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Home My WebLink About09-7557BRITTNEY HOFFMAN, Plaintiff vs. CHRISTOPHER GIBSON, Defendant 1. Plaintiff is Brittney Hoffman, who currently resides at 24 Tip Top Circle, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Christopher Gibson, whose current address is 8 John Drive, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff is the Mother of the following children and seeks a custody order regarding the following children: NAME DOB/AGE ADDRESS David Gibson 7/27/09 24 Tip Top Circle, Carlisle, Pa. 17013 Christain Gibson 4/25/08 8 John Drive, Carlisle, Pa. 17013 Mother and Father were never married. Mother has primary physical custody of David and Father has primary physical custody of Christain. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. Dg- 75.7 Civil Term IN CUSTODY CUSTODY COMPLAINT During the past five years, the child has resided with the following persons and at the following addresses: NAME ADDRESSES DATES Christopher Gibson Brittney Hoffman Brittney Hoffman 24 Tip Top Circle Carlisle, Pa. 17013 24 Tip Top Circle Carlisle, Pa. 17013 June 2008 - Oct. 09 Oct. 09 - present Christopher Gibson 8 John Drive Oct. 09 - present Sharon Doyle Carlisle, Pa. 17013 Paternal grandmother The mother of the children is Brittney Hoffman. She currently resides at 24 Tip Top Circle, Carlisle, Pa., 17013. She is not married. The father of the child is Christopher Gibson. He currently resides at 8 John Drive, Carlisle, Pa. 17013. He is not married. 4. The relationship of plaintiff to the child is that of Mother. The plaintiff currently resides with David Gibson. 5. The relationship of defendant to the child is that of Father. The defendant currently lives with Christain Gibson and paternal grandmother, Sharon Doyle. 6. Plaintiff 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. Plaintiff has no information of a custody proceeding concerning the children 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: The parties recently separated Father is living with paternal grandmother. The younger child David Gibson who is three months old has remained with Mother. The older child Chastain who is one ear old went to Father's home. Mother has requested that the child be returned and has also requested periods of partial physical custody with the child but Father and paternal grandmother refuse to give her any unsupervised periods of physical custody with the child Paternal grandmother refuses to return the older child even when Father is working Mother is requesting a .court Order which would provide for shared legal custody and confirm that she is to retain primary physical custody of both of her children Mother strongly opposes grandmother's attempt to unilaterally seize custody of the older child 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children has been named as parties to this action. WHEREFORE, Plaintiff requests the court to enter a custody order regarding the children. Respectfully submitted, Date: /ape Adams, Esquire I. . No. 79465 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 /36/07 l 4neeBn'yyMHHoffffmman, laintiff ?. F11.ED-?Ur??GF OF THE P?"?"T'yTARY 2449NoV -2 Aid 11: 11 *IUS50 PD ATT4 c?? 539q a3a8? ti BRITTNEY HOFFMAN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTOPHER GIBBON DF:FI?NDANT • 2009-7557 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Mond~November 09, 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 Friday, December 04, 2009 at g: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, Suecial Relief orders, and Custody orders to the conciliator 4$ hours prior to scheduled hearing. FOR THE COURT, By: _ /s/ Hubert X. Gilroy, Esq.,/~~ ~ __ Custody Conciliator ~.1 The Court of Common Pleas of Cumberland County is required by ]aw 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. A(1 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 SHOULL) TAKE "THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NO"I' HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTI~i BELOW TO FIND OUT WHERE YOU CAN GET LEGAL I-IELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 „,., ,~.5, _ z,t ,;, j '~, ~ ~r ~~~ ~~~~~~~ ~?~~ CHRISTOPHER GIBBON, Plaintiff vs. BRITTNEY HOFFMAN, Defendant BRITTNEY HOFFMAN, Plaintiff vs. CHRISTOPHER GIBBON, Defendant JAN ~ ~ LUAU 3 W -~, IN THE COURT OF COMMON P OFr CUMBERLAND COUNTY, PENN - VA~7IA : ~ s• Z CIVIL ACTION -LAW ~ r' NO. 2009-7364 ~ a0 IN CUSTODY -AND - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2009-7557 IN CUSTODY COURT ORDER 1 AND NOW, this ~ day of ~xa~ , 2010, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. A hearing is scheduled/i}n Court Room No. 3 of the Cumberland County Courthouse on the r ~~ day of ~~~I~C, ' 2010 at ~~ ~~~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 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 e Adams, Esquire /John E. King, Esquire t ~~ S /YL,a. ~ 14c~., ~/~t f rv ~~ CHRISTOPHER GIBBON, Plaintiff vs. BRITTNEY HOFFMAN, Defendant BRITTNEY HOFFMAN, Plaintiff vs. CHRISTOPHER GIBSON, Defendant PRIOR JUDGE: Edward E. Guido 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 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