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HomeMy WebLinkAbout01-2721 CLARK T. GODUSKy, Plaintiff : IN THE COURT OF COMMON PLEAS OF v. : CUMBERLAND COUNTy. PENNSYLVANIA : NO. 2001.2 721 CIVIL TERM BEVERLY j. SHUTE (GODUSKy). : Defendant : CIVIL ACTION. LA W : IN CUSTODy I. Plaintiff is Clark T. Godusky. an adult individual currently residing at 12 Belle Drive, Car/isle, Cumber/and County, Pennsylvania 17013. 2. Defendant is Beverly j. Shute (Godusky). an adult 7607 B Weatherworn Way. Columbia, Mary/and 21046. individual current/3, residing at 1986. 3. The Plaintiff is the natural mother of the child, Brittany Godusky, born April 28, 4. The child was bom in wedlock. 5. For the past five years, the child has resided with the following persons at the f°ll°w~resses tbr the following lengths oft/me: Clark Godusky Brenda Godusky 12 Belle Drive D.~ Carlisle, PA June 2000 to Beverly Godusky Present Oregon July 1997 to Beverly Goduskv June 2000 ' ' Maryland July 1997 to 1996 single. 6. The natural Mother of the child is the Defendant, who resides as £oresaid. She is married'7. The natural Father of the child is the P~ainti~ who resides as foresaid. He is 8. The relationship of the Plaint/fi'to the child is that of natural Father. The Plaintiff currently res/des with his wife, Brenda Godusky. a daughter, stepson, and the ch/Id at issue. 9. The relationship of the Defendant to the children is that of natural Mother. The Plaintiff currently resides alone. 10. The Plaintiff has no information ora custody proceeding concerning the child pending in any Court of this Commonwealth. l 1. The best interest and permanent welfare of the child will be best served by granting the relief requested as the Plaintiff is better suited to Provide a stable environment to foster the child's well being. 12. The Plaintiff does not know of an). person not a pan). to the proceedings who claims to have custody or visitation rights with respect to the child. WHEREFORE. the Plainti~ Clark T. Godusky, respectfully requests this Honorable Court to enter an Order scheduling the Parties for a Custody Conciliation. Respectfully submitted, Date: ~ ~ Attorney for the Plaintiff One West High Street, Suite 208 Post Ol'lqce Box 1290 Carlisle, Pennsylvania 17013 (7171 240-0833 : IN THE coURT OF COMMON PLEAS OF cLARK T. GODUSKY : cuMBERLAND cOUNTY, pENNSYLVANIA pLAINTIFF V. CIVIL ACTION LAW BEVERLY 1. sHUTE (GODUSKY) : 01-2'/21 DEFENDANT : : IN cusTODY Thursda , Ma 1'/, 2001 , upon constderattun of t. he attached Complaint,. , -- -'OW. ThursdS , Ma l ~, ~,,,,- before ~' the concthator, AND t,i ' ~ , .~. :~-.ective counsel appear at it is hereby directed that pan'acs and tlae~r respc~ - ... Thur~da , June 0'/, 2001 ..... ..A...thouse, CarusJe on ~ +.. ,~nlve the issues tn d~sput~, Floor- Cumberland Coun t;our~ ..... - ..... -- effort will be made to res,, at 4th ~l°°r' "~.f,.renCe. At such ennference' un ~,. +~e court, and to ent~r iht° a temp°t~ for a Pre-Hearing Custody ~.on, ..... - ~.-.-, the issues to be hearu vy .... conference may ~f this cannot be acoomphshed, to define ann n~,,,-- Failure to appear at the order. All children age five or older may also be present at the cnnference' provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any aud all existing protectiOn from Abuse orderS, Custody orders to the conCiliator 48 hours prior to scheduled hearing. Special Relief orderS, and FOR THE COURT, with the reasonable The Court of Common pleas of Crunberland County is required by law to comply to disabled individuals having business before the court, please contact our offtce. Americans with Disabilites Act of 1990. For information about accessible facilities and accommodations available 'n or business hefore the court. You must All arrangementS must he made at least 72 hours prior to any heart g onfereuee or hearing. attend the scheduled c __.-,-, vc~ R ATTORNEY AT oNCE. IF YOU DO NOT yOU sHoULD TAKE THIS PAP~'tc tu '"%0 TO OR TELEPHONE THE OFFICE SET HAVE AN ATTORNEY OR CAIqNOT AFFORD ONE, FORTH BELOW TO FIND OUT wHERE yOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, pennsylvania 17013 Telephone (717) 24%3166 : TN THE ¢oUP,.T OF CoMMO]4 ?L,E,^S .. ]40.01-2721 CI¥1L BEVERLY j' SHUTE (oODUSKY). : I]4 cUSTODY Defendant day of June. 2001, upon consid~rarion of the auached Custody {'~ord~ as folloWS: A]4D ]4OW, this . . ~ and directed - unu. have jurisdiction to Conciliation Report, it ~s determines that pennsylvania and Cumharland Co ,~ 1. The court order Dr Brittany Oodusky, bom April 28, 1986. enter a custody The Father, Clal~ T. Oedusky' and the Mother, Beverly L Shut~, shall anjoy shared legal custody of BrittanY Oodusky, born APrtl 25, 1986- 2. of the minor child. The Father shall e~oY primary physical custody · · , -ustedY with the ruinor _ _rary puystcai ~' ,'/,, b~ ~uarant~e, xl 3. . riods o[ t~npu her sntm · -'-'1 cnioY liberal po c-~-ificallY, the Mot e Mother ~ ~.~ ~,~ the l~ties. 4. c~ld as alp~a upu,, vj -- -- time as follows: · For a planned trip to portland that is scheduled for June 15.2001 for ^' a p~riod of at le.~st two weeks. ' and ~osc weeks For at least other w ks during the summer months for a period · _t.~A, defl cheerleadinl~ can~p. do not hltc~el~ wiut child's previousty s~,,~,. .. ....,,os Monday. For ditto'nat g . · *~,=r's ucrtou~ ~'" C. Monday is a holiday, ~.,o, ..... D MAi suUdacl'°ther times as may be agreed between tT~chTdiSen the child Mother shall enjoy reasonable telephone contact w~? the nuno 5. is in the custody of the Father, and Father shall enloy reasonable telephone contact with the minor child wheu she is in the custody of the Mother. · -%-ss o,~.d ottterwis~ ~OB ~0~ ~.u ~dte ~ ~ · ,~*~er's obh~UO fion ~t Mo~g. In u~t iss~ ~d at ~t time ~uest t~ Fa~er ~o~ all or a ~ion of mcoasid~ ~is thc ~s~~ti°n for exc~ge of cugo&Y. ~is o~ at 7. In the cyst eithg ~ ~sigs to m~ ~n, t~t ~ ~Y ~fition the co~ to Cust~Y ConCiliator for a conf~n~' ~om~ S. Die~, E~~ Beverly ~. Sh~ 7~7 B Wea~e~om Way Cot~b~ MD 21~6 : IN THE cOURT OF coMMON pLEAS OF CLARK T. oODUSKY' : cUMBERLAND coUNTY, pENNSYLVANIA Plaintiff : : CIVIL ACTION - LAW V : NO. 01-2721 CIVIL BEVERLY j. sHUTE (GODUSKY), : IN CUSTODY Defendant Prior Judge: ~N cONFERENCE sUMMARY I~PORT IN AccORDANCE WITH THE cUMBERLAND cOUNTY CIVIL RULE OF PROCEDURE 1015 3-8(b), the undersigned Custody Conciliator submits the following report: · the subject of this litigation is as 1. The pertinent information pertaining to the child who is follows: Brittany Oodusky, born April 28, 1986. 2. A Conciliation Conference was held on June 7. 2001, with the following individuals in attendance: The Father, Clark T. Oodusky, with his counsel, ThomaS S. Diehl, Esquire; and the Mother, .... ~ without counsel. Beverly J. Shute wt~o appcm~,, 3. The parties agree to the entry of an order in the form as attached.