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Home My WebLink About06-1782 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CRAIG M. LANGLEY, Plaintiff CIVIL ACTION - LAW v. NO. 2006- I 7 ~:J- I J, ~.C C iv; ./ SIMONE MCRAE, Oefendant IN CUSTOOY NOTICE 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 aod 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 aod a judgment may be entered against you by the court without further notice for aoy 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 00 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 Street Carlisle, Pennsylvania 17013 (717) 249-3166 ... NOTIClA Le han demandado a usted en la corte. Si usted qui ere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (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 corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion yporcualguierqueja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiendades 0 otros derechos importantes para usted. LLEVE EST A OEMANDAA UN ABOGAOO IMMEDIA T AMENTE. SINO TIENE ABOGAOO o SINO TIENEELOINEROSOFICIENTEOEPAGAR TALSERVICO, V A Y AENPERSONAL o LLAME POR TELEFONO A LA OFICINA CUY A OIRECCION SE ENCUENTRA ESCRIT A ABAJO PARA A VERIGUAR OONDE SE PUEOE CONSEGUIR ASISTENCIA LEGAL Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 \ ~T & ASSOCIATE I / / " M. Shul z, Esquire Attorney ill No. 90946 II Roadway Orive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 Attorneys for Plaintiff .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CRAIG M. LANGLEY, Plaintiff v. CIVIL ACTION - LAW /i' . ,----- NO. 2006- / '1 p. ~ /0..... SIMONE MCRAE, Oefendant IN CUSTOOY COMPLAINT FOR PRIMARY CUSTODY AND NOW, this ~ day of March, 2006, comes Plaintiff, Craig M. Langley, by and through his attorneys, Knight & Associates, P.c., and files the following Complaint for Primary Custody in support thereof avers as follows: I. The Plaintiff is Craig M. Langley, who resides at 42 Dupont Place, Irvington, New Jersey 0711 L 2. The Oefendant is Simone McRae, who resides at IlIA Spruce Street, Shiremanstown, Cumberland County, Pennsylvania. 3. The Plaintiff seeks primary custody and visitation of the following children: Name Present Residence Age O/O/B Jared McRae 111 A Spruce Street 2 Shiremanstown, P A 17011 11/30/03 Jared McRae was born out of wedlock. The child is presently in the physical custody of the Oefendant. In addition to the child's present address, during the past five years, the child has resided with either Plaintiff or Oefendant at the following addresses: None. , - The mother of the child is the Oefendant who resides at IlIA Spruce Street, Shiremanstown, Pennsylvania 17011, The father of the child is the Plaintiffwho resides at 42 Dupont Place, Irvington, New Jersey 07111. 4. The relationship of Plaintiff to the child is that of natural father. The Plaintiff currently resides alone. 5. The relationship of the Defendant to the child is that of natural mother. It is unknown with whom the Defendant resides. 6, Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the child in this or another court. The Plaintiffhas no information of a custody proceeding concerning the custody of the child in this or any other court. 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. 7. The best interests and permanent welfare of the child will be served best by granting the reliefrequested because: a) The Plaintiff has had shared physical and legal custody of the child since the child's birth; b) The Plaintiff provides the child with a home with adequate moral, emotional and physical surroundings as required to meet the child's needs; c) The Plaintiff is, and has always been, willing to accept custody of the child; d) The Plaintiff continues to exercise parental duties and responsibilities and enjoys the love and affection of the child; and .- e) The Plaintiff provides a more stable home environment. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody ofthe child has been named as parties to this action. There are no other persons who are known to have or claim a right to custody or visitation of the child. WHEREFORE, Plaintiff respectfully requests Your Honorable Court grant him physical custody and shared legal custody of Jared McRae. Respectfully submitted, n M. Shultz, Esquiie.___ Attorney ill No. 90946 11 Roadway Orive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 Attorneys for Plaintiff .- VERIFICATION I verify that the statements made in the foregoing Complaint 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. Section 4904, relating to unsworn falsification to a orities. /....... I I o/9/0Y N 0 ~ t~ it ':::::: t ~ () "-.. C "-...... '^ ..:( \)' -- ) r-..) 0 CJ C'::.} \l' "'-D ,....., --11 ~- ~ c ,','-" --l C) ---"I": ~~'J ~'" ~ ~ ---J ~J r-',.) 1.....-: ---- ~ b -' 1.-:: '---1 N -J..- -;-1 ;~ (' j _. ....,)(";1 -+-..- - r f..:? '_.~ (' ~5 ..~ en '< _J " CRAIG M. LANGLEY PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV ANJA v. 06-1782 CIVIL ACTION LA W SIMONE MCRAE IN CUSTODY DEFENDANT ORDER OF COllRT AND NOW. Wednes<!"Y-L Marc!t.,~.1.006 , upon consideration of the attached Complaint. it is hereby directcd that partics and their respective counsel appear beforc Melissa P. Greevy, Esq. , the conciliator, at_ MDJ Manlov~, 1901 State.S~:-,--~alllJ'l:Ii11,R~_l?()}I_ on _.___J1.riday,_~atJl~~006__.__ at },:3.Q..JM for a Prc-Hcaring Custody Conference. At such conference. an effort will be made to rcsolve the issucs in dispute; or if this cannot be accomplished, to define and narrow the issucs to bc 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 hearinl!. FOR THE COURT. By:.. /s/ iV../ Melissa P. Gree~q,__.....J~_ Custody Conciliator ., The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilitcs Act of 1990. For in/ormation about accessible facilities and reasonablc accommodations available to disabled individuals having business before the C01ll1, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or husiness betore the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR A HORNEY 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 1.77'17' P-' 1 fiI"'" t-4; ":;1 of; " ,L J 117'''''' ':J:"I10 "Iv .rE ffr - ,11 <lJ(fv>' [ ~ p,; Iff'" 'ffl}} 1"8 ' . 1,\ \ '~:, 'I ~-? \, ~,rl, "-,.' ,,' ,.'-' 0_" .<".,. . ,.' ,d., C':,-; -------- ~ IN THE COURT OF COMMON PLEAS OF CUMBERLANO COUNTY, PENNSYL V ANlA CRAIG M. LANGLEY, Plaintiff v. CIVIL ACTION - LAW No. 06-1782 SIMONE MCRAE, Defendant IN CUSTOOY } CERTIFICATE OF SERVICE AND NOW, this 1) 7day of April, 2006, I, Sean M. Shultz, Esquire, hereby certify that the following person was served with a True and Correct copy of the Complaint in Custody and Order of Court dated March 29, 2006, scheduling a Custody Conciliation for May 5, 2006, at 2:30 p.m. filed in the above-referenced matter. The documents were mailed on April 4, 2006, but actual service took place on April II , 2006, by Defendant signing for a copy of the Complaint in Custody and Order which were mailed in the United States Mail, Certified Mail--Return Receipt Requested, Restricted Delivery, Postage Prepaid, addressed as follows: Simone McRae IliA Spruce Street Shiremanstown, Pennsylvania 17011 A copy of the signed Domestic Return Receipt is attached hereto as Exhibit "A" and by reference incorporated herein and made a part hereof. Respectfully submitted, K r F\UserFolderIFirmDocs\Gendocs2006\3933-lceI1.service_wpd ean M. Shultz, He Attorney ill No. 90946 II Roadway Drive, Suite B Carlisle, Pennsylvania l7013 (717) 249-5373 Attorneys for Plaintiff . " SENDER: COMPLETE THIS SECTION . Complete items 1, 2. and 3. Also complete item 4 if Restricted Delivery Is desired. . Print your name and address on the reverse sa that we can return the card to you. . Attach this card to the back of the mail piece, or on the front if space permits. 1. Article Addressed to: S hn 0 VLR Nk Q.a.e. \ f r A Spf uce $-keet Sh( (~rY1lW5tvlttJlt, P1t 11-'OJ 2. ArticleT (Trans!s . . . A. Signature \..1 ~ 0 Agent X JL.---,.,L..g Addressee B. Rec ved by (Printed Name) C. Date of Delivery ': i V'Vi. c/r-r--W C~."" D. Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: 0 No 3. Service Type ~rtified Mail '0 Registered o Insured Mail o Express Mail o Return Receipt for Merchandise o C.O.D. 4. Restricted Delivery? (Extra Fee) es 7005 1160 0002 1108 9520 10259S-Q2-M-1540 PS Form 3811, February 2004 Domestic Return Receipt -." p A/." ".2 \ t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CRAIG M. LANGLEY, Plaintiff No. 06-1782 Civil Term Civil Action - Law v. IN CUSTODY SIMONE MCRAE, Defendant CUSTODY AGREEMENT AND STIPULATION THIS AGREEMENT, made this 5 +.:!l day of M Q. \{ 2006, by and between Plaintiff, Craig M. Langley, of 42 Dupont Place. Irvington, New Jersey, hereinafter referred to as "Father," and Simone McRae, of IlIA Spruce Street, Shiremanstown, Cumberland County, Pennsylvania, hereinafter referred to as "Mother," or collectively referred to as "the Parties." WHEREAS, Father and Mother desire to provide for the custody of their child, Jared McRae, born November 30,2003, hereinafter referred to as "Jared." WHEREAS, the parties desire the provisions of the present Custody Agreement and Stipulation to 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, the Parties, in consideration of the mutually made and to be kept promises set forth herein and for other good and valuable consideration, intending to be legally bound, do hereby covenant, promise and agree as follows: 1. . The Parties shall have shared legal custody of Jared. F:\User FolderlFinn Docs\Gendocs200613933-I.agreement.custody. wpd ..... .," 2. Father shall have primary physical custody of Jared, subject to Mother's periods of custody. 3. Mother shall have partial physical custody of Jared one weekend per month. The Parties shall agree upon which weekend mother shall have at least one week in advance of her custodial period. 4. The Parties have agreed that they can and will make custody arrangements for the holidays by mutual agreement as the holidays arise. 5. Each party agrees to keep the other apprised in writing to the Party's then current mailing address at least twenty days prior to any move of residence. 6. The Parties have agreed to meet at a neutral site for custody exchanges. Unless otherwise agreed, the custody exchanges shall not take place at the Parties' residences. 7. Neither party shall disparage the other parent to Jared, and they shall prevent Jared from being exposed to third parties disparaging the other parent. 8. Mother shall not allow her paramour, Mark Anthony Perry, to have any contact whatsoever with Jared. 9. The Parties agree that this Custody Agreement and Stipulation shall be made an order of court and shall resolve the Complaint for Custody filed by Father at docket number 06- 1782 Civil Term. 10. This Agreement may be modified in writing by the Parties' mutual consent at any time without resort to the Court. F:\User Folder\Firm Docs\Gendocs2006\3933-I.agreement.custody.wpd ..~ .,. ... I . l' IN WITNESS WHEREOF, the Parties have set their hands and seals the day and year first above written. WITNESSED BY: (SEAL) S-1fJ9Q ~~ Simone McRae STATE OF~)' ) :SS. COuNTY OF ~~ ) On the 0 r day of ~, 2006, before a Notary Public, personally appeared Craig M. Langley, known to ~re the person whose name is subscribed to the within document, and acknowledged that he executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. ~ ~~ S. R. PATEL J;~R~ P~BLJC OF NEW JERSEY mrsslOl1 Expir96 Sept. 16 2007 10 #2104266 ' Notary Public COMMONWEALTH OF PENNSYLVANIA ) :SS. COUNTY OF CUMBERLAND ) On the llP-I!>cray of Av>rr), 2006, before a Notary Public, personally appeared Simone McRae, known to me to b~son whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. C\'::'1,V "/, '-"...._~._'~(1'. "Yr::"'.....v ':".~..:'l~"; 5,,:,,'1,'" ~/;d211C'" W"')., C~}""':""I,~,.....,,....~.:1 'S''':''.~I Vy~"""~" . - l_:y.pire.s ~0.:l~. ~L!.. ~::..-.",(. ,.. ~ot~'Cf4n~ ".,p,""" '-0,,..,... ": 1\1._...... ,,~t F:\User FolderlFirm'Docs\Gendocs2006\3933-I.agreement.custody. wpd (") c ~ :g :;~( -;:':' . ~ ""::. c--, " f'..;> <::::> C::> c:r. :r. ::::... -< o .,., :r! m'ilJ -0 fTl ~j~ ?:> :n ~~ (') ,.,-- rPl o ~ ~ -< 0"\ -0 :3: o ,. ~ MAY 1 7 2006 1"'1 --- - ---"---.'--..-. -. .. ~---- -', .. "'""'- --.---.--.--..----..- I .. , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CRAIG M, LANGLEY, Plaintiff v. CNIL ACTION - LAW No, 06-1782 SIMONE MCRAE, Defendant IN CUSTODY ORDER OF COURT NOW, this J'~ay of May, 2006, upon consideration of the within Custody Agreement andstipulation, the terms of the Agreement and Stipulation are hereb , J. -<' 'iIIWr\T\SNN3d U"1lif",I'.', ','li 1-'r]''I.'n'' J )\1j J,,^,' '.. .. ~'''''''Y'l V s S : II W~ S I A Viol 900l AWIONOHlO:Jd 3H.l. :JO 3:Ji:JjQ-{j::J1I:J Q ~(' E I Y t: 0 \,~ ~ V I) ~ "In.; .1. ~ \"" . '- j 1/" J Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-1782 CIVIL TERM CRAIG M. LANGLEY, v. CIVIL ACTION - LAW SIMONE MCRAE, IN CUSTODY Defendant ELlN UISH JURISDICTION AND NOW, this ~ day of May, 2006, the parties, having reached an agreement which has been memorialized in a Stipulation and filed with this Court, the Conciliator hereby relinquishes jurisdiction of the above captioned matter. elissa Peel Greevy, Esquire Custody Conciliator '" :275502 (") ,...." 0 = c = .,., en :::: ~ ~ fi1 Ii -< F N ,".J ~ ~u \,~..,; 0"\ ,._'<'~ , -.,- '-"", ",-. ~ ~:>-;,I _Or" 1 , -U ;=~ ......n :31: ':..,Jr~ i-S rl~ (,,) ::=-, ':'-:j '> -< c.n ~