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HomeMy WebLinkAbout02-3189SHARIF O. HUMPHREY, Petitioner TYESHA N. MOSLEY, Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO.-- ; : CIVIL ACTION - CUSTODY COMPLAINT FOR CUSTODY The Petitioner is Sharif O. Humphrey, a citizen of Permsylvania, residing at 113 Reilly Street, Harrisburg, Dauphin County Pennsylvania, 17102. o The Respondent is Tyesha N. Mosley, a citizen of Pennsylvania, residing at 607 Cumberland Point Circle, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Petitioner seeks custody of the following children: Name Present Residence Age Tyara S. Mosley 607 Cumberland Point Circle Mechanicsburg, PA 17055 4 (D.O.B. 12/30/97) TyricN. Mosley 607 Cumberland Point Circle Mechanicsburg, PA 17055 4 (D.O.B. 12/30/97) The children are presently in the custody of Respondent, Tyesha N. Mosley, who resides at 607 Cumberland Point Circle, Mechanicsburg, Cumberland County, Pennsylvania, 17055. From the date of birth, the children have resided with the following persons and at the following addresses: From T__~o With Whom Address 12/30/97 7/98 Respondent, Andre Hemandez Respondent's son Orchard Apartments Camp Hill, Pennsylvania 7/98 present Respondent, Petitioner (1/99-9/01) 607 Cumberland Point Circle Andre Hemandez ( 12/01-present) Mechanicsburg, Pennsylvania The children were bom out of wedlock. The mother of the child is Tyesha N. Mosley, residing at 607 Cumberland Point Circle, Mechanic sburg, Cumberland County, Pennsylvania, 17055. She is not married. The father of the child is Sharif O. Humphrey, residing at 113 Reilly Street, Harrisburg, Dauphin County Pennsylvania, 17102. He is not married. o The relationship of Petitioner to the child is that of father. The Petitioner currently resides with Judy Philippe and Malyra Philippe. The relationship of Respondent to the child is that of mother. The Respondent currently resides with children and Andre Hemandez. Respondent 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. Petitioner has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Petitioner 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 best interest and permanent welfare of the child will be served by granting the relief requested because he offers the child a more stable and secure environment. 10. 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 as parties to this action. WHEREFORE, Petitioner requests the Court to grant him custody of the child. DATE: 1 I01 North Front Street Harrisburg, Pa 17102 ID # 10625 (717) 234-4583 SHARIF O. HUMPHREY, Petitioner V. TYESHA N. MOSLEY, Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. : : CIVIL ACTION - CUSTODY ; VERIFICATION I, SHARIF O. HUMPHREY, hereby verify that the information contained in the foregoing Complaint is true and correct to the best of our knowledge, information and belief. I also understand that false statements made herein are subject to the penalties of 18 Pa. C.S. § 4904, relating to sworn falsification to authorities. DATE: VII [OZ. SHARIF O. HUMPHREY, Petitioner TYESHA N. MOSLEY, Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. : : CIVIL ACTION - CUSTODY : CERTIFICATE OF SERVICE AND NOW, this o,'~{}d day of ('Xll ~ .t_a_ ,2002, I, Lawrence J. Rosen, for the Law Firm of Krevsky & Rosen, P.C., attorneys for Petitioner SHARIF O. HUMPHREY, hereby certify that I have this day served a copy of the Complaint via First Class U.S. Mail, Certified Mail on the following: TYESHA N. MOSLEY 607 CUMBERLAND POINT CIRCLE MECHANICSBURG, PA 17055 ence J. Rosen North Front Street Harrisburg, PA 17102 (717) 234-4583 SHARIF O. HUMPHREY PLAINTIFF V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-3189 CIVIL ACTION LAW TYESHA N. MOSLEY DEFENDANT : IN CUSTODY ORDER OF COURT AND NOW, Wednesday, July 10, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West ~gain Street, Mechanicsburg, PA 17055 on Wednesday, Ausust 07, 2002 at 8:30 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: Is/ Dawn S Sunday. Es~,,,r,, 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 SHARIF O. HUMPHREY, Plaintiff VS. TYESHA N. MOSLEY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : 02-3189 CIVIL ACTION LAW : : IN CUSTODY ORDER OF COURT AND NOW, this ~ day of ,2002, upon consideration of the attached Custody Conciliation Report, it ' 'uerea and directed as follows: 1. The Mother, Tyesha N. Mosley, shall have primary physical and legal custody of Tyara S. Mosley and Tyric N. Mosley, both bom December 30, 1997. 2. The Father, Sharif O. Humphrey, shall have partial physical custody of the Children on alternating Saturdays from 12:00 noon until 7:00 p.m., beginning Saturday, November 23, 2002. In addition, during weeks following Saturdays when the Mother has custody of the Children, the Father shall have custody of the Children on Mondays from between 4:30 and 5:00 p.m. until 7:30 p.m., beginning Monday, November 18, 2002. 3. The parties shall share or alternate having custody of the Children on holidays as follows: A. CHRISTMAS: In every year, the Father shall have custody of the Children on Christmas Day from between 4:30 and 5:00 p.m. until 8:00 p.m. B. THANKSGIVING: In even numbered years, the Father shall have custody of the Children on Thanksgiving Day from between 4:30 and 5:00 p.m. until 8:00 p.m. and the Mother shall have custody on Thanksgiving in odd numbered years. C. EASTER: In even numbered years, the Father shall have custody of the Children on Easter Sunday from 10:00 a.m. until 8:00 p.m. and the Mother shall have custody of the Children on Easter in odd numbered years. D. MOTHER'S DAY/FATHER'S DAY: In every year, the Mother shall have custody of the Children on Mother's Day and the Father shall have custody of the Children on Father's Day from 10:00 a.m. until 8:00 p.m. E. JULY 4T}~: In odd numbered years, the Father shall have custody of the Children on July 4th from between 4:30 and 5:00 p.m. until 8:00 p.m. (if it is a work day) and from 10:00 a.m. until 8:00 p.m. (if July 4th falls on a day when the Father has off work). The Mother shall have custody of the Children on July 4th in even numbered years. F. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 4. Unless otherwise agreed between the parties, all exchanges of custody shall take place at the comer of Rocky Road and Wilson Drive in Mechanicsburg. 5. On work days, the Father's periods of custody shall begin as soon as the Father can pick up the Children after work between 4:30 p.m. and 5:00 p.m. and the Father shall contact the Mother by telephone to notify her when he is leaving work to pick up the Children. 6. Each party shall ensure that the other party has his or her current address and telephone numbers on an ongoing basis. 7. Neither party shall do or say anything which may estrange the Children from the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development of the Children's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Children comply with this provision. 8 This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent In the absence of mutual consent, the terms of this Order shall control. co(. David J. Schertz, Esquire - Counsel for Father / Joan Carey, Esquire - Counsel for Mother SHARIF O. HUMPHREY, Plaintiff VS. TYESHA N. MOSLEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-3189 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT, IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information conceming the Children who are the subjects of this litigation is as follows: NAME Tyara S. Mosley Tyric N. Mosley DATE OF BIRTH December 30, 1997 December 30, 1997 CURRENTLY IN CUSTODY OF Mother Mother 2. A Conciliation Conference was held on November 14,, 2002, with the following individuals in attendance: The Father, Sharif O. Humphrey, with his counsel, David J. Schertz, Esquire, and the Mother, Tyesha N. Mosley, with her counsel, Joan Carey, Esquire:. 3. The parties agreed to entry of an Order in the form as altached. Dawn S. Sunday, Esquire Date Custody Conciliator