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Home My WebLink About95-04777 ...........'- -- ,- 081 17 mt~ JOSEPH L. WELLS, . IN THE COURT OF CXXolMOO PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . CIVIL ACTION - LAW . vs. . . . NO. 95-4777 . SANDRA D. HEAGY, . . Defendant . CUSTODY/VISITATION . (lU)I!R (R (X)(Rr AND NOW, this 16th day of October, 1995, the Conciliator, being advised by Plaintiff's counsel that all custody issues have been resolved by agreement, hereby relinquishes jurisdiction in this case. d2~Ju.' . Dawn S. Sunday, ~e JOSEPH L. WELLS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, . : CIVIL ACTION - LAW : CUSTODYNISITATION ~ NO, 9SJ{7'2'IVIL TERM SANDRA D. HEAGY, Defendant AND NOW, ORDER OF COURT S' P(J 1-. I;), , 19 ~ upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before 0...."" f\ ) _ S.~~""I G" , the conciliator, at 6'1 W - M..:" 5} _ , M~ehc..'''<'5~~!Onthe !Olh-.dayof OC+"lJp.r ,19~-,at /0:32) o'clock, /l,m" 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 temporal}' order, All children age five or older may also be present at the conference, Failure to appear at tbe conference may provide grounds for entl}' of a temporal}' or permanent order, FOR THE COURT: BY:~"'~ ~d~~~~/ ustody Concihator ~ 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, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Office of the Court Administrator Cumberland County Court I-louse. Fourth Floor Carlisle, PA 17013 (717) 240-6200 ,,' JOSEPH L. WELLS, Plaintiff v, : IN TIlE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACfION - LAW : CUSTODY/VISITATION SANDRA 0, HEAGY, Defendant . , : NO, 95- CIVIL TERM COMPLAINT FOR CUSTODY 1. The Plaintiff is JOSEPH L. WELLS, residing at 705 Erford Road, Camp Hill, Cumberland County, Pennsylvania, 1701 I. Plaintiff is temporarily living with his sister in Dover, Pennsylvania, and has been since Saturday, August 26, 1995. 2, The Defendant is SANDRA 0, HEAGY, residing at 705 Erford Road, Camp Hill, Cumberland County, Pennsylvania, 17011, 3, Plaintiff seeks custody of the following child: NAME Zachary J, Wells RESIDENCE DOB 911191 AGE 705 Erford Road Camp Hill, PA 17011 4 Years The child was born out of wedlock, The children are presently technically in the custody of both Plaintiff and Defendant, however, Plaintiff is temporarily residing at the home of his sister, Julie Wells, in order to avoid confrontations with the Defendant which he believes to be detrimental to the child. During his life, the child has resided with the following persons and at the following address: NAME Joseph L. Wells Sandra 0, Heagy ADDRESS 705 Erford Road Camp Hill, PA 17011 DATES Birth to Present The mother of the child is Plaintiff, SANDRA D. HEAGY, currently residing at 705 Erford Road, Camp Hill, Pennsylvania, 1701 I. She is unmarried, The father of the child is Defendant, JOSEPH L. WELLS, currently residing at 705 Erford Road, Camp Hill, Pennsylvania, 17011, but temporarily living with his sister in Dover, Pennsylvania, He is unmarried. 4, The relationship of the Plaintiff to the child is that of Father, The Plaintiffs residence is as set forth above, 5, The relationship of the Defendant to the child is that of Mother, The Defendant's residence is as set forth above, 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, 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, 7, The best interest and permanent welfare of the child will be served by granting the relief requested for the following reasons: A. Plaintiff is best able to provide the care and nurture which the child needs for healthy development. B. A court order of custody and structured visitation is desired so that the Plaintiff and the child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion, C. Plaintiff is the sole owncr of the residence at 705 Erford Road and the child's daycare facility is very close thereto, Plaintiff desires to maintain the family household which has been established and the continued stability of the household is in the best interest of the child. D. A court ordered determination of custody is required to avoid continuing conflict between the parties regarding parental responsibility for custody and support. E, On at least three occasions when the child has been in the sole care of Defendant she has threatened to leave the home and leave the child alone in the home. F. The Defendant has become argumentative towards Plaintiff and has confronted him on numerous occasions yelling at him, screaming at him, and on at least one recent occasion slapping him five to eight times, all of which was done with the child in the home and some of which was done in the presence of the child, which Father believes to be detrimental to the best interest of the child, 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 as parties to this action, WHEREFORE, Plaintiff requests the Court to grant custody of the child to Plaintiff subject to partial custody by the Defendant. Respectfully submitted, ANDREWS & JOHNSON By' COMMONWEALTII OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) I verify that the statements made in the foregoing Complaint are true and correct I understand that false statements herein are made subject to the penalties of 18 Pa.C,S, 14904, relating to unsworn falsification to authorities, DATE: 8p//9r ~~P(LZ:~ "'" 0") - " ",>- ."."- IIJ~-" .' t~;. J".' . .. .,.OL).', .. . :II: ~ Q) N "" 'q> .1 .~'\ :..J;J!' r c::n "J .... ~ .. :.r ~J: