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Home My WebLink About99-06021 Q v Ad ? A I? t4z 0 t,= 4i) 1• _) CJ C O\ VAS s pp Zza Qtr ? W Y CL ? c W ? y r U y? r OCT 0 4 iggj? WILLIAM J. THOMAS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW TINA L. GILMAN, IN CUSTODY , / Defendant NO. W. CCW ORDER OF COURT AND NOW, this ___LL day of 1999, upon stipulation of the parties, it is HEREBY ORDERED AND DECREED that 1. The parties shall share legal custody of the child and each party shall consult with the other concerning all major decisions affecting the child, including but not limited to, health, education and religion. 2. The parties shall share physical custody of the child on an equal basis. At the present time, the parties are following a schedule whereby William J. Thomas has custody of Lauren from Thursday evening through Sunday and Mother, Tina L. Gilman, has custody from Sunday through Thursday. 3. The parties shall share the holidays equally. 4. The parties request the entry of this order of Court. 5. It is agreed between the parties that while the outlined schedule may vary and the parties agree to modify this Order as they mutually agree for and in the best interest of Lauren. BY THE COURT: J. 21640.1 S CST I ! I: 13 WILLIAM J. THOMAS, Plaintiff V. TINA L. GILMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY NO. e4_ 40. 21 Oc;, F STIPULATION AND NOW, this day of SP Pr?,?j?/2 1999, William J. Thomas, Plaintiff, together with his attorney, Sandra L. Meilton, and Tina L. Gilman, Defendant, hereby inform your Honorable Court that they have amicably resolved to their mutual satisfaction the issues of custody pertaining to Lauren Nicole Gilman, born January 27, 1998, and do hereby stipulate that the following is the substance of their agreement respectfully requesting that your Honorable Court issue an appropriate Order of custody and visitation in accordance with their agreement and stipulation. The parties stipulate as follows: 1. The parties shall share legal custody of the child and each party shall consult with the other concerning all major decisions affecting the child, including but not limited to, health, education and religion. 2. The parties shall share physical custody of the child on an equal basis. At the present time, the parties are following a schedule whereby William J. Thomas has custody of Lauren from Thursday evening through Sunday and Mother, Tina L. Gilman, has custody from Sunday through Thursday. 3. The parties shall share the holidays equally. 4. The parties request that this Stipulation be entered as an Order of Court. 5. It is agreed between the parties that while the outlined schedule may vary and the parties agree to modify this Order as they mutually agree for and in the best interest of Lauren. illiaThomas ?SW t Tina L. Gilman o m -- `\l s WOO?n.? Z ? ? z h O z a? H WILLIAM J. THOMAS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW TINA L. GILMAN, IN CUSTODY Defendant NO, ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Custody Conference Officer, on the day of _ 1999, at .m. at Pennsylvania, 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 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, at the request of either attorney or party, be present at the Conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT, Date of Order: By: Custody Conference Officer 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. Court Administrator 41h Floor, Cumberland County Courthouse Carlisle, PA 17013 Telephone No. (717) 240-6200 WILLIAM J. THOMAS, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW TINA L. GILMAN, : IN CUSTODY ? ® Defendant NO. q. ly0a / Gc/ftir COMPLAINT FOR CUSTODY 1. The Plaintiff is William J. Thomas, residing at 5200 Cobblestone Drive, Mechanicsburg, Pennsylvania 17055. 2. The Defendant is Tina L. Gilman, residing at 441 South Front Street, Steelton, Dauphin County, Pennsylvania 17113. 3. Plaintiff seeks shared legal and shared physical custody of Lauren Nicole Gilman, born January 27, 1998. The child was bom out of wedlock. The child is presently in the shared custody of both Plaintiff and Defendant residing at the above addresses. At the present time, the parties are following a schedule whereby William J. Thomas has custody of Lauren from Thursday evening through Sunday and Tina L. Gilman, has custody from Sunday through Thursday. Since birth, the child has resided with the following persons and at the following addresses: From Birth to 1/3/99 With Plaintiff and Defendant at 74 Kensington Drive, Camp Hill, PA From 1/3/99 to Present Sharing custody equally between the parties as set forth above. The mother of the child is Tina L. Gilman, currently residing at 441 South Front Street, Steelton, Dauphin County, Pennsylvania. She is single. The father of the child is Frederick F. Dater, 2510 Derry Street, Harrisburg, Dauphin County, Pennsylvania. Mr. Zlater's Consent to the schedule of custody between Plaintiff and Defendant concerning Lauren Nicole Gilman is attached hereto. He is single. 4. The relationship of Plaintiff to the child is that of Father in loco parentis. The Plaintiff currently resides with his girlfriend, Meredith Frank, and Lauren. 5. The relationship of Defendant to the child is that of Mother. The Defendant currently resides with Lauren. 6. Plaintiff has 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. Plaintiff has no information of a custody proceeding concerning the child 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 child or claims to have custody or visitation rights with respect to the child, other than Frederick F. Zlater, whose consent is attached hereto. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: a. Plaintiff has been actively involved in the child's daily activities since her birth; and b. The parties have agreed to and have been carrying out the custodial arrangement discussed in this Complaint and have executed a Stipulation setting forth their agreement. 8. The Plaintiff and Defendant have entered into a Stipulation which is being filed with the Court simultaneously with this Complaint for Custody. WHEREFORE, Plaintiff requests the court to grant shared legal and shared physical custody of the child to him. Sandra L. Meilton, E quire TUCKER ARENSBERG & SWARTZ 111 North Front Street, P.O. Box 889 Harrisburg, PA 17108-0889 (717) 234-4121 ATTORNEYS FOR PLAINTIFF 13554.1 VERIFICATION I, the undersigned, William J. Thomas, acknowledge that the facts stated in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unswom falsification to authorities. Dated: Cj 3v 9q &Jji /J,-- "Z' William J. Thomas CONSENT BY NATURAL FATHER I, Frederick F. Zlater, the natural father of Lauren Nicole Gilman, hereby confirm and consent to the shared legal and shared physical custodial arrangement for Lauren Nicole Gilman, established and agreed to between Tina L. Gilman, Lauren's natural mother, and William J. Thomas. Further, I hereby waive my right to receive notice of any hearing in connection with this matter. Dated: 1?-QOl Fre en i(F. lat r? z164s.1