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Home My WebLink About05-2693 (;> JOHN C. SHUMBERGER and TERESA M. SHUMBERGER, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. ;)C() 5" -.;1//8 CIVIL TERM JAMIE LYNN SHUMBERGER, Defendant CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, First Floor, Carlisle, Pennsylvania 17013, Telephone: (717)-240- 6195. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717)-249-3166 . JOHN C. SHUMBERGER and TERESA M. SHUMBERGER, Plaint:iffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. of ;l~ $13 CIVIL TERM JAMIE LYNN SHUMBERGER, Defendant CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes plaintiffs, JOHN C. SHUMBERGER and TERESA M. SHUMBERGER, by their attorney, MURREL R. WALTERS, III, ESQUIRE, who aver as follows: 1. The Plaintiffs are John C. Shumberger and Teresa M. Shumberger, husband and wife, adult individuals who reside at 55 Linda Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Defendant is Jamie Lynn Shumberger, an adult individual who resides at 8870 Spiral Cut Court, Columbia, Maryland 21045-2738. 3. Plaintiffs seek custody of Brandon Michael Shumberger, born December 15, 1997, who was born out of wedlock. 4. Brandon Michael Shumberger currently resides with Plaintiffs, John C. Shumberger and Teresa M. Shumberger, at 55 Linda Drive, Mechanicsburg, Pennsylvania. From his birth until March, 2005, Brandon resided with Defendant Jamie Lynn Shumberger. From March, 2005 until present, Brandon has resided with Plaintiffs, John C. Shumberger and Teresa M. Shumberger. From March, 2005 until present, Brandon has resided with Plaintiffs, John C. Shumberger and Teresa M. Shumberger. The mother of Brandon Michael Shumberger is Jamie Lynn shumberger, Defendant herein, who is currently residing at 8870 Sprial Cut Court, Columbia, Maryland. She is currently not married. The father of Brandon Michael Shumbergers is Keith Rummel, current address unknown. plaintiff and Defendant were never married to each other. 5. The relationship of Plaintiffs to Brandon Michael Shumberger is maternal grandfather and his wife. Brandon Michael Shumberger currently resides with the Plaintiffs, John C. Shumberger and Teresa M. Shumberger. 6. The relationship of Defendant to Brandon Michael Shumberger is that of natural mother. 7. Plaintiffs have no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiffs do 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. 8. The best interests and permanent welfare of the child will be served by granting full legal custody to Plaintiffs, subject to periods of visitation with Defendant. . 9. Plaintiffs have not participated as a party, witness or in another capacity or in other litigation concerning the custody of the child in this or another Court. 10. Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the child have been named as a party to this action. WHEREFORE, Plaintiffs request the Court to grant custody of subject to visitation with Defendant. the parties' minor grandson, BRANDON MICHAEL SHUMBERGER, t MURREL R. WALTERS, III, ESQ. Attorney for Plaintiff 54 East Main Street Mechanicsburg, PA 17055 (717) 697-4650 I.D. No. 24849 . . . VERIFICATION I verify that the statements made in this Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. !l4904, relating to unsworn falsification to authorities. r-', , o-j ~1 0 ( Date VERIFICATION I verify that the statements made in this Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. !l4904, relating to unsworn falsification to authorities. 6"l1O/0':'/ Date I . '...1A h"".}ll, ~~_ Teresa M. Shumberger "'* ~ --- ~ ......... - ~ Vd, "- -. ~ C"- e;-. "l:::, ~":\ -- ~ '(' s-- --r: \( ~ "" '- C;. ~ ,......,~ C) -n --I ~- i~ j~i ':~.:_' <.~'l -. 1'.) ,J;C" CJ ;,j (--,1 Ui JOHN C. SHUMBERGER and TERESA M. SHUMBERGER, Husband and wife, Petitioners IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA c.A -J~ CUSTODY Os-- ~ f.:;, 73 vs. JAMIE LYNN SHUMBERGER, Respondent AND NOW, this AGREEMENT FOR CUSTODY . II;> 1..? day of April, 2005, petitioners John C. Shumberger and Teresa M. Shumberger, husband and wife, petitioners, by their Attorney, Murrel R. Walters, III, Esquire, and respondent Jamie Lynn Shumberger, with regard to custody and visitation of Brandon Michael Shumberger, a minor child, stipulate and agree as follows: 1. The petitioners are John C. Shumberger and Teresa M. Shumberger, husband and wife, who reside at 55 Linda Drive, Mechanicsburg, Pennsylvania 17050. John C. Shumberger is the father of respondent Jamie Lynn Shumberger. 2. The respondent is Jamie Lynn Shumberger, who resides at 8870 Spiral Cut Court, Columbia, Maryland 21045-2738. 3. Jamie Lynn Shumberger is the mother of Brandon Michael Shumberger, born December 15,1997. 4. The natural father of the child is Keith Rummel. Father was never married to Jamie Lynn Shumberger and they only lived together briefly after the birth of the child. Mother moved from the residence with Father shortly after the birth of Brandon, taking the child with her. There has been almost no contact whatsoever between Father and " Brandon Michael Shumberger. Mother has filed for child support but has only received several payments. Keith Rummel is obligated to pay child support for approximately five (5) children to various mothers and has been incarcerated on at least one occasion for his failure to pay support. No child support has been paid nor has there been any contact in the last five years. 5. The parties desire to enter into an amicable agreement for custody and visitation of Brandon Michael Shumberger. 6. Brandon Michael Shumberger presently resides with his maternal grandfather, John C. Shumberger, and his wife, Teresa M. Shumberger, the petitioners, at their home at 55 Linda Drive, Mechanicsburg, Cumberland County, Pennsylvania. 7. The parties have reached an agreement with regard to the custody of the minor child and they do hereby stipulate and agree as follows: a. John C. Shumberger and Teresa M. Shumberger, husband and wife, shall have legal custody of the child. b. John C. Shumberger and Teresa M. Shumberger, husband and wife, shall have primary physical custody of the child. c. Respondent, Jamie Lynn Shumberger, shall have temporary physical custody of the child as the parties may from time to time agree. Initial visitation shall be limited to the home of Petitioners. d. It is the intent of all parties that if and when the Respondent is capable of providing proper parenting care and supervision that she shall spend more time with the . child, having as a goal the ultimate transfer of physical and legal custody to the Respondent as natural parent. e. Jamie shall participate in parenting classes and necessary treatment and counseling relative to substance abuse, so that she may be better able to provide required necessary care for Brandon Michael Shumberger. 8. It is the desire and intention of the parties hereto that this stipulation be entered in the Court of Common Pleas of Cumberland County, Pennsylvania, and that it be endorsed as an order of court, so as to have the full effect thereof. WHEREFORE, Petitioners request this Court to enter an order confirming full legal, as well as primary physical custody of Brandon Michael Shumberger, with them, subject / / to temporary physical custody with Respondent, Jamie Lynn Shumberger./I Murrel R. Walters, III, Esq. Attorney for Petitioners Attorney No. 24849 54 East Main Street Mechanicsburg, PA 17055 (717) 697-4650 . , I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Ann S 4904 relating to unsworn falsification to authorities. \~~} John J hum~ger Date: ~-160tJ I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Ann S 4904 relating to unsworn falsification to authorities. ~{~}Vl. ~d'5''L. Teresa M. Shumberger </ Date: Lf- .~~ -05 . . . ~ I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Ann S 4904 relating to unsworn falsification to authorities. ~A e 1I'#.Jk:hl~~ ltness Date: </-- ;) ! -IJS . JOHN C. SH1}MBERGER and TERESA M. SHUMBERGER 'v. JAMIE LYNN SHUMBERGER : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2005-2693 CIVIL TERM ORDER OF COURT AND NOW, this 7TH day of JUNE, 2005, it appearing to the Court that Father is a necessary party to this action, the request for a stipulated order is DENIED without prejudice. ~rrel R. Walters, III, Esquire 54 East Main Street Mechanicsburg, Pa. 17055 ~ ~mie Lynn Shumberger 8870 Spiral Cut Court Columbia, Maryland 21045-2738 :sld Edward E. Guido, J. I P V-""r" (^" "', '-'-<'~'rl" I\J...I\: ;,~)__,.;:i ,'-I''''''~i~,',''~~:'''11 V 8 I :9 ~J\1 B - Nor SOOl ^')...~ll"fl""'" ;'fll' I ....H1 ~IO \.lv....V!\iUt1.1.v'tJQ j ;;j 3Q!:!.:!Q-031l:1 . ( JOHN C. SHUMBERGER and TERESA M. SHUMBERGER, Husband and wife, Petitioners RECEIVED MAY 25 ZOOV' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CUSTODY J trY) . ~(/;3 JAMIE LYNN SHUMBERGER, Respondent CUSTODY ORDER IK AND NOW, this 3' day of f'\. Vl5 ,2005, upon presentation of the foregoing Agreement, it is hereby ordered that JOHN C. SHUMBERGER and TERESA M. SHUMBERGER, shall have full legal custody, as well as primary physical custody of BRANDON MICHAEL SHUMBERGER, subject to temporary physical custody with JAMIE LYNN SHUMBERGER, as the parties may from time to time agree. J. JOHN C. SH\lMBERGER and TERESA M. SHUMBERGER 'v. JAMIE LYNN SHUMBERGER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-2693 CIVIL TERM ORDER OF COURT AND NOW, this 7TH day of JUNE, 2005, it appearing to the Court that Father is a necessary party to this action, the request for a stipulated order is DENIED without prejudice. ~rrel R. Walters, III, Esquire 54 East Main Street Mechanicsburg, Pa. 17055 -.1 v-J1tmie Lynn Shumberger 8870 Spiral Cut Court Columbia, Maryland 21045-2738 :sld Edward E. Guido, J. Al~.;ri;:!~:;!~J;;J:\(~,~\:I:\?;~~;~;i"in8 C I :9 1411 B- Mnf SOOZ Al:.M.oi,;OHlOlid 3Hl. .:10 30i::!:iO{j31tl JOHN C. SHUMBERGER and TERESA M. SHUMBERGER, Husband and wife, Petitioners IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CUSTODY vs. ":l <.7 0 -.:f . -:J. (, q '1 c/o/,o- JAMIE LYNN SHUMBERGER, Respondent PETITION FOR CUSTODY AND NOW, this 28th day of April, 2005, petitioners John C. Shumberger and Teresa M. Shumberger, husband and wife, petitioners, by their Attorney, Murrel R. Walters, III, Esquire, and respondent Jamie Lynn Shumber,ger, with regard to custody and visitation of Brandon Michael Shumberger, a minor child, stipulate and agree as follows: 1. The petitioners are John C. Shumberger and Teresa M. Shumberger, husband and wife, who reside at 55 Linda Drive, Mechanicsburg, Pennsylvania 17050. John C. Shumberger is the father of respondent Jamie Lynn Shumberger. 2. The respondent is Jamie Lynn Shumberger, who resides at 55 Linda Drive, Mechanicsburg, Pennsylvania 17050. 3. Jamie Lynn Shumberger is the mother of Brandon Michael Shumberger, born December 15, 1997. 4. Keith Rummel is the father of Brandon Michael Shumberger. Father was never married to Jamie Lynn Shumberger and they only lived together briefly after the birth of the child. Mother moved from the residence with Father shortly after the birth of Brandon, taking the child with her. There has been almost no contact whatsoever between Father and Brandon Michael Shumberger. Mother has filed for child support but has only received several payments. No child support has been paid nor has there been any contact in the last five years. The consent of Keith Rummel is attached hereto. 5. The parties desire to enter into an amicable agreement for custody and visitation of Brandon Michael Shumberger. 6. Brandon Michael Shumberger presently resides with his maternal grandfather, John C. Shumberger, and his wife, Teresa M. Shumberger, the petitioners, at their home at 55 Linda Drive, Mechanicsburg, Cumberland County, Pennsylvania. 7. The parties have reached an agreement with regard to the custody of the minor child and they do hereby stipulate and agree as follows: a. John C. Shumberger and Teresa M. Shumlx~rger, husband and wife, shall have legal custody of the child. b. John C. Shumberger and Teresa M. Shumberger, husband and wife, shall have primary physical custody of the child. c. Respondent, Jamie Lynn Shumberger, shall have temporary physical custody of the child as the parties may from time to time agree. Initial visitation shall be limited to the home of Petitioners. d. It is the intent of all parties that if and when the Respondent is capable of providing proper parenting care and supervision that she shall spend more time with the child, having as a goal the ultimate transfer of physical and legal custody to the Respondent as natural parent. e. Jamie shall participate in parenting classes and necessary treatment and counseling relative to substance abuse, so that she may be better able to provide required necessary care for Brandon Michael Shumberger. 8. It is the desire and intention of the parties hereto that this stipulation be entered in the Court of Common Pleas of Cumberland County, Pennsylvania, and that it be endorsed as an order of court, so as to have the full effect thereof. WHEREFORE, Petitioners request this Court to enter an order confirming full legal, as well as primary physical custody of Brandon Michael Shumberger, with them, subject Murrel R. Walters, III, Esq. Attorney for Petitioners Attorney No. 24849 54 East Main Street Mechanicsburg, PA 17055 (717) 6974650 I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Ann ~ 4904 relating to unsworn falsification to authorities. Date: LJ-rib-05 ~' C Jo .Shumberger I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Ann ~ 4904 relating to unsworn falsification to authorities. ~1rt, ~A Teresa M. Shumberger Date: 4 ~ d.~ -<yj I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Ann ~ 4904 relating to unsworn falsification to authorities. Q ~ J.-/1Jv t;rJi fJ kArl. Itness '(, f 'Sh~h~~ . 'e LynnS umberger Date: Ij-clt-os CONSENT I, Keith Rummel, am the father of Brandon Michael Shumberger, born December 15, 1997. The mother of my son is Jamie Lynn Shumberger. The maternal grandparents of my son who are, John C. Shumberger and Teresa M. Shumberger wish to obtain legal custody. I consent to the entry of a court order by which John C. Shumberger and Teresa M. Shumberger will become the legal and physical custodians of my son, Brandon Michael Shumberger. I realize that I might have to petition the Court if! ever want to gain custodial rights. .i{;jgqO Wi rVf'A.ItUl/1r.__ ~A'X 4'4C-- ~ -///4~ fJ n C. ....' C::l <'" cr' c;....=. U::J Q. ::r'-" r\1r;;, -ocr. ~';JO 1~)1\=) 'T '.., ,-n )P, ,-,.,) "~::! j) --<. -;-:"> ~ w .c- - ,S RECEIVED JUL 21 2005r JOHN C SHUMBERGER and TERESA M. SHUMBERGER, Husband and wife, Petitioners IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CUSTODY vs. ")005-. -:J <P'1 J Ct 11'1 /... JAMIE LYNN SHUMBERGER, Respondent CUSTODY ORDER AND NOW, this J d) day o~ ' 2005, upon presentation of the foregoing Agreement, it is hereby ordered that JOHN C SHUMBERGER and TERESA M, SHUMBERGER, shall have full legal custody, as well as primary physical custody of BRANDON MICHAEL SHUMBERGER, subject to temporary physical custody with J AMIE LYNN SHUMBERGER, as the parties may from time to time agree, ------ theCol~ r ~'\;',:,rl~(Vl ..,,1,-, as :6 Wi S21nnOOl . \J .F" "'\'H ~." . 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