HomeMy WebLinkAbout98-06307
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DAVID C. SHOVER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
NO.jj'. (.1c'/CIVIL
CUSTODYNlSIT A TION
vs.
MICHELE R. SHOVER,
Defendant
ORDER.oECOURT
AND NOW, this (date) \ \ I '11 '/8. , upon consideration of the attached
Complaint, it is hereby directed that the parties and their respective counsel ~ear before
t2~~\~ ~ . b.c!'\<j~' i:""cl1, , ,the conciliator,!!t :IS0 ~. \,,~ ..:::.\, ,
c \ 1 (: I~ on the ,).., day of \)('( ('(n~X' (' .
1998, at d.IJU P,M. for a Prehearing 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.
Either party may bring the child who is the subject of this custody action to the conference.
but the child/children's attendance is not mandatory, Failure to appear at the conference
may provide grounds for entry of a temporary or permanent order.
FOR THE COURT:
By:_l1ii'cl)\{)oQ,d. ~~
Custody Conciliator (\$)
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
COURTHOUSE, FOURTH FLOOR
CARLISLE, PA 17013
(717) 240-6200
105865-1
DAVID C. SHOVER.
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYLVANIA
vs.
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r.lJ........
MICHELE R. SHOVER,
Defendant
CIVIL ACTION. LAW
IN CUSTODY
C.QM~LAINI,EQR.CU5:[QD_Y.
AND NOW. comes David C. Shover. by his attorneys, Caldwell & Kearns. P.C,. and
respectfully represents as follows:
1. The Plaintiff. David C. Shover, is an adult individual. presently residing at
1049 Oyster Mill Road. East Pennsboro Township. Cumberland County (Camp Hill).
Pennsylvania, 17011.
2. The Defendant. Michele R. Shover. is an adult individual, presently residing
at 34 Brentwood Road. Wormleysburg, Cumberland County (Camp Hill), Pennsylvania.
17011.
3. The following minor children are the subject of this Complaint:
lliu:ne
Present Address
Birth Date
Jonathan D. Shover
34 Brentwood Road. Camp Hill. PA 17011
34 Brentwood Road. Camp Hill. PA 17011
3/31/89. Age 9
5/9/91. Age 7
Lauren M. Shover
The aforementioned minor children were not born out of wedlock.
The parties have no other children.
4. The aforementioned minor children are presently in the physical custody of
their mother, the Defendant, who presently resides at 34 Brentwood Road, Camp Hill,
Pennsylvania 17011.
5. For the past five years, the subject minor children have resided with their
natural parents, the Plaintiff and Defendant, at the following residences for the stated
periods of time: from 1993 to June 1998, the two minor children resided with their parents
at 15 Bellview Road, Marysville, Perry County. Pennsylvania; from June 1998 until October
22, 1998, the two minor children resided with their natural parents at 34 Brentwood Road,
Camp Hill, Pennsylvania 17011; and, from the date of the separation of the Plaintiff and
Defendant on October 22, 1998. the children have resided with their natural mother, the
Defendant, at 34 Brentwood Road, Camp Hill, Pennsylvania 17011.
6. The relationship of the Plaintiff to the subject minor children is that of natural
father.
7. The relationship of the Defendant to the subject minor children is that of
natural mother.
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8. The Plaintiff has not participated as a party or witness, or in any other
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capacity, in other litigation concerning the custody of the children in this or any other Court.
Plaintiff has no information of a custody proceeding concerning the children 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 children or claims to have custody or
visitation rights with respect to the children.
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DAVID A. SHOVER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 98.6307 CIVIL TERM
vs.
MICHELE R. SHOVER,
Defendant
CIVIL ACTION - CUSTODY
eRAECle.E
TO: Curtis R. Long, Prothonotary
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013-3387
In accordance with Pa. R.C.P. 229, please discontinue the within custody action.
Respectfully submitted,
CALDWELL & KEARNS
By:
Carl G. Wass, squire
Attorney 1.0. #07268
3631 North Front Street
Harrisburg, PA 17110
(717) 232-7661
Date: ~~ \'\ I \C\C\.q
Attorneys for Plaintiff
108884-1
98-516