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Home My WebLink About07-4252Jeffrey B. Engle, Esquire SHAFFER & ENGLE LAW OFFICES 129 Market Street Millersburg, PA 17061 717-692-2345 * phone 717-692-3554 * fax j eff@shafferengle.com KATHY LYNN BROOKS, Petitioner vs. ELISHA A. STONER and JOSHUA B. HILEMAN, Respondents IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. O ? - y~zs'.t ~.c.~,1 ~.~~ CIVIL ACTION -LAW 1N CUSTODY CUSTODY COMPLAINT & STIPULATION 1. Plaintiff is KATHY LYNN BROOKS, an adult individual currently residing at 5 Park Street, Mt. Holly Springs, Cumberland County, Pennsylvania, 17065. 2. Defendants are ELISHA A. STONER, an adult individual currently residing at 279 B. E. Pomfret Street, Carlisle, PA Cumberland County, Pennsylvania, 17013, and JOSHUA B. HILEMAN, an adult individual currently residing at 490 S. Columbus Ave, Littlestown, PA 17340. 3. Plaintiff seeks custody of the following children: Name Present Residence Ate. ee Sierra Lynn Hileman 5 Park Street 1 month (DOB 5/24/07) Mt. Holly Springs, PA 17065 The child was born in wedlock. The child is presently in the custody of Petitioner, Kathy Lynn Brooks, paternal grandmother, who: resides at 5 Park Street, Mt. Holly Spring, PA 17065. During the child's lifetime she has resided with the following persons at the following addresses: Name Address Date Kathy Lynn Brooks Elisha A. Stoner Destiny A. Hileman-sister Kathy Lynn Brooks 279B Promfret Street Carlisle, PA 17013 5/24/07 - 6/15/07 5 Park Street 6/15/07 -present Mt. Holly Springs, PA 17065 The mother of the child is Elisha A. Stoner who currently resides at the addressed noted in paragraph 2. The father of the child is Joshua B. Hieeman, who currently resides at the address noted in paragraph 2. 4. The relationship of Petitioner to the child is that of paternal grandmother; the Petitioner currently resides with the child. 5. The relationship of Respondent, Elisha A. Stoner, to the child is that of natural mother, who currently lives with Destiny A. Hileman. 6. The relationship of Respondent, Joshua B. Hileman, to the child is that of natural father, who currently lives with his girlfriend (name unknown). 7. Petitioner has rnot participated as a party or witness, or in another capacity in other litigation concerning the custody of the child in this or another court. Petitioner has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 8. Petitioner does not know of a person not a party to the proceeding who has physical custody of the child, or claims to have custody or visitation rights with respect to the child. 9. The Petitioner and Respondent have agreed upon custody of the child and have executed the original attached Stipulation for consideration by the Court for entry of an Order. 10. The best interest and permanent welfare of the child will be served by granting the relief requested. WHEREFORE, Petitioner seeks entry of the attached Stipulation as an Order of Court. Respectfully submitted, Dated: r SHA~rFFER~~iC GLE LAW OFFICES 129 Marke reet Millersburg, PA 17061 (717) 692-2345 Attorney for Petitioner KATHY LYNN BROOKS, Petitioner vs. s-ha~U~,e ELISHA A. S~~ErR and JOSHUA B. HILEMAN, Respondents IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION -LAW IN CUSTODY CUSTODY STIPULATION AND NOW, this ~-day of ~/ L _, 2007, KATHY LYNN BROOKS, the Pa--r~~a~ s~wa ~l grandmother of the minor child LYNN HEILMAN, and ELISHA A. s-raauFc ST6NER, natural mother, and JOSHUA B. HILEMAN, the natural father of the minor child, hereto stipulate and agree as follows: s~~~ SOLE LEGAL CUSTODY of the minor child, ~fi~E-I~ZA LYNN HEILMAN, DOB 5/24/07, shall be with Grandmother, KATHY LYNN BROOKS, which will include decision making with regards to important matters such as education, medical care, religious training, etc. 2. SOLE PHYSICAL CUSTODY of the minor child shall be with Grandmother, KATHY LYNN BROOKS. 3. This STIPULATION shall be entered as an Order of Court. Wi ness T L BROOKS ELISHA A. S~'$1'dE~ sta{~J~e.. S UA B. HILEMAN L~- Witne ~ VERIFICATION I verify that the averments in this Custody Complaint and Stipulation 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: 7~~~ C~ b~ ..._ ~ '~ ray r {yZ r..~ ~_~ v 8 - _., ~ , ~ ~~; ~ v 1 O ~ ~ b ~> ~ :a t'' ~- ~` ~ ~~ .~. - -~ Jeffrey B. Engle, Esquire SHAFFER & ENGLE LAW OFFICES 129 Market Street Millersburg, PA 17061 717-692-2345 * phone 717-692-3554 * fax Jeff a~shafferengle.com KATHY LYNN BROOKS, Petitioner vs. ELISHA A. STARNER and JOSHUA B. HILEMAN, Respondents IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ~~ - '~o~, 5 c~ L.i vi l ~j-+e~m CIVIL ACTION -LAW 1N CUSTODY CUSTODY COMPLAINT & STIPULATION 1. Plaintiff is KATHY LYNN BROOKS, an adult individual currently residing at 5 Park Street, Mt. Holly Springs, Cumberland County, Pennsylvania, 17065. 2. Defendants are ELISHA A. STARNER, an adult individual currently residing at 279 B. E. Pomfret Street, Carlisle, PA Cumberland County, Pennsylvania, 17013, and JOSHUA B. HILEMAN, an adult individual currently residing at 490 S. Columbus Ave, Littlestown, PA 17340. 3. Plaintiff seeks custody of the following children: Name Present Residence Age Serra Lynn Hileman 5 Park Street 1 month (DOB 5/24/07) Mt. Holly Springs, PA 17065 The child was born in wedlock. The child is presently in the custody of Petitioner, Kathy Lynn Brooks, paternal grandmother, who resides at 5 Park Street, Mt. Holly Spring, PA 17065. During the child's lifetime she has resided with the following persons at the following addresses: Name Kathy Lynn Brooks Elisha A. Starner Destiny A. Hileman-sister Kathy Lynn Brooks Address 279B Promfret Street Carlisle, PA 17013 5 Park Street Mt. Holly Springs, PA 17065 Date 5/24/07 - 6/15/07 6/ 15/07 -present The mother of the child is Elisha A. Starner who currently resides at the addressed noted in paragraph 2. The father of the child is Joshua B. Hielman, who currently resides at the address noted in paragraph 2. 4. The relationship of Petitioner to the child is that of paternal grandmother; the Petitioner currently resides with the child. 5. The relationship of Respondent, Elisha A. Starner, to the child is that of natural mother, who currently lives with Destiny A. Hileman. 6. The relationship of Respondent, Joshua B. Hileman, to the child is that of natural father, who currently lives with his girlfriend (name unknown). 7. Petitioner 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. Petitioner has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 8. Petitioner does not know of a person not a party to the proceeding who has physical custody of the child, or claims to have custody or visitation rights with respect to the child. R. The Petitioner and Respondent have agreed upon custody of the child and have executed the original attached Stipulation for consideration by the Court for entry of an Order. 10. The best interest and permanent welfare of the child will be served by granting the relief requested. WHEREFORE, Petitioner seeks entry of the attached Stipulation as an Order of Court. Dated: ,U Respectfully submi Jeff gle, E ire I. 0 6644 ER & E LAW OFFICES 129~Market tre Millersburg, A 17061 (717) 692-2345 Attorney for Petitioner KATHY LYNN BROOKS, Petitioner vs. s-t~a~,v~,e ELISHA A. ~£rR and JOSHUA B. HILEMAN, Respondents IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION -LAW IN CUSTODY CUSTODY STIPULATION AND NOW, this _ day of ~/ ~ , 2007, KATHY LYNN B] Pa-r~.wAt. sue. x~~al grandmother of the minor child LYNN HEILMAN, and ELISHA STA~V~ S F~~?d~R, natural mother, and JOSHUA B. HILEMAN, the natural father of the m hereto stipulate and agree as follows: stv~ SOLE LEGAL CUSTODY of the minor child, -StA LYNN HEILMAN 5!24/07, shall be with Grandmother, KATHY LYNN BROOKS, which will decision making with regards to important matters such as education, medic religious training, etc. 2. SOLE PHYSICAL CUSTODY of the minor child shall be with Grandmotht LYNN BROOKS. 3. This STIPULATION shall be entered as an Order of Court. ELISHA A. ST-~FE•R ~~z.~~2. ., Wi Hess S UA B. HILEMAN ,.. r ~~ Witne ;~, . ~~ VERIFICATION I verify that the averments in this Custody Complaint and Stipulation 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: ?~~~ .,,,,. r~s c~ c~ ~ ~-; "`.' +~ -` ~~ ~.~ ~ °,~, th.:,: r W a ~, ~.~- ~* ~' ~ ~ ?~ ~ ~ vt't t V C,~'i C~ ~ CIS -G KATHY LYNN BROOKS, Petitioner vs. ELISHA A. STARNER and JOSHUA B. HILEMAN, Respondents IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0'7- Hasa C:ivi 1 TerM CIVIL ACTION -LAW IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint and Stipulation, the attached ~~ ~ s Stipulation is made an Order of Court this 30 day of '~ , 2007. FOR THE COURT, Date 7 3D 0`7 Distribution: ~frey B. Engle, Esq. 129 Market Street, Millersburg, PA 17061 * 717-692-2345 (P) 717-692-3554(F) * Jeff@shafferengle.com ~hua B. Hileman 490 S. Columbus Ave, Littlestown, PA 17340 * 717-359-$268 (P) ~,ksha A. Starner 279B E. Pomfret Street. Carlisle, PA 17013 * 717-701-0946 (P) ~ ' ~~ ~~;~~n~~sN~-~j a r~ Az~1U~vH.~~'d 3t~tl. ~0 ~~i3~~~-t1~3~