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Home My WebLink About05-4178 Jeffrey B. Engle, Esquire SHAFFER & ENGLE LAW OFFICES 129 Market Street Millersburg, PA 17061 Phone: 717-692-2345 Fax: 717-692-3554 Jeffengl@epix.net IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA Scott Andrew Harvey, Plaintiff vs, : No, OS- - iff?? C~ULL~D2-L Shannon Elizabeth Stebbins, Defendant CIVIL ACTION - LAW CUSTODY CUSTODY COMPLAINT 1. The Plaintiff is Scott Andrew Harvey, an adult individual residing at 4512 Florence Avenue, Apt. E, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2, The Defendant is Shannon Elizabeth Stebbins, an adult individual currently residing at 504 Hogestown Road, Mechanicsburg, Pennsylvania, 17575. 3. The Plaintiff is the natural father of the minor child, Kaleb Alexander Harvey, four years of age, DOB 6/26/01. 4. The Defendant is the natural mother of the minor child Kaleb Alexander Harvey, four years of age, DOB 6/26/01. 5. Plaintiff seeks custody of the following child: Name Present Residence Kaleb Alexander Harvey 504 Hogestown Rd, Mechanicsburg, P A The child was born out of wedlock. Age 4 The child, Kaleb Alexander Harvey, is presently in the custody of Defendant. During the lifetime of the child, the child has resided with the following persons at the following addresses: Name Scott Harvey Shannon Stebbins Pamela & Lester Harvey Scott Harvey Shannon Stebbins Shannon Stebbins Jennifer Clayton Shannon Stebbins Anthony Stebbins Shannon Stebbins Anthony Stebbins Hannah Stebbins Address 33 W, Maple Avenue Shiremanstown, P A Coover Street Mechanicsburg, PA Delbrook Manor Mechanicsburg, P A Main Street Mechanicsburg, P A Hogestown Road Mechanicsburg, PA 6. The Plaintiff currently resides with the following persons: Name Mary E, Davis Makayla Spotts Relationship Fiance' Fiance"s daughter Date 6/26/01 - 11102 11102 - 2/03 2/03 - 2/04 2/04 - 8/04 8/04 - Present 7. The Defendant currently resides with the following persons: Name Relationship Anthony Stebbins Hannah Stebbins Kaleb Harvey Husband Daughter Son 8. 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, 9, Plaintiff does not know of a person not a party to the proceeding who has physical custody of the child, or claims to have custody or visitation rights with respect to the child, 10, 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, II, The best interest and permanent welfare of the child will be served by granting the relief requested, WHEREFORE, Plaintiff requests that This Honorable Court grant his legal and partial physical custody of the subject minor child, Respectfully submitted, SHAFFER & ENGLE LAW OFFICES Dated: fih;{-- I ( VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C,S, 4904 relating to unsworn falsification to authorities, Scott Date: '~S;jtJ 5 AJ (J '-6Q t "- i:J. '- "- - '- "'C ~ ~ C> 0 ,...., ~ = -< C C;;:;J >On f:J ~ --u ..., ".,... ~::n c:: n,- pe- en :x8 '() VI (3;- ..-,{~ ~ -0 I-n ,")- , :;:: ',,0 ,'- orn ~ ~~.~ Y7 S; ~ .c-- 5:J N -< SCOTT ANDREW HARVEY PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 05-4178 CIVIL ACTION LAW SHANNON ELIZABETH STEBBINS DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, August 19,2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberlaud Couuty Courthouse, Carlisle on Friday, September 23, 2005 , the conciliator, at 10:30 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 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 hearin\!:. FOR THE COURT, By: Isl Hubert X Gilrov. E~ Custody Conciliator P' 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 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 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 ~ ~"P< '" ~~ J'", ' JL - . i'~,$ . 7"r';17 :2 ~ r.;I;o, ">/./ ,.... - ---r-"'-J~, {'F.~ ~ fiv "" ~ .:-~ ~ ""P .so I:e.,g )JJJCY',I'" '-"'T.-\H18 ('7 :Jflil SDOl SO :IJ lid <,'" '\":JH1 :10 Al:lV1Ci~J:{;.V(lo~nIJ 301~;I\J-, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Scott Andrew Harvey, Plaintiff vs, : No, 05-4178 Shannon Elizabeth Stebbins, Defendant CIVIL ACTION - LAW CUSTODY AFFIDAVIT OF SERVI<~ COMMONWEALTH OF PENNSYL VANIA SS: COUNTY OF DAUPHIN Jeffrey B. Engle, Attorney for Scott Andrew Harvey, Plaintiff in the above-captioned action, being duly sworn, according to law, deposes and says that he served a certified copy of the Complaint in Divorce in said action on Shannon Elizabeth Stebbins, Defendant, by posting same on August 27, 2005, in the U,S. Mail, Certified, Return Receipt Requested, See Return Receipt Card, signed by Shannon Stebbins, attached hereto, marked Exhibit "A", and made a part hereof, SWORN TO AND SUBSCRIBED BEFOREMETHIS6l-~'t"\ DAY OF 'Auts",:-..f , 2005. v~ [LUll->> Notary Public NOTARIAl SEAl MEUSSA E, WISE Notary Public MILLERSBURG BOROUGH. DAUPHIN COUNTY My Commission expires Jul23. 200B I SCHEDULE "A" ,. Article Addressed to: 8hohV\on [, Skbb~ boL\ ~loLOn I<d Meck.o.V\?c;bu3 PA- I '7 Ob (j dto/D 1006 {&10 6ODLM1~. 1~Lf4 . Complete ilems 1, 2. and 3. Also complete ~em 4 ~ Restricted DellvOI)f is d...lnld, . Print your name and address on the reverse so that we can retum the card to you, . Attach this card to the back of the mailpiece, or on the front ~ space permits, 2. Articfe Number (llllnsfor from stNVics JabeO PS Form 3811 , March 2001 3. Service Type ~if\edMall o Registered D-Insured Mall o Agent 0- Iil Yes DNa , Domestic Return Receipt 102595-<J1-M-1424 (') s; <--'<'" c'lT. fT'f: -::;" 5~; 5~- ;--< ~2 Z ~ --I [ ,) C', " I !} RECEIVED OCT 0 5 ZOO~ SCOTT ANDREW HARVEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 05-4]78 CIVIL ACTION - LAW SHANNON NICOLE SEBBlNS, Defendant IN CUSTODY COURT ORDER AND NOW, this lb~ day of O~ ,2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Scott Andrew Harvey, and the Mother, Shannon Nicole Stebbins, shall enjoy shared legal custody of Kaleb Alexander Harvey, born Jnne 22, 2001. 2. The Mother shall enjoy primary physical custody of the minor child. 3. The Father shall have periods of temporary physical custody of the minor child as follows: A. On alternating weekends from Friday through Sunday, the times for exchange should be agreed upon by the parties. B. On every Tuesday from approximately 4:00 p.m. until 8:00 p.m. C. At such other times as agreed upon by the parties. 4. The parties shall share transportation for exchange of custody. 5. The parties shall share or alternate major holidays pursuant to a schedule as they may agree. 6. Mother shall always have custody on Mother's Day, and Father shall always have custody on Father's Day. This provision shall supercede the alternating weekend schedule set forth above. 7. Each Parent shall have at least two full weeks of vacation with the minor child during the summer, which vacation may be consecutive or nonconsecutive and which vacation will include the weekend schedule for the Parent. Each party shall notify the other Parent at least thirty (30) days in advance as to when they intend to exercise their vacation. 8. In the event either party is going to relocate out of the Mechanicsburg area such that the Order set forth above is not workable for the custody situation and there is no agreement between the parties with respect to modification of the Order, the party relocating must petition the Court prior to relocation. 9. In the event either party desires to modify this Order and cannot reach an agreement with the other party, either party may petition the Court to have this case again scheduled with the Custody Conciliator for a conference. Judge Cc: 'V\ , ,,-) 6n ,c <::,1 '. oJ) ,",,', J.... , , ~ '. II 1::10 sauz RECEIVED OCT 052005 ~~ SCOTT ANDREW HARVEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-4178 CIVIL ACTION - LAW SHANNON NICOLE SEBBINS, Defendant IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Kaleb Alexander Harvey, born June 26,2001 2. A Conciliation Conference was held on September 23, 2005, with the following individuals in attendance: The Father, Scott Andrew Harvey, with his counsel, Jeffrey B. Engle, Esquire, and The Mother, Shannon Nicole Stebbius, who appeared without counsel 3. The parties agreed to an entry of an Order in the fonn as attached. Date: IO-~- t)~