HomeMy WebLinkAbout03-5658SHELLEY R. HEINZIG,
Plaintiff,
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY
COMMONWEALTH OF PENNSYLVANIA
:
: Civil Action At Law---Custody
: Case No. (~
VS. :
ANTHONY L. SMURO, :
Defendant, :
COMPLAINT FOR CUSTODY
1. The plaintiff is Shelley R. Heinzig, residing at 1067 Nanroc Dr. Mechanicsburg
17055, in the County of Cumberland, Commonwealth of Pennsylvania,
The defendant is Anthony L. Smuro, currently residing at 119 N. Enola Dr.
Enola, PA. 17025 County of Cumberland.
3. Plaintiff seeks custody of the following child:
Name Address Age
Anthony J. Smuro 1067 Nanroc Dr.. 9/26/2000 3 Years
Mechanicsburg, PA. 17055
4. The child was bom outside of wedlock.
5. The child is presently in the custody of
plaintiff Shelley R. Heinzig, who
resides at 1067 Nanroc Dr. Mechanicsburg 17055, in the County of Cumberland,
Commonwealth of Pennsylvania,
6. The child has resided with the mother since birth and currently resides at 1067
Nanroc Dr. Mechanicsburg 17055, in the County of Cumberland, Commonwealth of
Pennsylvania,
7. The biological mother of the child is Shelly R. Heinzig, who currently resides at
1067 Nanroc Dr. Mechanicsburg 17055, in the County of Cumberland, Commonwealth
of Pennsylvania.
8. The mother has been separated from the father since June of 2001, and is currently
unmarried to the same.
9. The father of the child is Anthony L. Smuro, currently residing at 119 N. Enola
Dr. Enola, PA. 17025 County of Cumberland.
10. The father is separated and remains unmarried to the mother.
11. The relationship of the plaintiff to the child is that of a biological Mother. The
Plaintiff currently resides with the following persons:
Name Relationshil~
Jason W. Heinzig Husband
Anthony Smuro Son
Colby Ruth Son
12. The 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.
13. The plaintiff has no other information of a custody proceeding concerning the child
Pending in a Court of this Commonwealth.
14. Plaintiffdoes 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.
WHEREFORE, Plaintiff, Shelley R. Heinzig, respectfully requests for the
aforementioned reasons, that the court grant and award him Sole Primary Physical
custody of the child Anthony.l. Smuro.
GREGORY S. HAZLETT
20 S~(uth Market~gtreet
Mechanicsburg, PA. 17055
(717) 790-5500
VERIFICATION
I verify that the statements made in this 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 unswom falsification to authorities
g, PlaintffO ~,.)
SHELLEY R. HEINZIG
PLAINTIFF
ANTHONY L. SMURO
DEFENDANT
AND NOW, _ T
it is hereby directed that partie
at 39 West Main Street,
for a Pre-Heating Custody Co]
if this cannot be accomplished
order. All children age five o~
provide grounds for entry of a
The court hereby dir
Special Relief orders, and C
The Court of
with Disabilites Act of
available to disabled ind
must be made at least 72
conference or hearing.
YOU SHOUI
HAVE AN ATTORNE~
FORTH BELOW TO FI
: 1N THE COURT OF COMMON PLEAS OF
: CUMBERLAND cOUNTY, PENNSYLVANIA
: 03-5658 CIVIL ACTION [,AW
IN CUSTODY
ORDER OF COURT
mrsday, October 30, 2003 , upon consideration of the attached Complaint,
~ and their respective counsel appear before _ Dawn S. Sunday, Esq. , the conci
fleehaniesbur§, PA 17055 on Tuesday, December 02, 2003 at 8:30
tference. At such conference, an effort 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 tempm
older may also be present at the conference. Failure to appear at the conference m
temporary or permanent order.
~ets 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,
By: /s/
Dawn S. Sunday. Esq.
Custody Conciliator
ommon Pleas of Cumberland Cotmty is required by law to comply with the Amerk
790. For information about accessible facilities and reasonable accommodations
viduals having business before the court, please contact our office. All arrangeme~
hours prior to any heating or business before the court. You must attend the sched
D TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
· OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
qD OUT WHERE YOU CAN GET LEGAL. HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
iator,
; or
ary
aris
ts
~led
SHELLEY R. HEINZIG
Plaintiff
VS.
IN THE COGRT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
03-5658 CIVIL ACTION LAW
ANTHONY L. SMURO
Defendant
IN CUSTODY
ORDER
AND NOW, this 12TM day of November~ 2003 , the conciliator, being advised by
counsel that a related petition has been assigned to another conciliator, hereby relinquishes jurisdiction
to facilitate the consolidation of both petitions. The Custody Conciliation Conference scheduled for
December 2, 2003, is cancelled.
FOR THE COURT,
Custody Conciliator