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Home My WebLink About95-04947 G CT 2 0 199~f1-. vs, ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA I f. I MARY W. SHEEHAN Plaintiff NO, 95-4947 CIVIL TERM LINDA G, SHEEHAN and KERRY DANNER Defendant CIVIL ACTION - LAW ORDER AND NOW, this 17th day of October 1995, it being reported to the Conciliator that the parties have reached an agreement which makes further proceedings unnecessary, the undersigned Conciliator hereby relinquishes jurisdiction and returns this matter to the Court Administrator. If either of the parties wishes further proceedings in this action, they should petition the court anew, FOR THE COURT, T..:/j' . i'. . ,,(,. : (' \"'~~'.~'.~' ~- MICHAEL L. BANGS J Custody Conciliator / Joseph L. Hitchings. Esquire Attorney for Plaintiff Ms. Linda G, Sheehan 24 E, Columbia Avenue Enola, PA 17025 Mr. Kerry Danner 221 A Seventh Street New Cumberland. PA 1 7070 OOB979.{)()()()2/Seplemher IS. I99SIMCD/MH/46692 MARY W. SHEEHAN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.1')' q '74; (It tLt t .j I L t< Plaintiff vs. CIVIL ACTION - LAW LINDA G. SHEEHAN and KERRY DANNER, Defendants ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respe..'live counsel appear hefore M. l h..., l L _ (.7"""" ~ ('5t, ,the Conciliator, on the -3 day I f 6c'~ > '51" ~l-, ('.....1'14,'1 of _()c \dH< , 1995. at .m. in RUUIII , fhN, of die Cillllbetlalld Cuunty Olu.d.uu.", ll::t1Iu:thllll[t "qll~re ror1i&lt, IliR...,lvdlJia, for a Pre-Hearing Custody Conference. At such conference, an effon will he made to resolve the is~ues and dispute.\; or if this cannot be accomplished, to define and narrow the issues to he heard by the Coun. and to enter into a temporary Order. All children age five or older ~~so be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent Order. For the Coun, By: 0, ~I ~ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU 00 NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE mE omCE SET FORm BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Coun Administratur Cumherland County Counhouse I Cuunhuuse Square Carlisle. Pennsylvania 17013 Telephone: 1717) 240-tl200 OOB979-OOOOUSqum...., IS. I99S/MCD/MH/46692 7. The Plaintiff is the maternal grandmother of Joseph Earl Sheehan. 8. The Plaintiff currently resides with her grandson and now seeks primary physical and legal custody of her grandson, Joseph Earl Sheehan. 9. During the past five (5) years, Joseph Earl Sheeban has resided with the following persons at the following addresses: ~ Address I2ala Linda G. Sheehan, Dave McManuels, Jennifer Mem and Rehecca Mem 101 Nonh Second Street Wormleysburg, PA 17043 August 1990 to October 1990 Pastor and Mrs. John Shuey Summerdale, PA October 1990 York County Foster Care - Runkles (Foster Parents) Various Locations October 21, 1990 to November 1991 Mary W. Sheehan and Linrla G. Sbeehan 797 Valley Street Enola, PA 17025 November 1991 to December 1992 Linda G. Sheehan 24 East Columbia Road Enula, PA 17025 December 1992 to July 1993 Mary W. Sheehan 797 Valley Street Enola, PA 17025 July 1993 to Present 10. The Plaintitf, Mary W. Sheehan, 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 coun. II. The Plaintiff, Mary W. Sheehan, has nu information of a custody proceeding concerning the child pending in a coon of this Communwea1th. 12. The Plaintiff, Mary W. Sheehan. dues not know of a person not a party to the proceedings who has physical custody of the child ur claims to have custody or visitation rights with respect to the child. OOB979-OOOOUSeJ1lem....' IS. I99S/MCD/MH/%692 13. Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the child have heen named as partie.s to this action. 14. Plaintiff, Mary W. Sheehan, seeks and Order of Court granting her primary physical and legal custody of her minor grandson, Joseph Earl Sheehan. IS. The best interests and permanent welfare of the child will be served by granting the Plaintiff, Mary W. Sheehan, primary physical and legal custody of her minor grandson, Joseph Earl Sheehan, because Plaintiff is the minor child's primary custodian and care giver and such a custody order would officially confirm the parties' custody arrangement. WHEREFORE, Plaintiff, Mary W. Sheehan, respectfully requests the Court to grant her primary physical and legal custody of her minor grandson. Joseph Earl Sheeban. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER Date: 9 -/5.. 1:; By: sep L Hitchings ttorney 1.0. No. 6S551 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Mary W. Sheehan OOB979.OOClO2ISeJ1Iem....' 15. I99SIMCD/MH/46692 . . VERIFICATION The statements In this Complaint for Custody are hased upon information which has been assembled by my attorney in this litigation. The language of the statements is not my own. I have read the statements; and to the extent that they are based upon information which I have given III my counsel, they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa, C.S. 14904 relating to unsworn falsification to authoritie.s. Date: 9-/~' 'IS u . ) . ~ it'. ~6.L" Ma W. Sheehan , (f - ---"",- . SfP 18 3 16 PH '95 fll.~::'~:;: FtC: Cf :'.;< ';:~'ICN,TAr.y (.'.-'\t::C'. .,1 CC.1iTt ~', U " ~ j ,....d, IjI ~ Ii #b:g OAt 172.3 ( e-,J, (ib.l1~ . ~ ~ ,,)S'--' J~ /;-s's?t -'--"'~-"_.._-i!>< "', ......."...,., , .- ,OOB979-OOOOUSeplemhe, 2S. I99S/MCDIMH/467OG .., MARY W. SHEEHAN. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. NO. 95-4947 CIVIL TERM CIVIL ACTION - LAW LINDA G. SHEEHAN and KERRY DANNER. Defendants h MUR~ AND NOW, this I Y day of . , 1995, upon consideration of the Custody Stipulation of the parties which is attached hereto and incorporated herein by reference, it is hereby ORDERED AND DECREED that said Stipulation is approved and adopted as an Order of Court with full weight and effect. BY TH COURT, J. c:J " ... .. -' ..., u .... ;:.1.; - U) U'1 OOB979.00002/SCI~emher 2~. 1995/MCD'MH'467~ .. MARY W. SHEEHAN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-4947 CIVIL TERM Plaintiff vs. CIVIL ACTION - LAW LINDA G. SHEEHAN and KERRY DANNER, Defendants CUSTODY STIPULATION THIS STIPULATION, made this ~".A day of ~ c.Jo..her- ,1995, by and between MARY W, SHEEHAN, of 797 Valley Road, Enola, Cumherland County, Pennsylvania (hereinafter "Plaintiff') and LINDA G. SHEEHAN, of 24 East Columhia Avenue, Enola, Cumherland County, Pennsylvania and KERRY DANNER, last known residence of 221A Seventh Street. New Cumberland, Cumberland County, Pennsylvania (hereinafter "Defendants"). WHEREAS, the Defendants are unmarried; and WHEREAS, the Defendants are the natural parents of a minor child, Joseph Earl Sheehan, born on April 21, 1979, in Harrishurg, Dauphin County. Pennsylvania; ilnd WHEREAS, the Plaintiff is the maternal grandmother of Joseph Earl Sheehan; and WHEREAS, Joseph Earl Sheehan has resided with Plaintiff for the last several years, and Plaintiff is the minor child's primary custodian and care giver; and WHEREAS, the parties hereto are desil1lus of confirming the long standing custody arrangement for the mino child with the Plaintiff. NOW THEREFORE, the parties hereto. each intending tu he legally bound hereby, du stipulate and agree follows: