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Home My WebLink About02-2849RALPH F. HEPFER, JR., Plaintiff JESSICA LEACH, Defendant :IN THE COURT OF COMMON PLEAS OF : :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 02- o~q~ CIVILTERM : : :CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Ralph F. Hepfer, Jr., residing at 242 Larch Avenue, Chambersburg, Franklin County, Pennsylvania. 2. The defendant is Jessica Leach, believed to be residing at 523 Hamilton Street, Carlisle, Cumberland County, Pennsylvania. 3. The plaintiff seeks custody of the following child: Name Present Residence Age Andrew F. Leach 523 Hamilton Street 4; DOB 5/1/98 Carlisle, PA The child was bom out of wedlock. The child is presently in the custody of Jessica Leach, who is believed to be residing at 523 Hamilton Street, Carlisle, Cumberland County, Pennsylvania. During the past five years, the child has resided with the following persons and at the following addresses: Name Jessica Leach, Marlin Leach, Elizabeth Leach Jessiea Leach Address 523 Hamilton Street Carlisle, PA Hamilton Street Carlisle, PA Date approx. 3/02-present approx. 3/01-3/02 Jessica Leach, Marlin Leach, Elizabeth Leach Ralph Hepfer, Jessica Leach Marlin Leach, Liz Leach 523 Hamilton Street Carlisle, PA 523 Hamilton Street Carlisle, PA approx. 4/00-3/01 approx. 5/98- 4/00 The mother of the child is Jessica Leach, currently residing at 523 Hamilton Street, Carlisle, Pennsylvania. She is single. The father of the child is Ralph F. Hepfer, Jr., currently residing at 242 Larch Avenue, Chambersburg, Pennsylvania. He is single. 4. The relationship ofplaintiffto the children is that of father. The plaintiff currently is residing at 242 Larch Avenue, Chambersburg, Pennsylvania. 5. The relationship of defendant to the children is that of mother. The defendant is believed to be currently residing with the following persons: Name Marlin Leach Elizabeth Leach Relationship Defendant's father Defendant's mother 6. The plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 7. The plaintiff has no information ora eustodyproceeding concerning the children pending in a court of this Commonwealth. 8. The plaintiffdoes not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation fights with respect to the children. 9. The best interest and permanent welfare of the children will be served by granting the relief requested for reasons including the following: a. The plaintiff/father has expressed an interest in the care and upbringing of the child and, recently, has not been allowed to see the child. b. The father can provide a stable environment for the child. c. It is in the best interest of the child to have a nurturing relationship with both father and mother. 10. Each Parent whose parental rights to the children have not been terminated and, to the best of the plaintiff's knowledge, the person who has physical custody of the children have been named as parties to this action. WHEREFORE, the plaintiff requests this Court to grant shared legal custody and partial physical custody of the child. Respectfully submitted, Dat~d/Lopez, Attorney fo~Plaj~iff MIDPENN LEGAL SER~I(~S 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 VERIFICATION The above-named Plaintiff, Ralph F. Hepfer, verifies that the statements made in the above Complaint for Custody are tree and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities. Date: RALPH F. HEPFER, JR., Plaintiff V. JESSICA LEACH, Defendant :IN THE COURT OF :CUMBERLAND COI : :No. 02-_~4ff CIV]I, .' : .. :CUSTODY PRAECIPE TO PROCEED IN FORMA PAUl To the Prothonotary: Kindly allow, Ralph F. Hepfer, Plaintiff, to proceed in forma I, David Lopez, attorney for the party proceeding in forma paup~ party is unable to pay the costs and that I am providing free legal servi. DMMON PLEAS OF NTY, PENNSYLVANIA ER_IS auperis. ;tis, certify that I believe the :es to the party. David Lopez -Iff t'~ Attorney for Ralph F;~e~e~r ~ k~J~.- MIDPENN LEGAL SER/'ICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 RALPH F. HEPFER, JR. : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. ! : 02-2849 CIVIL ACTION ILAW : JESSICA LEACH DEFENDANT IN CUSTODY : ORDER OF COURT AND NOW, Friday, June 14, 2002 , upon consideratim it is hereby directed that parties and their respective counsel appear before Hubert at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, July for a Pre-Hearing Custody Conference. At such conference, an effort will be made t¢ if this cannot be accomplished, to define and narrow the issues to be heard by the cou order. All children age five or older may also be present at the conference. Failure t( provide grounds for entry ora temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protec Special Relief orders, and Custody orders to the conciliator 48 hours prior to scI~ FOR THE COURT, of the attached Complaint, L Gilroy, Esq. , the conciliator, 2, 2002 at 9:30 AM resolve the issues in dispute; or rt, and to enter into a temporary appear at the conference may tion from Abuse orders, eduled hearing. By: /s/ Hubert X. Gilroy, Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by la~ with Disabilites Act of 1990. For information about accessible facilities and reas available to disabled individuals having business before the court, please contact must be made at least 72 hours prior to any hearing or business before the court. scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT O1~ HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHOI FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 to comply with the Americans >nable accommodations ~ur office. All arrangements You must attend the 'CE. IF YOU DO NOT ~E THE OFFICE SET ¥1NVA'I],CSNN3d ~lS :~I ~t L 1 ~fll' ~0 AblVLONO?-,uiO~?, :7,-LL .40 RALPH F. HEPFER, JR. Plaintiff VJ JESSICA LEACH Defendant : IN THE COURT OF COMMON PLEAS OF : : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-2849 TERM : : PROTECTION FROM ABUSE AFFIDAVIT OF SERVICE I, David Lopez, Attorney for Plaintiff, do hereby certify that on June 21, 2002, I served by · certified mail restricted delivery upon Defendant, Jessiea Leach, a certified copy of the above- captioned Order of Court for a custody conciliation conference, to her residence, 523 Hamilton Street, Carlisle, PA 17013, Cumberland County, Penngylvania. See Exhibit A. l~avid A. Lopez Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 m ~C°~4 ~ ~ items 1, 2, and 3. AJeo compiMe I"l C.O.D. 2. Article Number ~ ~ ~ ~ ~ ~1-M~4 EXHIBIT A RALPH F. HEPFER, JR., Plaintiff V JESSICA LEACH, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ; : CIVIL ACTION - LAW : : NO. 02 - 2849 CIVIL : IN CUSTODY COURTO~ER AND NOW, this '/'' day of December, 2003, this case coming before the conciliator on the request of the Court Administrator to address the outstanding referral for a conciliator and the conciliator being advised that the parties had previously resolved the matter without the need of further involvement of the conciliator, the conciliator relinquishes jurisdiction. BY THE COURT, Hubert X. ~iroy C ust od/y/~f~nciliator