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Home My WebLink About04-5585 SAIDIS SHUFF, FLOWER & LINDSAY ATIORNEYSoAToLAW 26 W. High Street Carlisle. P A LLOYD SHOEMAKER III, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. CIVIL TER~__ l~ C>4- C","PS C!lO\-' l€R..k/} IN CUSTODY l V5. MARIA VERDEKAL, Defendant COMPLAINT FOR CUSTODY 1. The Plaintiff is Lloyd Shoemaker III, residing at 91 Ridge Road, Newville, Cumberland County, Pennsylvania 17241. 2. The Defendant is Maria Verdekal, residing at 1435 Three Square Hollow Road, Newburg, Pennsylvania 17240. 3. The Plaintiff seeks custody of the following child, Camden C. Verdekal, born March 5, 2004. 4. The child was born out of wedlock. The child is presently in the custody of his Father who resides at 91 Ridge Road, Newville, Pennsylvania. During the past five years, the child has resided with the following persons and at the following addresses: Name Lloyd Shoemaker III Address FromlTo 67 Countryview Estates, Birth to March 2004 Newville 4830 E. Trindle Road Birth to March 2004 Carlilse, PA Maria Verdekel The mother of the child is Maria Verdekel, currently residing at 1435 Three Squae Hollow Road, Newburg, Pennsylvania 17240. She is married. The father of the child is Lloyd Shoemaker III, currently residing at 91 Ridge Road, Newville, Pennsylvania 17241. He is single. The relationship of the Plaintiff to the child is that of Father. The Plaintiff currently resides with the following person(s): Deborah Shoemaker and Curtis Rauch, Jr. 6. The relationship of the Defendant to the child is that of Mother. The 5. SAlOIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street Carlisle. P A :1 Defendant currently resides with the following person(s): Jamie Rhone. 7. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation concerning the custody of the child in this or another jurisdiction. 8. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of the Commonwealth. 9. The 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. 10. The best interest and permanent welfare of the child will be served by granting the relief requested because: a) The Plaintiff can best provide for the physical and emotional needs of the child. 11. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, the Plaintiff requests this Court to grant primary physical custody of the child to the Plaintiff. Respectfully submitted, Said is, Shuff, Flower & Lindsay By: Ii I r:r. ~ :~ Carol J. Ljnd ay 10 #446 26 West igh Street Carlisle, PA 17013 (717) 243-6222 < . . SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYSoAToLAW 26 W. High Street Carlisle. PA VERI FICA liON I, the undersigned, hereby verify that the statements made herein 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. ~(./)[} Lza- @Vd Shoemaker III, Plaintiff Date: 1(!~/04: J;!CJ ~\ , '" ~ ~ - ...:t ~ ~ ~ -.. () . Crt () fl J ;pi. . . ~~,: ~: . r'::~. : ~'- -~. \-~ (,) () C~ -;.-.... "7 ~ r--..) c-'") =c; ..1-- o ., --.1 G..I-:~9 =:t:n Q(3 ; ':.- ,'11 ::::; .'t_" ~D ~ -,- a <: , co ~ -".~.... '-0 U1 LLOYD SHOEMAKER, III PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COU1'1J'TY, PENNSYLVANIA V. 04.5585 CIVIL ACTION LAW MARIA VERDEKAL DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, November 16,2004 , 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 Friday, December 03, 2004 at 10:30 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 existing: Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearin!!. FOR THE COURT. By: Isl facqueline M. Veml~v. 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 th,e 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 . ~ ~ ~ ~ ~ ~>it?~C'.// --?P ~ ~ ~u, "'~-_~'J/ ~ ~ ~ ~Jft' ~rr; At/-lie .J/ \llt\j~\lj\S\jt\j~d I H ({'!tit') ,~~ " .-;: '--.,.-,, \1"1"\ I\.Ll\ !C.'.' ..;., ':',~_,,~'I ,I k.J 8 ~ :01 WV fJ2 !tON ~aal Acl'710NOH108d 3Hl:i0 3JiJ:lD-031/:l SAlOIS SHUFF, FLOWER & LINDSAY A1TORNEYS'AT'LAW 26 W. High Street Carlisle, P A LLOYD SHOEMAKER III, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V5. CIVIL ACTION - LAW NO. 04-5585 CIVIL TERM MARIA VERDEKAL, Defendant IN CUSTODY STIPULATION OF COUNSEL The parties hereto are Lloyd Shoemaker III who resides at 91 Ridge Road, Newville, Cumberland County, Pennnsylvania 17241, hereinafter Shoemaker and Maria Verdekal residing at 1435 Three Square Hollow Road, Newburg, Pennsylvania 17240, hereinafter Verdekal. 1. The parties are parents of Camden C. Verdekal born March 5, 2004. 2. The parties will share legal custody of Camden. Shoemaker shall have physical custody of the child and Verdekal shall have partial custody on the following schedule: a. Every Sunday from 10:00 a.m. until 7:30 p.m., provided, however, that on five Sundays per year, Shoemaker, with two weeks notice to Verdekal, may keep custody of the child for Sunday so as to have a weekend with the child. b. One evening per week, 6:00 p.m. to 8:00 p.m. The weekday may be decided between the parties and if they cannot agree then the weekday shall be Friday. c. On Christmas Eve from 9:00 a.m. until 8:00 p.m. 3. The parties will share transportation with the receiving party picking up the child at the home of the parent having custody. However, Shoemaker will provide transportation for pick up and delivery until he provides two weeks notice to Verdekal that he wishes to return to a shared transportation arrangement. 4. The parties shall transport the child at all times in a safe car seat suitable for the child at his age. 5. Both parties shall have a valid driver's license and will transport the child only in a vehicle covered by insurance. 6. The parties intend that this Stipulation of Counsel be entered as an order of court and authorize their attorneys to sign this stipulation their behalf. ." f} r'\ (~~ Carol J"~nd~ay, Esquire- Counse~laintiff ' SAIDIS SHUFF, FLOWER & LINDSAY ATIURNEYSOAToLAW 26 W. High Street Carlisle, P A (Ai ~ r\(~ . G.t9-\j! I - (_ . ~ce D'Alo, Esquire Counsel for Defendant Mid Penn Legal Services () ,...", C=> 0 r-: <:;.::) 11 ...c- t~; :'':j": 0 :r S_!!:~_: rq nif!1 (J -.......t." - 1'0..> :r.;f:J ~i) '. _/' \..0 O~ C :::-i_~ ;~- -0 _.C -Tl i~) -,.. :::-:('') -... ~:'-rn ..r.:- () '-~ ;0'-/ :2: ~;:'> :~ C:l ~..l.,) N -< SAlOIS SHUFF, FLOWER & LINDSAY ATfORNEYSeAT'LAW 26 W. High Street Carlisle. P A DEe 3 0 2004 j' ~7 LLOYD SHOEMAKER III, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V5. : CIVIL ACTION - LAW NO. 04-5585 CIVIL TERM MARIA VERDEKAL, Defendant : IN CUSTODY ORDER OF COURT NOW, this l,t day of _~( , 20~on consideration of the within Stipulation of Counsel, the terms of the Stipulation are hereby made an Order of Court. .... ~---- ------ - J ------- . ?~ ~~O? 0'"' \ F1LED-O::Fi8E r::: TL!C F);Y'\T'r-!()\'('J1 i r.:.v ..)1 r~L... .i\,Jl '~r'''<'.. \1\:.. 2005 JAN II Af110: 59 ClJrv':~:"'~' 0,,';: :':':!'J;\JT'( PC-i' ~i\J~;YL\/),~\~f.!\ _... _~..~.... .'. <''- .".- -::0"- "'.) ...,......--....,,,.-:;7"'.'Ir.)- . ,"'\ ~r;1 a I -,..J RECEIVED MAY 1 · onn. ~ LLOYD SHOEMAKER, III, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2004-5585 CIVIL TERM MARIE VERDEKAL, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this II th day of May, 2005, having scheduled this matter for a Conciliation conference on December 3, 2004, which was continued by the Plaintiff, and not having heard from the plaintiff to reschedule the matter and more than ninety days have passed, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, AV Conciliator , :..-~! I,r f'\,:;