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HomeMy WebLinkAbout09-6506 Pamela L. Purdy, Esquire Attorney ID No. 85783 308 N. 2"d Street, Suite 200 Harrisburg, PA 17101 (717) 221-8303 tel (717) 221-8403 fax pipurdy@verizon.net Attomey for Plaintiff BECKY L. SHETRON, Plaintiff V. TERRY J. SHETRON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0,7- 6s-a(, C,?;,.P T - CIVIL ACTION - LAW IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, Plaintiff, by and through her attorney, Pamela L. Purdy, Esquire, files a Complaint for Custody against Defendant, and in support thereof, avers the following: 1. Plaintiff Becky L. Shetron (hereafter referred to as "Mother") is an adult individual who temporarily resides at 108 E. Orange Street, Shippensburg, Cumberland County, Pennsylvania. 2. Defendant Terry J. Shetron (hereafter referred to as "Father") is an adult individual who currently resides at 1505 Walnut Bottom Road, Newville, Cumberland County, Pennsylvania. s ? 3. Plaintiffs seek custody of the following children: Name Present Address Birthdate Bailey Shetron 1505 Walnut Bottom Rd. 12/16/97 Newville, PA Riley Shetron 1505 Walnut Bottom Rd. 12/27/01 Newville, PA 4. The children were born in wedlock. 5. The children are currently in the custody of Father. 6. In the last five years, the children have resided with the following person(s) and at the following address(es): Person(s) Address(es) Date(s) Father 1505 Walnut Bottom Rd. September 2004 to Mother Newville, PA September 21 2009 Father 1505 Walnut Bottom Rd. September 21, 2009 Newville, PA to present 7. The father of the children is Terry J. Shetron, who currently resides at 1505 Walnut Bottom Road, Newville, Cumberland County, PA. He is married. 8. The mother of the children is Becky L. Shetron, who currently resides at 108 E. Orange Street, Shippensburg, Cumberland County, PA. She is married. 9. The relationship of Plaintiff to the children is that of Mother. Plaintiffs currently reside with the following person(s). Name(s) Relationship Bonnie Gutshall mother 10. The relationship of Defendant to the children is that of Father. Defendant - 4 currently resides with the following person(s): Name(s) Relationship Bailey Shetron daughter Riley Shetron daughter 11. Mother has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 13. Mother has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 14. Mother 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. 15. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. 16. It is in the best interests of the children that the parties be granted shared legal custody and that Mother be granted primary physical custody of the children. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order granting the parties shared legal custody and Mother primary physical custody of the children, with Father having visitation with the children. Respectfully submitted, - piq4n4 t. PC,.. Pamela L. Purdy Dated: 1 ZS Attorney for Plaintiff . VERIFICATION I verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities. R 1,?,L- - Becky L. She n . t H FILED 11)'F T 2099 SEP 28 Pry ?i OU *1&G.50 PD A-" at'# 13q I RT# aaitso . BECKY L. SHETRON IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. TERRY L. SHETRON DF.FF.NDANT 2009-6506 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, October 07, 2009 , 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, October 22, 2009 at 10:30 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 Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilroy, Es q. 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 ?c TH c,c,??'?,MARY 2BE9 0r I -8 AM 11. 4 8 OSL4 rY M-a L " -11). 1 IL, Copy macLcL Ao 4?? rAxjv?lllf n OCT 15 2009 Cr, BECKY L. SHETRON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PF,NNSYLVANIA v CIVIL ACTION - LAW TERRY L. SHETRON, NO. 2009-6506 Defendant IN CUSTODY ORDER AND NOW, this /j day of October, 2009, the Conciliator being advised the parties have reached an agreement, the Conciliator relinquishes jurisdiction. Hubert X. G' roy, Esquire Custody C ciliator FILE D-C""F'r, OF THE PR-Is -N`OTARY 2009 aICT 15 P.1 2* 48 ??. f ? A l BECKY SHETRON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW TERRY J. SHETRON, NO. 2009-6506 Defendant IN CUSTODY COURT ORDER NOW, this /6?'4 day of July, 2011, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in courtroom No. 4 of the Cumberland County Courthouse on the day of tJi1. , 2011, at /? ?C. m. At this hearing, the Mother shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a Memorandum setting forth the history of custody in this case, the issues currently before the Court, a list of witnesses who will be called to testify on behalf of each party, and a summary of the anticipated testimony of each witness. This Memorandum shall be filed at least five (5) days prior to the mentioned hearing date. 2. Pending further Order of this Court, this Court's prior Order of October 1, 2009, shall remain in place. BY THE COURT, cc: ? Pamela L. Purdy, Esquire Diane G. Radcliff, Esquire Kevin . Hess, Judge .? rn CO c- :r--n r -vM r G6 7Z)6 r -tom, -? -n A N CD M BECKY SHETRON, Plaintiff vs. TERRY J. SHETRON, Defendant Prior Judge: The Honorable Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2009-6506 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Bailey Shetron, born December 12, 1999 Reiley Shetron, born December 27, 2001 2. A Conciliation Conference was held on July 1, 2011, with the following individuals in attendance: The mother, Becky Shetron, with her counsel, Pamela L. Purdy, Esquire, the father, Terry J. Shetron, with his counsel, Diane G. Radcliff, Esquire The Mother filed a Petition for Modification of a custody Order in 2010. At the conciliation conference in March of 2010, the parties to agreed to have a custody evaluation performed and to continue with the existing Order from October of 2009. 4. An evaluation is now completed and the Mother wants to move forward with her request to have the custody Order modified. The parties are unable to reach an agreement on any modification of the Order. Accordingly, a hearing is necessary and the Conciliator recommends an Order in the form as attached. Date: July , 2011 /' 24 4 ?// - Hubert X. G' roy, Esquire Custody nciliator _ FILED-OFFIC". "- TIFF PR, 0THCH0TAR",,; 2011 JUL 25 PM 2: 04 CUMBERLAND COU T`i PENNSYLVANIA BECKY SHETRON IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 2009-6506 TERRY J. SHETRON CIVIL ACTION - LAW Defendant IN CUSTODY RESCHEDULING ORDER AND NOW, this -9? day of 2011, IT IS HEREBY ORDERED that the hearing on October 6, 2011 scheduled for 1:30 pm. is hereby continued and rescheduled for the 20th day of October, 2011 at 1:30 p.m., to be held in Courtroom No.4 of the Cumberland County Courthouse, Carlisle, PA. By the C urt: / Kevin . Hess, Judge Distribution: Attorney for Plaintiff: Pamela L. Purdy, Esquire, 1820 Linglestown Road, Harrisburg, PA 17110 ?Attorney for Defendant: Diane G. Radciff, Esquire 3448 Trindle Road, Camp Hill, PA 17011 69P es jka. DIANE G. RADCLIFF, ESQUIRE 3448 Trindle Road, Camp Hill, PA 17011 Phone: 717-737-0100 Fax: 717-975-0697 July 21, 2011 The Honorable Kevin A. Hess Cumberland County Courthouse One Courthouse Square Carlisle; PA 17013 Re: Becky Shetron v. Terry J. Shetron Cumberland County Custody Action No. 2009-6506 Dear Judge Hess: am in receipt of your July 18, 2011 Order of Court in the above referenced matter scheduling the Custody Hearing for October 6, 2011 at 1:30 pm. Both myself and Attorney Purdy are scheduled for hearings in other cases on October 6, 2011 and are in agreement to the rescheduling of this hearing. I coordinated a date and time with your assistant and Attorney Purdy for October 20, 2011 at 1:30 pm. and enclosed and Order for your review and signature. Should you require anything further please do not hesitate to contact me Very truly yours, DIAN DCLIFF, ESQUIRE DGR/ r Enclosure(s): Order Transmitted to Addressee by mail cc: Pamela Purdy w/encl by mail Terry Shetron Wend by mail File