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Home My WebLink About97-07143 4. Contemporaneously herewith, Petitioner has flied a complaint for custody for the subject minor child. 6. Since the child's birth, the child has resided with the Plaintiff and the Defendant at 1712 English Drive, Mechanlcsburg, Cumberland County, Pennsylvania. 6. On December 19, 1997, Defendant and the parties' minor child traveled to Alabama to visit with the Defendant's family during the holiday season, 7. On December 28, 199'7, Defendant telephoned Plaintiff from Alabama end Informed him that the parties' minor child would not be returning to Pennsylvania; rather, Defendant intends to return for the sole purpose of retrieving her personal Items, as well as the child's belongings. 8. The Plaintiff Is scheduled to arrive in Harrisburg on December 30, 1997 . without the parties' minor child, 9, The best interests of the child would be served by granting Plaintiff temporary primary physlcel custOdy for the following reasons: a. Defendant has already removed the parties' child from the child's home and has refused to cooperate In anyway whatsoever to return the child, Refusing 2 Plaintiff contact with his child Is detrimental to a child of such a tender age. b. It Is believed that the child's safety and welfare mey be In Jeopardy In that the Defendant and the child are residing with the maternal grandparents. It Is believed that the maternal grandfather physically abused the Defendant during her childhood. Consequently, the safety of the parties' child Is of concern. c. The minor child developed a strong bond with Mary Shorter, the paternal grandmother. Mrs. Shorter cared for the child on a dally basis since the child was six weeks of age. d. Petitioner has the ability to provide the minor child with continuing nurturing necessary to ensure stability and safety for the child, WHEREFORE, Petitioner respectfully requests your Honorable Court grant Petitioner special relief pursuant to Pa. R.C.P, 1915.13 by awarding Petitioner primary physical custody of the minor child pending a hearing In this matter or future Court Order. Respectfully submitted, GOLDBERG, KATZMAN & SHIPMAN, P.C. DATE: l,:).f,Jr )/'1 7 . By l'.fJ.iU1 J ! j h:fZd"lC(/ DIANA WOODSIDE, ESQUIRE 320 Market Street P.O, Box Harrisburg, PA 17108 (717) 234-4161 Attorneys for Petitioner 3 ,01, ,I 'J , , . , , VERfFfCATf~ ' I verity that the statements contained in the foregoing PETITION FOR SPECIAL ,. , RELIEF are tru~ and correct to the best of my knowledge, information a~d belief., I understand , , that t1llse statements contained therein are made subject to the penalties of 18 Pa. C.S, ~4904 ' , , relating to unswomfhlslfIcailcln to authorities. Date: / )., / 3D /9 7 c;.~.", ,_ . /) ~ 1 . ~a~.../J(J ~j4,~ DAVID A, SHORTER ,I " I I I I /, " ,I 'i ( >> '- ,~ ~- c:: ". d' .. "'-. c- ., Ip...: ..:J i :i', 'r2 (;'~ :-':: .. p.... " ~_."', ,l"j'. l'_ ':J t. ,:)t:, U") :, : i ~ 1J"' , ",_:; fi:: I~\.I :,it;. 1.;')(;-, r; ""t. J,l!I.t.. ~'I It,. ~t.:l ;'i 0 en ',) " v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYL.VANIA NO. (} '7- '7/ I-Cj CIVIL ACTION. LAW IN CUSTODY DAVID A. SHORTER, Plaintiff CANDACE E. EUBANKS, Defendant QBQg~ QF COURT AND NOW, ---1J .:) I q'~ , upon consideration of the attached complaint, It )s hereby directed that the parties and their respective counsel appear before ',-:. \ - -X- ~, the conciliator at.~1 \..J. \...\ CII;-, _.' ' ".\, he. on the ,S . day of \e\'r\.J(lI---trt\,1998,at II ~C)J<:\m., for a Pre-Hearl g Custody Conference, AI such conference, an eft rt will be made to resolve the Issues In dispute; or If Ihls cannot be accomplished, to define and narrow the Issues to be heard by the court, and to enter Into a temporary ofder, All children age five or older may also be present et the conference. Failure to appear at the confefence may provide grounds for entry of a temporary or permanent ofder. FOR THE COURT: BY: d'3o \ \ Ii, "J\ J~M\rk1 ur fHi. Custody Conciliator (T1:J. ') ( , '0' ' 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 have business tJefore the court, plesse 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 FINO OUT WHERE YOU CAN GET LEGAL HELP, OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE, PA 17013 . (717) 240-6200 , I" FII.F.IH)r-I~ICE OF T' :i: rl:nIlY"':nTAnY ~lO .IM! -6 ['II 2151 CU~li::;'i',:.f..' "CUi'IW 1'[:I'iI' ~:;)'II.'iI'.i 1','\ ,I) It.. If L &.1 ~ ,;d4< 1. 4'1 ~(..4 )-!R,9f 7#l1b /441"" ~~T ' . Il~ ~ ~ ". /l J -.J './ " . r~ 11I~ ~ Y' <:V/....1-1d'#' .' " WHEREFORE, Plaintiff requests the courlto gfant /'11m primary physical custody of the parlles' minor child, SYDNEY ABIGAIL SHORTER. .. Respectfully submitted, GOLDBERG, KATZMAN & SHIPMAN, P.C. . DATE: ~ By DIANA WOODSIDE, ESQUIRE 320 Markel' Street Post Office Box 1268 . Harrisburg, PA 17108-1268 (717) 234-4161 . Attorneys for Plaintiff , . , , , ~lUFICAT~PN I veritY that the statements contained hI the foregoing COMPLAINT FOR CUSTODY are true' and correct to the best of my knowlcdge,informa,lon and belief. I understand that false 'statements contained therein are made subject to the penalties of l8Pa, C.S, H904 relatirlg to unsworn falslllcation to authorities. . Date: -.1 '2 I '"30 /9 '} ~~".~/() .j~. . DAVIDA SHORTER . " ., ' "