HomeMy WebLinkAbout09-0239Filed bv:
Attorney Michael J. Wilson PA Atty ID No.: 52680
Attorney for Plaintiff (717) 774-7018
816 Derby Avenue (717) 774-7019 (fax)
Camp Hill PA 17011-8367 attorneymichaeljwilson@michaeljwilsonlaw.com
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
JEFFREY A. SHAUB
938 Pinetree Way
Lancaster PA 17601
Plaintiff
v. No. ~ 4- Oa 39 (,.~c..trc.~ ~.c.~
LISA NADINE SGHMIDT
719 Elkwood Drive :
New Cumberland PA 17070 .
Defendant CUSTODY
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ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEF,.
Court Administrator
4th Fl., Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 1.7013
(717) 240-6200
Filed by:
Attorney Michael J. Wilson PA Atty ID No.: 52680
Attorney for Plaintiff (717) 774-7018
816 Derby Avenue (717) 774-7019 (fax)
Camp Hill PA 17011-8367 attorneymichaeljwilson@michaeljwilsonlaw.com
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
JEFFREY A. SHAUB
938 Pinetree Way
Lancaster PA 17601
Plaintiff
v.
LISA NADINE SCHMIDT
719 Elkwood Drive
New Cumberland PA 17070
Defendant
No. ~' , U :Z 3 `j
CUSTODY
COMPLAINT FOR CUSTODY
BACKGROUND
1. Plaintiff Father is an adult individual who resides at the above-captioned address
in Lancaster County, Pennsylvania.
2. Defendant Mother is an adult individual who resides at the above-captioned
address in Cumberland County, Pennsylvania.
3. Plaintiff Father and Defendant Mother are the natural parents of Bryan Russell
Shaub, born July 5, 1989 and currently 19 years of age and emancipated, and Deanna Elizabeth
Shaub, born November 3, 1991 and currently 17 years of age
4. Plaintiff Father and Defendant Mother were husband and wife from October 19$5
to April 1995 at which time they were granted a decree in divorce from the Court of Common
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present date, Defendant Mother has failed to consistently maintain contact with and provide
information to Plaintiff Father concerning the general health and welfare of their remaining
Minor Child, Deanna, to include more specifically her educational progress and the status of her
health and mental and physical well-being.
12. Minor Child Deanna is currently enrolled in the West Shore School District and
attends Cedar Cliff High School.
13. Minor Child Deanna is believed to currently receive routine medical treatment or
care from a general family doctor, a family dentist, orthodontist and an optometrist.
14. Minor Child Deanna is believed to receive specialized medical treatment or care
from a pediatric cazdiologist and hematologist due to past diagnoses that the Minor Child suffers
or has suffered from a mitral valve prolapse and a blood disorder.
15. Upon the failure of Defendant Mother to periodically and consistently provide
Plaintiff Father with said information concerning Minor Child Deanna, Plaintiff Father began a
process to attempt to directly contact all of the appropriate school district officials, religious
pastor and health caze providers of Minor Child Deanna in order to obtain disclosure directly to
him such information concerning her education, religious activities and the status of her health,
and mental and physical well-being.
16. Plaintiff Father is unable to fully and completely discuss such information with
school officials and remains unable to access or receive full and complete disclosure of
scholastic information from the school pertaining to Minor Child Deanna and is unable to fully
and completely discuss such information and remains unable to access or receive full and
complete disclosure of medical or health information from the health care and religious
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