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
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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
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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