HomeMy WebLinkAbout99-06243?.,0
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BARBARA A. SHOWERS,
Plaintiff
V.
DANIELLE L. ECKERT and
JOHN RICHARDS,
Defendants
:IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
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:NO. -1'l - 1;c f16 &
:CIVIL ACTION -LAW
:IN CUSTODY
The Plaintiff is Barbara A. Showers ("Grandmother') who resides at 2114 Beacon
Circle, Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. The Defendant is John Richards ("Father') who resides at 125 Jamestown Road,
Apt. D, Ocean City, Maryland 21842.
3. The Defendant is Danielle L. Eckert ("Mother) who resides at 2114 Beacon
Circle, Mechanicsburg, Cumberland County, Pennsylvania 17055.
4. The child was bom out of wedlock. The child is presently in the custody of
Grandmother.
5. During the past five (5) years, the child has primarily resided with the following
persons at the following addresses:
NIL= Address Approx. Dates
Barbara A. Showers 2114 Beacon Circle 8/98 to present
Danielle L. Eckert Mechanicsburg, PA 17055
6. The mother of the child is Danielle L. Eckert. She is single.
The father of the child is John Richards. He is single.
S. The relationship of Plaintiff to the child is that of maternal grandmother. She
resides with Danielle L. Eckert and Kiera M. Richards.
9. The relationship of Defendant John Richards to the child is that of father.
10. The relationship of Defendant Danielle L. Eckert to the child is that of mother.
11. Plaintiff has not participated as a party or a witness, or in any other capacity in
other litigation concerning the custody of the child in this or any other Court.
12. Plaintiff has no information of a custody proceeding concerning the child pending
in a court of this Commonwealth.
13. 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.
14. The best interest and permanent welfare of the child will be served by granting the
relief requested.
15. Each parent whose parental rights to the child has not been terminated have been
named as parties to this action.
WHEREFORE, Plaintiff requests the Court to grant her custody of the child.
Respectfully submitted,
BY:
EMILY L. H FFMAN, ESQUIRE
Suprcme Coun LDA 66307
105 North Front Street
Post Office Box 11475
Harrisburg, PA 17108-1475
(717) 233-1112
Attorney for Plaintiff
DATED: 9/4/99
84151.1
1, EMILY LONG HOFFMAN, on behalf of Plaintiff due to time constraints, hereby
verifies and states that to the extent that the foregoing document contains facts supplied by me,
they are true and correct to the best of my knowledge, information and belief, however, to the
extent that the foregoing document and/or its language is that of counsel, I have relied upon
counsel in making this Verification.
I understand that false statements made herein are subject to the penalties of IS Pa.C.S.A.
§4904, relating to unsworn falsification to authorities.
G??LA,?
Emily Long Hoffman
DATED: 91.11,1/y
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BARBARA A. SHOWERS, :IN THE COURT OF COMMON PLEAS
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
V. :NO. qf- A;w3
DANIELLE L. ECKERT and :CIVIL ACTION -LAW
JOHN RICHARDS, :IN CUSTODY
Defendants
AND NOW, this -i flay of ndlo (t, f , 1999, it is hereby
ORDERED and DECREED that the attached Stipulation executed by the above parties on
September 30, 1999, is hereby rendered arl O ER of Court. S o plo w) ?
GU-c (a. 7 QJclw J By t c court:
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BARBARA A. SHOWERS,
Plaintiff
V.
DANIELLE L. ECKERT and
JOHN RICHARDS,
Defendants
:IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
NO.
:CIVIL ACTION -LAW
:IN CUSTODY
AND NOW, this day of Qq?c? , 1999, the parties
hereby agree that the following shall be entered as an Order of Court:
1. Barbara A. Showers, Plaintiff, shall have full legal and physical custody of the
minor child, Kicra M. Richards, bom August 2, 1998.
2. Defendants Danielle L. Eckert and John Richards shall have rights of visitation
at the times as agreed upon by Barbara A. Showers.
3. Defendant John Richards shall continue to pay child support and all medical
expenses for the child and Danielle L. Eckert will remit the payment to Barbara A. Showers.
4. This Order shall remain in effect until Dr. Robin Miller verifies that Danielle
L. Eckert is capable of caring for the minor child and of assuming custody of the child.
5. This Agreement may be executed in counterparts, each of which shall be an
original and which together shall constitute one and the same instrument.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals.
f)a . ?
Barbara A. Showers 11
IN WITNESS WHEREOF, the parties hereto have set their hands and seals.
V
IN WITNESS WHEREOF, the parties hereto have set their hands and seals.
Witness Danielle L. Eckert
BARBARA A. SHOWERS,
Plaintiff
V.
DANIELLE L. ECKERT and
JOHN RICHARDS,
Defendants
:IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
:NO.
:CIVIL ACTION -LAW
:IN CUSTODY
AND NOW, comes Plaintiff, Barbara A. Showers, by and through her attorney, Emily
Long Hoffman, and in support of her motion avers as follows:
1. The parties have executed the attached stipulation.
2. Plaintiff requests that this Honorable Court render the Stipulation an Order of Court.
WHEREFORE, Plaintiff requests that this Honorable Court grant her request to render
stipulation order of court.
esPcctfull/y'submitted,
Emily Long Hoffman, Esquirc
Sup. Ct. ID N 66307
105 North Front Street
Date: I0II/C',
Harrisburg, PA 17108
(717)233-1112
Attorney for Plaintiff
MOTION
CERTIFICATE OF SF.RVI
1 hereby certify that a true and correct copy of the document was served upon the
following person by U.S. Mail mailed on this day:
Ms. Danielle L. Eckert
2114 Beacon Circle
Mechanicsburg, PA 17055
Mr. John Richards
125 Jamestown Road
Apt. D
Ocean City, Maryland 21842
tfully subm'it'ted,
By: Cam(
Emily Long Ho fman, Esquire
Sup. Ct. ID N 66307
105 North Front Street
P.O. Box 11475
Harrisburg, PA 17108
(717)233-1112
Date: 1018199
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