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HomeMy WebLinkAbout06-3268 DAWN M. SHUGHART, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 06- 3.2.(., 'I CIVIL TERM WILLIAM F. SHUGHART, Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff and Mother is Dawn M. Shughart, residing at 1519 Embassy Drive, Harrisburg, Dauphin County, Pennsylvania. 2. The defendant and Father is William F. Shughart, residing at 2156 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff seeks increased partial custody of the following children: Name Madelyn L. Shughart Mackenzie R. Shughart Morgan E. Shughart Present Residence 2156 Walnut Bottom Road " Age 10 6 3 " The children were not born out of wedlock. The children are presently in the primary custody of father. During the past five years, the children have resided with the following persons and at the following addresses: Person Father Both Parents Both Parents Address As above 14 Farm Lane, Carlisle 605 Roxbury Road, Newville Dates July 2005 - present Dec 2004-July 2005 1998 - Dec 2004 Mother and Father are divorced and neither remarried. 4. The plaintiff currently resides with her paramour, Gary Hoover. 5. The defendant currently resides with the children. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children 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 children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because they will benefit from more time with their mother. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. Wherefore, plaintiff requests the court grant increased periods of partial custody of the children. I verify that to the best of my knowledge and belief, the statements in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS ~4904 relating to unswom falsification to authorities. ~~ &--- Dawn M. Shughart ~R~ ~~ ~ U\........... OQ ........ C> ~ ~ (") c r--' c-.:> ~:"" cr c"~ c;::: ~.: \ c:P ~ .-:\ ~-o p1f: ---(';t!l _ ~_Jj '-... -' ('-;~(:) ,-S:i~ '(5\'-1;1. -^-~ d.~>' 3: -:.:: -' <..~? c1'1 c:P DA WN M. SHUGHART PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 06-3268 CIVIL ACTION LAW WILLIAM F. SHUGHART DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, June 13,2006 , 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, July 20,2006 , the conciliator, at 8:30 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: /s/ Hubert X Gilroy, 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 infonnation 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. 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 170 I 3 Telephone (717) 249-3166 ~ ~# "": ~~ ?C1N? . ~ 11 ~ ~Jt, ?t?-I1/-? ~ r.~ ~~ -P'? "Jt?1JI.'l A.U-l:i" " "-~':"'. !/iJ\'lJ ('"7." III ',~il I' .. '\. ,. .. ,.," v V ~'.~.. tll inr ciii17 ,I, < tlVU.J DAWN M. SHUGHART, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 06- 3268 CIVIL TERM WILLIAM F. SHUGHART, Defendant : IN CUSTODY PETITION TO WITHDRAW CUSTODY COMPLAINT AND NOW, comes the plaintiff, by and through her counsel, Lindsay D. Baird, Esquire, and avers the following: 1. The plaintiff filed an original custody complaint in error on June 8, 2006. 2. There is already a custody action open at docket number 05-3016. WHEREFORE, Plaintiff, Dawn M. Shughart, respectfully requests that this Honorable Court allow her to withdraw her custody complaint which was filed in error. \. . I verify that to the best of my knowledge and belief, the statements in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS ~4904 relating to unsworn falsification to authorities. l_._' . .. . DAWN M. SHUGHART, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA s v. : No. 06- 3268 CIVIL TERM JUl1920/ WILLIAM F. SHUGHART, Defendant : IN CUSTODY ORDER OF COURT "' AND NOW, this lD day of July, 2006, it is hereby ordered and decreed that the custody complaint filed to the above docket number is dismissed. By the Court, J. Cc: Lindsay D. Baird, Esquire Galen Waltz, Esquire ~ ~ 1.~-~{.. Q.-. . , /'.1 ,,-, II I,ll., 0(,: o:~