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Home My WebLink About09-3847IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HILLARY AUKER, Plaintiff V. EDWARD A. EAMES, Defendant CIVIL ACTION 3917 CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Hillary Auker who currently resides at 2 Subdivision Road, Newville, Pennsylvania, which is in Cumberland County, Pennsylvania. 2. The defendant is Edward Eames who currently resides at 241 Middle Road, Newville, Pennsylvania, which is in Cumberland County, Pennsylvania. 3. The plaintiff is seeking custody of the following child: Name Residence Age Olivia Jane Eames 2 Subdivision Road, 2 Newville, PA 17241 DOB 10-6-2006 The child was born out of wedlock. Since the date of birth of the child, the child has resided with the following persons at the following address: (List all Persons) (List all Addresses) (Dates) Hillary Auker 2 Subdivision Road May 2009-present Newville, Pennsylvania Hillary Auker and 2 Subdivision Road October 2008- Edward Eames Newville, Pennsylvania May 2009 Hillary Auker 2 Subdivision Road October 2007 - Newville, Pennsylvania October 2008 Hillary Auker and 2 Subdivision Road October 2006 Edward Eames Newville, Pennsylvania October 2007 The mother of the children is Hillary Auker, currently residing at 2 Subdivision Road, Newville, Pennsylvania. She is single. The father of the children is Edward A. Eames, currently residing at 241 Middle Road, Newville, Pennsylvania. He is single. 4. The relationship of Plaintiff to the children is that of mother. The plaintiff currently resides with the following persons other than children: No one. 5. The relationship of defendant to the children is that of father. The defendant currently resides with the following persons other than the children: Derreck Castle (friend). 6. Plaintiff has not participated as a party or witness or in another capacity, in other litigation concerning the custody of this 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 children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: Plaintiff is willing and able to perform the primary parental responsibilities for the children. Plaintiff is in the best position to provide the care and nurture which the child needs for healthy development. Defendant is not capable of providing appropriate supervision for the child. Incidents have occurred that makes the Plaintiff concerned about the safety of the child if she was to be left alone with the Defendant. These incidents include excessive drinking while the child was left in Defendant's care to the point that he was unconscious and was not aroused when smoke from the woodstove filled the entire home and the fire alarms were going off. The Defendant also uses physical discipline on the child despite the Plaintiffs requests for the Defendant not to do so. 8. 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 as parties to this action. WHEREFORE, plaintiff requests the court to grant her custody of the minor child. Respectfully submitted, $heri D. Coover, Esquire Attorney ID 92385 44 S. Hanover Street Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HILLARY AUKER, Plaintiff V. EDWARD A. EAMES, Defendant CIVIL ACTION CUSTODY VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. D.,<ok,U,Rior)OCR FILED--OFCE OF W PIROTHIONOTARY 1004 JUN - 10 PM 1: 4 8 LVEY??+ ...?'? ill l,.r?JIJdY1 ! PENIVSY4VAN A f /? S? Pct Ck? a-!? HILLARY AUKER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA v. EDWARD A. EAMES DEFENDANT • 2009-3847 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, June 17, 2009 ,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 Thursday, July 16, 2009 at 9:30 AM for aPre-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 Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: ls/ jacgueline M. Verne ,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 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 ~F TNT E~~=``,~.~.'-!'.'~~'~:~z~AY 2D0~ J11~~ ! 7 ~~~ 2~ :~~ GUa~ . i:: ~~~; Y ~~-=t gin, ;~:~ui ~ j.. ;_ r'r~~u.~ 5~~.~r~`~a,, ~ -~~ - 09 ~d~e ~ ~ ~~~ ~-i~-off' ~ ,~~~' -~ ~ ~.-~~~ . HILLARY AUKER, Plaintiff v. EDWARD A. EAMES, Defendant IN THE COURT OF COMMON P] CUMBERLAND COUNTY, PENN NO.: 09-3847 CIVIL TERM CNIL ACTION -LAW IN DIVORCE TO THE PROTHONOTARY OF SAID COURT: PRAECIPE OF ENTRY OF APPEARANCE Please enter my appearance on behalf of the Defendant, Edward A. Eames, in tl captioned matter. D ATE Z Respectfully submitted, AaoNr & KvTUr.Axls~ LLP Kara W. Haggerty, 2 West High Street Carlisle, PA 17013 (717) 249-0900 ID No. 86914 VANIA e above- CERTIFICATE OF SERVICE AND NOW, this 24`h day of June, 2009, I, Kara W. Haggerty, of ABOM & KU ULAKI LLP, hereby certify that I did serve a true and correct copy of the foregoing Praecipe of ntry of Appearance by depositing, ox causing to be deposited, same in the United States Mail, ~irst-class mail, postage prepaid addressed to the following: Sheri D. Coover, Esquire 44 S. Hanover Street Carlisle, PA 17013 Respectfully submitted, ABOM&KUTOLaxI~ LLP D:~T'E D ~ D ~. Kara W. Haggerty, 2 West High Street Carlisle, PA 17013 (717) 249-0900 ID No. 86914 FIL'.., ,:. ,~,: ,~-- - ~ , ' -~~,n,Y .~ ~i`ii~ L U ~ S.~ rv : ~ ~ ~ P•:. i ~ i ~ ~: 'l.n `~..~. .... .. ~.~-"fir i f ~. ., AUG 14 2009G HILLARY L. AUKER, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA ~. :CIVIL ACTION -LAW EDWARD A. EAMES, NO. 2009-3847 CIVIL TERM Defendant IN CUSTODY ORDER OF COURT t~ AND NOW this i l day of Av ~ ~~ ~ , 2009, the attached Custody Stipulation and Agreement is hereby made an Order of Court. BY THE COURT, 1 `~~ ~~ cc: / Hannah Herman-Snyder, Esquire Attorney for Plaintiff /ra W. Haggerty, Esquire Attorney for Defendant I ~( g1~~~~ _~ __.,} F1~~~:~~~=1~~ CAF THE P~'~ `-i~`':~;~7AR`! 7DQ9 AUG ! 7 APB $~ :?9