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HomeMy WebLinkAbout01-04315TAMMY HOLMAN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. SHEA D. QUINN 01-4315 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday,~July 18, 2001 ;upon consideration of the attached Complaint, it is hereby directed that:parties and their respective counsel appear before Hubert X. Gilroy, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, August 23, 2001 at 8:30 a.m. for aPre-Hearing 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. 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. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, BY~ /s/ Hubert X. Gilroy, Esq. Custody Conciliator The Court of Common 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 THIS 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 -; ~_ , ~~ I.. ~,~. 'y~,20/!)1 ~ rn Si Lam, ~ ICCk7l~sc~ ~- ~£cJ ~, ~c~ m~~~ ~ ~~' 1 eo~~Y , Pte- "~~ ~ ~Y ~ ~~ '~~~ ~'' . _ _ -ss~r . ~!~ ,.-~rex.~x~ce#sriP" rx4r.:e~»~ `ktN RY+z+3 _-x9;;~~P. - ;?9 [er i JUL -~ 7 200Y~ IN THE COURT of COMMON PLEA3 of COMBERLAND COUNTY, PENNSYLVANIA CIVIL.ACTION - LAW TAMMY HOLMAN, Plaintiff v. 3HEA D. QUINN, Defendant CASE No. "'y ~S vcL `~ Custody ORDER OF COURT You, Shea D. Quinn, have been sued in Court to obtain custody of the child: Piper Quinn. You are Ordered to appear in person at the Cumberland County Courthouse, Carlisle, Pennsylvania, Room on , 2001 at o'clock _.m., for: a conciliation or mediation conference. a pretrial conference. a hearing before the Court. The presence of the child is not required. The presence of the child is required. If you fail to appear as provided by this Order, or to bring the child if so ordered, an order for custody, partial custody or visitation may be entered against you or the Court may issue a warrant for your arrest. 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 County Bar Association 2 Liberty Avenue, Carlisle, PA 17103 717-249-3166 BY THE COURT: J. Dated: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TAMMY HOLMAN, Plaintiff v. SNEA D. QUINN, Defendant CASE No .: d i- y 3 is Custody Action COMPLAINT IN CUSTODY AND NOW, TO WIT, this day of July 2001, comes the Plaintiff, Tammy Holman, by and through her attorney, Revin G. Robinson, Esquire, ROBINSON & KOENIG, and files the within Complaint of which the following is a statement: 1.) Plaintitf is Tammy Holman, an adult individual who resides at 225 Walton Street, Lemoyne, PA 17043. 2.) Defendant is Shea D. Quinn, an adult individual who resides at 225 Walton Street, Lemoyne, PA 17043. 3.) The Plaintiff and Defendant are not married. 4.) The Plaintiff seeks majority physical and shared legal custody of the following child, TO WIT: Name: Date of Birth: Piper Quinn June 2, 1998 Plaintiff is the natural parent of the above-mentioned minor child. Defendant is the natural parent of the above-mentioned minor child. The child is presently residing with Plaintiff/Mother a , and Defendant/Father and Maternal Grandmother at 225 Walton Street, Lemoyne, PA 17043. The child has resided her entire like with Plaintiff/Mother, Defendant/Father and Maternal Grandmother in Lemoyne, PA. The Mother of the child is the Plaintiff, Tammy Holman, currently residing at 225 Walton Street, Lemoyne, PA. The Father of the child is the Defendant, Shea E. Quinn, currently residing at 225 Walton Street, Lemoyne, PA. 6. The Plaintiff has not participated as a party or witness, or in any other capacity in any other litigation concerning the custody of the child in this or any other Court. The Plaintiff has no information of a custody proceeding concerning-the child pending in a County of this Commonwealth. The Plaintiff does not know of a person nor a party to the proceedings who has physical custody of the child or claims to have custody or visitation with respect to the child. 7. The Plaintiff is requesting, primary physical and legal custody of the minor child, Piper Quinn, (b. 6/2/98). 8. The best interest and permanent welfare of the child will be served by granting the relief requested because: a.- The Plaintiff has been the primary physical custodian of the minor child since birth. b. It is in the best interests and welfare of the minor child to reside with Plaintiff/Mother. ~ d WHEREFORE, the- Plaintiff/Mother requests the Court to grant physical custody to the PlaintiffJMother and visitation rights to the Defendant/Father every other weekend. Respectfully submitted, 1 Kevin G. Robinson, Esq. ROBINSON & KOENIG 60 East Middle Street Gettysburg, PA 17325 (717) 334-3341 PA I.D.#49676 IN THE COURT OF COMMON PLEAS OF COMBERLAND COUNTY, PENNSYLVANIA CIVIL - LAW Tammy Rolman, Plaintiff CASE NO.: v. Custody Action Shea D. Quinn, Defendant VERIFICATION I verify that the statements made in the aforegoing COMPLAINT IN CUSTODY are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. 5 July 2001 Date Tammy Holman r ~~8 z~ r l~ c c- -- C ~ -_ ~~- _ ~_ ~„ ~ ; ~+~~ ~ gzoox~ TAMMY HOLMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION -LAW SHEA D. QUINN, NO.Ol - 4315 CIVIL Defendant IN CUSTODY COURT ORDER ti~ AND NOW, this ~3 day of August, 2001, the conciliator being in attendance at a custody conciliation conference and the attorney for the Plaintiff having left word with the Court Administrator that the matter is now settled, the conciliator relinquishes jurisdiction. BY THE COURT, Hubert X ilroy Custod Conciliator