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Home My WebLink About10-0850r1LEC J F'4 K Y 20!?FF -2 j f LAW OFFICES OF DILS & DILS DIANE M. DILS, ESQUIRE Attorney I.D. No. 71873 1400 North Second Street, First Floor, Front Harrisburg, PA 17102 Telephone No. (717) 233-8743 Attorney for Plaintiff, Collin Swanger COLLIN SWANGER Plaintiff, vs. DANIELLE STINE Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. l0- 850 CIv;ITp,+rN1 CIVIL ACTION -LAW IN CUSTODY COMPLAINT FOR SHARED LEGAL AND PHYSICAL CUSTODY ,17. Vii( ) AND NOW, this day o , ffA-e ^ comes the Plaintiff, Collin Swanger, by his attorney, Diane M. Dils, Esquire, and respectfully avers the following: 1. Collin Swanger, the Plaintiff above named, is an adult individual currently residing at 15 Highland Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant above named, Danielle Stine, is an adult individual currently residing at 868 Polecat Road, Landisburg, PA 17041. -f 1'4. 00 P4 AT Y aO 35a i/as is alt a(o7Ia9 3. Plaintiff and Defendant were not married; however, they are the natural parents of one child; namely: Jamison Collin Swanger, born August 31, 2009. 4. Immediately after birth, Plaintiff and Defendant were able to work out substantial periods of custody between Plaintiff and the minor child. 5. Since several weeks ago, the Plaintiff has been denied all contact with his son. 6. Plaintiff, Collin Swanger, respectfully requests that he be granted shared legal custody of his minor child and a regular custodial schedule so that he may be involved with the upbringing of his child on a regular basis and be a hands-on father. 7. This is the second child of the Plaintiff, Collin Swanger, and he has all of the necessary facilities to enjoy periods of custody with his son including but not limited to a crib, high chair when necessary, and everything else that is necessary to care for a four month old child. 8. In the past when the Plaintiff was permitted periods of custody with his son, the child did take formula for the father and therefore any allegations of breast feeding are irrelevant. 2 9. The Plaintiff, Collin Swanger, is well able to care for his minor child and desires that his custody schedule coordinate with his daughter, so that his children may be raised together. 10. The minor child has resided in Cumberland County, Pennsylvania since his birth on August 31, 2009. 11. The Court of Common Pleas of Cumberland County has jurisdiction in this matter. 12. The Plaintiff has not participated as a party or witness in any capacity in other litigation concerning the custody of the minor children in this or any other Court. 13. The Plaintiff has no information of the custody proceedings concerning the children pending in a Court of this Commonwealth or any other state. 14. The 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. 3 WHEREFORE, the Plaintiff, Collin Swanger, respectfully prays your Honorable Court to grant him shared legal and shared physical custody of his son. Respectfully submitted, BY: 1400 North Second Street First Floor, Front Harrisburg, PA 17102 (717) 232-9724 I.D. No. 71873 Date: /46'-/ D l 4 VERIFICATION COMPLAINT FOR SHARED LEGAL I verify that the statements made in this AND PHYSICAL CUSTODY are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA. C.S. Section 4904 relating to unsworn falsification to authorities. I Date: January 19, 2010 COLLIN SWANGER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 2010-850 CIVIL ACTION LAW DANIELLE STINE DEFENDANT IN CUS"fODY ORDER OF COURT AND NOW, _____ Monday, Februa~ 08, 2010 _____, upon consideration oPthe attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. ,the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, March 11, 2010 at 9:00 AM tier 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 hereUy 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. FOK THE COURT. 13y: _ /s/ Dawn S. Sunday Es Custody C,'onciliator 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 a~~ailabie 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 ar hearing. YOU SHOULD TAKE THIS PAPER TO YOUR A"I'TORNF,Y AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH F3ELOW TO FIND OiJT WFIERE YOU C'AN GET LEGAL I-iELP. Cumberland County I3ar Association 32 South E3edford Street Carlisle, Permsylvania 17013 Telephone (717) 249-3166 ~~~ F1LE~rF~CE Thy ~~~'1~~?~-~T~RY 2DID FEg _g P~ 3, ~ 8 V r ._ ., ,,,. .. V :.Yi 1. ~,i -,- t.~ THE PRO ~dti4F~I' 20(0 MAR -4 PM 12~ 07 CUM~~=~ ~~tiu ~ ~UNiY pENIvS}'l.V~'~~1 JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Defendant COLLIN SWANGER, Plaintiff vs. DANIELLE STINE, Defendant THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2010-850 CIVIL ACTION - AT LAW CUSTODY PRAECIPE TO ENTER APPEARANCE AS COUNSEL FOR DEFENDANT TO THE PROTHONOTARY: Please enter my appearance as counsel of record for Defendant, Danielle Stine, in the above custody action. By: Dated: ~/ ` ~~r ~ JE . COSTOPOU DIRE Attorney LD. No. 68735 ~-. 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 CERTIFICATE OF SERVICE I, Jeanne B. Costopoulos, Esquire, Attorney for Defendant, Danielle Stine, do hereby certify that on this date I served the foregoing document by depositing a true and exact copy thereof in the United States mail, first class, postage prepaid, addressed as follows: Diane M. Dils, Esquire DILS &DILS 1400 North Second Street, First Floor Front Harrisburg, PA 17102 Dated: ~ / ~~2~ l 0 ___.' By: JEA OSTO „_QUIRE Attorney LD. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Defendant, Danielle Stine NdV 01 2010 COLLIN SWANGER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2010-850 CIVIL ACTION LAW DANIELLE STINE Defendant IN CUSTODY ORDER AND NOW, this 28th day of October. 2010 ,the conciliator, having been advised by counsel that there is no longer a need to reschedule the custody conciliation conference originally set for October 5, 2010, as the parties have reached an agreement, hereby relinquishes jurisdiction. FOR THE COURT, ~: . ~.~ R ~: ~,~I t f , J~~ ¢ •- ie...~ i E S d D S y ~ ~ ...... 9 r~ `=` re ay, squ un awn . ' ~:-: Custody Conciliator ~ ~; , r ~~ rU ~, ~~~. r.,,~ I\> , FILED-UFFICF !t5 7-o ' e1tf L 11[ JAN to Pfd I,: COLLIN SWANGER : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 2010-850 DANIELLE STINE CIVIL ACTION -LAW Defendant IN CUSTODY STIPULATION AND AGREEMENT OF THE PARTIES AND NOW, this day o , 2010, comes Collin Swanger and &4 Danielle Stine, after conferring with their counsel, Diane M. Dils, Esquire and Jeanne B. Costopoulos, Esquire, respectively, the parties intending to be legally bound do hereby agree that the following holiday schedule shall be incorporated into the Order of Court dated March 31, 2010 and further, by execution of this Stipulation and Agreement hereby confirm their desires that this Stipulation and Agreement become an Order of Court. The parties hereby affirm all other aspects of the Order of Court dated March 31, 2010 and hereby further agree as follows: 1. Thanksgiving - In every year, the Father shall have custody of the child from the Wednesday before Thanksgiving at 5:00 p.m. through Thanksgiving Day at 3:00 p.m. and the Mother shall have custody from Thanksgiving Day at 3:00 p.m. through Friday at 5:00 p.m. 2. Easter - In even numbered years, the Mother shall have custody of the child on the Saturday before Easter from 9:00 a.m. until 5:00 p.m. and the Father shall have custody on Easter Sunday from 9:00 a.m. until 6:00 p.m. In odd numbered years, the Father shall have custody on the Saturday before Easter from 9:00 a.m. until 5:00 p.m. and the Mother shall have custody on Easter Sunday from 9:00 a.m. until 5:00 p.m. 3. Christmas - In even numbered years, the Mother shall have custody Christmas Eve from 11:00 a.m. until Christmas Day at 11:00 a.m. and the Father shall have custody from Christmas Day at 11:00 a.m. until December 26th at 11:00 a.m. In odd numbered years, the Father shall have custody from Christmas Even from 11:00 a.m. until Christmas Day at 11:00 a.m. and the Mother shall have custody from Christmas Day at 11:00 a.m. until December 26th at 11:00 a.m. 4. Memorial Day/Labor Day - In every year, the Father shall have custody of the child on Memorial Day from 9:00 a.m. until 5:00 p.m. and the Mother shall have custody on Labor Day from 9:00 a.m. until 5:00 p.m. 5. Mother's Day/Father's Day - In every year, the Mother shall have custody of the child on Mother's Day and the Father shall have custody on Father's Day from 9:00 a.m. until 5:00 p.m. IN WITNESS WHEREOF, the parties hereto have signed their hands and seals the day and year first,above written. 2 Diane M. ils, Esquire ,AL) G,...._ (SEAL) J e B. Costopoulos, Esquire kele Stine