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Home My WebLink About10-0268r ed - 04.`c-e aC 4e Pmt n¢a,° 7 ao/a 1-a P, - ?- Pm a 33 ?c?b?rla?? County pehkiS 00nr6L JAMIE SHUMBERGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW C. SID EWELL, No. 10 - ,24 ? CIVIL, Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Jamie Shumberger, residing at 223 Lincoln Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant C. Sid Ewell, residing at 139 Lincoln Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks custody of the following child: Name Present Residence DOB Age Sydney Ewell 223 Lincoln Street 2/21/2008 1 year old Carlisle, PA 17013 Synclaire Ewell 223 Lincoln Street 2/4/2009 10 months old Carlisle, PA 17013 The children were born out of wedlock The children are presently in the custody of Jamie Shumberger, residing at 223 Lincoln Street, Carlisle, Cumberland County, Pennsylvania. 17013. During the past five years, the child has resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Jamie Shumberger 112 W. High St., Apt. B 2/2008-6/2008 Carlisle, PA 17013 Jamie Shumberger 102 W. High St., Apt 320 6/2008-2/2009 Carlisle, PA 17013 Jamie Shumberger 237 Lincoln St., Apt. 2 2/2009-2009 Carlisle, PA 17013 4 6. 7 8 Jamie Shumberger 223 Lincoln Street 2009-present Carlisle, PA 17013 The mother of the child Jamie Shumberger, residing at 223incoln Street, Carlisle, Cumberland County, Pennsylvania. 17013. She is not married. The father of the child C. Sid Ewell, residing at 139 Lincoln Street, Carlisle, Cumberland County, Pennsylvania 17013. He is not married. The relationship of plaintiff to the children is that of Mother. The plaintiff currently resides with the following persons. Name None. Relationship The relationship of defendant to the child is that of Father. The defendant currently resides with the following persons. Name Richard White Pat Ewell Relationship Grandfather Mother 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. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children and claims to have custody or visitation rights with respect to the child. The best interest and permanent welfare of the children will be served by granting the relief request because: A Court Order of custody and structured visitation is desired so that the Plaintiff and the children may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the children are not used in a manipulative fashion. Plaintiff desires to maintain the family household which has been established, and the continued stability of the household is in the best interest of the children. A Court Ordered determination of custody is required to avoid continuing conflict between the parties regarding responsibility for custody and support. WHEREFORE, Plaintiff requests this Court grant Plaintiff primary physical custody subject to structured visitation by the Defendant. Respectfully submitted, Rominger & Associates Date: 2 E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court I.D. # 81924 Attorney for Plaintiff r JAMIE SHUMBERGER, Plaintiff V. C. SID EWELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. CIVIL IN 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 the penalties of 18 Pa. Cons. Stat. § 4904 relating to unworn falsification to authorities. F11 FD-OFH- GE Jamie Shumberger, OF THE PFGT'C"NOT% THE COURT OF COMMON PLEAS Plaintiff F CUMBERLAND COUNTY, 2010 JAN '$ 2':3 PENNSYLVANIA V. CUP, u1i Lc?LLV?, ,I,' 1"O. lU- CIVIL TERM C. Sid Ewell, Defendant CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Jamie Shumber er a,Plaintiff, to proceed in forma au ris. I, Karl E. Rominger, Esquire, attorney for the parry proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Date: Respectfully Submitted, Romin er & Associates 1 E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID# 81924 Attorney for Plaintiff JAMIE SHUMBERGER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2010-268 CIVIL ACTION LAW C. SID EWELL IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, January 14, 2010 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, February 12, 2010 at 9:30 AM fora 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 2010 JAN 14 PM 2= 08 Jamie Shumberger, IN THE COURT OF COMMON PLEAS Plaintiff 1 10 'y t? j : W CUMBERLAND COUNTY, 0 U" PENNSYLVANIA V ? Ptir V. { 4 ' N0.2010-268 CIVIL TERM C. Sid Ewell, Defendant CUSTODY PRAECIPE TO WITHDRAW TO THE PROTHONOTARY Please settle, withdraw and discontinue the above captioned matter on behalf of the Plaintiff. Date: &&C' C201 Respectfully Submitted, Rominger & Associates -Srl E. Rominger, Esquire 1 ?5 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID# 81924 Attorney for Plaintiff MAR 2 2 2010 JAMIE SHUMBERGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION -LAW C. SID EWELL, NO. 2010-268 Defendant IN CUSTODY ORDER pp,I, AND NOW, this / U day of March, 2010, the Conciliator being advised that Plaintiff's counsel has filed a Praecipe to Discontinue this matter, the Conciliator relinquishes jpsdiZdon.p u , o r r'c7 r Hubert X. Gilroy squire Custody Concili for