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HomeMy WebLinkAbout04-3510SHAWN M. HOLUB, Plaintiff LISA M. CRAIN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : (--)q - 3~i~ CIVIL TERM _. IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, Shawn M. Holub, by his attorneys, Irwin & McKnight, and presents the following Complaint for Custody. The Plaintiff, Shawn M. Holub, is an adult individual with an address of 11 Piper Court, Carlisle, Cumberland County, Pennsylvania 17013. The Defendant, Lisa M. Crain, is an adult individual with an address of 10 Piper Court, Carlisle, Cumberland County, Pennsylvania 17013. The parties are the natural parents of two (2) children, namely, Shawn M. Cramer, bom November 13, 2002, age 20 months, and Gregory A. Holub, bom October 19, 2003, age 9 months. 4. The Plaintiff desires that the parties have shared legal custody of said minor children, Shawn M. Cramer and Gregory A. Holub. 5. The Plaintiff desires primary physical custody of said minor children with periods of temporary physical custody to Defendant as can be agreed by the parties. 6. The best interests and permanent welfare of said minor children requires that the Court grant the Plaintiff s request as set forth above. WHEREFORE, Shawn M. Holub, respectfully requests that he be awarded primary physical custody and shared legal custody of Shawn M. Cramer and Gregory A. Holub, as provided herein, with periods of temporary physical custody to Defendant as provided herein. By: Respectfully submitted, IRWIN &~ Marcus Mc igh ,sq. Attorney for Plai tiff 60 West Pomfret Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court 1. D. No. 25476 Date: July 20, 2004 VERIFICATION The foregoing Complaint for Custody is based upon infonnation which has been gathered by counsel and myself in the preparation of this action. I have head the statements made in this docwnent and they are true and correct to the best of my knowledge, infonnation and belief. r understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. ~--r1. ~ SHAWN M. HOLUB Date: July 20, 2004 /0 D ~7i - ~ lr-t ~ , ~ olQ. "'- - ~ ", () -u l(=- I ~-? c-, f,:;rr't --\'. 1.) ..-. ',--" :: ' - "\~, SHAWN M. HOLUB PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 04-3510 CIVIL ACTION LAW LISA M. CRAIN DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, July 28, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, September 02, 2004 , the conciliator, 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 if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. 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 existin~: 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. GUm),'. Esq. Custody Conciliator mhc 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 - ~ ~ps- ~ ~ ~~ Ittl;e.L, h;e ~ ~tL, At/-Je-L ~aJV ~.?!~ ~'r9 Ar?~eL A1.N ViNvti7ASNN3d nOJ Qt,J\f)!:!jgwno Sa :fJ /.{d BZ Inr ?OOZ )JJV10NOH.LO!:Jd 3HJ. :10 3JI::I.:!D-o:n1::J SHAWNM.HOLUB, Plaintiff SEP 1 6 Za04 f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v CIVIL ACTION - LAW LISA M. CRAIN, Defendant NO. 2004 - 3510 IN CUSTODY COURT ORDER AND NOW, this ].. o' day of September, 2004, upon consideration of the attached Custody Conciliation report, it is ordered as follows: 1. The parties to the above action shall not relocate the minor children, Shawn M. Cramer, born November 13, 2002, and Gregory A. Holub, born October 19, 2003 from their current residence at 3 Piper Court, Carlisle, Pennsylvania without written agreement of the parties or further order of this Court. 2. This order does not address any issues with respect to which party should have custody of the minor children in the event of a separation nor does it address any issues relative to whether the parties have standing to seek custody of the minor children. 3. Legal counsel for the parties may contact the Custody Conciliator directly to schedule another conciliation conference, which may be a telephone conference, in the event one is necessary. BY THE COURT, ,Iii cc: -Marcus McKnight, Esquire Py Kruzel, Student Attorney ) 'V\l\\\1K\J..SNIHd I llo.\/"',(() r'.~f'.~l::;q\W'f'I f\J.J,.\ '......._. ,'o ,.J""''''' '\\ h.J stj :\\~'\I LZ <l3S'I6Ul A\:NlC~~O(-\iO'dd 3\-11 ~O 3'J\:Ho--01\\::l SEP 16 2ot14 f SHAWN M. HOLUB, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA \-, v CIVIL ACTION - LAW LISA M. CRAIN, Defendant NO. 2004 - 3510 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Shawn M. Cramer, born November 13, 2002 and Gregory A. Holub, born October 19, 2003. 2. A Conciliation Conference was held on September 2, 2004, with the following individuals in attendance: The father, Shawn M. Holub, with his counsel, Marcus McKnight, Esquire and the mother, Lisa M. Crain, with her counsel, Student Attorney, Amy Kruzel, Dickinson School of Law Family Law Clinic. 3. Based upon information received at the conciliation, the Conciliator recommends an order in the form as attached. DATr 13/ tJ 1 g{~ Cnstody Conciliator : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA SHAWN M. HOLUB, Plaintiff/Petitioner v. CIVIL ACTION - LAW 2004-3510 CIVIL TERM LISA M. CRAIN, DefendanURespondent IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY AND NOW comes the Plaintiff/Petitioner, Shawn M. Holub, by his attorneys, Irwin & McKnight, and presents the following Petition for Modification of Custody. L The Petitioner, Shawn M. Holub, is an adult individual with an address of 11 Piper Court, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Respondent, Lisa M. Crain, is an adult individual with an address of 10 Piper Court, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties are the natural parents of two (2) children, namely, Shawn M. Cramer, born November 13, 2002, and Gregory A. Holub, born October 19, 2003. 4. The Respondent has stated that she intends to leave the area and conceal herself and said minor children from the Plaintiff. 5. The Petitioner desires that the parties have shared legal custody of said minor children, Shawn M. Cramer and Gregory A Holub. 6. The Petitioner desires primary physical custody of said minor children with periods of temporary physical custody to Respondent as can be agreed by the parties. 7. The best interest and permanent welfare of said minor children requires that the Court grant the Petitioner's request as set forth above. WHEREFORE, Petitioner, Shawn M. Holub, respectfully requests that he be awarded primary physical custody and shared legal custody of Shawn M. Cramer and Gregory A. Holub, as provided herein, with periods of temporary physical custody to Respondent as provided herein. Respectfully submitted. IRWIN & McKNIGHT By: ~ Date: February 16.2005 VERIFICATION The foregoing document is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. .~Pl~ SHAWN M. HOLUB Date: February 16, 2005 (') ("'1 -.1 t"I- ;~ .-1 VJ '-,'" ~ G> ...,,.1 )-1-\ 91 -~ r G\ ~ C- \) -"'" - --' ~ -," b ~ \-.. C',) ~ -,j ~ ~ U\ 3' (' r- ::? ~. ,...- ...;-. - SHAWN M. HOLUB PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 04-3510 CIVIL ACTION LAW LISA M. CRAIN DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, February 17, 2005 , 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 Thursday, February 24, 2005 at 9:30 AM for a Pre-Hearing Custody Conference. At slIch eonference, 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 ILhe court, and to enter into a temporary order. All children age five or older may also be present at the conference. 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: Isl Hubert X Gilrov. Esq. Custody Conciliator 0' t The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of I990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, pleas" 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 A TTORNEY 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 ] 70] 3 Telephone (717) 249-3166 .~~..~ ~)"'~ ~ JOt.Jr: ;L//P J'. ~~ J?J-(/-e ~vt/ ~~ ~1;A!~t7~/?9 5o.(j-C' h'"j ;~~ : '"J L i c:'~.:J SHAWN M. HOLUB, Plaintiff IW' f] 7 ~y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v CIVIL ACTION - LAW LISA M. CRANE, Defendant NO. 2004-3510 IN CUSTODY COURT ORDER AND NOW, this %. =::' day of /'l?hc4 , 2005, upon consideration of the attached Custody Conciliation report, it is ordered that this Court's Order of September 20, 2004 is vacated and replaced with the following Order: 1. The parties are currently residing together. In the event the parties separate, the following custody arrangement shall be in place: a. The Father, Shawn M. Holub, and the Mother, Lisa M. Crain, shall enjoy shared legal custody of Shawn M. Cramer, born November 13, 2002 and Gregory A. Holub, born October 19, 2003. b. Physical custody shall be handled on a shared 50-50 custodial arrangement. Unless the parties are able to agree otherwise, the arrangement shall be a week on/week off basis with exchange of custody every Sunday at 6 p.m. 2. Neither party shall take the minor children out of the Commonwealth of Pennsylvania without the written consent of the other party. 3. Based upon the agreement of the parties, the parties have each reserved the issue to raise the standing of either party to seek custody of the minor children at any future proceedings in this case. cc: ~us A. McKnight, Esquire In') I ~ f'\ ') r M. enu., ......re .> ~ ~s BY THE COURT, . Ad evin A. Hess v\1\r<';\lX::'; \:,r:k~ II.,L~-<(';'--:(--. <)' "\ I J' ., '''~'l.'''.' __;1 :G h,d (.- tnt~~ ~tlU.~ l<!;<J:~';,;..ck;d 3Hl ::0 ~:)::-::l :;~:1i-:: ..c:nH SHAWN M. HOLUB, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW LISA M. CRAIN, Defendant NO. 2004-3510 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Shawn M. Cramer, born November 13, 2002 and Gregory A. Holub, born October 19, 2003. 2. A Conciliation Conference was held on February 24, 2005, with the following individuals in attendance: The Father, Shawn M. Holub, with his counsel, Marcus A. McKnight, Esquire, and the Mother, Lisa M. Crain, with her counsel, Nathan C. Wolf, Esquire. 3. The parties agree upon the entry of an Order in the form as attached. )- ~g- Or DATE {/)IJ-