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Home My WebLink About06-0442 SHANE PATIERSON, Plain tiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNT'{, PA v. NO. o{" .W). CW<1 --- . I e___ ASHLEY MOFFITT, Defendant CIVIL ACTION -LAW IN CUSTODY COMPLMNTFORCUSTODY 1. The Plaintiff is Shane Patterson, who cuttendy resides at 16 Forest Avenue, Fayetteville, Franklin County, Pennsylvania 17222. 2. The Defendant is AsWey Moffitt, who currendy resides on Sunset Avenue, Shippensburg, Cumberland County, Pennsylvania. The house number of the Defendant's residence is unknown. 3. The Plaintiff seeks custody of the following child: Name: Xzaiver Graham Moffitt Date of Birth: January 31, 2005 Sunset Avenue, Shippensburg, P A Address: 4. The child was born out of wedlock. 5. The child is presendy in the custody of Ashley Moffitt, who currendy resides on Sunset Avenue, Shippensburg, Cumberland County, Pennsylvania. The house number of the Defendant's residence is unknown. 6. During the child's lifetime, he has resided with the following persons and at the following addresses: Name Address Date AsWey Moffitt and Donald Moffitt Sunset A venue) January 31, 2005, to ptesent Shippensburg, P A 7. The mother of the child is Ashley Moffitt, who currendy resides on Sunset Avenue, Shippensburg, Cumberland County, Pennsylvania. The house number of the Defendant's residence is unknown. 8. Mother of the child, Ashley Moffitt, is married. 9. The father of the child is Shane Patterson, who currendy resides at 16 Forest J\venue, Fayetteville, Franklin County, Pennsylvania 17222. 10. Father of the child, Shane Patterson, is not married. 11. The relationship of Plaintiff to the child is that of Father. 12. The relationship of Defendant to the child is that of Mother. 13. The Defendant currendy resides with the following persons: Donald Moffitt, Defendant's husband, and Damien Nichol, Defendant's son. 14. The 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 any other court. 15. The Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 16. The 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 child. 17. The best interest and permanent welfare of the child will be served by granting the relief requested for reasons including the following: a. Father is able to provide a stable environment for the child. b. Mother has refused Father all contact with the child. c. Mother is not furthering a relationship between Father and the child. d. Mother does not share any information regarding the child with Father, including but not limited to, any medical information. e. Mother works two jobs, a first and second shift position, and leaves the child in the care of her husband and to the exclusion of Father. f. Mother does not have a vehicle to transport the child in the case of an emergency. g. On or about or before Thursday, January 19, 2006, the child suffered an injury to his knee while in the care of Mother's husband. The child was taken to the emergency room and a follow-up appointment with his pediatrician. Father was not notified of any of these events nor was he provided any information as to what happened to the child. h. It is believed and therefore averred that Mother's husband is engagmg ill drug-related activities at their home and in the presence of the children. 1. It is believed and therefore averred that sometime in the past two weeks the police conducted a raid of Mother's home for drug-related activity, resulting in criminal charges being brought against Mother's husband. J. It would be in the best interest of the child for him to not be left in the care of Mother's husband, Donald Moffitt. k. I t would be in the best interest of the child for him to develop a relationship with his Father. 18. Each parent whose parental rights to the child have not been tenninated has been named as parties to this action. WHEREFORE, the Plaintiff requests that this Court grant primary physical custody of the child to the Plaintiff/Father. Respectfully submitted, ABOM & KUTULAKlS, L.L.P. OK" m( U,(Dlp ~. Kara W. Haggerty ID No. 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff VERIFICATION I, Shane Patterson, verify that the statements made in this Custody Complaint arc true and correct to the best of my knowledge, information, and belief. I understand that false statements herein arc made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Date: #' ~c:x:? ~,/ ~;;::z.___ ____ Shane Patterson CERTIFICATE OF SERVICE 7 2 rtL- ..-,- AND NOW, this &2- day of ~6, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.l', hereby certify that I did serve a true and correct copy of the foregoing Custody Complaint, upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Ashley Moflitt Sunset Avenue Shippensburg, PA 17257 Respectfully submitted, ADOM & KUTULAKIS, L.L.P. Kara W. Haggerty ID No. 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff SHANE PATTERSON, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, P A NO. 01.,-'1'1.2 CwJ. J~ ASHLEY MOFFITf, Defendant CIVIL ACTION - LAW IN CUSTODY TO THE HONORABLE JUDGE OF SAID COURT: PETITION FOR SPECIAL RELIEF AND NOW, this 23,d day of January, 2006, comes the Petitioner, Shane Patterson, by and through his attorney, Kara W. Haggerty, Esquire, of ABoM & KUTULAKIS, L.L.P., and respectfully petitions This Honorable Court to grant Petitioner special relief, and in support thereof avers the following: 1. The petition of Shane Patterson, Father, respectfully represents that on January 23, 2006, simultaneously with this Petition, Father flied a Complaint for Custody of the parties minor child, Xzaiver Graham Moffitt, born January 31, 2005, seeking primary physical custody. (Copy attached as Exhibit "A"). 2. Father believes that it would be in the child's best interest to be in his primary physical custody, because he can provide a safe and stable home for his son. 2 3. Father believes it would be in the child's best interests if Father were granted primary physical custody and shared legal custody. 4. Mother has refused Father all contact with the child. 5. Mother is not furthering a relationship between Father and the child. 6. Mother does not share any information regarding the child with Father, including but not limited to, any medical information. 7. Mother works two jobs, a first and second shift position, and leaves the child in the care of her husband and to the exclusion of Father. 8. Mother does not have a vehicle to transport the child in the case of an emergency. 9. On or about or before Thursday, January 19,2006, the child suffered an injury to his knee while in the care of Mother's husband. The child was taken to the emergency room and a follow-up appointment with his pediatrician. Father was not notified of any of these events nor was he provided any information as to what happened to the child. 10. It is believed and therefore averred that Mother's husband is engaging in drug-related activities at their home and in the presence of the children. 11. It is believed and therefore averred that sometime in the past two weeks the police conducted a raid of Mother's home for drug-related activity, resulting 3 in criminal charges being brought against Mother's husband. 12. It would be in the best interest of the child for him to not be left in the care of Mother's husband, Donald Moffitt. 13. It would be in the best interest of the child for him to develop a relationship with his Father. WHEREFORE, Petitioner prays that This Honorable Court grant his Petition for Special Relief and award him primary physical custody and shared legal custody of the minor child. Respectfully submitted, ADOM & KUTULAKIS, L.L.P. n^,,~ f 23/0& ~\ Kara W. Haggerty, Es Attorney ID No. 869 36 South Hanover Street Carlisle, P A 17013 (717) 249-0900 Attorney for Petitioner 4 SHANEPATfERSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. NO. ASHLEY MOFFITI, Defendant CNIL ACTION - LAW IN 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 2006, at .m., 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 the scheduled Hearing. BY THE COURT, 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. 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 BAR ASSOCIATION 32 SOUTH BEDFORD CARLISLE, PA 17013 (717) 249-3166 OR (800)990-9108 [~h,6:t A SHANE PATTERSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. NO. ASHLEY MOFFITT, Defendant CNILACTION -LAW IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Shane Patterson, who currently resides at 16 F orest Avenue, Fayetteville, Franklin County, Pennsylvania 17222. 2. The Defendant is Ashley Moffitt, who currently resides on Sunset A venue, Shippensburg, Cumberland County, Pennsylvania. The house number of the Defendant's residence is unknown. 3. The Plaintiff seeks custody of the following child: Name: Xzaiver Graham Moffitt Date of Birth: J anuaty 31, 2005 Address: Sunset Avenue, Shippensburg, PA 4. The child was born out of wedlock. 5. The child is presently in the custody of Ashley Moffitt, who currently resides on Sunset Avenue, Shippensburg, Cumberland County, Pennsylvania. The house number of the Defendant's residence is unknown. 6. During the child's lifetime, he has resided with the following persons and at the following addresses: Name Address Dare Ashley Moffitt and Donald Moffitt Sunset Avenue, January 31, 2005, to present Shippensburg,PA 7. The mother of the child is Ashley Moffitt, who currently resides on Sunset Avenue, Shippensburg, Cumberland County, Pennsylvania. The house number of the Defendant's residence is unknown. 8. Mother of the child, Ashley Moffitt, is married. 9. The father of the child is Shane Patterson, who currently resides at 16 Forest Avenue, Fayetteville, Franklin County, Pennsylvania 17222. 10. Father of the child, Shane Patterson, is not married. 11. The relationship of Plaintiff to the child is that of Father. 12. The relationship of Defendant to the child is that of Mother. 13. The Defendant currently resides with the following persons: Donald Moffitt, Defendant's husband, and Damien Nichol, Defendant's son. 14. The 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 any other court. 15. The Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 16. The 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 child. 17. The best interest and permanent welfare of the child will be served by granting the relief requested for reasons including the following: a. Father is able to provide a stable environment for the child. b. Mother has refused Father all contact with the child. c. Mother is not furthering a relationship between Father and the child. d. Mother does not share any information regarding the child with Father, including but not limited to, any medical information. e. Mother works two jobs, a first and second shift position, and leaves the child in the care of her husband and to the exclusion of Father. f. Mother does not have a vehicle to transport the child in the case of an emergency. g. On or about or before Thursday, January 19, 2006, the child suffered an injury to his knee while in the care of Mother's husband. The child was taken to the emergency room and a follow-up appointment with his pediatrician. Father was not notified of any of these events nor was he provided any information as to what happened to the child. h. It is believed and therefore averred that Mother's husband is engagmg m drug-related activities at their home and in the presence of the children. 1. It is believed and therefore averred that sometime in the past two weeks the police conducted a raid of Mother's home for drug-related activity, resulting in criminal charges being brought against Mother's husband. J. It would be in the best interest of the child for him to not be left in the care of Mother's husband, Donald Moffitt. k. It would be in the best interest of the child for him to develop a relationship with his Father. 18. Each parent whose parental rights to the child have not been terminated has been named as parties to this action. WHEREFORE, the Plaintiff requests that this Court grant primary physical custody of the child to the Plaintiff/Father. Respectfully submitted, ADOM & KUTULAKIS, L.L.P. DATE D/ll3 (D!p I ~ Kara W. Haggerty ID No. 86914 36 South Hanover Street Carlisle, P A 17013 (717) 249-0900 A ttowey for Plaintiff VERIFICATION I, Shane Patterson, verify that the statements made in this Custody Complaint are tlUe and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Date: hi c2Pc:<<? ~,,"'~--- Shane Patterson CERTIFICATE OF SERVICE 72 rd- -- AND NOW, this ~ day of ~6, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a tme and correct copy of the foregoing Custody Complaint, upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Ashley Moffitt Sunset Avenue Shippensburg, PA 17257 Respectfully submitted, ABOM & KUTULAKIS, L.L.P. Kara W. Haggerty ID No. 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff VERIFICATION I, Shane Patterson, verify that the statements made in this Petition ior Special Reliei are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 5 4904 relating to unsworn falsification to authorities. Date: //~, ~~ '::> Shane Patterson CERTIFICATE OF SERVICE AND NOW, ,hi, 23rL;"y Ofuo:,,~06, I, KM, W. H'l'''''~' Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Petition for Special Relief, upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Ashley Monitt Sunset Avenue Shippensburg, PA 17257 Respectfully submitted, Abom & Kutulakis, L.L.P. Kara W. Haggerty, Attorney ID No. 86 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 5 ,~ . ~. ...... 'J 8 ~ )J N ~. ,~ ~ \j \::) '0 ~ '" ~. (~ f~~'" (..~ c_ ,'. ~.. ( SHANE PATTERSON, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 06-0442 CIVIL V. ASHLEY MOFFITT DEFENDANT CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this 25th day of January, 2006, upon consideration of the attached Petition for Special Relief, it is ORDERED that the parties and their respective counsel appear before this Honorable Court on January 31,2006 at 10:00 a.m. for a hearing on said Petition. Said hearing will be restricted solely to the emergency nature of the requested placement, to wit: the alleged lack of transportation available to the mother, and the effect the police raid and/or the alleged drug related activity has had or will have upon the safety of the child. The plaintiff/petitioner shall have the burden of proof with regard to altering the status quo in this case. By the Court, M~,:t l~l- ~ Haggerty, Esquire Attorney for Plaintiff Aley Moffitt ~ - ~ ~ Defendant fO\( ~, bas 1/ n ~~O~ D\-'J--J ;" j ,....c., .,;" , SHANE PATTERSON PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 06-442 CIVIL ACTION LAW ASHLEY MOFFIT IN CUSTODY DEFENDANT ORnER OF COURT AND NOW, Thursday, JlIn_lI"-'T~~,l~~~.._.__, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at ~.t_~._~!~~E,_ Cumberland County Courthouse, Carlisle on_ Fridar,Xebruary 17,2006 , 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 fivc or older may also be present at the confcrencc. 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: Isl Hubert X Gilrov. Esq._ ---------d-1i-'- Custody Conciliator [J The Court of Common Picas 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 oflice. 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 . ~ ~/1iX';/> '~/Pzp' t~} -/,vi: IJrPn/ ~H, r-1iJ:/p ~? .2 ff'~'v -~v /-";P \iINW\lN2NN3d - ",..., '......-.MnJ I i"l^,r',r-'i' ,!,-,:+..,,..,IL,~ !\..'J\l :'-...'., ',', "._., ...., , j 90 :2 lId L2 NVr900l l"\.N',.t"i'.'IL"','.J :lHl :10 )\tl'l.l..'.JI'\.il. v.....'.,! -' 3:JI::Ho-031I:l '7c7 I 1:J ./ "?CJ . 'f SHANE PATTERSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. NO. 06-442 ASHLEY MOFFITT, Defendant CIVIL ACTION - LAW IN CUSTODY MOTION TO CONTINUE HEARING AND NOW, this 30'1, day of January, 2006, comes the Plaintiff, Shane Patterson, by and through his attorney, Kara W. Haggerty, Esquire of ABOM & KUTULAKlS, L.L.P., who fIles this Motion to Continue Hearing and, in support thereof, avers as follows: 1. A hearing is scheduled in the above referenced matter for testimony on Petition for Special Relief on January 31, 2006 at 10:00 a.m. 2. Plaintiff and Defendant are negotiating an agreement as to custody of the subject minor child. 3. Therefore, Plaintiff and Defendant request additional time to complete an agreement about custody. 4. Defendant, Ashley Moffitt, has agreed to a continuance in this matter. S. Therefore, a continuance is requested in the above-captioned matter to allow the parties to negotiate a custody agreement. WHEREFORE, the Plaintiff requests that This Honorable Court grant the Plaintiff a continuance for the hearing scheduled in the above-referenced matter. Respectfully submitted, ADOM & KUTULAKIS, L.L.P. DATE 1/36/0 Y, 4~L't'jC Kara W. Haggerty . - Attorney ID No. 86914 36 South Hanover Street Carlisle, P A 17013 (717) 249-0900 Attorney for Plaintiff . CERTIFICATE OF SERVICE AND NOW, this 30th day of January 2006, I, Kathleen A. Engle, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Motion to Continue Hearing, upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Ashley Moflitt 108 Springhouse Road Shippensburg, PA 17257 Respectfully submitted, Abom & Kutulakis, L.L.P. athleen A. Eng e, Esquire Attorney ID No. 200616 36 South Hanover Street Carlisle, P A 17013 (717) 249-0900 n ('~- '"< ~b\;" ""l ~~~> , . J.._ ,_ ~;.;\.;:~ "J<"',. ''::1 ~ <;:i.? ,--:/" ~ --;? .....' o ~ -;,t... ~ ,~"" -::L,-"" ....."\s: . 'r" .co '9,h '''-~(~ ::.;\ ),q, -"<_~lf '--:.\ o ~\1 ".-"-0 ,- ~~ . j !:0\i'~ Ii /ULG SHANE PATTERSON, Plaintiff IN THE COURT OF COMMON PLEAS ~ CUMBERLAND COUNTY, PA v. NO. 06-442 ASHLEY MOFFITT, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW; this JD'/fJ. day of ~ ' 2006, Hearing on the matter shall be held on the 9"t:L- day of ~~ ,2006, in Courtroom S ,DO No. _ of the Cumberland County Courthouse, Carlisle, Pennsylvania at 02. o'clock j-.m.. By the Court, ~--1 , ~ lVJt ( \ \ j J. Kara Haggerty, Esquire, Counsel for the Plaintiff C opr ~iVen Ashley Moffitt, 108 Springhouse Road, Shippensburg, P A 17257 copy fr1a: /."r.{ s S :S I1d 08 NVr 900Z AtJV10NUH10dd 3Hl::J0 3:)i:J~O-(f:lll:l SHANE PATTERSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. NO. 06-442 ASHLEY MOFFITT, Defendant CIVlL ACTION - LAW IN CUSTODY MOTION TO CONTINUE HEARING AND NOW, this 6th day of February, 2006, comes the Plaintiff, Shane Patterson, by and through his attorney, Kara W. Haggerty, Esquire of ABOM & KUTULAKIS, L.L.P., who files this Motion to Continue Hearing and, in support thereof, avers as follows: 1. A hearing is scheduled in the above referenced matter for testimony on Petition for Special Relief on February 8, 2006 at 2:00 p.m. 2. Plaintiff and Defendant are negotiating an agreement as to custody of the subject minor child. 3. Therefore, Plaintiff and Defendant request additional time to complete an agreement about custody. 4. Defendant, Ashley Moffitt, has been contacted by undersigned counsel and has agreed to a continuance in this matter. 5. Therefore, a continuance is requested in the above-captioned matter to allow the parties to negotiate a custody agreement. WHEREFORE, the Plaintiff requests that This Honorable Court grant the Plaintiff a continuance for the hearing scheduled in the above-referenced matter. Respectfully submitted, ABOM & KUTULAKIS, L.L.P. DATE 02- DLY {j;; Kara W. Haggerty Attorney ID No.8 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney jor Plaintiff . CERTIFICATE OF SERVICE AND NOW, this 6th day of February 2006, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Motion to Continue Hearing, upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Ashley Moffitt 108 Springhouse Road Shippensburg, PA 17257 Respectfully submitted, Abom & Kutulakis, L.L.P. ~wJj). Kara W. Haggerty , Attorney ID No. 86 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 I,' r; ,..., G? > :.:;;-. --" '" (Xl I 0' o -n ~'T'. ;nl~~ -,'T.'..,! "(' CO! -n ') ro- ~.' '-~,~r ~? ..~:::\ Clj :..;: \.0 - SHANE PATIERSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUN1Y, P A v. NO. 06-442 ASHLEY MOFFITT, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this / 'tf1 day of -:!1~ ,2006, Hearing on the 3rd matter that was scheduled for February 8, 2006 shall be now be held on the cJ day of .J- 4 ' 2006, in Courtroom No. ~ of the Cumberland County Courthouse, Carlisle, Pennsylvania at /Ll;{?c!ock :!...m.. By the Court, 't J. Kara Haggerty, Esquire, Counsel for the Plaintiff Ashley Moffitt, 108 Springhouse Road, Shippensburg, P A 17257 ~J~~ ~.07.D(. 9r-, '~J 68 =8 Hd ^tNJC(\.:~;;. -< ",1' ...,"'.i' L - 8J.:l9U!JZ :::IL :10 :\)~.(rnJJ SHANE PATTERSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, P A v. NO. 06-442 ASHLEY MOFFITT, Defendant CIVIL ACTION -U.W IN CUSTODY ACCEPTANCE OF SERVICE AND NOW, this ~ day of January, 2006, I, Ashley Moffitt, Defendant in the above- captioned matter, hereby certify that I did receive and accept service of the Complaint in Custody and Petition for Special Relief in the above-captioned matter. DATE /.;)~ -6/.0 JiU ~) Ashley M~ffitt , 1':" <,) ,- t...;-' .---"i :_\:\ -:;.1--r! \'~~~\-~; , ~, > ,r, ,'"-, ()'? r<} - '7" -'. SHANE PATIERSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, P A v. NO. 06-442 ASHLEY MOFFITT, Defendant CIVIL ACTION - LAW IN CUSTODY PRAECIPE TO DISCONTINUE SPECIAL RELIEF PETITION TO THE PROTHONOTARY: Please enter Plaintiffs voluntary discontinuance of the Special Relief action only and keep the general custody matter open. Respectfully submitted, ABOM & KUTULAKIS, L.L.P. Date: [;'1/22.-/ ULP ka1Jlt0. -{(WtJ atr". Kara W. Haggerty, E q 're ( 36 South Hanover, eet ' Carlisle, P A 17013 (717) 249-0900 Attorney for Plaintiff . CERTIFICATE OF SERVICE AND NOW, this 22nd day of February 2006, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Praecipe to Discontinue the Special Relief Action in this custody matter, upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Ashley Moffitt 108 Springhouse Road Shippensburg, PA 17257 Respectfully submitted, Abom & Kutulakis, L.L.P. ( Kara W. Haggerty , Attorney ID No. 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 --j'i ...., ~, r-.J " j''':: .- '-~~ .... s - ""~:.,,! ~~J.~~J .~, l. i5/ SHANE PATTERSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, P A v. NO. 06-442 ASHLEY MOFFITf, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Praecipe to Discontinue, it is hereby ordered that the Special Relief action in this custody matter be discontinued this 1'1 *" day of t:' ~~Nll.;-'l-, 2006. BY THE COURT: J. Kara W. Haggerty, Esquire Ashley Moffitt 108 Springhouse Road Shippensburg, P A 17257 - ~ ~ ;l.-)..'Ij)!., ~ \;1' I ,"7, ,1 J I, i;;';J :{; ~."_ 'j (,. t_!-..i~ " ;-;-:"'-!\I'O cr-. ,t,.H, d ",- '-1;L l-l-_U",~.___ly7 SHANE PATTERSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. NO.06-442 CIVIL ACTION - LAW ASHLEY MOFFIT, Defendant IN CUSTODY ORDER AND NOW, this ;2 J'Vl.l day of February, 2006, the Conciliator being advised that the parties desire a general continuance in this case, the Conciliator relinquishes jurisdiction. II-J/- Hubert Gilroy, Esquire cus~ Conciliator / .... " L~2 n:L:l