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HomeMy WebLinkAbout03-5475DAYNE L. SHANNON, Plaintiff JAMIE K. DUPERT, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : O5" 3-¥75~ CIVIL TERM : IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, Dayne L. Shannon, by his attorneys, Irwin, McKnight and Hughes, and presents the following Complaint for Custody. 1. The Plaintiff, Dayne L. Shannon, is an adult individual with an address of 107 Andrew Court, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant, Jamie K. Dupert, is an adult individual with an address of 270 West Ridge Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties are the natural parents of one (1) child, namely, Tristen D. Shannon, bom June 23, 2001. 4. The Plaintiff seeks custody of the following child: Name Present Address Date of Birth Age Tristen D. Shannon 107 Andrew Court June 23, 2001 2 Years Carlisle, PA 17013 The child was born out of wedlock. The child is presently in the custody of the Plaintiff, Dayne L. Shannon. 7. During the past 2 years, the child has resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Dayne L. Shannon 270 West Ridge Avenue 06/23/01 to 06//25/03 Jamie K. Dupert Carlisle, PA 17013 Dayne L. Shannon 107 Andrew Court 06/25/03 to the present Carlisle, PA 17013 8. The mother of the child is Jamie K. Dupert, currently residing at 270 West Ridge Street, Carlisle, Pennsylvania 17013. She is unmarried. 9. The father of the child is Dayne L. Shannon, currently residing at 107 Andrew Court, Carlisle, Cumberland County, Pennsylvania 17013. He is unmarried. 10. The Plaintiff desires that the parties have shared legal custody of the minor child, Tristen D. Shannon. 11. The Plaintiff desires primary physical custody of the minor child, Tristen D. Shannon, with periods of temporary physical custody to Defendant as the parties agree. 13. The best interests and permanent welfare of the minor child requires that the Court grant the Plaintiff's request as set forth above. WHEREFORE, Plaintiff, Dayne L. Shannon, respectfully requests that he be awarded primary physical custody and shared legal custody of Tristen D. Shannon, as provided herein, with periods of temporary physical custody to Defendant as provided herein. Date: October 13, 2003 Respectfully submitted, IRWIN, McKNIGHT & HUG HE$ Marchs A~. M~g_hy III, Es~ uire Attorney for Pl~int~TF 60 Westj Carlisle, Pennsylvania~[71Yl 3-3222 (717) 249-2353 Supreme Court I. D. No. 25476 VER/FICATION The foregoing Complaint for Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have head the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. DAYNEL. SHANNON Date: OCTOBER 13, 2003 DAYNE L. sHANNON PLAINTIFF JAMIE K. DUPERT DEFENDANT AND NOW,. Ti it is hereby directed that parties at 4th Floor, Cumberland ( for a Pre-Hearing Custody Con if this cannot be accomplished, order. All children age five or provide grounds for entry of a The court hereby dire Special Relief orders, and Cu IN IZIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-5475 CIVIL ACTION LAW : IN CUSTODY ORDER OF COURT ursday, October 23, 2003 , upon consideration of the attached Complaint, md their respective counsel appear before J_a_equeiine M. Verney, Esq. , the concili ~untyCourthouse, Carlisle on Tuesday, NovemberlS, 2003 at 9:30 erence. At such conference, an eflbrt will be made to resolve the issues in dispute; to define and narrow the issues to be heard by the court, and to enter into a tempora )lder may also be present at the conference. Failure to appear at the conference ma' emporary or permanent order. :ts the parties to furnish any and all existing Protection from Abuse orders, stody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, M or -y The Court of C{ with Disabilites Act of 19 available to disabled indb must be made at least 72 ] conference or hearing. YOUSHOULI HAVE ANATTORNEY FORTH BELOW TO FI~ By: /s/ facqueline M. Verney. Esq. Custody Conciliator .mmon Pleas of Cumberland County is required by law to comply with the America 70. For information about accessible facilities and reasonable accommodations iduals having business before the court, please contact our office. All arrangement~ tours prior to any hearing or business before the court. You must attend the schedul ) TAKE TItlS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE SE .T D OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 177013 Telephone (717) 249-3166 DAYNE L. SHA. N~qON, Plaintiff JAMIE K. DUPER~I Defen~ AND NOW, SHANNON and JA Agreement regardin The Plaintiff, Carlisle, Cumberland The Defendant, Street, Carlisle, Cumbe The parties are June 23, 2001. The parties agre, The Plaintiff/Fat lant : IN 'IHE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW CIVIL TERM : IN CUSTODY CUSTODY STIPULATION this~ day of ~_~_ a ! , 2003, the parties, DAYNE L. lIE K. DUPERT hereby enter into the following Custody Stipulation and heir minor son, TRISTEN D. SHANNON: 1. ,ayne L. Shannon, is an adult individual who resides at 107 Andrew Court, ~ounty, Pennsylvania 17013. 2. Jamie K. Dupett, is an adult individual who resides at 270 West Ridge rland County, Pennsylvania 17013. 3. the natural parents of one (1) child, namely, Tristen D. Shannon, bom o have shared legal custody of the minor child, Tristen D. Shannon. 5. ~er shall have primary physical custody of Tristen D. Shannon. 2 The Defendm the parties. The parties si to his best interest. The parties sh medical emergency c~ health and well-being parties shall have the r proper medical care of The parties sha injure the opinion of th of the child's love and The parties may child so long as they mt of this Stipulation in on if the parties cannot rea( control. t/Mother shall have temporary physical custody at times as agreed upon by ill provide for custody of Tristen D. Shannon, during all holidays pursuant 11 keep each other advised immediately in the event of serious illness or acerning the child, and shall take any necessary steps to ensure that the )fthe child are protected. During such illness or medial emergency, both ght to visit the child as often as he or she desires consistent with the the child. not do anything that may estrange the child from the other party, or child as to the other party, or hamper the free and natural development ffection for the other party. 10. make such alternate arrangements regarding the physical custody of the / mutually agree. The parties anticipate regularly varying from the terms ~r to accommodate the schedules of each other and the child. However, h a mutual agreement, the terms of this Stipulation and Order shall Any modifica only if made in writing Agreement. The parties de the Court of Common Common Pleas of Cra of the parties' minor shall retain such juris modification of said I The parties ac Agreement. Each part the result of duress or~ Each party has [ selection. Each party re signed it fi'eely and vol~ expressly set forth her 11. :ion or waiver of any other provisions of this Agreement shall be effective and only if executed with the same formality as this Stipulation and 12. fire that this Stipulation and Agreement be made an Order of the Court of Pleas of Cumberland County, and further acknowledge that the Court of ~berland County does, in fact, have jurisdiction over the issue of custody fild who has resided in Cumberland County for more than six months and iction should circumstances change and either party desires or requires 'der. 13. ~owledge that they have read and understand the provisions of this · acknowledges that the Agreement is fair and equitable and that it is not ndue influence. 14. ad an opportunity to consult independent legal counsel of his or her own ards the terms of this Agreement as fair and equitable, and each has tarily without relying upon any representation other than those 4 IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms set forth above, enter their hands and seals the date first set forth above. WITNESSETH: I~, DAYNE L. SHANNON J/~I~ ~.-DUPERT- ~ (SEAL) (SEAL) 5 DAYNE L. SHANNON, Plaintiff JAMIE K. DUPERT, Defend ant · CIVIL ACTION - LAW O3-5'q75- C1VIL TERM IN CUSTODY ORDER OF COURT O~ 2003, upon presentation and consideration of the attached Custodt Stipulation and Agreement, it is hereby Ordered and Directed that it be entered as an Order of ICourt. Jamie K. Dupert Defendant fMarcus A. McKnight, Attorney for P III, Esq. aintiff ~y~the Court, 10-31-CD '~ll,~^lASNhrad NOV 18 2003 DAYNE L. SHANNON, Plaintiff V. JAMIE K. DUPERT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-5475 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this 18th day of November, 2003, being advised that the parties have reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THECOURT, dJacqu~ine M. Vemey, Esquire, Custod~ Conciliator NOV ]7 2003 TERESA L. KAHLER, Plaintiff V EDWARD L. KAHLER, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 2002- 3173 CIVIL : IN CUSTODY COURT ORDER AND NOW, this / Y day of November, 2003, the conciliator being advised that the parties have reached an agreement, the conciliator relinquishes jurisdiction. BY THE COURT, Hubert X. G~...oy, Esquire Custody ~.~ciliator