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Home My WebLink About09-7364During the past five (5) years, the children have resided with the following persons and at the following addresses: NAME RESIDENCE DATE As regarding the minor child, Christain: Plaintiff/Father 8 John Drive DOB thru Defendant/Mother Carlisle, PA 17015 7/7/2008 Sharon Doyle (Maternal Grandmother) David Doyle (Stepgrandfather) Brandee Gibson (Aunt) Plaintiff and Defendant 24 Tip Top Circle 7/7/2008 thru David (Brother) Carlisle, PA 17015 10/24/2009 Plaintiff/Father 8 John Drive 10/24/2009 to Sharon Doyle (Maternal Grandmother) Carlisle, PA 17015 present David Doyle (Stepgrandfather) Brandee Gibson (Aunt) As regarding the minor child, David: Plaintiff and Defendant 24 Tip Top Circle DOB to Christain (Brother) Carlisle, PA 17015 10/24/2009 Defendant 24 Tip Top Circle 10/24/2009 to Carlisle, PA 17015 Present The mother of the children is Brittney Hoffman, currently residing at 24 Tip Top Circle, Carlisle, PA 17015 . She is single. The father of the children is Christopher Gibson, currently residing at 8 John Drive, Carlisle, PA 17015. He is single. 4. The relationship of the Plaintiff to the children is that of Father. The Plaintiff currently resides with the following persons: NAME Sharon Doyle David Doyle Brandee Gibson Christain Gibson RELATIONSHIP Mother Stepfather Sister Subject Son 5. The relationship of the Defendant to the children is that of Mother. The Defendant currently resides with subject son, David. 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: A. Father is employed and is licensed to operate a motor vehicle. B. Mother is unemployed and is not licensed to drive a motor vehicle. C. Father and the child's paternal grandmother, with whom Father resides, have provided significant and ongoing care to the children. D. Mother has recently exhibited erratic behavior by departing and returning to and from her current residence several times in the past week. E. Plaintiff/Father believes, and therefore avers, that Mother may unilaterally attempt to relocate with the children outside of this Court's jurisdiction. 8. 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 a party to this action. WHEREFORE, Plaintiff requests the Court to grant Plaintiff/Father custody of the children. Dated: October azt '2009 Respectfully submitted, JOHN F. KING LAW, P.C. J F. King, Esquire 19 S. Hanover Street Suite 103 Carlisle, PA 17013 Attorney for Plaintiff VERIFICATION I, Christopher Gibson, hereby acknowledge that I am the Plaintiff in the foregoing action; that I have read the foregoing Complaint for Custody; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. JJW Christopher Gibson Dated: A C!:> Th 1? OF .0 2009 OC T 26 PM 3: 08 ?.? i o ?? CHRISTOPHER GIBSON IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-7364 CIVIL ACTION LAW BRITTNEY HOFFMAN IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, October 29, 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 Friday, December 04, 2009 _ 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 Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ Hubert X. Gilroy, En. 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 THE M 2009 OCT 29 AM t t : 19 PENNSYLVANK 0 0 CHRISTOPHER GIBSON, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-7364 BRITTNEY HOFFMAN, : CIVIL ACTION - LAW Defendant : CUSTODYNISITATION CERTIFICATE OF SERVICE I hereby certify that I am this 3 6 day of October, 2009, serving the foregoing certified copy of order for conciliation and custody complaint upon the person and in the manner indicated below which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure. Service b First Class Mail Certified Restricted addressed as follows: Brittney Hoffman 1992 Mountain Chapel Road Breezewood, PA 15533 S arry Semans M 117 ¦ Complete Items 1, 2, and 3. Also complete A. Signature ° ' ' - = • Item 4 if Restricted Delivery is desired,, ? Agent ¦ Print your name and address on the reverse X lad, Addressee ° SO that - can return the card to you. B. Received by (Prln Name) C. a e of silvery ¦ Attach this card to the back of the mallplece, I r-3 or on the front if space permits. Postage $ 1. Article Addressed to: D. Is deliv dress different from kern 1? Yes C3 1 ..1 If YES, e er delivery address below: 9'No Q Certified Fee Y-% y I tie./ V ° Return Receipt Fee Ir`°1J o71' Ja ?? (Endorsement Required) ° ? Restricted Delivery Fee l/ ` rll ° (Endorsement Required) '9 ° ? I J ? Servi Type ..0 Total Postage & Fees ?-e e t,< Wood, P14 3. l9 Melted Mail ? Express Mail C3 Sent To 0 Registered 0 Return Receipt for Merchandise ° C3 Insured Mall 0 C.O.D. r? - ---- t, --A -- p if --No--- .; ------------------------------- or tree or PO Box No. 4. Restricted Delivery? (Extra Fee) --------- ------------------ City State, ZlP+4 2. Article Numb (TransrerfmmseMce/abeq 7006 0100 0005 1040 4093 .. PS Form 3800, June PS form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 {-t ?G 9 K!fJ 12 1`17-1112': ti -i K!07 r.? ti it1 w, ,~ L 4! TUTU 3 CHRISTOPHER GIBSON, IN THE COURT OF COMMON PLEA F: i.o y. Plaintiff CUMBERLAND COUNTY, PENNSY AN~ vs. CIVIL ACTION -LAW w ~~ ~ BRITTNEY HOFFMAN, NO. 2009-7364 Defendant IN CUSTODY r -AND - ~+ BRITTNEY HOFFMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW CHRISTOPHER GIBSON, NO. 2009-7557 Defendant IN CUSTODY COURT ORDER AND NOW, this ~ _ day of , 2010, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. A hearing is scheduled in Court Room No. 3 of the Cumberland County Courthouse on the .m. At this hearin the mother shall be the day of,~~~, 2010 at ~ Q~ g, 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 summary of each parties position on these issues, 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 days prior to the mentioned hearing date. 2. Pending further Order of this Court, this Court's prior temporary Custody Order shall remain in place subject to the following modifications: A. Both parties shall keep the other parent advised with respect to their current mailing address and residence. BY T OURT Judge Edward E. Guido cc: ~J Adams, Esquire ./John E. King, Esquire a/mot j~v ~~ ~. ~. CHRISTOPHER GIBBON, Plaintiff vs. BRITTNEY HOFFMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2009-7364 IN CUSTODY -AND- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2009-7557 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL BRITTNEY HOFFMAN, Plaintiff vs. CHRISTOPHER GIBBON, Defendant PRIOR JUDGE: Edward E. Guido PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The Conciliator conducted a conference call with legal counsel for both parties. The mother is dissatisfied with the temporary order entered in September and wants it modified. The father is unable to agree and a hearing is required. The Conciliator recommends an Order in the form as attached. Date: January a ~ , 2010 Hubert X. Gilroy squire Custody Concil' for