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HomeMy WebLinkAbout03-5967JOHN C. WHITE and DEBORAH H. WHITE, Plaintiffs GARY L. SHUTT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiffs are John C. Wtfite and Deborah H. White, who reside at 1077 York Road, Dillsburg, Cumberland County, Pennsylvania 17019. 2. Defendant is Gary L. Shutt, last residing at 4440 Pine Hill Road, Dover, York County, Pennsylvmfia 17315. 3. Plaintiffs seek custody of the following child: Name Present Address Age Hollibeth Ann Shutt 1077 York Road 14 Dillsburg, PA 17019 D.O.B. 9-19-89 4. The child was not bom out of wedlock. The child is presently in the custody of John C. White and Deborah H. White who reside at 1077 York Road, Dillsburg, Cumberland County, Permsylvatfia 17019. 5. During the past five (5) years, the child has resided with the following persons at the following address(es): Name a. Jotm C. Wtfite Deborah H. White Address 1077 York Road Dillsburg, PA 17019 Dates 11/8/03 - present February 7. Gary L. Shutt (father) 4440 Pine Hill Road Sharon Shutt (stepmother) Dover, PA 17019 Theodore Amdt (stepbrother) Gary L. Shutt (father) 900 Fickes Road Annette M. Shutt (mother) Dillsburg, PA 17019 Kyle L. Lobo (Annette Shutt's nephew) Walter Lobo (Kyle's father) Mary C. White (grandmother) Heather Shutt (sister) Shawn P. Shutt (brother) 2000 - 11/8/03 The mother of the child is Annette Made Shutt. She is deceased. She died on 1, 2001. She was married. The father of the child was last residing at 4440 Pine Hill Road, Dover, Pennsylvania. He is married. He is traveling for at least six (6) weeks for long distances during track driver training. 8. currently resides with the following persons: Nmr~ The relationskip of Plaintiff to the child is that of maternal uncle and aunt. Plaintiff with the following persons: Name Relationship Plaintiffs Self Hollibeth Arm Shutt Niece The relationship of Defendant to the child is that of father. Defendant currently resides Relationship No one. He is traveling for truck driving training. Defendant is an employee training with Swift Trucking Company on the road as a long distance truck driver. 2 10. Plaintiffs have 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. 11. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 12. 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. 13. The best interest and permanent welfare of the child will be served by granting the relief requested. Defendant Father has requested Plaintiffs to assume custody ofHollibeth. A tree and correct original of said document authorizing the custody transfer is attached hereto as Exhibit 14. 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, Plaintiffs request the Court to enter an Order granting them custody of Hollibeth Ann Shutt. Dated: November 13, 2003 Respectfully Submitted, REAGER & ADI.FR, PC on I.D. No. 36461 ~ 2331 Market Street \ Camp Hill, PA 17011 (717) 232-2103 VERIFICATION We,~-0~}5 ~. b,)~'~_ and~oq[hoC(~ ~. ~,'& , hereby verify and state that the facts set forth in the foregoing pleading are tree and correct to the best of our information, knowledge and belief. We understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn ver'fficat~on' to authorities.' ' I, Ga~ Lee Shutt, being sole custodian of my daughter, Hollibeth Ann Shutt, do hereby grant permission to John C. White and Deborah H. White to start proceedings to take legal custody of my daughter, Hollibeth Until final court papers can be finalized, this is to serve as legal notice that effective immediately, November 10, 2003, John and Deborah White will have full custody of Hollibeth Shntt. They will be contacting their lawyer today, so that paperwork can be started and forwarded to me. Name (Printed) ig ature:. Nme(Printed) Date: Date: Date: Date: Date: Date: JOHN C. WHITE and DEBORAH H. WHITE, Plaintiffs GARY L. SHUTT, Defendant IN THE COURT OF' COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. c'D3-- ~(~ CIVIL ACTION - LAW IN CUSTODY ORDER AND NOW, this ]~ day of ~ ~ _, 2003, upon review of the attached Complaint for Custody and the notarized agreement attached thereto, it is hereby ORDERED and DECREED that John C. White and Deborah H. White shall have primary physical and legal custody of the minor child, Hollibeth Ann Shutt.