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HomeMy WebLinkAbout00-05345 , PEARL M, MCGOUGH & JAMES A, MCGOUGH PLAINTIFF V, RODNEY L. SHELLER & TRACY L. MCGOUGH DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-5345 CML ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 3rd day of AU2ust ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on the 13th day of October , 2000, at 8:30 a.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 defme and narrow the issues to be heard by the court, 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 permanent order, FOR THE COURT, By: Isl Hubert X. Gilro Es Custody Conciliator The Court of Cornmon Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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 TillS PAPER TO YOUR ATTORNEY AT ONCE, IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 "~'Il~~~I...":".id"""","""lii,t"'''\1",,,~,,'4.'';';<'",,",~,'"''~f';;''Mdf'"_'''''';;:;&ciOk;;''~.<d&'''''_~iIiill~~~'it"*".....-cl!;;,l~r.bl!i> ~, ,,,,"-,,",",",,,,,, - -1iIlll~-~"""" e,;:o[j2, c<,,?'! ,,~,r).-\,)\ \",,\()Ir' C\\};: ~-,~ i"'\-";"\~\''''' " 'i-I s\ cf \'\\ 3\ . \j\J t.\i~ ~ 1 CO\}~ C\}\II~~~~ - ~. -; 'co &d. tb;j ~ -j:, 4" .rO~.:/ ~-)t?c? ~ ~ Z ~ ?-Z '8'/"" ~ ~ ..:- ,v.~ ~ ,j. - ..~P;;LJ_",~" ,~-,_, ~<. _~. ,,~,_. _~'-'_ _'~,.~'r ,_ ,,", ,.J'b c_ ,,_,_, ,',~ _ _,~. ~,~, ,~ !iL ,. PEARL M. McGOUGH JAMES A. McGOUGH, Plaintiffs v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; No. 2000.53(,15' CIVIL TERM RODNEY 1. SHELLER TRACY 1. McGOUGH, Defendants IN CUSTODY ORDER OF COURT AND NOW, ,2000, upon consideration of the attached petition, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at on the day of ,2000, at 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 def"me and narrow the issues to be heard by the court, 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 permanent order. FOR THE COURT, By: Custody Conciliator 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 TAI<E 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 COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 cc: Lindsay Dare Baird, Esquire Tracy 1. McGough Rodney 1. Sheller ''''. ~ PEARL M. McGOUGH JAMES A. McGOUGH, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2000- .6'3<;.::,- CIVIL TERM RODNEY L. SHELLER TRACY L. McGOUGH, Defendants IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiffs are Pearl M. McGough and James A McGough, husband and wife, residing at 5 Cooper Circle, Carlisle, Cumberland County, Pennsylvania. 2. The defendants are Rodney L. Sheller, residing at 2 Stuart Street, Mt. Holly Springs, Cumberland County, Pennsylvania, and Tracy L. McGough, residing at 222 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiffs seek primary custody of the following child: Name Present Residence Al!e Austin James Sheller 5 Cooper Circle, Carlisle, PA 17013 6 The child is presently in the custody of maternal grandparents (the plaintiffs) who reside at 5 Cooper Circle, Carlisle, PA. During the past five years, the child has resided with the following persons and at the following addresses: Person James and Pearl McGough Dennis Trimmer and Tracy McGough Trimmer Address 5 Cooper Circle, Carlisle, PA Dates August 99-Present 29 Watson Drive, Carlisle, PA 400 N. Bedford St. Carlisle, PA Oct. 96 - Aug. 99 Nov. 95 - Oct. 96 The mother of the child is Tracy L. McGough, currently residing at 222 Walnut Bottom Road, Carlisle, P A. She is unmarried. The father of the child is Rodney L. Sheller, currently residing at 2 Stuart Street, Mt. Holly Springs, PA He is unmarried. I"",!! 4. The relationship of plaintiffs to the child is that of maternal grandparents. The plaintiffs currently reside with the following persons: Name Relationship Austin James Sheller Grandson 5. The relationship of defendants to the child is that of mother and father. The defendants currently reside with the following persons: Name Rodney L. Sheller resides with his girl friend named Crystal. Tracy L. McGough resides with a female friend, Sherise Darhower and Ms. Darhower's daughter . 6. Plaintiffs have 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. Plaintiffs have no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiffs do 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 because: a) Plaintiffs can provide the child with a home with adequate moral, emotional and physical surroundings as required to meet the child's needs; b) Plaintiffs are willing to continue custody of the child; c) Plaintiffs continue to exercise parental-type duties and enjoy the love and affection of the child. 8. Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim NONE Wherefore, plaintiffs request the court to grant primary custody of the child. Y/k~ ~ Linds6y Dare Baird, Esquire 37 South Hanover Carlisle, PA 17013 Attorney for Plaintiffs """\.. "".;<q'T'llII'lII We verify that to the best of our lmowledge and belief, the statements made in the foregoing document are true and correct. We understand that false statements herein are made subject to the penalties of 18 Pa.C.S.~4904 relating to unsworn falsification to authorities. jffW\W tt- ?Wlt"?f(), es A McGough, Plaintiff ~~ MIJO?JJ,~~f ~~ ~ " ~-~"'-"""'.~-" ,- _,~J)~",~~ ,~' _~", ~J!.l!~' -,." , w __" 'ffd.-,_,.,,~, '~,h ,___>> =, ~ n C) '('- ~ I~' ~.::::: \!:: -z <' ~) -' <;) ~( '"-I:l ~ o 8 C ,.. (/) 0:- ~ -0 --0 ~< -- r:'- >l ;;;- ,-'-- ~ ~ -0 ~~;_~'.o. :D (11 ~ f' p.. C. ........ ::t:. +> .:-- ---T -..< ..... ~ -< "'" ~ St.' . "....".y,....1'" .D (:.:; (-.::::. );:~ :.'") :::> :---; -,' -< l!II]ffl.~MllM_l1{'~l'<O?'i!>"'iIWW'lll!Af'11mWi"w'?Jj.illYJI!R~~l~Imilri'lfi'l~I:l.."~~ ~",.._ " ~ PEARL M. McGOUGH JAMES A. McGOUGH, Plaintiffs v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2000- 5345 CIVIL TERM RODNEY L. SHELLER TRACY L. McGOUGH, Defendants IN CUSTODY ORDER OF COURT AND NOW, this \ () Ii. day of ~, 2000, upon consideration of the attached custody stipulation with respect to the parties' child/grandchild, Austin James Sheller, born October 18, 1993, the terms of the stipulation are entered as an order of court, BY THE COURT, Lo 0 ~~ 10-// -OQ 'RX.9 J. Lindsay Dare Baird, Esq, 37 South Hanover Street Carlisle, PA 17013 Attorney for Plaintiffs Rodney Sheller, Defendant 2 Stuart Street Mount Holly Springs, PA 17065 Tracy McGough, Defendant 222 Walnut Bottom Road Carlisle, PA 17013 '>~,~ ,=~ .' '~~-''''''~i~~i;;$~fti~$~.ilbt..j\IG!ln''ilJrE1l>~~f.&if<!!Ui<;!l\I\IDllliIll$'~i.ll~' -~'Ift;:d1~~~Jl:l. ,I,I",.",!., "", Mmtl! OF ;lLED'-J;~F:Ct - , "C'!OTAFlY ",", G~~ I I I.JU :L! . ""1'1 ", "-1 I,jlfl. ". C:UiViiEEF-!ij,>,~U (~()UNTY PENNSYLVAI\JiA .."" , .""'''-'~-' ~. ,,_c ~-i';r ,'<-' ~L.;.,.. ~ 'I;'. ~ , PEARL M. McGOUGH JAMES A. McGOUGH, Plaintiffs v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2000- 5345 CIVIL TERM RODNEY L. SHELLER TRACY L. McGOUGH, Defendants IN CUSTODY STIPULATION FOR CUSTODY STIPULATION made this ~ day of ~ ,2000, between Pearl and James McGough, hereinafter referre 0 as Grandparen s, ana Rodney Sheller and Tracy McGough, hereinafter referred to as Father and Mother. WHEREAS, the above-named Mother and Father had born to them the following child on the following date: NAME BIRTH DATE Austin James Sheller October 18, 1993 AND WHEREAS, the above-named Grandparents, Mother and Father desire to enter into a Stipulation as to the custody of the above-said child and to the partial custody rights of the non- custodial parents: NOW, THEREFORE, in order to effectuate the above purpose, the above-named Grandparents, Mother and Father hereby stipulate that: 1, The Grandparents shall have legal and primary physical custody of the child, 2, The Mother and Father shall have periods of partial custody of the child as follows: a, The Father shall have every other weekend from Friday at 5:00 PM through Sunday at 8:00 PM, b, The Mother shall have periods of partial custOdy by agreement of the parties, c, Holidays shall be scheduled by agreement of the parties, TO THIS PURPOSE, The parties hereto intend to be legally bound by the terms of this Stipulation and desire to have the Stipulation entered as an Order of Court, Witness: ~~)?}, 1J;CJj+ ~o~1 1f.1n ~~ :1 1 :1 :1 ~~ " 'say a, air, sqUire >. ~- .. , Witness: . c , . ~ u. ~ .lrf~ f. fYJ9&ugh ~.jJ~ ~ a er ,-""",. , ~ .1\"'1 .. I 'M~-. ._"~" ',"0" ", ._h" ~ ."~ (') C '-p~ fl1l:1..: '.,;;;.Jr I~ ~.: :< (,,? <fl ~~.~ .~.~,~~ ' "--'~""'-l C'J a a C") -I c,) --I"] CY'l ;--;~:g --:;(~J , " ~)j~l~ :0 ",-.i ?i -< 1 ~..",.. _~, _~",~""",""",~~~~~ffl'elfH"'F~.jf'1:J;''',5!''rN'5'$~w<'}~:;~~m:~iiffi~:plig;'I!J!ll~,,~ "',~ ~ ""1- OCT 1 3 20~~ PEARL M, McGOUGH and ,fAMES A. McGOUGH, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW RODNEY L. SHELLER and TRACY L. McGOUGH, Defendants NO. 2000 - 5345 CIVIL IN CUSTODY COURT ORDER Ttr AND NOW, this lel day of October, 2000, the Conciliator being advised that the parties have reached an agreement in the above case, the Conciliator relinquishes jurisdiction. BY THE COURT, D(If- Hubert X. Gilroy, Es Custody Conciliator ". ','_," '~"'"' _ _'.', 0 ~_ .,'_~" ~"'_~" c,_O', ,"'_ " " ~,_" L" '-,' ,~ ~'_ ^" 0 , .