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Home My WebLink About06-2849 Cheyenne L. Stouffer, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Cheyenne C. Dyarman, Defendant CIVIL ACTION - LAW No. C:t-- J.J>Lt? CIVIL IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Cheyenne L. Stouffer, residing at 132 West Orange Street, Shippensburg, Cumberland County, Pennsylvania 17257. 2. The defendant is Cheyenne C. Dyarman, residing at 120 Lebo Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks custody of the following child: Name Present Residence DOB Age Landon Stouffer 132 W. Orange Street Shippensburg, Pa 17257 8-28-05 8 Months The child was born out of wedlock The child is presently in the custody of Cheyenne L. Stouffer, residing at 132 W. Orange, Shippensburg, Cumberland County, Pennsylvania 17257. During the past five years, the child has resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Cheyenne L. Stouffer 132 W. Orange Street Shippensburg, Pa 17257 Since Birth 4. The mother of the child is Cheyenne L. Stouffer, residing at 132 West Orange Street, Shippensburg, Cumberland County, Pennsylvania 17257. She is unmarried. The father of the child is Cheyenne C. Dyarman, residing at 120 Lebo Road, Carlisle, Cumberland County, Pennsylvania 17013. He is unmarried. 5. The relationship of plaintiff to the child is that of Mother. The plaintiff currently resides with the following persons. Name Bonnie Marpoe Relationship Mother 6. The relationship of defendant to the child is that of Father. The defendant currently resides with the following persons. Name Sherri Ritchey Hunter Ritchey Ms. Ritchey Relationship Girlfriend Girlfriend's son Girlfriend's daughter 7. 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 and claims to have custody or visitation rights with respect to the child. 8. The best interest and permanent welfare of the child will be served by granting the relief request because: Plaintiff has undertaken and performed the primary parental responsibilities for the child. Plaintiff is best able to provide the care and nurture which the child needs for a healthy development. A Court Order of custody and structured visitation is desired so that the Plaintiff and the child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion. Plaintiff desires to maintain the family household which has been established, and the continued stability ofthe household is in the best interest of the child. A Court Ordered determination of custody is required to avoid continuing conflict between the parties regarding responsibility for custody and support. Defendant's erratic and abusive behavior poses a threat of harm to the child. Defendant frequently abuses alcohol and is therefore unreliable as custodian ofthe child. WHEREFORE, Plaintiff requests this Court grant Plaintiff primary physical custody subject to structured partial custody by the Defendant. Respectfully submitted, ROMINGER, BAYLEY & WHARE Date: 511'l/0(. I ( Leslie A. To 0, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court J.D. # 200198 Attorney for Plaintiff Cheyenne L. Stouffer, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. Cheyenne C. Dyarman, Defendant CIVIL ACTION - LAW No. CIVIL IN CUSTODY VERIFICATION I verifY that 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. Cheyenne L. Stouffer, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Cheyenne C. Dyarman, Defendant CIVIL ACTION - LAW No. CIVIL IN CUSTODY CERTIFICATE OF SERVICE I, Leslie A. Tomeo, Esquire, attorney for Plaintiff do hereby certify that I this day mailed a copy of the within Motion upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Cheyenne C. Dyarman 120 Lebo Road Carlisle, Pa 17013 Date: ~II 11 d" L~~ 155 South Hanover Street Carlisle, P A 17013 (717) 241-6070 Supreme Court LD. # 200198 Attorney for Plaintiff ~ ~ () ,..., N c = ~ = ::::: Q'" If- ", ;% ~:!J ~ XM ....., 6 en 13m '- C)~ '- ~~- - ~ U) :S! ()l ~ ...... t:) -'" .~ - F! c: ~ 0'" ~ ~ -"I v:> 3J 0'- 00<: ~ ~ CHEYENNE L. STOUFFER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. 06-2849 CIVIL ACTION LAW CHEYENNEC.DYARMAN DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, May 26, 2006 , 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, June 29, 2006 , the conciliator, 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 hearing. FOR THE COURT. By: Isl Hubert X Gilrov. Esq. Custody Conciliator F- 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 cOUl1, 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 HA VE 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 ~ ~~-# ~~4; ~.ac5' - ~ ;!2 ~ ~~ '}(/- O[:f" ~Jp ~ ~4.~ 'W.QE'~ ..,. \/ii\>,;'':'-: (('\!f' !::Jd . .; f' .n"...... ~,.., \ ;/ -,~)i "tz \i.J!" I\.L ~~ /.<, ~', -,: -';: :," 8 ilun 1"\ ...t.' V 68 :2 Hd 08 AVW 900Z AWIOi~G:-EOl:id 3Hl :10 3JI~jO-Q31lj ,.. ... ) JUl 0 6 2006(.1" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CHEYENNE L. STOUFFER, Plaintiff v CIVIL ACTION - LAW CHEYENNE C. DYARMAN, Defendant NO. 06-2849 IN CUSTODY COURT ORDER AND NOW, this 7'h day of ~, 2006, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. The mother, Cheyenne L. Stouffer, shall enjoy legal and physical custody of Landon M. Stouffer, born August 28,2005. 2. The father, Cheyenne C. Dyarman shall enjoy periods of temporary physical custody of the minor child as follows: a. Father shall enjoy supervised visitation initially pursuant to a schedule arranged by the father. The father shall initiate and pay for a supervised visitation arrangement and shall notify the mother with respect to what type of schedule he is able to arrange. It is anticipated that the initial visitation shall be a few hours at a time. Mother shall cooperate with regard to insuring that the minor child is in attendance at the supervised visitation sessions. b. It is anticipated that once father completes his periods of supervised visitation and things are going well that his time with the minor child shall be expanded to unsupervised and, ultimately, overnight visitation. ..- --- .. c. The parties shall meet again with the Custody Conciliator on September 8, 2006 at 9:30 a.m. cc: Leslie A. Tomeo, Esquire Cheyenne C. Dyarman BY THE COURT, JUdg~ ~ ~~ ~ ~ ?ID-O(, ~ 1\ :';1. 1 !'~ 0 I I ,l,L' .. 1 i I Y