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Home My WebLink About10-0916JOHN F. KING LAW, P.C. John F. King, Esquire ID #61919 19 S. Hanover Street Suite 103 Carlisle, PA 17013 Tel.: (717) 258-4343/Fax: (717) 422-5526 Y91o F874 4M S' 38 AttornSHARON SIEGFRIED Plaintiff V. TANYA GIBB and JEREMY GIBB, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW CUSTODY/VISITATION COMPLAINT FOR CUSTODY 1. The Plaintiff is Sharon Siegfried, residing at 10 Peiper Court, Carlisle, Cumberland County, PA 17015. 2. The Defendant is Tanya Gibb, currently incarcerated in the Cumberland County Jail. The second Defendant is Jeremy Gibb, currently homeless, but who uses the address of his grandmother for mail purposes, that being 724 Grahams Woods Road, Newville, Cumberland County, PA.. 3. Plaintiff seeks custody of the following child: NAME PRESENT RESIDENCE AGE Cameron Gibb 10 Peiper Court 2 yo Carlisle, PA 17015 The child was not born out of wedlock. DOB 01/14/2008 S p9.6() fd. a'?7 tek /v2( A a-3,7193 The child is presently in the custody of Plaintiff/Grandmother, who resides at 10 Pieper Court, Carlisle, PA. During the past five (5) years, the child has resided with the following persons and at the following addresses: NAME RESIDENCE DATE Tanya Gibb, Defendant/Mother 99 Baughman Drive Birth to 10/09 Jeremy Gibb, Defendant/Father Newville, PA Jordan (5 yo other child of Defendant Tanya) Sharon Siegfried, Plaintiff 10 Peiper Court 10/09 to Todd Siegfried, Plaintiff's Husband Carlisle, PA 12/28/09 Madelynn Siegfried, Plaintiff Sharon's 2 '/2 yo daughter Barb Fischer, Maternal Grandmother 230 Leeds Road 12/28/09 to Greg Fischer, Maternal Step-Grandfather Huntsdale, PA 01/28/10 Sharon Siegfied, Plaintiff 10 Peiper Court 01/29/09 to Todd Siegfried, Plaintiff's Husband Carlisle, PA ongoing Madelynn Siegfried, Plaintiff's Sharon's 2 '/2 yo daughter The mother of the child is Defendant, Tanya Gibb, currently residing at the Cumberland County Jail. She is married to co-Defendant/Father. The father of the child is Jeremy Gibb, who is currently homeless . He is married to co-Defendant/Mother. 4. The relationship of the Plaintiff to the child is that of Paternal Grandmother The Plaintiff currently resides with the following persons: NAME RELATIONSHIP Todd Siegfried Husband Madelynn Daughter 5. The relationship of the Defendants to the child is that of parents. The Defendant currently resides with the following persons: N/A 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. The Defendant/Mother is currently incarcerated due to an alcohol violation of her probation status. B. Defendant/Mother has a past history of drug and alcohol use. C. Defendant/Father is currently homeless. D. Defendant/Father has executed a Stipulation granting Plaintiff temporary primary physical custody of the subject minor child. E. Upon Defendant/Mother being incarcerated, Defendant/Father was directed by the subject minor child's maternal step-grandfather, with whom the child has been residing since December 28, 2009, to immediately remove the child from his and the maternal grandmother's residence, which removal took place on Thursday, January 28, 2010. F. Plaintiff/Paternal Grandmother is able to provide a safe and secure living environment for the subject minor child, which cannot be currently provided by either parent. 8. Each parent whose parental rights to the child have not been terminated, and the person who has physical custody of the child, have been named a parry to this action. WHEREFORE, Plaintiff requests the Court to grant custody of the child. Dated: Februarys--- , 2010 Respectfully submitted, JOHN F. KING LAW, P.C. hn F. King, Esquire 19 S. Hanover Street Suite 103 Carlisle, PA 17013 Attorney for Plaintiff VERIFICATION I, Sharon Siegfried, 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. Sharon Siegfried Dated: February, 2010 SHARON SIEGFRIED IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2010-916 CIVIL ACTION LAW TANYA GIBB AND JEREMY GIBB IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Mond, February 08, 2010upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, March 02, 2010 at 10:30 AM .. for a Pre-Ilearing 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 entrv 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 hearinp- FOR THE COURT. By: /s/ ac ueline M. Verne Es 4p- -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 FORTtI BELOW TO FIND OUT W1IERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 OF THE PPO'Irporj)tApy 2010 FEB -S Pty 3.- 09 t i iWrLL',, 4A "?11` SHARON SIEGFRIED : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v :NO. 2010-916 TANYA GIBB and JEREMY GIBB, : CIVIL ACTION - LAW c7 c? Defendant : CUSTODY/VISITATION ` t.4. PRAECIPE TO DISCONTINUE CUSTODY ACTION TO: Prothonotary N Kindly discontinue the instant custody action, without prejudice, and so mark the pocket; Dated: February 11, 2010 Respectfully submitted: JOHN F. KING LAW, P.C. By: %-j-- J ohn F. King, Esq. ID# 61919 19 S. Hanover Street, Ste. 103 Carlisle, PA 17013 (717) 258-4343 (717) 422-5526 FAX Attorney for Plaintiff c N n C ? Na N N FEB I "_' Zulu FILED-4:)Fr-ICE OF THE Fr7HIO OTARY 2010 FEB 12 AM 11: 43 CLUB, =v ? : r tJNTY PENt YLVP,1 A SHARON SIEGFRIED, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2010-916 CIVIL ACTION - LAW TANYA GIBB, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 11 `" day of February, 2010, the Plaintiff having withdrawn her complaint, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, A vx_??: acq eline M. Verney, Esquire, Custody nciliator