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HomeMy WebLinkAbout95-00853 ~ J ",' " ~ ~ ' ",. ,/~,. . - ; ,- , ", ',', ";', '~ t, , :" '. ^".' ....-...:~'.<.. , , ,:;-;-"_''--h . " ~.' I ~) 01 z .....; - ':V-' " . .,',' ,,,-,,;:t -';.- ,- '(e::~,.. ',;);~.;f:'::" Jorge EChevarria, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 94- CIVIL TERM Beverly Sheaffer, Defendant CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Jorge Echevarria, currently incarcerated at Cumberland County Prison, 1101 Claremont Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is Beverly Sheaffer, residing at 7073 Carlisle Pike, Lot 150, CarliSle, Cumberland County, PennSYlvania 17013. 3. The plaintiff seeks visitation of the fOllOWing child: ~ Present Residence AlYssa Marie 7073 Carlisle Pike Sheaffer Lot 150 Carlisle, PA 17013 The child was born out of wedlock. AIDl 1 1/2 years old The child is presently in the custody of Beverly Sheaffer, who resides at 7073 Carlisle Pike, Lot 150, Carlisle, Pennsylvania. During the child's lifetime, she has resided with the following persons and at the following addresses: HAmi Address Plaintiff/ defendant and Cory Simon (defendant's minor son) ~ 11/27/92 to 12/3/93 During the day at the plaintiff's residence: 2 W. Penn Street, #112 CarliSle, PA 17013 During the evening at the defendant's residence: 7073 Carlisle Pike, #150 CarliSle, PA 17013 Plaintiff Simon The and Cory 7073 Carlisle Pike, .160 Carlisle, PA 17013 mother of the child is Beverly Sheaffer, 12/3/93 to present currently residing at 7073 Carlisle Pike, Lot 160, Carlisle, Pennsylvania. She is single. The father of the child is Jorge Echevarria, currently incarcerated at Cumberland County Prison, 1101 Claremont Road, Carlisle, Cumberland County, Pennsylvania. He is single. 4. The relationship of plaintiff to the child is that of father. The plaintiff currently is incarcerated at Cumberland County Prison, 1101 Claremont Road, Carlisle, Cumberland County, Pennsylvania. 6. The relationship of defendant to the child is that of mother. The defendant currently resides with the following persons: Name Relationship Alyssa Marie Sheaffer Cory Simon Daughter Son 6. 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 another court. 7. The plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. e. 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. 9. The best interest and permanent welfare of the child will be served by granting the relief requested for reasons including that it is important for the child to maintain a relationship with her father who has consistently provided for her needs since her birth. See Exhibit "A", attached and incorporated by reference. 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, the plaintiff requests this Court to grant the plaintiff periods of visitation during his incarceration. Respectfully submitted, J(A IJ an Carey Attorney for Plain iff LEGAL SERVICES, INC. a Irvine Row Carlisle, PA 17013 (717) 243-9400 Jorge Echevarria, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 94- CUSTODY CIVIL TERM BeverlY Sheaffer, Defendant CQ~jiLA~BE~Mj:J'!I This Agreement is entered on this'~ day of v~ 1994, by the plaintiff, Jorge Echevarria, and the defendant, BeVerly Sheaffer. The plaintiff is represented by Joan Carey. of Legal Services, Inc.: the defendant is unrepresented but is aware of her right to have an attorney. The defendant. hereinafter referred to as the mother, and the plaintiff, hereinafter referred to as the father. agree to the entry of an Order providing for the following custody schedule for their child, Alyssa Maria Sheaffer: 1. The father will have visitation according to the following schedule while he is incarcerated in Cumberland County Prison: a. Contact visits every other Friday, from 7:00 p.m. to 7:45 p.m. Christee Bender, or another adult mutually agreed upon by the mother and father, will bring the child to and from the prison and stay with the child at all times while the child is visiting the father. b. If the mother and father cannot agree concerning who will bring the child to visit the father, the mother The above-named Plaintiff, Jorge Echevarria, verifies that the statements made in the above Petition are true and correct. Plaintiff understands that false statements herein are made sUbject to the penalties of 18 Pa. e.s. 64904, relating to unsworn falsification to authorities. Date: 7-7-7~ Plaintiff Jo .. ..- v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96- 853 CIVIL TERM IN CUSTODY JORGE ECHEVARRIA, Plaintiff BEVERLY SHEAFFER, Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Jorge Echevarria, Plaintiff, to proceed in forma oauoeris. I, Joan Carey, attorney for the party proceeding in forma oauoeris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. an Carey Attorney for Plai iff LEGAL SERVICES, INC. a Irvine Row Carlisle, PA 17013 (717) 243-9400 / " JORGE ECHEVARRIA, plaintiff IN THE COURT OF COMMON PLEAS OF v. CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94- CIVIL TERM BEVERLY SHEAFFER, Defendant CUSTODY AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am the plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. Address: Joroe Echecarria. BB4736 State Correctional Inst. (a) Name: Dallas. PA 18612 Social Security Number: 200-60-1896 (b) If you are presently employed, state Employer: Address: N/A Salary or wages per month: Type of work: If you are presently unemployed, state Date of last employment: Salary or wages per month: Type of work: (c) Other income within the past twelve months Business or profession: 0 Other self-employment: 0 Interest: 0 Dividends: 0 Pension and annuities: 0 Social security benefits: 0 Support payments: 0 Disability payments: 0 Unemployment compensation and supplemental benefits: 0 Workman's cOlnpensation: 0 Public Assistance: 6 monts received S524.00/month other: 6 months received food stamos SlOO.OO/month (d) Other contributions to household support (Wife) (Husband) Name: N/A If your (husband) (wife) is employed, state Employer: Salary or wages per month: Type of work: Contributions from children: (e) Property owned Cash: S30.00 Checking Account: Savings Account: o o Certificates of Deposit: 0 Real Estate (including home): N/A Motor vehicle: Make Imcounded Year Cost Amount owed stocks; bonds: o o other: (f) Debts and obligations Mortgage: Rent: N/A N/A Loans: Personal loan $1000.00 balance Monthly Expenses: Incarcerated. no excenses (g) Persons dependent upon you for support (Wife) (Husband) Name: N/A Children, if any: Name: Age: 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit are true and correct. 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: :J. - / /- '1f:;- , ~J . ;, lNtIJ..IJA, Jorife ~h varria, Plaintiff J a.n J ~ :>-,.. ""... ~ :c ..s...: a- hJ~:::t'" co ,,-::=C;-:Z N t..l:J~< t...XO;'- <::.rl<-X-' B ....,:~-<i.~ UJu..&;~ <-C ::'..h.UJ;:':: .0 ...........,i:J ~Xi\.. n) - ;.;> 111 ... :5'" L.-..