HomeMy WebLinkAbout08-6756BONNIE K. SHIELDS,
Plaintiff
vs.
REBECCA FOOSE, and
THOMAS BRINK,
Defendants
1. Plaintiff is Bonnie K. Shields, (hereinafter referred to as "Grandmother"), who
currently resides at 139 South Side Drive, Newville, Cumberland County, Pennsylvania,
17241.
2. Defendant Rebecca Foose (hereinafter referred to as "Mother"), has a current
address of 139 South Side Drive, Newville, Cumberland County, Pennsylvania, 17241.
Defendant, Thomas Brink (hereinafter referred to as "Father"), lives in Newville,
Pennsylvania. His exact address is currently unknown.
3. Plaintiff is the Maternal Grandmother of the following child and seeks a
custody order regarding the following child:
NAME DOB/AGE ADDRESS
Isaac Foose 11/11/02 (6) 139 South Side Drive
Newville, Pa. 17241
Mother and the child have lived in Grandmother's home since the child's birth.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 03-- V 7 SG Civil Term
IN CUSTODY
CUSTODY COMPLAINT
During the past five years, the child has resided with the following persons and at
the following addresses:
NAME
ADDRESSES
DATES
Bonnie K. Shields
Kenneth W. Shields
Rebecca Foose, mother
Briann Shields (14)
Bryan Shields (14)
139 South Side Drive
Newville, Pa. 17241
birth - present
The mother of the child is Rebecca Foose. She currently resides at 139 South
Side Drive, Newville, Pennsylvania, 17241. She is not married.
The father of the child is Thomas Brink. He lives in Newville, Pennsylvania. He
is not married.
4. The relationship of plaintiff to the child is that of Maternal Grandmother.
The plaintiff currently resides with Mother, the child, Maternal step-grandfather, and her
two fourteen year old children.
5. The relationship of defendant Thomas Brink to the child is that of Father.
The defendant currently lives alone.
6. 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 or any other state.
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.
7. The best interest and permanent welfare of the child will be served by granting
the relief requested because: Mother and the child have been living in Grandmother's
home since the child was born. Grandmother has had an integral part in providing for the
child's care. She is requesting a formal custody Order which would provide her with shared
physical and legal custody. This request would be in the best interest of the child because
it would provide safety and stability for the child.
8. 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.
child.
WHEREFORE, Plaintiff requests the court to enter a custody order regarding the
Respectfully submitted,
Date:
J Adams,
D o.79465
1 W. South St.
'Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
VERIFICATION
I verify that the statements made in this Custody 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 unsworn falsification to authorities.
Date: 1 C•)?,I o U
r
Bonnie . Shields, Plaintiff
J V-11
OCR
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BONNIE K. SHIELDS IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
REBECCA FOOSE AND THOMAS BRINK
DEFENDANT
2008-6756 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Monday, November 17, 2008 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Monday, December 15, 2008 __ at 8:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. 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 Custodv orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT.
By: _ Is1 ?jacgueline M. Verne Esq-, ILA
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 SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO 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
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ILA
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BONNIE K. SHIELDS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2008-6756 CIVIL ACTION - LAW
REBECCA FOOSE and
THOMAS BRINK, : IN CUSTODY
Defendants
ORDER OF COURT
AND NOW, this 14th of September, 2009, being advised that the parties have
reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this
matter.
FOR THE COURT,
acq ine M. Verney, Esquire, Custody ciliator
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