HomeMy WebLinkAbout10-1676LANE ADAMS
ATTORNEY AT LAW
Attorney I.D. No. 79465
17 W. South St.
Carlisle, Pa. 17013
(717) 245-8508
esgadams@gmail.com
SHELLY L. HAMILTON,
Plaintiff
vs.
JIMMY HAMILTON, III,
Defendant
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1010 MAR 10 AM 9: 16
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 10 -11-1(- Civil Term
IN CUSTODY
CUSTODY COMPLAINT
1. Plaintiff is Shelly L. Hamilton, who currently resides at 62 Countryview
Estates, Newville, Pa. 17241.
2. Defendant is Jimmy Hamilton, III, who currently resides at 1128 Fairfield St.,
Mechanicsburg, Pa. 17055.
3. Plaintiff is the Mother of the following child and seeks a custody order
regarding the following child:
NAME DOB/AGE ADDRESS
Amanda Hamilton 9/24/2003 (6) 62 Countryview Estates
Newville, Pa. 17241
Mother and Father were married on June 7, 2003 and were separated in
December 2008. Mother currently has primary physical custody of the child.
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.$17q.00
j?,? a387?
During the past five years, the child has resided with the following persons and at
the following addresses:
NAME
ADDRESSES
DATES
Shelly Hamilton
Sherry Brunner (14)
Shelly Hamilton
Sherry Brunner (14)
Shelly Hamilton.
Jimmy Hamilton, III
Sherry Brunner (14)
62 Countryview Estates
Newville, Pa. 17241
23 West Main St.
Walnut Bottom, Pa. 17266
Jan. 2009 - present
Dec. `08 - Jana 09.
23 West Main St. 2003 - 2008
Walnut Bottom, Pa. 17266
The mother of the child is Shelly Hamilton. She currently resides at 62
Countryview Estates, Newville, Pa. She is married to Father.
The father of the child is Jimmy Hamilton, III. He currently resides at 1128
Fairfield St., Mechanicsburg, Pa. 17055. He is married to Mother.
4. The relationship of plaintiff to the child is that of Mother. The plaintiff currently
resides with the child.
5. The relationship of defendant to the child is that of Father. The defendant
currently lives with his mother, Vicki Cromer.
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: The parties separated in December 2008. Mother has
maintained primary custody. Mother is seeking an Order which provides for shared legal
custody and confirms that she will maintain primary custody of the child. She is requesting
that periods of partial custody for father be well defined. This request is in the best
interest of the child since it provides for stability of the child and provides contact with both
parents.
8. Each parent whose parental rights to the child 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
child.
Respectfully submitted,
Dater
v ! U ne Adams, Esquire
JD. 79465
No.
17 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.
C
lei ?/,, 91// /1/ W,
W,WI Date: h y Ha alto , Plaintiff
SHELLY L. HAMILTON IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
2010-1676 CIVIL ACTION LAW
JIMMY HAMILTON, III
IN CUSTODY
DFFFNDANT
ORDER OF COURT
AND NOW, Tuesday, March 16, 2010 upon 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 _ Thursday, April 08, 2010 at 9:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
il'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/ ac ueline M Verney, E-sq. ,A _
Custody Conciliator 1'
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
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SHELLY L. HAMILTON, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
V• : N0.2010-1676 CIVIL ACTION -LAW
JIMMY HAMILTON, III, .
Defendant : IN CUSTODY
ORDER OF COURT
AND NOW, this 13t" day of July, 2010, being advised that the parties have
reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this
rr~ter.
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acq Pine M. Verney, Esquire, Custo Conciliator