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HomeMy WebLinkAbout03-6530TAMMY M. SHERMAN, Plaintiff V. DAVID S. SHERMAN Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. ~ '-/.~iD CIVIL TERM : IN CUSTODY COMPLAINT FOR CUSTODY The plaintiff is Tammy M. Sherman, residing at 24 Tunbridge Lane, Carlisle, Cumberland County, Pennsylvania 17013. The defendant is David S. Sherman, residing at 59 Partridge Circle, Carlisle, Cumberland County, Pennsylvania 17013. Plaintiff seeks custody of the following child: Name Presem Residence DOB Age Alycia M. Sherman 24 Tunbridge Lane 4/23/1991 12 Carlisle, PA 17013 The child was bom out of wedlock The child is presently in the custody of Tammy M. Sherman, residing at 24 Tunbridge Lane, Carlisle, Cumberland County, Pennsylvania 17013. During the past five years, the child has resided with the following persons and at the following addresses: List All Persons David & Tammy Sherman Tammy Sherman List All Addresses 59 Partridge Circle Carlisle, PA 17013 24 Tunbridge Lane Carlisle, PA 17013 Dates 3/1995 to 8/2003 8/2003 to present 10. The mother of the child is Tammy M. Sherman, residing at 24 Tunbridge Lane, Carlisle, Cumberland County, Pennsylvania 17013. She is married. The father of the child is David S. Sherman, residing at 59 Partridge Circle, Carlisle, Cumberland County, Pennsylvania 17013. He is married. The relationship of plaintiff to the child is that of mother. The plaintiff currently resides with the following persons. Name Relationship Thomas & Doris Wickard Parents The relationship of defendant to the child is that of father. The defendant currently resides with the following persons. Name Relationship Himself 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. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know ora person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. The best interest and permanent welfare of the child will be served by granting the relief request because: Plaintiff has undertaken and performed the primary parental responsibilities for the child. Plaintiff is best able to provide the care and nurture which the child needs for healthy development. 11. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim N/A WHEREFORE, Plaintiff requests this Court grant Plaintiff primary physical custody with visitation with Father as agreed upon. Respectfully submitted ROMINGER & BAYLEY Mark F. Bayley, Esquire" 155 S. Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 87663 Attorney for Plaintiff VERIFICATION I verify that the statements made in this complaint are tree and correct. I understand that false statements herein are made subject to the penalties of 18 ]?a. Cons. Stat. § 4904 relating to unswom falsification to authorities. Tammy ~. Sherman, Plaintiff TAMMY M, SHERMAN PLAINTIFF V. DAVID S. SHERMAN DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-6530 CIVIL ACTION LAW IN CUSTODY ORDER OFCOURT AND NOW, Tuesday, December 23, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. _, the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, January 15, 2004 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effbrt will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow tbe 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 hearinl~. FOR THE COURT. By: /s/ Hubert X. Gilroy, Esq. 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 SttOULD TAKE TItlS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, (30 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 TAMMY M. SHERMAN, Plaintiff DAVID S. SHERMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 03-6530 CIVIL : IN CUSTODY COURT ORDER AND NOW, this ~day of January, 2004, the conciliator being advised that the parties have reached an agreement and there is no need for the conciliation conference scheduled in this case, the conciliator relinquishes jurisdiction. BY THE COURT, Hubert X. Gilroy,/Igsqulre Conciliator ~/ TAMMS' M. SHERMA, Plaintiff DAVID S. SHERMAN Defendant ' N 1N THE COURT OF COMMOi PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -. LAW NO. 03-6530 - CIVIL TERM LAW : IN CUSTODY STIPULATION REGARDING CUSTODY-VISITATION Plaintiff, Tammy Sherman, hereinafter referenced as Mother, and Defendant, David Sherman, hereinafter referred to as Father, hereby agree to the entry of the following terms in a Court Order defining custody and partial custody rights and responsibilities in relation to the parties' minor child, Alycia Sherman, bom April 23, 1991, hereinafter referenced as Child: 1. Shared legal custody of Child as contemplated b.y the Act of November 5, 1984. P.S. §1001, et seq., is awarded to Mother and Father. 2. Primary physical custody of the Child is awarded to Mother subject to visitation by Father at such times as the parties from time to time agree. 3. Plaintiff and Defendant agree to withdraw the request for a conciliation on the matter, which is scheduled for January 15, 2004. Date Date_]- David S. Sherman