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HomeMy WebLinkAbout02-4290MARIA P. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIRE Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Plaintiff JEREMY A. HARING, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. HOLLY SEYBOLD, CIVIL ACTION -LAW Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Jeremy A. Harding, residing at 620 B Street, Enola, Pennsylvania. 2. Defendant is Holly Seybold, residing at 268 Spruce Street, Etters, Pennsylvania. 3. Plaintiff seeks custody of the following child: Name Present Address Age Jeremy Haring, Jr. 620 B Street Enola, PA 6 years old 4. The child was born out of wedlock. The child is presently in the custody of Plaintiff who resides at 620 B Street, Enola, Pennsylvania. 5. During the past five (5) years, the child has resided with the following persons at the following address(es): Name Address Dates Jeremy Haring 231 W. Columbia Ave. 8/97 to 7/99 Enola, PA Jeremy Haring 6108 Knisley Street 8/99 to 12/00 Harrisburg, PA Jeremy Haring 6108 Knisley Street 1/01 to 7/02 Allison Haring Harrisburg, PA Jeremy Haring 620 B Street 8/02 to Present Allison Haring Enola PA 6. The mother of the child is currently residing at 268 Spruce Street, Etters, Pennsylvania. She is single. 7. The father of the child is currently residing at 620 B Street, Enola, Pennsylvania. He is married. 8. The relationship of Plaintiff to the child is that of father. Plaintiff currently resides with the following persons: Name Relationship Allison Haring Wife Sandra Marie Connare Mother Edward J. Connare, Jr. Step-father 9. The relationship of Defendant to the child is that of mother. Defendant currently resides with the following persons: Name Relationship Betty Seybold Grandmother 10. Plaintiff has not participated as a parry or a witness, or in any other capacity in other litigation concerning the custody of the child in this or any other Court. 11. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 12. 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. 13. The best interest and permanent welfare of the child will be served by granting the relief requested. 14. 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, Plaintiff requests the Court to grant him primary physical custody and sole legal custody of the child. Respectfully Submitted: MARIA P. COGNETTI & ASSOCIATES Date: September 4, 2002 By: MARIA . COG TI, ESQUIRE Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff VERIFICATION I, Jeremy A. Haring, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. DATE: 7/y/Cz G )t--y rem A. Har eg CERTIFICATE OF SERVICE I, Maria P. Cognetti, Esquire, Attorney for Plaintiff herein, do hereby certify that on this date I served the foregoing Custody Complaint by depositing a true and exact copy thereof in the United States mail, first class, postage prepaid, addressed as follows: Holly Seybold c/o Chelsea Settlement 3800 Market Street Camp Hill, PA 17011 Maria P. ogn ti squire Sup. Ct. I.D. #27914 210 Grandview Avenue Ste. 102 Camp Hill, PA 17011 (717) 909-4060 Dated: September 4, 2002 /`D 1 i _ tJ l f fi JEREMY A. HARING IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 02-4290 CIVIL ACTION LAW HOLLY SEYBOLD IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, September 13, 2002 upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. _,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, October 03, 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: /s/ facqueline AL Vemey, Esq. 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 I tp?Ino e'1 :u 4,'d 9 1 ddS Z9 OCT 2 9 ?007r JEREMY A. HARING, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2002-4290 CIVIL TERM HOLLY SEYBOLD, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 29th day of October, 2002, the Conciliator being notified that the parties have reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, L acq line M. Vern ey, Esquire, Cus dy Conciliator >- j= v i .=r Cr w MARIA p. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIRE AttomeY I.D• No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 4060 Telephone No. (717) 909 Attome s for Plaintiff G JEREMY A. HARIN Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND CONY' PENNS` LV ANIA NO. 02-4290 V. CIVIL ACTION -LAW HOLLY SEYBOLD, : Defendant IN CUSTODY STIPULATION FOR CUSTODY B r , 2002, the parties, having the best AND NOW, this 5_ day of rest of their minor child, Jeremy Haring, Jr., born September 4, 1996, in mind, do hereby interest agree and stipulate as follows: custody of the 1 _ The parties hereby agree that Father shall have primary physical minor child, Jeremy Haring, Jr. 2 The parties agree that Mother shall have supervised visitation Tuesday and every week. Thursday nights at Father's house from 5:30 PM until 7:30 PM, Mother shall have additional periods of supervised visitation at Father's house, 3 • Easter, from 5:30 PM until 7:30 PM on the following holidays: Thanksgiving, Christmas Day, child's Day and on the minor birthday. • Mother shall provide her own tran sportation to the supervised visitation. 4 dental, religious or schoc 5. Each parent shall be provided access to all the medical, records of the minor child, the residence of the child and any other information reasonably necessary for effective parenting or as otherwise provided in this Custody Stipulation. 6• Mother will have reasonable telephone contact with the minor child. However, no telephone calls shall be made after 8:00 PM. 7. Each party shall inform the other of any change in their address, telephone number, or employment situation as soon as practical after the change becomes known to the party. 8. The parties agree that this Stipulation shall be entered as an Order of Court, and, as such, shall have the full and same force and effect as if the matter had been tried and decided. 9. This Stipulation and Order of Court shall replace and supersede any existing custody arrangements between the parties. 10. The Stipulation and Order of Court shall continue in full force and effect until further Order of Court and/or amended Agreement in writing between the parties. 11. The parties hereby waive their right to present this Stipulation in open Court or to have their case heard by the Court at this time. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals on the date and year first above written. U Witness mess Cl Je my . Haring 1 r? -- 5= 7-; f,_ . _ _ r ?; M JEREMY A. HARING, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 02-4290 HOLLY SEYBOLD, CIVIL ACTION -LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, to wit, this day of _ Afig4-# v 2002, it is hereby ORDERED and DECREED that the attached Stipulation for Custody, dated Ac_(&4t,dS i 2002, is made an Order of this Court and said Stipulation is adopted in its entirety and incorporated herein as an Order of Court. BY THE COURT: a l pC? \ ? nv ? arY?' )'SCI C e ?l 1 J?j JEREMY A. HARING, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 02-4290 HOLLY SEYBOLD, CIVIL ACTION -LAW Defendant IN CUSTODY TO THE PROTHONOTARY OF CUMBERLAND COUNTY: ENTRY OF APPEARANCE AND NOW, this day of November, 2006, comes the undersigned counsel, Joseph H. Hitchings, Esquire and respectfully requests that his appearance be entered on behalf of the Defendant, Holly Seybold, in the above-captioned case. Respectfully submitted, MCSHANE & HITCHINGS, LLC eph L. Hitchings, Esquilp-1, Attorney ID No.: 65551 4807 Jonestown Road, Suite 14$' Harrisburg, Pennsylvania 17109 (717) 657-3900 Attorney for Defendant x . CERTIFICATE OF SERVICE I, Joseph L. Hitchings, Esquire, hereby certify that the following service has been JEREMY A. HARING, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 02-4290 HOLLY SEYBOLD, CIVIL ACTION -LAW Defendant IN CUSTODY TO THE PROTHONOTARY OF CUMBERLAND COUNTY: completed in compliance with the Rules of Civil Procedure: Via first class mail Maria P. Cognetti, Esquire 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Respectfully submitted, MCSHANE & HITCHINGS, LLC Jo h L. Hitc ngs, Esquire torney ID No.: 65551 4807 Jonestown Road, Suite 148 Harrisburg, Pennsylvania 17109 (717) 657-3900 Attorney for Defendant _g- 1` ? ,3 i JEREMY A. HARING, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 02-4290 HOLLY P. SEYBOLD, CIVIL ACTION -LAW Defendant IN CUSTODY PETITION TO MODIFY CUSTODY AND NOW, this ?O 0" day of June 2007, comes the Defendant/Petitioner, Holly Seybold, by and through her undersigned attorneys, McShane & Hitchings, LLC, and Joseph L. Hitchings, Esquire, and avers in support of her Petition to Modify Custody as follows: 1. The Defendant is Holly Seybold, an adult individual residing at 64 Westwood Court, Enola, Cumberland County, Pennsylvania 17025. 2. The Plaintiff is Jeremy A. Haring, an adult individual residing at 627 Brisbane Lane, Enola, Cumberland County, Pennsylvania 17025. 3. Defendant seeks to modify the current custody order to receive unsupervised, partial physical custody of the following child: Name: Jeremy A. Haring, Jr. Present Residence: 650 B Street, Enola, PA 17025 Date of Birth: September 4, 1996 Age: 10 years old 4. The child was born out of wedlock. 5. The child is presently in the custody of the Plaintiff who resides with the child at 627 Brisbain Lane, Enola, Cumberland, PA 17025. Defendant has periods of partial, supervised custody. 6. The current custody Order was entered on November 14, 2002, pursuant to a Stipulation between the parties, granting primary physical custody to father/Plaintiff with mother/Defendant having periods of supervised visits. A true and correct copy of the current Court Order and Stipulation are attached hereto as Exhibit "A". 7. Defendant has no information of a custody proceeding concerning the child pending in any other Court of this Commonwealth or any other state. 8. The best interest and permanent welfare of the child will be served by granting the relief requested and granting the mother/Defendant a set schedule of partial physical custody without supervised visits with her son. 9. Defendant respectfully requests that this Petition be forwarded to the Court for the scheduling of a Custody Conference. WHEREFORE, Defendant, Holly P. Seybold, respectfully requests that This Honorable Court grant her unsupervised partial physical custody of her minor son, Jeremy A. Haring, Jr. Respectfully Submitted, Date: Z -a ( , Q -7 MCSHANE & HITCHINGS, LLC By: Q \ pkn?- - J eph L. Hitchings, Es?i Attorney for Defendant/Peti ner Supreme Court ID# 65551 4807 Jonestown Road Suite 148 Harrisburg, Pennsylvania 17109 Telephone: (717) 657-3900 Fax: (717) 657-2060 1_ VERIFICATION I, Holly P. Seybold, verify that the statements made in this Petition to ModfY Custody are true and correct to the best of my knowledge information and belief and that I am authorized to make this Verification. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. (4 IC-f I /n I Dat JEREMY A. HARING, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 02-4290 HOLLY P. SEYBOLD, CIVIL ACTION -LAW Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Joseph L. Hitchings, Esquire of McShane & Hitchings, LLC, Attorney for the Defendant, Holly Seybold, do hereby certify that I served a true and correct copy of the attached Petition to Modify Custody, by United States Mail, First Class, postage prepaid and by certified mail, restricted delivery upon the party listed below: Maria P. Cognetti, Esquire 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Respectfully Submitted, MCSHANE & HITCHINGS, LLC Date: / _ L i -Q] By: seph L. i chings, uire Attorney for Defendan titioner Supreme Court ID# 65551 4807 Jonestown Road Suite 148 Harrisburg, Pennsylvania 17109 Telephone: (717) 657-3900 Fax: (717) 657-2060 y j } i _ R 1 W 0 o c .. ^\n W . JEREMY A. HARING IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 02-4290 CIVIL ACTION LAW HOLLYSEYBOLD IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, August 03, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on _ _Thursday, August 23, 2007 at 10:30 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: /s/ ac ueline M. Verne Es . 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 V i,;NVA?A,?N NO d. 8', : i i wv 9- onv Looz 48VIUNvHiO d 'Nl J0 30U? `--QDIA SEP 18 2007 13Ay k JEREMY A. HARING, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 20024290 CIVIL ACTION - LAW HOLLY SEYBOLD, Defendant IN CUSTODY ORDER OF COURT AND NOW, this q' day of _"l_.4.- , 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated November 14, 2002 is hereby vacated. 2. The Mother, Holly Seybold and the Father, Jeremy A. Haring, shall have shared legal custody of Jeremy A. Haring, Jr., born, September 4, 1996. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 3. Father shall have primary physical custody of the child. 4. Mother shall have the following periods of partial physical custody (unsupervised) on a phased in schedule: A. For two months beginning Tuesday, September 18, 2007, every Tuesday and Thursday, from 5:30 p.m. to 7:30 p.m. and alternating kNnoo, S 0 I I Wy a dS A'L i4 al© :Iol Saturdays, beginning September 29, 2007, from 10:00 a.m. to 2:00 p.m. B. For the next two months, every Tuesday and Thursday from 5:30 p.m. to 7:30 p.m. and alternating Saturdays from 10:00 a.m. to 6:00 p.m. C. For the next two months, every Tuesday and Thursday from 5:30 p.m. to 7:30 p.m. and alternating weekends, Saturdays and Sundays, from 10:00 a.m. to 6:00 p.m. D. For the next two months, every Tuesday and Thursday from 5:30 p.m. to 7:30 p.m. and alternating Saturdays overnight from 10:00 a.m. to Sunday at 6:00 p.m. E. Continuing thereafter every Tuesday from 5:30 p.m. to 7:30 p.m. and alternating weekends from Friday at 5:30 p.m. to Sunday at 6:00 p.m. 5. Holidays: A. Mother shall have four hours of physical custody of the child during the Thanksgiving holiday as agreed by the parties. B. Mother shall have six hours of physical custody of the child on December 26, 2007 at times agreed by the parties. C. Mother shall have physical custody of the child on Easter Saturday from 10:00 a.m. to 6:00 p.m. Father shall have physical custody of the child on Easter. D. Mother shall have physical custody of the child on Mother's Day from 10:00 a.m. to 6:00 p.m. and Father shall have physical custody of the child on Father's day from 10:00 a.m. to 6:00 p.m. 6. Transportation shall be shared such that the receiving party shall transport. 7. 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. ccJoseph L. Hitchings, Esquire, Counsel for Mother ? Aaria P. Cognetti, Esquire, Counsel for Father > (2,opj'es envl6c 1-?q JEREMY A. HARING, Plaintiff V. HOLLY SEYBOLD, Defendant PRIOR JUDGE: Kevin A. Hess, J. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 200242" 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 concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Jeremy A. Haring, Jr. September 4, 1996 Father 2. A Conciliation Conference was held in this matter on September 18, 2007, with the following in attendance: The Mother, Holly Seybold, with her counsel, Joseph L. Hitchings, Esquire and the Father, Jeremy A. Haring, with his counsel, Maria P. Cognetti, Esquire. 3. A prior Order of Court was entered by the Honorable Kevin A. Hess dated November 14, 2002, providing for shared legal custody, Father having primary physical custody and Mother having periods of supervised visitation. 4. The parties agreed to an Order in the form as attached. -?i 7 . V Date acq line M. Verney, Esquire Custody Conciliator