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Home My WebLink About05-5014 STEVEN PAUL GRIFFITH, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA NO. 05- -.!>-OIY (};,;J J,u.... SANDRA LEE GRIFFITH, Defendant CIVIL ACTION - LAW IN CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DNISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DNORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER 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. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE P A 17013 (717) 249-3166 Le han demandado a usted en la corte. Si usted qui ere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la ~orte tomara medidas y pueda entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE P AGAR TAL SERVICIO, VA Y A EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRIT A ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE P A 17013 (717) 249-3166 STEVEN PAUL GRIFFITH, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA ; NO. t:!:J- SD tY Q;;j ~ SANDRA LEE GRIFFITH, Defendant CIVIL ACTION - LAW IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the above-named Plaintiff, Steven Paul Griffith, by his attorney, Mark A. Mateya, Esquire, and seeks to obtain full custody of JEREMY WYATT GRIFFITH and JORDAN LAZARUS GRIFFITH. I. Plaintiff is STEVEN PAUL GRIFFITH, an adult individual who currently resides at 926 Grahams Woods Road, Newville, Cumberland County, Pennsylvania 17241. 2. All legal papers may be served on Plaintiff by service on his Attorney, Mark A. Mateya, Esquire with a mailing address of P.O. Box 127, Boiling Springs, Pennsylvania 17007. 3. Defendant is SANDRA LEE GRIFFITH, an adult individual who currently resides at 2668 Constitution Circle, Woodbridge, Virginia 22192. 4. Plaintiff seeks full physical custody of JEREMY WYATT GRIFFITH, born April 8, 2002, age 3 years, and JORDAN LAZARUS GRIFFITH, born May 13, 1999, age 6 years. Jordan Lazarus Griffith currently resides with Plaintiff at 926 Grahams Woods Road, Newville, Cumberland County, Pennsylvania and Jeremy Wyatt Griffith currently resides with Defendant at 2668 Constitution Circle, Woodbridge, Virginia 22192.. 5. The child JORDAN LAZARUS GRlFFITH was born out of wedlock and the child JEREMY WYATT GRIFFITH was born in wedlock. 6. The child JORDAN LAZARUS GRlFFITH is presently in the custody of Plaintiff at 926 Grahams Woods Road, Newville, Cumberland County, Pennsylvania 17241 and the child JEREMY WYATT GRIFFITH is presently in the custody of Defendant Sandra Lee Griffith, at 2668 Constitution Circle, Woodbridge, Virginia 22192. 7. During the past five years the children have resided with the following persons at the following addresses: A. From 1999 to 2000, at Aquia Harbor, Stafford, Virginia with Steven Paul Griffith and Sandra Lee Griffith; B. From 2001 to 2002 at Lakeland Florida with Steven Paul Griffith and Sandra Lee Griffith. C. In 2003, in Raleigh, North Carolina with Steven Paul Griffith and Sandra Lee Griffith. D. In 2004, in Woodstock, Virginia with Steven Paul Griffith and Sandra Lee Griffith. E. In January I, 2005 to the present, with Steven Paul Griffith and Sandra Lee Griffith in Newville, Cumberland County, Pennsylvania 17241. 8. The father ofthe children, Steven Paul Griffith, is currently residing at 926 Grahams Woods Road, Newville, Cumberland County, Pennsylvania, and he is married. 9. The Mother of the children, Sandra Lee Griffith, is currently residing at 2668 Constitution Circle, Woodbridge, Virginia, and she is married. 10. The relationship of the Plaintiff to Jordan Lazarus Griffith and Jeremy Wyatt Griffith, is that of natural father. I I. The relationship ofthe Defendant to Jordan Lazarus Griffith and Jeremy Wyatt Griffith is that of natural mother. 12. The Plaintiff has not participated as a party or a witness, or in any other capacity, in other litigation concerning the custody ofthe children in this or another Court. 13. Plaintiff has no information of a custody proceeding concerning the children pending in a Court of this Commonwealth or any other state. 14. Plaintiff does not know of a person not a party to this custody proceeding who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 15. The best interests and permanent welfare of the children will be served by granting the relief requested because: a. Plaintiff is the father of the children. b. The child Jordan Lazarus Griffith has been attending school at Frankfort Elementary School. c. Plaintiff has been the primary caregiver ofthe children since their birth. d. Plaintiff can continue to provide a stable home for the children. e. Plaintiff can continue to provide financially for the children. f. Defendant recently left Plaintiff in August for fourteen (14) days when she traveled to Houston, Texas to stay with a friend. g. Defendant has progressively abused alcohol throughout the entire length of the children's lives. h. Defendant has a history of abandoning her prior children from her two (2) . . pnor marnages. I. Defendant takes prescription drugs which she mixes with alcohol. J. Defendant has been an occasional marijuana user in the recent past. WHEREFORE, the Plaintiff requests this Honorable Court to grant full physical custody of the of the children to Plaintiff and shared legal custody of the children with Plaintiff and Defendant.. Respectfully submitted, w, Mark A. Mateya Attorney I.D. No. 789 P.O. Box 127 Boiling Springs, P A 17007 (717) 241-6500 Dated: q!~3/W; I { Attorney for Plaintiff VERIFICATION I, STEVE GRIFFITH, verify that the facts set forth in the foregoing Complaint for Divorce and Custody are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. g 4904, relating to unsworn falsification to authorities. DATED: 11?-~!o~ f / ~\2 STEVE GRIFFITH ~ n ...., = 0 ~ " C:;:::J ~ ,-" ., ~ u, .... ,..., :c." l"- v rnp N "l? ~ -0 ----- W ";~C~ ~ -U ."",', -s:) :J:: f~j:D 0- :,':~ w 6~ m u.. .... ..-1 ,> .-.:. '"^' ::0 <;l$ -.J .< .............. -- --- C/l D' STEVEN PAUL GRIFFITH PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 05-5014 CIVIL ACTION LA W SANDRA LEE GRIFFITH IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, September "~!l-,-2095 _".__, upon consideration of the attached Complaint. it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. at----.it_h},Io()~,_(:umberland County Courthonse, Carlisle on Thnrsday, Octo.~~~}~,~,o.0.5"" . thc conciliator, at 9:30 AM """-,,-,,~ for a Pre-Hearing Custody Conference" At sllch conference, an effort will be made to rcsolve the issucs in dispute; or if this cannot bc 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 eonference 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 Tacqueline M.., Vemey, Esq. Custody Coneiliator ~If\ The Court of Common Pleas of Cumberland County is required by law to eomply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the eourt, please contact our omce. 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 . .cf ~ y ~ 1""'1' kt.,J ~,~~ ~W- ~~ 1r' <; rtf":" J<hl .f"J J"c7 ,e. /1 )'<7' je"y )(7$e.tJ 21'1 :S 11d 82 cBS ~Ual XdV1C~'~J\.';lC'dd 3t-ll :10 :j:;I~:lO-CEn!:l --------- P, CI" I,' '! :'~TI 03 '00' " . . ~ STEVEN PAUL GRIFFITH, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : NO. 2005-5014 CIVIL TERM SANDRA LEE GRIFFITH, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 3'd day of October, 2005, the Conciliator being advised that the parties have reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, y~.J.'L---( /h .:Lev,' L( ine M. Verney, Esquire, Custody -,:'j -< ,..., = c;:;:y <':'.,n co f.~ ....; o -n ~.,.., f"i1e -~l ': ~_r_\C, ~:'A~'f'; '~.~';~~ ":",:.! :~~~ 1 0) --,' -:.', ~? ...0 v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. 05- 5011f sf ; CIVIL ACTION - LAW ~ IN 9IVORgE .~IB CUSTODY STEVEN PAUL GRIFFITH, Plain tiff SANDRA LEE GRIFFITH, Defendant CHILD CUSTODY STIPULATION AND AGREEMENT AND NOW, this So.f:i.-dayof CVep-t0W\ W- , 2005, come the parties Steven Paul Griffith of Cumberland County, Pennsylvania, hereinafter referred to as "the Father," and Sandra Lee Griffith, presently residing at 2668 Constitution Circle, Woodbridge, Virginia, fonnerly of Cumberland County, Pennsylvania, hereinafter referred to as "the Mother," and enter into this Child Custody Stipulation and Agreement and state the following: WHEREAS, the parties are the natural parents of two (2) minor children, namely JORDAN LAZARUS GRIFFITH, born May 13, 1999 and JEREMY WYATT GRIFFITH, born April 8, 2002, hereinafter referred to as "children:" /1""t'!1f7 , ~ rj '; v-I WHEREAS, the parties were married on AI':a 1,2000, in Las Vegas, Nevada; WHEREAS, the child Jordan Lazarus Griffith was born out of wedlock and the child Jeremy Wyatt Griffith was born in wedlock; WHEREAS, there is no Order of Court regarding Custody of the children; WHEREAS, the parties have reached a custody agreement, delineating the parties' rights and responsibilities, the tenns of which agreement they desire to set forth: WHEREAS, the parties desire the provisions of this Child Custody Stipulation and Agreement be approved by This Honorable Court and entered as a court order with the same force and effect as though said Order had been entered after Petition, Notice and Hearing. NOW THEREFORE, with the foregoing incorporated by reference, and intending to be legally bound, and in consideration of the mutual promises and agreements contained herein, the parties agree as follows: 1. The parties agree that they shall share legal custody of the children. 2. The parties agree that Father shall have primary physical custody of the children with Mother having the following periods of partial physical custody: (a) Every other weekend commencing with Saturday, October 1, 2005. (b) Weekend is defined as Saturdays at 9:00 a.m., until Sunday at 6:00 p.m. ( c) Mother will enjoy physical custody and not be limited to Pennsylvania but rather will be able to take the Children to her present address in Virginia as well to her new address in Virginia which is her brother's residence in nearby King George/Fredericksburg, Virginia. 3. The parties agree any of the above custody schedules may be modified by mutual agreement of the parties. 4. Transportation: The transportation shall be shared by the parties, the parties shall exchange custody at the designated times by traveling on Route 15 and meeting at the VirginiaJPennsylvania border at the nearest convenient stop, as the parties agree. 5. Each parent shall have the right to communicate daily with the children while in ~ " the care of the other parent. 6. The parties agree that they have an obligation to act in the very best interests ofthe children. Each party, therefore, shall exercise every reasonable effort to foster a feeling of love, affection, or respect for the other party or that party's family. Each party shall, to the best of his or her ability, limit the children's exposure and knowledge of any disputes between the parties and the details oftheir legal and financial dealings with each other. Each party shall refrain from making disparaging remarks about the other party or that party's family, nor allow anyone else to do so in the children's presence. 7. Neither party shall prevent the other from taking the children to the house of worship of his or her choice. 8. The parties agree that the non-custodial parent shall advise the custodial parent of any medical emergencies which occur while the children are in that parent's care, within twenty- four (24) hours, if possible. 9. The parties agree that both parents shall have equal access to information regarding the children's school records and activities. Each party shaH execute any and all legal authorizations so that the other parent may obtain information from the children's schools, physicians, psychologists, or other individuals concerning their progress and welfare. It shall be the responsibility of each party to retrieve the children's records for him- or herself. 10. The parties agree that the Cumberland County Court of Common Pleas will retain jurisdiction in any dispute whatever involving the custody of the Children. 11. The parties agree that this Stipulation shaH be entered as an Order of Court in the Cumberland County Court of Common Pleas. <' , 1<] ~ \ IN WITNESS WHEREOF, the parties hereto, after full disclosure made, have signed, sealed and delivered this Agreement, as of the day and date first above written. Witness: '3~~ j~ Steven Paul Griffith , ~ , ~ .' n ~'!7":--- ~ 1./.' ,( J 'j/ Sandra Lee Griffith 9 ..-> "'" '611 o " -' \ <..,-; Q, .-\ ::;:'-1\ n1f~ -C1~ "Jl \) I.,),C} -~~_ -~1 ~:~~;~ <.,., n' ":'~~ -\'7 ~ -t' _.' -" - r:- -' - ------ o STEVEN PAUL GRIFFITH, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 05-5014 SANDRA LEE GRIFFITH, Defendant CIVIL ACTION - LAW IN CUSTODY AFFIDAVIT OF SERVICE AND NOW, this 3rd day of October, 2005, comes Mark A. Mateya, Esquire, Attorney for Plaintiff, who, being duly sworn according to law, deposes and says that: I. A Complaint for Custody was filed to the above term and number on September 23, 2005. 2. On or about September 26,2005, a certified copy of the Complaint for Custody was mailed to Defendant by Certified Mail, Restricted Delivery, Return Receipt Requested. Plaintiffs counsel received the Return Receipt card on or about October 3, 2005. A copy of the Receipt is attached hereto as Exhibit "A" and is incorporated herein by reference. 3. A certified copy ofthe Complaint was mailed to the Defendant via first class mail, postage prepaid on September 26, 2005. The Certificate of Mailing is attached hereto as Exhibit "B" and is incorporated herein by reference. Respectfully submitted, ~~;,5;ro Attorney J.D. No. 78931 P.O. Box 127 Boiling Springs, P A 17007 (717) 241-6500 (717) 241-3099 Fax Attorney for Plaintiff rn ru ru ru U1 ru rn ru U.S. Postal Service", CERTIFIED MAIL", RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) Postage $ $0.60 $2.30 $1.75 $3.50 .0007 /iY.; l'j~ "/f' SlUGHere\,' ' ! 97, '\Q.941S200$ wQRIiiEfVA Ma I ~ o CJ Return Reciept Fee CJ (Endorsement Required) t:J Restricted Delivery Fea D (Endorsement Required) U1 o Certified Fee $ $8.15 Total Postage & Fees ~ :3A.ND.eA L ,eIFF[ril,nmnunnmuuu, r'- ~:'t~r!/::L"i~If:::,_Q~~rii~nQg'nCj_&U_f c;;';' Stat?lJoo & J ME; " A .;,A ) qJ... " · C<ln1lIele ~ 1, 2, and 3. Aleo CClmpIete 11Im 4 If Aoil.lllllW Dellveryla doeIrecJ. · Pllnt your name and address on the ......... . that we C8ll return the cera to you. · AIloch ltIIo card 10 the back of the IIl8IIj:lIq, ..on the frllnt If lIpllCe permits. ; C".c, I._Met. ~to: CAgent C C. Date of ~ S4~.. I... fiR. IrnTJ./ ~t1; 8 eo))srifuTio~ e/f..C.L6 "oo},/llbblrl: V A ~) q ~ D.Io-...y___fnlmlt8ml? 0... ~YE8.enl8r~___ CNo '-~~ - a.~,~... , (7lohsW~~1obOI) PS Form 3811, FebnJary 2004 3. -1n>e )(CertIIIod Moll 0 ~ Moll o ~od 0 RoIum Aocoipt for Moool_..... o ino&nd Moll 0 C.<1D. 4. Reo.I.."'" DeIlvory? /EltI1t Feo) ... 7.EE3 . O~~EOO~q'1__2~2~c~223_ llCmestJc Return ~pt ~~T 102595-02-M-16iID EXHIBIT I A ,l'NOH.LUlId U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT PROVIDE FOR INSURANCE - POSTMASTER Received From: IY)AR.-K A. 7r;ATfOYA) ES€j. r o. -SOx. )&-1 noiL IN r; SPt,rJb5 PA- !'TD01 One piece of ordinary mail addressed to: 0AJJDRA J.. r;~ I mTJ-I. ;{ 1e~)5 COJJ.5TtluTiDA/ (! /R.f!...LE lDoo) BIC ID&E V A ':P,)CJJ... PS Form 3817. Mar. 1989 EXHIBIT I~ '" "- UJ '" '" '" '" Z In .... - Q (.f) 0:1'....1- 0(:Ja..,::) .z a..-(/)':::)(O::=l <1: I.....NO .a....t:).- ::E: (I"J Z a..(1: . _ UJ ::J d en a <D IQt " S ~ ~ ~. "~ ! ~ C:,' C~. ., c:..J ~, C> C. ::,~- .~..\i0j, ".-yo.t. ~:;.:' r I, r-} (i .-.::-;-:1, ,;;.] 'Zi" C> C) -' '. f:';'~'/ 7C:' z.. ~.L::, \ (oon ..,., -;::i;; ::; r--' o o ~CEIVED OCT 0 610n~ ^y STEVEN PAUL GRIFFITH, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-5014 SANDRA LEE GRIFFITH, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER AND NOW this 1.cikuay of o"i , 2005, upon consideration of the foregoing Stipulation and Agreement entered into by the parties attached hereto: IT IS HEREBY ORDERED AND DECREED that the Stipulation and Agreement regarding Custody/Visitation dated September 24, 2005, entered into by the parties herein is hereby approved as fully as though, and with the same force and effect as if such Order had been entered after Petition, Notice and Hearing.. BY THE COURT: () r cfJ ,O,\t- lur<r"'" - ~<:\!n::) S8 :01 HI! Z I 1.:10 saaz Ai:iVl.U: F~,.:'Ct'd 3Hl :10 ~{JLJ,',J(}-C!T!H