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HomeMy WebLinkAbout02-1316EMMANUEL SHUGHART, Plaintiff ROSANNA WICICARD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 02- /~3./~, CIVIL TERM _. : IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Emmanuel Shughart, residing at 255 Old State Road, Gardners, Cumberland County, Pennsylvania . 2. The defendant is Rosanna Wickard, residing at 2348 Rimer Highway, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following child: Name Present Residence Alexis Rosalynn Shughart 2348 Rimer Highway, Carlisle, PA 17013 3 %yrs The child is presently in the custody of mother who resides at 2348 Rimer Highway, Carlisle, PA. During the past five years, the child has resided with the following persons and at the following addresses: Person Address Dates Rosanna Wickard 2348 Ritner Highway 7/27/98 to Present Carlisle, PA 17013 The mother of the child is Rosanna Wickard, currently residing at 2348 Ritner Highway, Carlisle, PA. She is married. The father of the child is Emmanuel Shughart, currently residing at 255 Old State Rd, Gardners, PA. He is married. 4. The relationship of plaintiff to the child is that of father. The plaintiff currently resides with the following persons: Name Relationship Deanna ]ohnson Spouse Larry Kurtz Son of spouse Christian Kurtz Son of spouse $. The relationship of defendant to the child is that of mother. The defendant currently resides with the following persons: Name Relationship Kevin Wickard Spouse 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. 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: a) Plaintiff can provide the child with a home with adequate moral, emotional and physical surroundings as required to meet the child's needs; b) Plaintiff is willing to accept custody of the child; c) Plaintiff continues to exercise parental duties and enjoys the love and affection of the child. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: .Name Address B sis of CI 'm NONE Wherefore, plaintiff requests the court to grant to him periods of partial custody of the child. //I~ndsay~..,,,~ 3 7 SouthD~;ae ]~'~rnbverd' Esq~ Carlisle, PA 17013 Attorney for Plaintiff I verify that to best of my knowledge and belief, the statements made in this 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. Emmanuel Sh~f EMMANUEL SHUGHART PLAINTIFF : 1N THE cOURT OF cOMMON PLEAS OF : CUMBERLAND coUNTY, PENNSYLVANIA : 02-1316 CIVIL ACTION LAW RosANNA WICKARD : IN CUSTODY DEFENDANT AND NOW, _ Monday, March 25, 2002 ., upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before J~acq~eline M. Verney, Esq. , the conciliator, Wednesday, May 01, 2002 at 9:30 AM at4th Floor, Cumberland County Courthouse, Carlisle on - - for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot bc accomplished, to define and narrow the issues to bc heard by thc 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: Is/ .[acqueline M. Verney. Esq. Custody Conciliator 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. IF YOU DO NOT YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. SET HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE 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 EMMANUEL SHUGHART, Plaintiff V. ROSANNA WICKARD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 02- 1316 CIVIL TERM : IN CUSTODY STIPULATION FOR CUSTODY STIPULATION made this ~ day of (~7)o~, / ,2002, between Rosanna Wickard, hereinafter referred to as Mother, a- . ' nd Emman'uel Shughart, hereinafter referred to as Father. WHEREAS, the above-named Mother and Father had born to them the following child on the following date: NAME Alexis Rosalynn Shughart BIRTH DATE July 27, 1998 AND WHEREAS, the above-named Mother and Father desire to enter into a Stipulation as to the custody of the above-said child and to the partial custody rights of the non-custodial parent: NOW, THEREFORE, in order to effectuate the above purpose, the above-named Mother and Father hereby stipulate that:: 1. Mother and Father shall share legal custody of the child. 2. Mother shall have primary physical custody of the child. 3, Father shall have periods of partial custody on Wednesdays and Saturdays for four hours at times agreed upon by the parties. 4. Father shall provide transportation. 5. It is anticipated that the four-hour period of time will expand as agreed upon by the parties and will be reviewed in two months. TO THIS PURPOSE, The parties hereto intend to be legally bound by the terms of this Stipulation and desire to have the Stipulation entered as an Order of Court. Witness: ughart, F-~ther EMMANUEL SHUGHART, Plaintiff ROSANNA WICKARD, DefendanL : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 02- 1316 CIVIL TERM : IN CUSTODY STIPULATION FOR CUSTODY STIPULATION made this'~ d~y of~'"~'~'-_¢Z~ , 2002, between Rosanna WicKard, hereinafter referred to as Mother, and Emmanuel Shughart, hereinafter referred to as Father. WHEREAS, the above-named Mother and Father had born to them the following child or' the following date: NAM E Alexis Rosalynn Shughart B~RTH DATE July 27, 1998 AND WHEREAS, the above-named Mother and Father desir~ to enter into a Stipulation as to the custody of the a~ove-said child and to the pa~ai custody rights of the non-custodial parent: NOW, THEREFORE, in order to effectuate the above purpose, the above-named l¥1o'[he[' and Father hereby stipulate that:: 1. Mother and Father shall share legal custody of the child. 2. Mother sr~all have pdmary physical custody of the child. 3. Father shall have periods of parlial custody on Wednesdays and Saturdays for four hours at times agreed upon by the parties. 4. Father shall provide transportation. 5. It is anticipated that the ~'our-hour period cf time will expand as agreed upon by the parties and will be reviewed in two months. TO THIS PURPOSE, The parties hereto intend to ba legally bound by the terms of this Stipulation and desire to have the Stipulation entered as an Order of Court. ~~,~' ness: David A, Bario, Esquire F~osanna-Wi~kard, Motl~e~- - EMMANUEL SHUGHART, Plaintiff V, ROSANNA WICKARD, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 02-1316 CIVIL TERM IN CUSTODY ORDER OF COURT · AND NOW, this ~ day of ~, 2002, upon consideration of the attached custody stipulation with respect to the parties' child, Alexis Rosalynn Shughart, born July 27, 1998, the terms of the stipulation are entered as an order of court. Lindsay Dare Baird, Esquire 37 South Hanover Street Carlisle, PA 17013 Attorney for Plaintiff J= David A. Baric, Esquire 17 West South Street Carlisle, PA 17013 Attorney for Defendant l?1o EMMANUEL SHUGHART, Plaintiff ROSANNA WICKARD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 02- 1316 CIVIL TERM IN CUSTODY STIPULATION FOR CUSTODY made this"~"~ day of~d_~,)o~., / . 2002, between Rosanna Wickard, STIPULATION hereinafter referred to as Mother, and Emmanuel Shughart, hereinafter referred to as Father. WHEREAS, the above-named Mother and Father had born to them the following child on the following date: NAME Alexis Rosalynn Shughart BIRTH DATE July 27, 1998 AND WHEREAS, the above-named Mother and Father desire to enter into a Stipulation as to the custody of the above-said child and to the partial custody rights of the non-custodial parent: NOW, THEREFORE, in order to effectuate the above purpose, the above-named Mother and Father hereby stipulate that:: 1, Mother and Father shall share legal custody of the child. 2. Mother shall have primary physical custody of the child. 3. Father shall have periods of partial custody on Wednesdays and Saturdays for four hours at times agreed upon by the parties. 4, Father shall provide transportation. 5, It is anticipated that the four-hour period of time will expand as agreed upon by the parties and will be reviewed in two months. TO THIS PURPOSE, The parties hereto intend to be legally bound by the terms of this Stipulation and desire to have the Stipulation entered as an Order of Court. Witness: S ughart, F-a'ther EMMAI'~UEL ,.~HUGHART, Plaintiff ROSANNA WICKARD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 02- 1316 CIVIL TERM : IN CUSTODY STIPULATION FOR CUSTODY STIPULATION made this ~¢r"r'W day of'~""'~'~/~ ,2062, between Rosanna Wick;oral, hereinafter referred to as Mother, and Emmanuel Shughart, hereinafter referred to as Father. WHEREAS, the above-named Mother and Father had born to them the following child or' the following date: NAM E Alexis Rosalynn Shughart BIRTH I~ATE July 27, 1998 AND WHEREAS, the above-named Mother and Father desire to enter into a Sbpulation as to the custody of the above-said child and to the pavia[ custody rights of the non-custodial parent: NOW, THEREFORE, in order to effectuate the above purpose, the above-named Mother and Father hereby stipulate that:: 1. Mother and Father shall share legal custody of the child. 2. Mother snail have pdmary physical custody ortho child. 3. Father shall have periods of partial custody on Wednesdays and Saturdays for four hours at times agreed upon by the parties. 4. Father shall provide transportation. 5. it is anticipated that the four-hour period of time will expand as agreed upon by the parties and will be reviewed in two months. TO THIS PURPOSE, The parties hereto intend to be legally bound by the terms of this Stipulation and desire to have the Stipulation entered as an Order of Court. David A. Boric, Esquire R'osanna Wickard, Mother OCT 0 EMMANUEL SHUGHART, Plaintiff ROSANNA WICKARD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-1316 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 3rd day of October, 2002, the Conciliator being notified that the parties have reached an agreement regarding custody, the Conciliator hereby relinquishes jurisdiction in this matter. FORTHECOURT, ~acq~/eline M. Vemey, Esquire, Cus~dy Conciliator'