Loading...
HomeMy WebLinkAbout09-7125SHAWN WEAVER, Plaintiff vs. MICHELLE WEAVER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 9- "2 3 Civil Term IN CUSTODY CUSTODY COMPLAINT 1. Plaintiff is Shawn Weaver, who currently resides at 3514 Ritner Highway, Newville, Cumberland County, Pennsylvania, 17241. 2. Defendant is Michelle Weaver, who currently resides at 22 Winchester Gardens, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff is the Father of the following child and seeks a custody order regarding the following child: NAME DOB/AGE ADDRESS Rebecca Weaver 9/12/00 (9) 22 Winchester Gardens Carlisle, Pa. 17013 Mother and Father were married on November 7, 1998. The parties separated on May 1, 2002, and were divorced on September 16, 2008. The parties have shared legal and physical custody of the child since separation. During the past five years, the child has resided with the following persons and at the following addresses: NAME ADDRESSES DATES Michelle Weaver 22 Winchester Gardens 2002 - present Carlisle, Pa. 17013 The mother of the child is Michelle Weaver. She currently resides at 22 Winchester Gardens, Carlisle, Pa. 17013. She is divorced from Father. The father of the child is Shawn Weaver. He currently resides at 3514 Ritner Highway, Newville, Pa. 17241. He is divorced from Mother. 4. The relationship of plaintiff to the child is that of Father. The plaintiff currently resides with his parents, Mark and Doris Weaver. 5. The relationship of defendant to the child is that of Mother. The defendant currently lives with the child. 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: The parties separated in 2002 Since that time Father has had the child ever Friday through Monday during the school year, and every Friday through Tuesday during the summer. Father is seeking a court Order which would confirm this shared custody arrangement and would provide for shared legal custody. 8. Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the child have been named as parties to this action. child. WHEREFORE, Plaintiff requests the court to enter a custody order regarding the Date: Respectfully submitted, J,bne Adams, Esquire 4D. No. 79465 17 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: /0 Shawn We l ?? aver, Plaintiff FiL ?t i_ > r L- Y I 1 OF THE ,%'()TORY 2009 OCT 19 AM ltd'. S 1 ?ufv _ , i l ?fmil L.ti A-* SHAWN WEAVER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-7125 CIVIL ACTION LAW MICHELLE WEAVER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, October 27, 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 Count Courthouse, Carlisle on Thursday, December 03, 2009 at 9:30 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: /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 FILED- )FFIC E OF THE PROTHONOTARY 2009 OCT 27 PM 2: 40 CUMBIUI-?L:,,;4? ?; OUNTY PENNSYLVANIA X0 el y yl