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(5) The mother and father shall transfer Sarah for each alternate weekend
period on Saturday at 10:00 a,rr., and Sunday at 4:00 p,m, with the tran.ter location
/
/
Bradley L, Griffie, Esquire
ForPlalntltf .. l"..-u... ,.......~l. IIIH/1S,
--if n ~\ ,',
Joan Carey, Esquire
For Defendant
:IIA
v.
IN THE COURT OF COIOlON PLIAS OF
CUMBERLAND COUNTY, ~EHNSYLVANIA
CIVIL ACTION - LAW
NO. CIVIL 1995
IN CUSTODY
STIVI A. SilBERT,
Plaintitt
CHRISTINA M. ST JEAN,
Detendant
....1'1'10. ~. ...0IllL ULI.. .auUUl'l' '1'0
.....YL~1& .D~. O. CIVIL .aoc.Du.. .1.11.13
AND NOW, come. Petitioner, steve A. Seibert, by and throu9h
his counsel ot record, Bradley L. Grittie, Esquire, and the law
tir. ot Griftie , Associate., and petitions the Court a. follow.1
1. Your Petitioner i. the above-named Plaintitf, an adult
individual currently re.iding at 179 Hair Road, Newville,
cuaberland County, Pennsylvania.
2. Your Re.pondent i. the above-named Detendant, an adult
individual believed to be residing at 591 Noland Drive,
Sykesville, Carroll County, Maryland.
3. The partie. are the natural parent. of Sarah Marie at
Jean/ born March 27/ 1991.
4. Conte.poraneously with the filing of this Petition, the
Petitioner has tiled a Complaint for CU.tody ot his dauCJhter,
Sarah Marie st Jean, with the Court of Common Pleas ot CUmberland
county.
5. The child has re.ided for her entire lite with the
Petitioner at 179 Hair Road, Newville, Cumberland County,
Pennsylvania.
6. On or about November 7, 1995, the Re.pondent took the
child with her to visit relative. in Maryland with the
Petitioner's consent.
7. On or about November 18, 1995, the Respondent notified
the Petitioner that she was not returning to the Petitioner and
would not allow the Petitioner to have contact with his daughter
again.
8. During the more than four and one-half years that the
child resided with the parties at the Newville, Cumberland
County address, Petitioner has been the primary custodian of
the child.
9. The petitioner, although he has been the only party to
be gainfully employed during the parties' relationship, has also
assumed responsibill ty for the child's mental, emotional, and
physical needs.
10. The Petitioner has been the primary party responsible
for seeing that the child has proper and clean clothing; that the
child is properly bathed; that the child has proper mecUcal
treatment; and that the child's basic needs, including food and
shelter, have been provided.
11. The Respondent has shown a total inability to provide
for the child's most basic needs, despite the fact that the
Respondent has not been gainfully employed but for extremely
brief periods of time, since the child's birth.
12. The reasons for the Respondent refusing to return to the
parties' residence at 179 Hair Road, Newville, Cumberland County/
Pennsylvania, are unknown to the Petitioner.
13. The child has exhibited a fear of the Respondent,
presumably due to the lack of interaction and contact between the
child and the Respondent.
14. Petitioner and Respondent were in constant conflict over
the tact that Respondent retused to allow the child to have state
..ndated inoculations.
15. The child presently does not have inoculations that are
required ot a child at her age, despite the Petitioner's ongoing
attempts to secure the Respondent's consent to s.curing those
inoCUlations.
16. Respondent hall now advised Petitioner that he ill not
qoinq to have contact with his daughter and, in tact/ Respondent
ha. refu.ed to allow the child to even speak with her father on
the telephone.
17. Petitioner believes that the filinq of the Complaint tor
CUstody in this action will cause the Respondent to hide trom the
juriSdiction ot the Court ot Common Plea. ot CUmberland County,
Pennsylvania, which will thwart the Court's ettorts to enter an
appropriate Order in this matter.
18. Althouqh the Respondent was raised principally by her
maternal qrandparents in Newville / Cumberland County,
Pennsylvania, and although the parties and the child have resided
.olely in CUmberland County, Pennsylvania, particularly since the
child'. birth, it ill believed that the Rellpondent will remain
outside of the juriSdiction of the Court Common Pleas of
CUmberland County in an attempt to gain jurisdiction in another
state or County, particularly once Respondent has been .erved
with the Complaint for CUstody filed by the Petitioner in thia
action.
19. Despite the fact that petitioner was the only party
gainfully employed during the parties' relationship, Petitioner
was also rssponsible for the basic needs of the family and child,
including cooking, caretaking of the home, and the like.
20. Respondent has repeatedly told the Plaintiff that she is
unable to provide care for the child and does not have patience
to see to the child's daily needs.
21. Petitioner believes, and therefore avers, that if a
Te.porary Order is not entered providing for him to have primary
physical custody of the child, the Respondent will attempt to
avoid the jurisdiction of the Court of Common Pleas in Cumberland
county, Pennsylvania, and further, that the child will otherwise
be haraed or intimidated through the actions of the Respondent.
WHEREFORE, petitioner requests your Honorable Court to enter
an Order providing for him to have temporary physical custody of
the parties' child pending further Order of Court or agreement of
the parties.
Respectfully sUbmitted,
GRIFFIE & ASSOCIATES
.....-:>
By:
re
STEVE A. SEIBERT,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION -
No.9f t7/gIVIL
IN CUSTODY
LAW
CHRISTINA M. ST JEAN,
Defendant
1995
ORDER OF COURT
AND NOW, Oc-(. Ll, \q'IS'
/ upon consideration of the
attached Co.plaint, it is hereby directed that the parties and
their respective counsel appear before t\ ,...bl"r-I ';/-, (.,.~ If ,,'/ Ii"-'t. ,
the conciliator, atLlt~ -\ lc.'.)1 CL'-'Y'\' (". ("...r\'M-'~ on
the tf 1h day of -::j:.n","lI! 199' at )0. iJv;J .'11.,
for a Pre-Hearing custody Conference.
At such conferflnce, 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
chi1dre" 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.
FOR THE COURT,
By:
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 Courthouse
Fourth Floor
Carlisle, PA 17013
(717) 240-6200
STEVE A. SEIBERT, I IN THE COURT or COIOlON PL1!:A8 or
Plaintiff I CUMBERLAND COUNTY, PEllNSYLVANIA
I
v. CIVIL ACTION - LAW
.
.
CHRISTINA M. ST JIAH, . NO. CIVIL 19515
.
Def.ndant . IN CUSTODY
.
COMPLAINT FOR CUSTODY
1. Plaintiff 18 st.v. A. S.ib.rt, an adult individual
curr.nt1y r..idinq at 1751 Hair Road, N.wvill., CUaberland County,
Penn.ylvania.
2. Def.ndant i. Chri.tina M. st J.an, an adult individual
b.li.v.d to b. curr.ntly r..idinq at 5511 Noland Driv.,
Syk..vill., Carroll County, Maryland.
3. Th. Plaintiff i. the natural father of the child,
Sarah Mari. st J.an, born March 27, 19511.
4. Th. Def.ndant i. the natural .oth.r of the child, Sarah
Mari. St J.an, born March 27/ 1991.
Th. child wa. born out of w.dlock.
Sine. the child'. birth, the child ha. r..id.d with the
followin9 per.on. at the following addr..... for the followin9
period. of ti...
If.AIII
ADDRESS
179 Hair Road
N.wvill., PA
.Q6D
St.v. A. S.ib.rt
Chri.tina M. st. J.an
St.v. A. s.ib.rt, Jr.
On or about Nov..b.r 18, 1995, the D.f.ndant, who wa.
March 27, 151511
To pr...nt
viaitinq r.lativ.. in the stat. of Maryland, notifi.d the
Plaintiff, that .h. did not intend on returning to the parti..'
reaidenoe at 179 Hair Road, Newvi11e, cumberland county /
pennaylvania. The epeoifio "residence" of the child at preeent
ia unknown to the plaintiff.
4. The relationahip of the plaintiff to the child ie that
of natural father. The plaintiff ourrently reaidea at 179 Hair
Road, Newville, CUlllberland county, Pennsylvania, with hie eon,
steve A. seibert, Jr. He ie eingle.
5. The relationahip of the Defendant to the ohild ie that
of natural mother, whose residence at present is believad to be
591 Noland Drive, sykesville, Maryland. She iB believed to be
reaiding with her mother and at.pfather/ Kathy and John st Jean/
at 591 Noland Drive, sykesville, Maryland. She is single.
6. plaintiff has not participated as a party or witneee/
or in any other oapaoity in other litigation, oonoerning ouetodY
of the child.
7. plaintiff has no information of a custody proceeding
concerning the child pending in any Court of this commonwealth,
except a olaim for cUBtody filed in a protection from Abuee
Action docketed in the Court of Common Pleas of cumberland county
to No. 95-6662; which complaint was filed after the initial
preparation of thie Complaint.
S. The best interest and permanent welfare of the child
will be served by granting the relief requested because:
(al plaintiff has been the primary custodian of the child
since the child's birth;
(bl Defendant has shown an unwillingness or inability to
provide for the child's most basic needs; and
(c) Defendant has failed or neglected to provide for the
proper care, cu.tody, and control of the child, and has otherwi.e
failed to prov ide for the necessary mental, emotional and
phy.ical well-beinq of the child.
9. Plaintiff has provided for the child's needs, includinq
mental, emotional and physical needs, since the child's birth and
it i. in the child's best interests for him to have custody.
10. Plaintiff does not know of any person not a party to the
proceedinq. who claims to have custody or visitation riqhts with
respect to the child.
WHEREFORE, Plaintiff requests your Honorable Court to set a
ti.e and place for a hearinq at which Plainti!! reque.ts the
Court to qrant the custody of the child and request that he be
qranted primary physical custody of the child pendinq the hearinq
in this matter.
Respectfully submitted,
GRIFFIE , ASSOCIATES
ff e, Esqu re
y for plaintiff
200 North Hanover Street
Carlisle, Pennsylvania 17013
(717) 243-5551
(800) 347-5552
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v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
NO, 95-6719 CIVIL 1995
IN CUSTODY
STEVE A. SEIBERT,
Plaintiff
CHRISTINA M, ST,JEAN/
Defendant
PRAECIPE TO WITHDRAW APPEARANCE
TO THE PROTHONOTARY:
Please withdraw my appearance in the above referenced action,
Respectfully submitted,
Legal Services
V
Carey, Esq re
I.D, No,
8 Irvine Row
Carlisle, PA 17013
717/243-9400
Attorney for Defendant
...._-;,.--_.....
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Receipt for
Certified Mall
No InlUfBncO CovurDue Provided
Do not ula tor lntutn81ionill Mail
ISee Ruverlo)
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GRIFFIE It ASSOCIATES
ATTORNEVS AND COUNSELORS AT LAW
200 _ H_... S"'II.
C........, PA 17013
(717) 243,51551
1 (100) 30&7-5552
FAX 717-243-5063
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5ulTI55O, 14 _ MAw SWIT
e__, PA 17201
(7m 267.1350
AI.... TO: e........
April 10/ 1996
The Honorable Edg~r B. Bayley
Judge.' Challbers
Fourth Floor
cuaberland county courthouse
Carli.le, PA 17013
ae: seibert v. st. Jean
No. 95-6719
Dear Judge Bayley:
Your calendar will reflect that there is a custody hearing
scheduled for tomorrow 1II0rning / Thursday, April 11, 1996.
opposing counsel, Jacqueline M. Verney/ Esquire/ and I have
.ecured the consent of our clients to continue this hearing
generally. The parties are attempting to reconcile and before
they enter into any type of additional arrangelllent we would
prefer to alloW that reconciliation to take hold. If in fact the
partie. reconcile, then the Petitions that have been filed in
this case relative to custody will be withdrawn or SOllie type of
appropriate Order will be filed. If the parties' reconciliation
break. down, then either party will have the opportunity to
request that the hearing be rescheduled.
Therefore, if you could please issue an Order indicating
that the hearing scheduled for the 11th is continued generally,
that will suffice to resolve this case at this point. Your
attention is appreciated.
very truly yours,
BW/jllll
cc: Jacqueline M. Verney/
steve A. Seibert
..
Jt\f~ I 8 1996 t:Y
v
tIN THE COURT OF COHHON PLEAS OF
tCUHBERLAND COUNTY, PENNSYLVANIA
t
tNO. 6729 - CIVIL - 2995
STEVE A. SEIBERT,
Plaintiff
.
.
.
.
tCIVIL ACTION - CUS'l'ODY
COUR'l' ORDER
AND NOJi, this ~ day of ~.v^~, 2996, upon consideration
of the attached Custody Co*il1ati~ Report, it is ordered and
directed as follows:
2. g is scheduled in the above case for the \\~ day of
, 2996, at (i,'.I\"S, #1M.,. in Courtroom No-:-2of the
CU rland County Courthouse. At this Hearing, the Father
shall be the moving party and shall proceed initially with
testimony. Counsel for the parties shall file with the
Court and opposing counsel a Memorandum setting forth the
hiatory of custody in this case, the iaauea currently before
the Court, each party's respective position on theae iaauea,
a list of witnesses each party will call to teatify and a
summary of tne anticipated testimony of each witneaa. Thia
Memorandum shall be filed at least ten days prior to the
Hearing date mentioned above.
CHRISTINA M. S'l'. JEAN,
Defendant
2~ Pending further Order of this Court, this Court's prior Order
of November 28, 2995, shall remain in effect with the
modification that Father's periods of temporary custody on
alternating weekends shall start on Frfd)y evening at 8 P.M.
until Sunday at 6 P.M. / I ,
/. /
BY THE COUR'l', .
/ /
'~ ,X
Judge Edga~. Bayley
cc: Bradley L. Griffie, Esquire I'~"" (W,').o,.(, "1'1/%'
Jackie Verney, Esquire - -0 . . 1 .p;)
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STBVB A. SEIBBRT,
Plaintiff
IIN THE COURT OF COMMON PLEAS OF
ICUMBERLAND COUNTY, PBNNSYLVANIA
I
INO. 6719 - CIVIL - 1995
I
I
ICIVIL ACTION - CUS'l'ODY
v
CHRISTINA M. ST. JBAN,
Defendant
PRIOR JUDGE I JUDGB BDGAR B. BAYLEY
CONCILIATION CONFJ:RJ:NCE st1MGRY REPORT
IN ACCORDANCB WITH CUMBBRLAND COUNTY CIVIL RULB OF PROCBDURE
1915.3-8(b), the underBigned Custody Conciliator submits the
following report:
1. The information pertaining to the child who iB the subject
of this litigation is as fo110wsI
Sarah Marie St. Jean, born March 27, 1991.
2. A Conciliation Conference was held on January 11, 1996, with
the following individuals in attendance I
The Father, Stove A. Seibert, with his counsel, Bradley L.
Griffie, BBquire, and the Mother, Christina H. st. Jean, with
her counsel, Jackie Verney, Bsquire.
3. There is a temporary Order entered by Judge Bayley on
November 28, 1995, whereby the Mother was given primary
physical cUBtody and the Father waB given time on alternate
weekends from Saturday through Sunday.
4. The parties Beparated in November with the Hother moving to
Haryland. Father iB Beeking primary physical custody and
suggests that he is the better parent to be the primary
custodian. Hother seekB primary phYBical custody and
suggests that Bhe iB the better parent to be the primary
cUBtodian. There are various and numerous allegationB that
each party is making against the other with respect to their
parenting ability or lack thereof. The partieB were unable
to reach an agreement and a Hearing iB necessary. A Hearing
should take no more than one day.
5. The partieB have been exchanging custody on alternating
weekends at a halfway point near Gettysburg. Things Beem to
be going well, and the Conciliator feels that the alternating
weekends should be expanded to include Friday evenings.
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4. The parties shaD work with each other with respect to sharlna custody on major
hoUdays, birthdays, and other events. The Mother shall also have a period of an
extended custody durlna the summer months durlna Mother's vacation as such time
as qreed upon by the parties. The Father shaD have similar vacation time.
S. ExdJaqe of custody should be handled with the non-custodlal parent p1cklna up the
child at the other parent's home unless the parties aane otherwise.
6. In the event either party desires to modify this Order, that pIIrty may petition the
Court to have the ease again scheduled with the Custody eoncRlator for a
Conference.
BY THE COURT,
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cc~hlln C. Wolf, Esquire
~D1115 M. Clark, Esquire
I
~
STEVE A. SEIBERT
PLAINTIFF
IN TIlE COURT OF COMMON PLEAS OF
CUMBElU,AND COUNTY, PENNSYLVANIA
V,
95-6719 CIVIL ACTION LAW
CHRISTINA M, ST. JEAN
DEFENDANT
IN CUSTODY
ORDF.R OF COllRT
AND NOW. Monday, January OJ, 200S , upon consideration of the attached Complaint.
it is hereby directed that parties and their respective counsel appear before Ilubert X. Gilroy, Esq. . Ihe concilialor,
at 4th Floor, Cumberland Counly Courthouse, Carlisle on Frld.~, January 28, 200S al 10:JO AM
for a Pre-Hearing Cuslody Conference, At such conference, an elTort will be mude to resulve Ihe issues in dispute; or
if this cannot be accomplished, to de line IInd narrow the issues to be heard by the court, and to enter into a temporary
order, All children a~e live or older mllV also be present lit the conlerence, Fllilure to appellr at the conlerence muy
provide grounds lor entry of a temporary or pennllnent order,
The court hereby directs the parties to furnish any and all ellstlng Protection from Abuse orders,
Speela' Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearlOlI.
FOR THE COllRT.
l3y: Isl
Huben X. Gilroy, Esq,
Custody Conciliator
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The Court of Common Pleas of Cumberland County is required by law to comply wilh the Americans
with Disabilites Act of 1990, For inlonllation aboutllccessiblc l1Jcilitics and reasonable accommodalions
available to disabled individuals hllving business belore the court, please contnct our ollice, 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 nlls PAPER TO YOUR ATTORNEY AT ONCE, IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, aOTO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
Cumberlllnd Counl)' Bar Associulion
32 South l3edlbrd Slreet
Carlisle, Penns)'lvllnia 17013
Telephone (717) 249-3166
ELED-O,TI"';
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NATHAN C. WOLf, ESQUIRE
ATI'ORNEY ID NO, 17310
37 SOUl'H HANOVER STREET
CAaLlSLE PA I70U
(7\7) :141-4436
ATI'ORNEY fOR PlAINTiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
~ CIVIL ACTION . LAW q 5. b? J 'I
; NO, ..-rCMLTERM
: IN ct:rsTODY .
STEVE A. SEIBERT,
Plaintiff
CHRISTINA M, ST. JEAN
Defendant
AND NOW, this _ day of 200_, upon consideration of the attaChed
Glmplaint. it is hereby directed that the parties and their respective cOWlSel appear before
, Esquire, the conciliator, at . on the _ day
of , 200_, at _,m. for a Pre-Hearing Custody Glnference, At such
conference, an effon 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 GlUlt, 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 pennanent order,
FOR TIiE COURT,
By:
Custody Olnciliator
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.
Cumberland Glunty Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249.3166
, ,).
7, Father has not panicipated as a pattY, witness or in any other capacity in other litigation
concerning the custody of the child in this or another coun,
8, Father has no infonnation regarding any other custody proceeding concerning the child
pending in a coun of this Conunonwealth or any other state.
9. Father does not know of a penon not a pany to the proceedings who has ph~ica1 custody of
the child or claims to have custody or visitation rights with respect to the child,
10, The best interest and pennanent welfare of the child will be served by gr.mUng the relief
requested herein because upon Father's discovery of Mother's relationship with another man, Mother
Left the panies' residence to go to work and did not return home, Instead Mother began staying with
relatives in Newville,
11, Father recognizes that the child needs to have a meaningful and substantial relationship with
both parents and is wi\ling to encour.1ge such a relationship between the child and Mother.
12, Father maintains a stable household and environment within which to care for the child.
WHEREFORE, for the reasons set fOM herein, plaintiff, Steve A. Seiben, respectfully requests that
the Coun enter an order confinning shared legal custody in the parties and gr.mUng primary ph~ica1
custody of the child to the plaintiff, along with gr.mUng any other relief the Coun deems appropriate,
Respectfully submitted,
December.''? ,2004
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