HomeMy WebLinkAbout06-6384
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
v.
) CIVIL ACTION--LA W
)
)
) DOCKET NO.
)
) IN CUSTODY
)
Barbara Hegedus,
Plaintiff
Sandra Haller,
Defendant
JOINT EMERGENCY COMPLAINT FOR CUSTODY
594/
AND NOW, come the Plaintiff, B~egedUS, hereinafter referred to as
Grandmother, and Defendant, Sandra , hereinafter referred to as "Mother",
pursuant to Rule 1915.7 of the Pa. Rules of Civil Procedure, who respectfully represent:
1. Plaintiff is Maternal Grandmother, Barbara Hegedus, who currently resides at 701
Ohio Ave, Lemoyne, PA 17043.
2. Defendant is Mother, Sandra Haller, who currently resides at 1440 Potato Valley
Road, Harrisburg, P A, and is the natural parent of Tyler Hegedus, born March 3, 1992.
3. Plaintiff seeks custody of Tyler Hegedus, born March 3, 1992.
a) The child was born out of wedlock.
b) The child is presently in the LEGAL custody of Mother, but in the PHYSICAL
custody of Maternal Grandmother since September 22,2006.
c) During the past five years, until September 22, 2006, the child has resided with
his Mother Sandra Haller at 1440 Potato Valley Road, Harrisburg, P A, where she
currently resides. Mother is separated from her husband Larry Haller.
d) The father of the child is Dennis Devine, who mailing address is 28 Maple
Ave., Camp Hill, Pa., but whose current location is unknown. He is married to
Shannon Devine.
4. The relationship of Plaintiff to the child is that of Maternal Grandmother. Plaintiff
currently resides with her husband, Robert Hegedus and the minor child Tyler.
5. The relationship of Defendant to the child is that of Mother.
.
6. 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 another court.
Plaintiff has no information of a custody proceeding concerning the child pending in a
court of this Commonwealth or any other state.
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. The child's father, Dennis Devine, has not had any contact whatsoever with the
minor child for three years.
7. The best interest and permanent welfare of the child will be served by granting the
relief requested because:
On 01f: 31 ~ ,2006 the parties entered into an agreement regarding
custody of Tyler egedus, a mmor chIld, which IS attached hereto and
incorporated herein as Exhibit A.
The terms of that agreement do not affect, disrupt, or modify any partial custody
rights that the child's Father may have.
Maternal Grandmother has been attempting to enroll the minor in West Shore
School District, where she resides, but after five weeks of coordination, during
which time the minor has been out of school, the administration has now
refused to enroll him without a court order.
8. Each parent whose parental rights to the child have not been terminated and the person
who has physical custody of the child have been named in this action.
WHEREFORE, the PLAINTIFF and DEFENDANT JOINTLY pray this Court to
approve the foregoing agreement WITHOUT HEARING and make it an order of Court.
Respectfully submitted,
~~~
aintiff ," 7 / 7.- 7 ~ / - 3 tj ~ I
/ - ~ 1"1
':/ t^ ..v'l1M-./).; . <tJULtI'
Defendant 7 I~) - 517 -- 5 ~ 1/
Dated:
o-cA. ~ Ij ~660
I verify that the statements made in this Complaint are true and correct. I understand that false statements
here~t to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn ~~ification to authorities.
~ ~~ ~~~.&~
lamtlff Defendant
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNlY
PENNSYLVANIA
Barbara Hegedus,
Plaintiff
v.
) CML ACTION--LA W
)
)
) DOCKET NO.
)
) IN CUSTODY
)
Sandra Haller,
Defendant
ORDER
You, Sandra Haller, Defendant, have been sued in court to obtain custody of the minor child Tyler
Hegedus.
You are ordered to appear in person at the Cumberland County Courthouse, 1 Courthouse
Square, ROOM ,Carlisle, PA 17013
on -----------------------------------, at -----------------------, ---- .M., for
[] a conciliation or mediation conference.
[] a pretrial conference.
[] a hearing before the court.
If you fail to appear as provided by this order, an order for custody, partial custody or visitation may be
entered against you or the court may issue a warrant for your arrest.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD
TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION
ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGffiLE PERSONS AT A
REDUCED FEE OR NO FEE.
MIDPENN LEGAL SERVICES
401 E. Louther Street, Suite 103
Carlisle, PA 17013
BY THE COURT:
Date: --------------------
J.
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.
()
NOV 0 1 2006 fli
D.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
v.
) CIVIL ACTION--LA W
)
~ DOCKET NO. D' - ~3 r<l- eXit I
)
) IN CUSTODY
)
Barbara Hegedus,
Plaintiff
Sandra Haller,
Defendant
ORDER
AND NOW, this 1 S-{ day of tJ()'Jtw..\ot( , 2006, the foregoing
Stipulation of the parties as to Custody is made an Order of this Court.
By the Court:
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