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Home My WebLink About05-5034JAMIE MICHAEL STINE, Plaintiff IN TIIE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA LAURA STINE NO. 05- -5V3y CIVIL TERM vs CUSTODY Defendant COMPLAINT FOR CUSTODY 1. The plaintiff is JAMIE MICHAEL STINE. Plaintiff's permanent residence is 13 Northview Drive, Carlisle, Cumberland County, PA, 17013. 2. The defendant Laura Stine residing at 811 Gobin Drive, Carlisle, Cumberland County, PA, 17013. 3. The plaintiff seeks custody of the following child: Name Present 1Zesidence Age Jacob Michael Stine 811 Gobin Drive 11 months Carlisle, PA 17013 The child Jacob Michael Stine, October 28, 2004, Nvas born in wedlock. The child is presently in the custody of the mother, who resides at 811 Gobin Drive, Carlisle, Cumberland County, PA, 17013. During the child's lifetime, he has resided with the following persons and at the following addresses: Name Jamie Michael Stine and Laura Stine Michael Stine, Jamie Michael Stine, and Laura Stine Jamie Michael Stine and Laura Stine Address 167 N West Street Carlisle, PA 17013 13 Northview Drive Carlisle, PA 17013 Safe Harbor 102 W. High St. Carlisle, PA 17013 Date October 28, 2004 to e,.irly November 2004 early November 2004 to November 20, 2004 November 20, 2004 to early December 2004 Mr. Benson, 64 Willow Mill Park Rd. e:Tly December 2004 to Mrs. Benson, Mechanicsburg, PA 1 ?050 end of December 2004 3 Benson children, Jamie Michael Stine, and Laura Stine Bill Yufer, Jean Yufer, Jamie Michael Stine and Laura Stine 811 Gobin Drive Carlisle, PA 17013 J miuary 2005 to 1\1 ay 2005 Michael Stine Jamie Michael Stine and Laura Stine Bill Yufer, Jean Yufer, Laura Stine 13 Northview Drive Carlisle, PA 17013 811 Gobin Drive Carlisle, PA 17013 Nlay 2005 to September 4, 2005 September 4, 2005 to present The defendant in this action, Laura Stine, is the mother of the child and is currently residing at 811 Gobin Drive, Carlisle, Cumberland County, PA, 17013 She is married to the plaintiff. The Plaintiff hereinafter "father" of the children is Jamie Michael Stine, currently residing at 13 Northview Drive, Carlisle, Cumberland County, PA, 1-17013. He is married to the Defendant. 4. The defendant currently resides with the following persons: Name Michael Stine Relationship Uncle 5. A PFA entered against Father grants him partial custody only on Saturdays. 6. Father has no information of any pending custody proceeding concerning the child. 7. Father does 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 wi th respect to the child. 8. The best interest and permanent welfare of the children will be served by granting the relief requested for reasons including, but not limited to the following: VERIFICATION The above-named PLAINTIFF, Jamie Michael Stine, verifies that the statements made in the above complaint For custody are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: 912 o/9Ss i layr Jamie Michael Stine ?' C7 ?? -- ?? -;T -r>? ' -^'^'^ T _; - .?.-f : ,- r _? ,.-. _? f ?? ?J { '? .+l ?. ?..3 JAMIE MICHAEL STINE, IN WE COURT OF COMMON PLEAS OF Plaintiff CUMBERI-AND COUNTY, PENNSYLVANIA vs. NO. & 5 v 5?j CIVIL TERM LAURA STINE, Defendant CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Jamie Michael Stine, Plaintiff, to proceed in forma au eris. I, Grace E. D'Alo, attorney for the party proceeding in forma pay uperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. k C?-? L ?)' 'G *e E. D'Alo naging Attorney MidPenn Legal Services 8 Irvine Row Carlisle, PA 11013 (717) 243-9400 C t Gtt t'al t ??J i ? -?C JAMIE MICHAEL STINE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. LAURA STINE DEFENDANT 05-5034 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, October 04, 2005 , upon consideration of t'he attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, October 27, 2005 at 9:30_ 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 hearing. FOR THE COURT, By: /s/ ac ueRg M. Verney. Esq. 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 HAVE 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 ,?? ?o ?r -;? V al 92 oil r I.a S- L,;0 50L7 ]HI 210 6 RFCZIVFD 'EP 2 9 "'c,9 4 JAMIE MICHAEL STINE, Plaintiff IN THE COURT OF COMMON PLEAS OF VS. LAURA STINE CUMBERLAND COUNTY, PENNSYLVANIA NO. 65, ?D3 CIVIL TERM Defendant : CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at on the day of 2005, at _ in., 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. 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 hearing. By the Court, Date: Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOU R LAWYf; R 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 NN'HERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 1701 ) (717) 249-3166 OR (800) 990-9108 AMERICANS WITH DISABILITIES ACT 01 `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 ab )ut accessible facilities and reasonable accommodations available to disabled individuals havin- business before the court, Pease 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. JAMIE MICHAEL STINE, Plaintiff vs. LAURA STINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. os`5b3? CIVIL TERM IN CUSTODY MOTION TO DISMISSCOMPLANT IN CUSTODY By and through his counsel, Grace E. D'Alo, the Plainttiff, Jamie Stine, respectfully asks the Court to enter the attached Order and avers the following: 1. On September 26, 2005, Plaintiff filed a Complaint in Custody. 2. The Court scheduled a conciliation in this case for October 27, 2005, with Jackie Verney. 3. Since filing the Complaint, Plaintiff and Defendant have reconciled their differences and are living together and raising their child, Jacob, together. 4. After conferring with counsel, Plaintiff wishes to withdraw his Complaint and asks the Court to dismiss the above-captioned action without prejudice. WHEREFORE, Plaintiff asks that this Court enter the attached Order. Respectfully submitted, E. D'Alo ff s attorney N f 7p r" W n' j JAMIE MICHAEL STINE, Plaintiff VS. LAURA STINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 05- CIVIL TERM IN CUSTODY AFFIDAVIT OF SERVICE BY MAIL I, Grace E D'Alo, do hereby swear that I served Laura Stine on the date indicated below, with a Motion to Dismiss by regular, first class, U.S. mail to the address below: Laura Stine 13 Northview Drive Carlisle, PA 17013 I, Grace E. D'Alo, verify that the statements made in this Affidavit of Service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S. Section 4904 relating to unworn falsification to authorities. Date: Signatur • V J \f l '?J ?FJ t ?J7 CJ f-1 r J cn Ti n ? ? T G CJ Ci < Ir? RECEIVED OCT 1 7 M5 VI JAMIE MICHAEL STINE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA vs. NO. CIVIL TERM LAURA STINE, O? ?" Defendant IN CUSTODY ORDER AND NOW, this day of 05, upon consideration of Plaintiff's Motion to Dismiss, the Complaint in Custody filed by the Plaintiff in the above-captioned matter is hereby dismissed without prejudice to either party. CC. -S-a( 1?,? ?t-/ ?_i !Y? __ __ ;__ ?_ ,.-, r_?_ ?,:. -? OCT [z?? too5 By JAMIE MICHAEL STINE, : IN THE COURT OF COMMO Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-5034 CIVIL ACTION-LAW LAURA STINE, Defendant IN CUSTODY ORDER OF COURT AND NOW, this 2151 day of October, 2005, the Conciliator having been advised that the parties have reconciled, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, i cquel e M. Verney, Esquire, Custody Co Bator RECEIVED -Y D ,- <.= Jamie Michael Stine, Laura Jean Stine, Plaintiff v Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005 - 5034 IN CUSTODY CIVIL TERM - LAW MOTION FOR CONSOLIDATION Plaintiff, Jamie Michael Stine, by and through his attorneys, MidPenn Legal Services, move the Court for an Order consolidating two (2) docket numbers into one on the grounds that: 1. A Complaint for Custody, Docket 2005-5034, was entered on September 26, 2005 by Judge Bayley. 2. Parties reconciled and on October 18, 2005 Judge Bayley entered an Order dismissing the Complaint in Custody without prejudice to either party, after the Plaintiff had withdrawn the Complaint. 3. A Complaint for Custody, Docket No. 2009-5395 was entered August 3, 2009, and scheduled for conciliation with Conciliator Jacqueline M. Verney, Esq. 4. Plaintiffs counsel was contacted by the Court Administrators and asked to file a Motion to Consolidate the two (2) dockets numbers. Wherefore, Plaintiff requests that Docket No. 2009-5395 be consolidated with Docket No. 2005-5034, and that Docket No. 2005-5034 be the only identifying docket for the custody matter. Respectfully submitted, MIDPENN LEGAL SERVICES Date: b 3 By: /,//i I Abraham ozesky, orney for Plaintiff MidPenn Legal rvices 401 East Lo er Street, Suite 103 Carlisle, PA 17013 (717) 243-9400 VERIFICATION I verify that I am the Petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S.§4904, relating to unsworn falsification to authorities. Dated: s'l z 710 `r 42w'A, 44t Jamie Michael Stine, Plaintiff FLED-t F CE OF TW FROTHoNOTARY 2009 SEP - 8 PH 2: 4 5 PEN SYLVAINA SEP 0 9 2009 Jamie Michael Stine, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V NO. 2005 - 5034 CIVIL TERM - LAW Laura Jean Stine, Defendant IN CUSTODY ORDER FOR CONSOLIDATION AND NOW, this $ day of September, 2009, upon consideration of the attached Motion for Consolidation, the Docket No. 2009-5395 shall be consolidated with Docket No. 2005-5034 and the custody matter will be identified by Docket No. 2005-5034. By the Court,/ uate Distribution idPenn Legal Services 401 E Louther Street Carlisle PA 17013 Jek-6 J`Flk. ep t es mw , Judge flMi-lCE OF THE PRM OTARY 2099 SEP --9 PM 3.02 Cumbtr?,-,:?4-4u o'.1UN 1 PENNSYLVANA