETITION FOR CUSTODY PURSUANT TO Pa.R.Civ.P. 1915.13 1. Petitioner is Annette M. Grubb , paternal grandmother of tbe child Andrew Patrick Meck III and plaintiff in the above-captioned matter; petitioner currently resides at RR I Box 58G, Covington, P A 16917. 2. Respondents are Andrew Patrick Meck, Jr. and Danielle Janette Stone, father and mother, respectively, of the child Andrew Patrick Meck III and defendants in the above-captioned matter; the current residence of the defendants in unknown. 3. The child Andrew Patrick Meck III is three years of age and presently resides with petitioner at RR I Box 58G, Covington, PA 16917. 4. Petitioner has filed a Complaint for Custody simultaneously with the filing of this petition, and incorporates by reference the averments contained in the complaint. 5. Under order entered by the Court of Common Pleas of Cumberland County (civil docket number 03-3949) on August 8, 2003, the respondent father has primary physical custody and both respondent parents have shared legal custody. 6. The respondent Andrew Patrick Meck III, father of the child Andrew Patrick Meck III, gave the child to petitioner at her house on or about January 29, 2005 and stated that he would return on January 31,2005, but as to date he has not returned for the child. 7. The current whereabouts of the respondent Andrew Patrick Meck Jr. is unknown to the petitioner but it is believed that he is attempting to evade capture by the police. 8. Upper Allen Township police and Lower Allen Township police departments, both of Cumberland County, have both issued warrants for the arrest (If the respondent Andrew Patrick Meck Jr. in connection with the robbery of two convenience stores (on January 29,2005 and January 14,2005) and he is a suspect in two other convenience store robberies, one in Silver Springs Township (on January 16, 2005), also of Cumberland County, and another one in Upper Allen Township (on February 6, 2005). 9. The respondent Danielle Janette Stone, mother of the child, appeared at petitioner's church on January 30, 2005 and demanded to have the child but the petitioner refused at the counsel of the police, who had been called. 10. The current residence of the respondent Danielle Janette Stone in unknown to the petitioner but the respondent mother has not had a stable address for the last several years and petitioner has no way of contacting the respondent. 11. The respondent Danielle Janette Stone has a history of neglecting the child and of drug or alcohol abuse, which is why the respondent Andrew Patrick Meck Jr. was awarded primary physical custody. 12. If either respondent takes the child and flees, he or she would not be considering the needs of the child. 13. If either respondent takes the child and flees, the life of the child would be severely disrupted. 14. If either respondent takes the child and flees, the life of the child could be endangered. 15. The petitioner has contacted Tioga County Children and Youth, and Patty Miller of the CYS has conducted a home evaluation of petitioner's home and has found petitioner's home to be an extremely appropriate place for the child to be raised. Patty Miller can be reached at 1-800- 242-4417. 16. The best interest and welfare of the child would be served by granting the requested relief because it would be more stabilizing and safer for the child. wMI ...It~ql WHEREFORE, the petitioner respectfully requests that temporary sole physica1'1:ustody of the child be awarded to her pending the issuance of a final custody order. Attorney for Plaintiff Respectfully submitted, ~~ Z 0 iV, Ul, ~t- Ne-vJ'"r+,P!j 1707") (717) '3'H- 'tHo S"'prt~.",e C-r IO 901,'3 Petitioner verifies that the statements made in this Emergency Petition for Custody pursuant to Pa.R.Civ.P. 1915.13 are true and correct to the best of her knowledge, information, and belief. Petitioner understands that false statements herein are made subject to the penalties of 18 Pa.C.S.A. ~ 4904, relating to unsworn falsification to authorities. ~ LJY} 4JJ _MGru",~_, VERlFICATlON ~~ ~ ~ lr\ V'} tJ -- ...fO. II{ \) \> (). ~ ~ - t-..' __., (., '~ ,,,'--" -.'\ ~ < ; .. '- \ f'-) t.:..:', ~ ANNETTE M. GRUBB PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA v. os- 752 CIVIL ACTiON LAW ANDREW PATRICK MEeK, JR. DAN1ELLE JANETTE STONE DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, February 16,2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before JaC(IUeline M. Verney, Esq. ,the conciliator, at 4th Floor, Cnmberland County Courthouse, Carlisle on Thursday, March 10,2005 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effOlt 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 mav also be present at the conference. Failure to appear at the conference may provide grounds for cntry of a tcmporary Dr 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 hearin!!. FOR THE COURT. By: Isl facqueline M. Verney; Esq. Custody Conciliator ..j"J/ The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For infonnation about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our otIice. 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 VE 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 C'ff ~ fp -c r1" 4iV .~9/Lle .. ~,,!Ir t- /~mf'{77O'Ue r ':1 ~-, \ ,{~ ,!" ,-,;" . - ANNETTE M. GRUBB Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 05- 7s~ C;u;L~~'l CIVIL ACTION - LAW ANDREW PATRICK MECK, JR. DANIELLE JANETTE STONE Defendants CUSTODY CERTIFICATE OF SERVICE I, Michael E. Schechterly, Esquire, attorney for the plaintiff in the above-captioned case, hereby I served a copy of the Custody Complaint and the attached Emergency Petition for Custody on the defendants in the following manner: I personally served Andrew Patrick Meck, Jr., the defendant in the above-captioned case, by handing a copy of the copy Custody Complaint and the attached Emergency Petition for Custody it to him in person on February 19,2005. I personally served Danielle Janette Stone, the defendant in the above-captioned case, by handing a copy of the Custody Complaint and the attached Emergency Petition for Custody to an adult person at the residence for which the defendant gave as her residence on her bail piece before District Judge Zozos in Dauphin County; namely, RD #1 Box 383, New Bloomfield, P A 17068. Said personal service occurred on March 1, 2005. m Michael . Schechterly Pa. Supreme Court ID No. 90163 Law Office of Michael Schechterly 20. N. 6th Street Newport, PA 17074 ~:;.~; (,J ('~j '-\i ,:f~ :1' J')'" ~j I N ~~ c:> :J RECEIVED APR 19 2005:Y" ANNETTE M. GRUBB, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-752 CIVIL TERM ANDREW PATRICK MECK, JR. and DANIELLE JANETTE STONE, Defendants : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this -z...\ day of consideration of the attached Custody Conciliation Report, I follows: ,2005, upon is ordered and directed as L Paternal Grandmother, Annette M. Grubb, the Father, Andrew Patrick Meck, Jr. and the Mother, Danielle Janette Stone, shall have shared legal custody of Andrew Patrick Meck, III, born April 26, 2001. Each party shall have an equal right, to be exercised jointly with the other party, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. This means that all parties shall be entitled to all information from school and medical professionals. 2. Paternal Grandmother shall have primary physical custody of the Child. 3. Mother shall have periods of partial physical custody as agreed by Grandmother and Mother. 4. Father shall have periods of partial physical custody as agreed by Grandmother and Father. 5. No party shall do anything nor permit a third party to do anything that may estrange the child from the other party, or injure the opinion of the child as to the other party, or may hamper the free and natural development of the child's love or affection for the other party. 6. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms ofthis Order shall control. Another Conciliation Conference is scheduled for June 15, 2005 at 1 :30 p.m. c~ichael E. Schechterly, Esquire, Counsel for paternal Grandmother ~chard L Webber, Jr., Esquire, Counsel for Mother ~ew Patrick Meck, Jr., pro se 2627 Valley Road Marysville, P A 17053 DYTAE SOURT. 7/ , y(' ............ .. vi1/) J. W",kJ Oler, Jr., ( " ---., J. v . ~ ~~~~) ~ , I (.. () 'J:CD o~ - J'- \j.~ U') c:j ("J c~ c_ ...<;:r: 1"..'-:> ~..) ~;; (.) ,-. ANNETTE M. GRUBB, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA V. : 2005-752 CIVIL TERM ANDREW PATRICK MECK, JR. and DANIELLE JANETTE STONE, Defendants : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., J. 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 Andrew Patrick Meck, III April 26, 200 I paternal Grandmother 2. A Conciliation Conference was held in this matter on April 15, 2005, with the following individuals in attendance: paternal Grandmother, Annette M. Grubb, with her counsel, Michael E. Schechterly, Esquire, Father, Andrew Patrcik Meck, Jr., pro se and Danielle Janette Stone, with her counsel, Richard L. Webber, Jr., Esquire. 3. The Honorable J. Wesley Oler, Jr. previously entered an Order of Court at docket number 03-3949 providing for the parents to have shared legal custody and Father having sole physical custody. 4. The parties agreed to the entry of an Order in the form as attached. '-I . I :; 'u < Date . RECEIVED JUN 27 200y ANNETTE M. GRUBB, Plaintiff : IN THE COURT O]~ COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-752 CIVIL TERM ANDREW PATRICK MECK, JR. and DANIELLE JANETTE STONE, Defendants : CIVIL ACTION -loA W : IN CUSTODY ORDER OF COURT AND NOW, this Z 1 day of ,:Jige ~2' ,2005, upon consideration of the attached Custody Conciliation eport, It IS ordered and directed as follows: 1. The prior Order of Court dated April 21, 2005 shall remain in full force and effect with the following modification: 2. Paragraph 3 shall be deleted in its entirety and replaced with the following: Mother shall have partial physical custody provided she supplies a current address and telephone number to Grandmother as follows: A. The first weekend of every month from Friday at 3 :00 p.m. to Sunday at 4:00 p.m. B. One week during the summer from Sunday to Sunday. C. Paternal Grandmother and Mother shall share transportation such that the receiving party shall transport. 3. This Order is entered pursuant to an agreement of paternal grandmother and mother at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mut . rsen th erms of this Order shall control. / / / B;1HE COU1~}l~/ '\ /f Edgar B. Bayle: , J. cc: Michael E. Schechterly, Esquire, Counsel for paternal Grandmother Richard L. Webber, Jr., Esquire, Counsel for Mother Andrew Patrick Meck, Jr., pro se 2627 Valley Road Marysville, P A 17053 . ~ (,.;<f_Od' ~ . ( 1. - / , . ,':'n) ~ 8 :8 ~! d L Z f'nrsnoz 1''''l''''''''.'I-Hl '0 AUF lJ{\),.)l"llU;:']c::{ .:r 3~)!::!,~(}.u~nLj RECEIVED JUN 27 ZOO5 r ANNETTE M. GRUBB, Plaintiff : IN THE COURT 01' COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : 2005-752 CIVIL TERM ANDREW PATRICK MECK, JR. : CIVIL ACTION - LAW and DANIELLE JANETTE STONE, : Defendants : IN CUSTODY PRIOR JUDGE: Edgar B. Bayley, J. 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 ofthis litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Andrew Patrick Meck, III April 26, 2001 paternal Grandmother 2. A Conciliation Conference was held in this matter on June 24, 2005, with the following individuals in attendance: paternal Grandmother, Annette M. Grubb, with her counsel, Michael E. Schechterly, Esquire, Father, and D:mielle Janette Stone, with her counsel, Richard L Webber, Jr., Esquire. Father, Andrew Patrick Meck, Jr. did not appear. 3. The Honorable Edgar B. Bayley entered an Order of Court dated April 21, 2005 providing for shared legal custody, paternal grandmother having primary physical custody and the parents having periods of partial physical custody as agreed with Grandmother. 4. Grandmother and Mother agree to the modifkation of the prior Order in the form as attached. The Order does not change Father's periods of partial physical custody. (p - J... V'o ~ Date ~ (L{'~h lac eline M. Verney, EsqUIre Custody Conciliator