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Home My WebLink About05-4802 LOUANN SPEESE-ST ANLEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v, CIVIL ACTION - LAW IN CUSTODY NO.O!;'. 'I fv..tIVIL TERM HENRY H. STANLEY, Defendant NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE 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 South Bedford Street Carlisle, Pennsylvania 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. LOUANN SPEESE-ST ANLEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN CUSTODY HENRY H. STANLEY, Defendant , NO. 05. LJj't).l CIVIL TERM COMPLAINT FOR CUSTODY The plaintiff, Louann Speese-Stanley ("Mother"), by her attorneys, the Family Law Clinic, avers the following in support of her Complaint for Custody: I. The plaintiff is Louarm Speese-Stanley (hereinafter "Mother"), residing at 110 East Main Street, Shiremanstown, Cumberland County, Pennsylvania 170 II. 2. The defendant is Henry H. Stanley ("Father"), believed to be residing at 4201 Gettysburg Road, Camp Hill, Cumberland County, Pennsylvania 1701 I. 3. Plaintiff seeks custody of the following children: Name Present Residence Date of Birth Diana 1. Stanley 110 East Main Street Shiremanstown, P A 170 II 08/03/97 Hannah E. Stanley 110 East Main Street Shiremanstown, P A 170 II and Milton Hershey School Hershey, P A 17033 06/19/00 Grace B. Stanley 110 East Main Street Shiremanstown, P A 170 II 08/05/02 Diana 1. Stanley and Hannah E. Stanley were not born in wedlock. Grace B. Stanley was born in wedlock The children are presently in the custody of Mother, who resides at 110 East Main Street, Shiremanstown, Pennsylvania, 17011, Cumberland County. During the past five years, the children have resided with the following persons at the following addresses: Name Address Dates Louarm Speese-Stanley 110 East Main St. Shiremanstown, P A 170 II September 2004- Present Louann Speese-Stanley Henry H. Stanley 110 East Main St. Shiremanstown, P A 170 II September 2000 - September 2004 The mother of the children is Louarm Speese-Stanley, currently residing at 110 East Main Street, Shiremanstown, Cumberland County, Pennsylvania, 170 II. She is married. The father of the children is Henry H. Stanley, believed to be residing at 4201 Gettysburg Road, Camp Hill, Cumberland County, Pennsylvania 17011. He is married, 4. The relationship of the plaintiffto the children is that of mother. Mother resides with the following persons: Name Relationshio Diana 1. Stanley Daughter Grace B. Stanley Daughter Hannah E. Stanley Daughter The relationship of the defendant to the child is that of father. Father currently resides with the following persons: Name Relationshio Unknown Unknown 5. Mother has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Mother does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 6. The best interest and permanent welfare of the children will be served by granting the relief requested because: a. Mother has been the children's primary caretaker since the children's birth. b. Mother is able to provide the children with a home with the moral, emotional and physical surroundings required to adequately meet the children's needs. c. Mother exercises parental duties on behalf of the children and enjoys the love and affection of the children. d. Father has not made his current address or contact information known to Mother. Father has had no involvement in making any decisions regarding the religious, medical, and educational upbringing of the children. e. Mother is willing to encourage and support the children's relationship with their father. 7. Each parent whose parental rights of the children have not been terminated and the person who has physical custody of the children has been named as parties to this action. WHEREFORE, Plaintiff requests the Court grant Mother sole legal custody and primary physical custody of the children. Date: S~l)J.1L r~ ,21i.>5 / vall led Legal Intern ANNE ONALD-FOX LUCY OHNSTON-WALSH THOMAS M. PLACE ROBERT E, RAINS Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 234-2968 VERIFICATION 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. 34904 relating to unsworn falsification to authorities L "~" SP'~'- ~I"SR ~ Plaintiff/Petitioner V () "., 0 C-.::.l , 'n en G"" ~~ .." ;:,-;;: ""'\ 1--; '. , ~ C;~ G') "".1 ( ,) G' LOUANN SPEESE-STANLEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN CUSTODY HENRYH. STANLEY, Defendant NO, OS'$),ClVlL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Louann Speese-Stanley, Plaintiff, to proceed in forma pauperis. I, Jeffrey G, Stovall, of the Family Law Clinic, Certified Legal Intern, for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal service to the party. (' ,,2 1- ,ylr- Date:JPU:',n6t1i I J; j, J ~1' Certified Legal Intern . (I: J.. ~z \",'/ ':- l.,l, u/ ,_ '7-'41 VUe/I \.. T . PACE LUCY 10 STON-WALSH ROBERT E. RAINS ANNE MACDONALD-FOX Supervising Attorneys THE F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Attorneys for Plaintiff CD c.,) ,> ~~? LOUANN SPEESE-STANLEY PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 05-4802 CIVIL ACTION LAW HENRY H. STANLEY DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, Sepfember 21,2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator, at 4th Floor, C..,mberland County Courthouse, Carlisle on Thursday, October 13, 2005 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in disputc; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, 3nd 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 furuish any and all existing Protection from Ahuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: Isl facqueline M. Verney. Esq, :r' 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 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 ~~ f;w ~~~ .XJ'r::e& -* -P ~ ~u; ~;o.-ee; '7;;:/ " $- ~ 4;- PfJ 50- -el!'lJ \1lj\:IJ'/YI/\Sh;",1.:3d \ 'Nr~'-'-'''n'' rll 11 i'.__I,) "~: <:'[,'\:I IV 61 :8 !4d ZZ d3S ~uOl Al:lV10NOHlOQd :JrU :10 381:1:10-0311:1 LOUANN SPEESE-STANLEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN CUSTODY HENRYH. STANLEY, Defendant NO. 05-~8o~S:IVIL TERM CUSTODY AGREEMENT THIS AGREEMENT, made this L day of ~c..-. T ,2005, between Louann Speese-Stanley, hereinafter "Mother", and Henry H. Stanley, hereinafter "Father", concerns the custody of their children, Diana Stanll:y, born August 3,1997, Hannah Stanley, born June 19,2000, and Grace Stanley, bom August 5, 2002. Mother and Father desire to enter into an agreement as to the custody of the children. Mother and Father agree to the following: I. Mother shall have sole legal custody of the children. 2. Mother shall have primary physical custody of the children. Father's custodial periods shall be arranged through mutual agreement of the parties, 3. Transportation for the custodial periods shall be arranged through mutual agreement of the parties. 4. Holidays, including but not limited to, Easter, Memorial Day, Fourth of July, Labor Day, Thanksgiving, and Christmas shall be divided each year by mutual agreement of the parties. 5. Neither parent will do anything which may estrange the child from the other party, or injure the opinion of the child as to the other parent, or which may hamper the free and natural development of the child's love and respect for the other parent. 6. The parties intend to be bound by the terms of this Agreement and intend that this Agreement be entered as an OrdeT of Court. 7. The Father understands that the Family Law Clinic represents only the Mother's interests in this matter and has advised him that he should seek the adv' e oflegal counsel. I I fkWli~ /C)-~ ~~QOS Date ~~,,~ ;Aef c.tin"" LeFever Certified Legal Intern ~:;;,~:l~ ROBERT RAINS ANNE MACDONALD-FOX THOMAS M. PLACE Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2368 (') ,-- ....., <00 ~:'.:i.; o C) -1 o -n ..... :_1:.,- fllp:d ,,, c:/ (1..\ -; :s <,~~;.j ,rn ~a r;y W o RECEIVED OCT 11 Z005 IP1 LOUANN SPEESE-STANLEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYL VANIA V. : NO. 2005-4802 CIVIL TERM HENRY H. STANLEY, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 11th day of October, 2005, the Conciliator being notified that the parties have reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, ( t<.~~ ine M. Verney, Esquire, Cu dy Conciliator ;.\in8 III,!,.'.. '\~.l\' i OS :2 Pd Z i 1:30 SOUZ () LOUANN SPEESE-STANLEY, Plaintiff RECE E OCT 121005 IN THE COURT OF COMM PLEAS OF CUMBERLAND COUNTY, P SYL VANIA '}: v. CIVIL ACTION - LAW IN CUSTODY HENRYH. STANLEY, Defendant NO. 05-4802 CIVIL TERM ORDER OF COURT And now on thisli day of October, 2005, the attached Custody Agreement is ;' approved and entered as an Order of Court. " t1 -QJ 10 ~\~ OF TIE: 'Ii I ,~ 20D5 OCT 17 Pil i!: 18 __,'~,~~)'..JNTY