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Home My WebLink About07-3435 SUSAN HINDERLITER, Plaintiff vs. THOMAS M. SHOEMAKER, JR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. a 7 3~ 3 ~ Civil Term ACTION IN CUSTODY CUSTODY COMPLAINT 1. Plaintiff is Susan Hinderliter, who resides at 76 Partridge Circle, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Thomas M. Shoemaker, Jr., who currently resides at 445 B. Longs Gap Road, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff is the mother of the following child and seeks a custody order regarding the following child: NAME DOB ADDRESS Callie Courtlyn Hinderliter 1/15/07 76 Partridge Circle Carlisle, Pa. 17013 Mother and Father were never married. Mother currently has primary physical custody of the child. During the past five years, the children have resided with the following persons and at the following addresses: NAME ADDRESSES DATES Susan Hinderliter 76 Partridge Circle birth (1/15107) to present Carlisle, Pa. 17013 The mother of the child is Susan Hinderliter. She lives at 76 Partridge Circle, Carlisle, Pa. 17013. She is not married. The father of the child is Thomas M. Shoemaker, Jr. He currently resides at 445 B. Longs Gap Road, Carlisle, Pa. 17013. He is not married. 4. The relationship of plaintiff to the child is that of Mother. The Plaintiff currently lives with the child and maternal grandparents. 5. The relationship of defendant to the child is that of Father. The defendant currently resides alone. 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 other than as follows: On Apri124, 2007, a Protection from Abuse Order was entered against Thomas M Shoemaker Jr by the Honorable Judge M L Ebert Jr under Docket No 07 1711 The P F A provided that Plaintiff has primary custodv of the child and that Defendant would have partial visitation with the child at time and locations a reed upon by the parties Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a party to the proceedings who has physical custody of the child or anyone who 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: The parties separated on March 22 2007 Since that time Mother has had primary custodv of the child She has also been the primary caretaker of the child since birth Mother is seekms an Order which confirms that she has rp imary custodyand provides reasonable periods of partial custodv for Father 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiff requests the court to enter a custody order regarding the child. Date: ~ • `~ Respectfully sub fitted, J Adams, Esquire I 0. 79465 outh Pitt Street Carlisle, Pa. 17013 (717)245-8508 ATTORNEY FOR PLAINTIFF VERIFICATION I verify that the statements made in this Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date. <, ~` ~-~ ~~ Susan Hinderliter, P aintiff 6~ `~ ~ ~ O W ~ d b O W A" ~~, C'~ ~ O K} = ~ r • ~ T ~ C_.i ~.` -t ' _ ~ -r `iC; c _-a ~ N SUSAN HINDERLITER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 07-3435 CIVIL ACTION LAW THOMAS M. SHOEMAKER, JR. 1N CUSTODY DF..FF.,NDANT ORDER OF COURT AND NOW, Thursday, June 14, 2007 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, July 18, 2007 at 2:00 PM 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/ ohn .Man an r. Es . 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~i~ ~`' 1 ~~ ~J fI/'-,°j ~~,~y,.,~lt~n`,,, ~,R~~ F ! ~i L~ ~~ ~~d ~ ~ ~1(` L~~Z F: \FILES112539\ 12539. I . stip 1 /nlm Created: 9/20!04 0:06PM Revised: 7/3/07 11: OOAM 12539.1 Hubert X. Gilroy, Esquire MARTSON DEARDORFF WILLIAMS OTTO GII,ROY & FALLER MARTSON LAW OFFICES I.D. 29943 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant SUSAN HINDERLITER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 07-3435 CIVIL ACTION -LAW THOMAS M. SHOEMAKER, JR., Defendant JURY TRIAL DEMANDED STIPULATION The parties to the above-captioned custody action hereby agree and stipulate that the Court may enter an Order in the form as attached. WITNESS: e Adams, esquire Hubert X. G~'roy, Esquire / DATE: ®~-Qj~-~ Su an Hinderliter _ DATE: ~'l3'~`~ Thomas M. Shoemaker, Jr. ~t ~~ -s~y i ~. t-: ~-t r= ---- ' =, i• j, =, ri ~~ ': =', __ .: ~~ r ~x~ C.,? t,1'1 .~ . I ~ `~ - ~ '~L 18 200 Hubert X. Gilroy, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 29943 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant SUSAN HINDERLITER, Plaintiff v. THOMAS M. SHOEMAKER, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.07-3435 CIVIL ACTION -LAW JURY TRIAL DEMANDED ORDER AND NOW, this ~_ day of , 2007, upon consideration of the attached Stipulation, it is ordered and directed as follow cc 1. The Mother, Susan Hinderliter, and the Father, Thomas M. Shoemaker, Jr., shall enjoy shared legal custody of Callie Courtlyn Hinderliter, born January 15, 2007. 2. The Mother shall enjoy primary physical custody of the minor child. 3. The Father shall enjoy periods of temporary physical custody of the minor child as agreed by the parties. 4. In the event either party desires to modify this Order, that party may petition the Court to have the case again scheduled for a Custody Conciliation Conference. Hubert X. Gilroy, Esquire Jane Adams, Esquire ~' _.:~ .~ ~- t.1.1 =---;~ e.,z-. _ ~,.. ~:1 i - ~ -- . , ..a - ~~ ~_ ~~ i ~ ~~ ~,A~ ~ ~ f~ ~q,, ..3 STIPULATION The parties to the above-captioned custody action hereby agree and stipulate that the Court F.1Fl LES11 _'S39~ I_539.1. slip I ~ nlm Created. 9i]0/Oa O.O6PM Re ris ed. 7 i 3 i 07 11: OOA M I?s99 I Hubert X. Gilroy, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES ~ ~ -,.., LD. 29943 ~ n ~' ~,;- ,~ 10 East High Street -7 - ~_ ~. Carlisle, PA 17013 _.` , r-~;, :~ ~ (717) 243-3341 '~_' ~" c~ ~`'` 7 Attorneys for Defendant - ~ ? ~ r r- _ wia.. '_1 ~" ei,, ~_ ~ ~ rr, SUSAN HINDERLITER, IN THE COURT OF COMMON PI~AS~F ~' Plaintiff CUMBERLAND COUNTY, PENNSYL``~ANTA v. N0.07-3435 CIVIL ACTION -LAW THOMAS M. SHOEMAKER, JR., Defendant JURY TRIAL DEMANDED may enter an Order in the form as attached. WITNESS: e Adams, Esquire DATE: ~~ ' ~~~~ S an Hinderliter DATE: ~ -l3 -~'~ Thomas M. Shoemaker, Jr.