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Home My WebLink About06-3792GERLINDA SHOFF : IN THE COURT OF COMMON PLEAS OF PLAINTIFF, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION CIVIL TERM (94. 3 9 92 Cud -T-e. - JOYCE MILLER, DEFENDANT. : IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, Gerlinda Shoff, by and through her attorneys, IRWIN & McKNIGHT, and files the following Complaint for Custody: 1. The Plaintiff, Gerlinda Shoff, is an adult individual residing 243 Redwood Lane, Carlisle, Pennsylvania. 2. The Defendant, Joyce Miller, is an adult individual currently residing at 159 Big Spring Terrace, Newville, Pennsylvania. 3. Plaintiff seeks custody of the following child: Madisen Shoff; born August 2, 1999 and currently residing at 243 Redwood Lane, Carlisle, Pennsylvania 4. The child was born in wedlock. 5. The child currently resides with the Plaintiff. 6. The natural mother and father of the child are both deceased. 7. The natural mother died prior to 2002. 8. The natural father died on April 2, 2006. 9. The relationship of the Plaintiff to the child is that of stepmother. 2 10. The relationship of the Defendant is that of maternal grandmother. 11. The child has resided with the following persons at the following addresses: A. Robbie and Gerlinda Shoff, 243 Redwood Lane, Carlisle, Pennsylvania, from January 16, 2002 until April 2, 2006. B. Gerlinda Shoff, 243 Redwood Lane, Carlisle, Pennsylvania, from April 2, 2006 until the present. 12. Since 2002, Plaintiff has lived continuously with the child and has acted as mother to the child. 13. The child regards Plaintiff as a parent and has continuously referred to her as mother since 2002. 14. Plaintiff has standing to pursue custody based on her in loco parentis status. 15. A custody action between Joyce Miller and Robbie Shoff, was filed August 4, 2005, civil term 05-3990. 16. Based on a stipulated agreement, an order was issued, September 22, 2005, granting shared legal custody with both parties and granting primary physical custody to father, Robbie Shoff. A copy of said order and agreement is attached hereto as Exhibit "A". 17. On June 16, 2006, Defendant filed a Petition for Civil Contempt and Motion to Modify Partial Custody Order. A custody conciliation has been scheduled by Order of Court for July 20, 2006 with conciliator, Jacqueline M. Verney, Esq. A copy of said order is attached as Exhibit "B". The Plaintiff seeks consolidation of the conciliation conference in this action with the conference already scheduled for July 20, 2006. 18. Plaintiff desires sole legal and primary physical custody of the minor child, Madisen Shoff, with periods of supervised visitation for the Defendant. 19. The best interests and permanent welfare of the minor child requires that the Court grant the Plaintiff's request as set forth above. WHEREFORE, Gerlinda Shoff, respectfully requests that she be awarded primary physical custody and legal custody of the minor child, Madisen Shoff, as provided herein, with periods of supervised visitation for the Defendant as provided herein. Respectfully submitted, IRWIN & McKNIGHT By: 44M?' MMajiliml; A. cKnight, Esquire Attorney for Plaintiff 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Date: July 3, 2006 Supreme Court I. D. No. 93010 4 CERTIFICATE OF SERVICE I, the undersigned hereby certify that on this 3ril day of July, 2006, a copy of the Complaint for Custody was served by first-class, postage prepaid United States mail in Carlisle, Pennsylvania upon the following: Kara W. Haggerty, Esquire ABOM & KUTULAKIS, LLP 36 South Hanover Street Carlisle, PA 17013 IRWIN & McKNIGHT Mattl w c {night, Esquire Supreme ourt I.D. No: 93010 60 West Pomfret Street Carlisle, PA 17013 (717) 249-2353 Attorney for the Plaintiff, Gerlinda Shoff VERIFICATION The foregoing document is based upon information which has been gathered by our counsel and ourselves in the preparation of this action. We have read the statements made in this document and they are true and correct to the best of our knowledge, information and belief. We understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unworn falsification to authorities. g2z?&a I 9f1f GERLINDA SHO +F Date: T4 ? - Oo EXHIBIT "A" IRECEIVED SEP 22 M JOYCE MILLER IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. 05-3990 ROBBIE SHOFF : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW this Z Z*'Iday of _014.4+ 12005, the attached Custody Stipulation is hereby made an Order of Court. BY THE COURT, J. =bution: W. Haggerty, Esquire .Wlbie Shoff 143 Redwood Lane Carlisle, PA 17013 J op''?' oq?? S I : 111.11 CZ 83S SOOZ 1 N1G'?YC46 3M JOYCE MILLER : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PA V. : NO. 05-3990 ROBBIE SHOFF CIVIL ACTION - LAW Defendant IN CUSTODY CURDY SMULATION AND NOW, comes Joyce Miller, (hereinafter "maternal grandmother"), by and through her attorney, Kara W. Haggerty of Abom & Kutulakis, L.L.P., and Robbie Shoff (hereinafter "father"), who hereby agree as follows: WHEREAS, the parties are the father and grandmother of one minor child: Madisen Shoff, DOB: 08102199; WHEREAS, the parties desire to enter into an agreement as to the custody of the above said child and to the visitation rights of both parties; NOW, THEREFORE, intending to be legally bound hereby, the parties agree as follows: 1. The father and maternal grandmother shall have shared legal custody of the subject minor child. 2. The father shall have primary physical custody of the subject minor child. 3. The maternal grandmother shall have partial physical custody of the subject minor child as follows: Zw?e ?P vw?a5 5 K??? a. Every weekend from Friday through Sunday; b. Custodial time on Christmas Day in the evening; c. Alternating weeks during the summer holiday; and d. OdW times as the parties a Fo s (? v P ? `? C4+ad ,Q1 wto ?.t C C>;5 U(? ?tovK W l L` ? c ® Father shall transport the child to and from maternal grandmother's residence. 5. The parties agree that this Agreement shall be entered as an Order of Court. IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms hereof, set forth their hands and seals the day and year hereinafter mentioned. WITNESSETH: er, Plaintiff Robbie Shoff, Defendant ... ?? ? ? ?? ;_> ?. Q ?-' ?- os- ? "' a.. _i„? ?, ' ?1 ?1, 0 ? °? EXHIBIT "B" JOYCE MILLER IN THE COURT OF COMMON PLEAS OF PLAINTIFF . CUMBERLAND COUNTY, PENNSYLVANIA V. 05-3990 CIVIL ACTION LAW ROBBIE SHOFF IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, June 20, 2006 , 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 Thursday, July 20, 2006 at 9:30 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 ante 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/ Iacauchrze M. Verney, Es r 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 flans 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 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 OF THE ''riAHY 2L°6 JUA 22 P!i 12: 09 L G '? l "? ::j} r" ?. .? ? 1 f G? ...y y., . . sr =% GERLINDA SHOFF IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 06-3792 CIVIL ACTION LAW JOYCE MILLER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, July 07, 2006 , 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 Tuesday, August 08, 2006 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 Custodv orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ jacgueline M. Verney, Esq.,kT 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. 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 ??sS?,,? r???, %O-? .C ?,y L ?, ,_ ... ;?? _ ?„ ? _ . GERLINDA SHOFF, Plaintiff V. JOYCE MILLER, Defendant : IN THE COURT OF : CUMBERLAND CO NO. 2006-3792 ?C : IN CUSTODY JOYCE MILLER, Plaintiff V. ROBBIE SHOFF, Defendant : IN THE COURT OF : CUMBERLAND CO NO. 05-3990 IN CUSTODY ORDER OF COURT AND NOW, this /o ' day of Iqu consideration of the attached Custody Conciliation port, it is follows: 1. The actions at Docket No. 06-3792 and 05-3990 2. The prior Order of Court at Docket No. 05-3990 2005 is hereby vacated. 3. The Stepmother, Gerlinda Shoff shall have sole Shoff, born August 2, 1999. child. 4. Stepmother, Gerlinda Shoff shall have primary RECEIVE AUG 0 9 2006 Y:_ My WON PLEAS OF ,PENNSYLVANIA ACTION - LAW MON PLEAS OF ,PENNSYLVANIA 2006, upon d and directed as hereby consolidated. September 22, custody of Madisen custody of the 5. Grandmother, Joyce Miller, shall have periods of artial physical custody on alternating weekends beginning Friday, August 11, 2006 fro Friday at 5:00 p.m. to Sunday at 5:00 p.m. 6. Stepmother shall be responsible for obtaining 7. Grandmother shall be responsible for obtaining child, stepmother and grandmother. for the child. counseling for the FILED-CFFICE OF TWEE PROT HONOTARY 2006 AUG i i AM 9= 58 CUtv1E3»;+-k,,L; GOUNTY PENNSYLVANIA i s 8. Transportation shall be shared such that the 9. This Order is entered pursuant to an agreement o Conciliation Conference. The parties may modify the provisior consent. In the absence of mutual consent, the terms of this Orc Custody Conciliation Conference is scheduled for November 7, BY THE COURT, Kevin cc: Matthew A. McKnight, Esquire, Counl for Stepmother Kara W. Haggerty, Esquire, Counsel for Grandmother party shall transport. the parties at a Custody of this Order by mutual r shall control. Another 006 at 8:30 a.m. J. GERLINDA SHOFF, Plaintiff V. JOYCE MILLER, Defendant JOYCE MILLER, Plaintiff V. ROBBIE SHOFF, Defendant : IN THE COURT OF : CUMBERLAND CO NO. 2006-3792 C IN CUSTODY : IN THE COURT OF : CUMBERLAND CO NO. 05-3990 IN CUSTODY PRIOR JUDGE: Kevin A. Hess, J. IN ACCORDANCE WITH CUMBERLAND PROCEDURE 1915.3-8, the undersigned Custody Coi report: 1. The pertinent information concerning the Child litigation is as follows: NAME Madisen Shoff DATE OF BIRTH August 2, 1999 MON PLEAS OF ,PENNSYLVANIA ACTION - LAW WON PLEAS OF ,PENNSYLVANIA rY RULE OF CIVIL submits the following is the subject of this Y IN CUSTODY OF Shoff, stepmother 2. A Conciliation Conference was held in this ma er on August 8, with the following in attendance: The Stepmother, Gerlinda Shoff, wi her counsel, Matthew A. McKnight, Esquire, and the maternal Grandmother, Joyce Mil er, with her counsel, Kara W. Haggerty, Esquire. 3. Natural Mother died in 2002. Natural Father died in 2005. 4. A prior Order of Court was entered by the Honc stipulation of the parties at Docket Number 05-3990 dated Sep for shared legal custody between natural Father and maternal g having primary physical custody and Grandmother having two 5. The parties agreed to an Order in the form as 8-g-()? Date Kevin A. Hess upon r 22, 2005 providing iother, with Father ends per month. M. Ver(ley, Esquire Custody NOV 0 7 2006 GERLINDA SHOFF, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-3792 CIVIL ACTION - LAW JOYCE MILLER, Defendant : IN CUSTODY JOYCE MILLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 05-3990 ROBBIE SHOFF, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 7`n day of November, 2006, having been advised that the parties are satisfied with the current Order of Court and no addition conciliation conference is necessary, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, (Lzx?,? A, L/t=:, cqu ne M. Verney, Esquire Custody Conciliator TRUE COPY FROM RECORD to T whereof, I ?.nre unto set my hand W the seed of said (Aw at Carina, PL of uovember ,ADN,. e? A?pb? Oil ? d9 d? C? GERLINDA SHOFF, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 06-3792 CIVIL ACTION - LAW JOYCE MILLER, IN CUSTODY Defendant JOYCE MILLER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 05-3990 CIVIL ACTION -- LAW GERLINDA SHOFF, Defendant IN CUSTODY PETITION TO MODIFY CUSTODY 1. Petitioner is Joyce Miller, an adult individual residing at 159 Big Spring Terrace, Newville, PA 17241. 2. Respondent is Gerlinda Shoff, an adult individual residing at 243 Redwood Lane, Carlisle, PA 17013. 3. Petitioner is seeking modification of the Custody Order entered into by this Court on August 10, 2006, regarding Madisen L. Shoff, born August 2, 1999, currently residing at 1873 Walnut Bottom Road, Newville, PA 17241. 4. Petitioner seeks primary physical custody of the child for reasons set forth below. 5. The child is presently in the custody of paternal grandparents, who have no current right to legal or physical custody of the child. 6. The child has lived with the following parties and at the following addresses: John W. & Barbara A. Shoff 1873 Walnut Bottom Rd., Newville, Pa. November 16, 2006 to Present 12. A Custody Order was issued by the Court on September 22, 2005, awarding Petitioner shared legal custody and partial physical custody of the child. 13. Robbie S. Shoff died on April 2, 2006. 14. Petitioner filed with the Court a Petition for Civil Contempt against Gerlinda Shoff, widow of Robbie S. Shoff and step-mother of the child, and a Motion to Modify Partial Custody Order on June 16, 2006. 15. Gerlinda Shoff, residing at 243 Redwood Lane, Carlisle, PA 17013, filed a Complaint for Custody with the Court on July 3, 2006. 16. A Custody Order was issued by the Court on August 10, 2006, wherein: the matters of Shoff v. Miller (06-3792) and Miller v. Shoff (05-3990) were consolidated into one, Gerlinda Shoff was awarded legal custody and primary physical custody of the child, Petitioner was awarded partial physical custody, and a conciliation conference was scheduled for November 7, 2006. (Exhibit 1, Custody Order, is attached and incorporated herein as if fully set forth.) 17. Stanley E. Richwine, natural maternal grandfather of the child residing at 1004 North West Street, Apt. 1, Carlisle, PA 17013, filed a Petition for Appointment of Temporary Guardian on August 16, 2006. 18. Gerlinda Shoff subsequently filed a Petition for Appointment of Temporary Guardian. 19. On October 13, 2006, the Honorable Judge J. Wesley Oler, Jr., issued an Order consolidating the petitions of Stanley E. Richwine and Gerlinda Shoff. 20. On November 7, 2006, following cancellation of the scheduled conciliation conference, Jacqueline M. Verney, Esquire relinquished jurisdiction as conciliator in the consolidated matter of Shoff v. Miller (06-3792) and Miller v. Shoff (05-3990). 21. John W. and Barbara A. Shoff, natural paternal grandparents of the child residing at 1873 Walnut Bottom Road, Newville, PA 17241, filed a Petition for Appointment of Temporary Guardians on February 12, 2007. 22. Kara W. Haggerty, Esquire, withdrew as counsel for Petitioner on March 1, 2007. 23. Galen R. Waltz, Esquire, the undersigned counsel, entered appearance as counsel for Petitioner on March 2, 2007. 24. On March 2, 2007, Jane Alexander, Esquire, counsel for John W. and Barbara A. Shoff, granted to Petitioner an extension to answer the Shoffs' petition until March 9, 2007. 25. Petitioner filed an Answer to the Shoffs' Petition for Appointment of Temporary Guardians and her own Petition for Appointment of Temporary Guardian on March 9, 2007. 26. Respondent has relinquished actual physical custody of the child since November 16, 2006 to the paternal grandparents, who have no current right to physical or legal custody of the child. 27. Respondent's surrender of custody to another party, after the Court awarded Respondent custody, is not the stable life the child needs and deserves. 28. Respondent is in a state of declining health to such a degree that she is unable to have the charge of a minor child. 29. It is believed, therefore it is averred, that Respondent was and is incapable of looking after the child and cannot manage her energetic nature. Petitioner, however, has been and continues to be competent to watch over and manage the vivacity of the child. 30. Petitioner is the only party other than Respondent (who has now relinquished custody) with any right to physical custody of the child. 31. Relocation of the child to Petitioner's home will allow the child to continue in the same school which she already attends. 32. Petitioner continues to see and take care of the child every other weekend, pursuant to the August 10,2006 Custody Order. 33. Petitioner will provide a perpetually stable and safe home environment for the child. 34. The child has often voluntarily indicated her desire to live with Petitioner. 35. Petitioner will foster the child's ongoing relationship with all of her next-of-kin. 36. Petitioner has initiated acquisition of counseling in accordance with paragraph 7 of the August 10, 2006 Custody Order. 37. The best interest and permanent welfare of the child will be best served by granting the relief requested for the reasons stated above. WHEREFORE, Plaintiff requests your Honorable Court schedule a conciliation conference and subsequently grant the Plaintiff's requests for modification of the August 10, 2006 Custody Order and grant Plaintiff primary physical custody. Respectfully Submitted Date TURO OFFICE len R. Waltz, Es 28 South Pitt Stre Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff AUG 0 9 2006 GERLINDA SHOFF, Plaintiff V. JOYCE MILLER, Defendant JOYCE MILLER, Plaintiff V. ROBBIE SHOFF, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV NO. 2006-3792 , CIVIL ACTION - Lam' ^ IN CUSTODY &`'S f w : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3990 IN CUSTODY ORDER OF COURT AND NOW, this ly ? day of , 2006, upon consideration of the attached Custody Concilia on Report, it is ordered and directed as follows: 1. The actions at Docket No. 06-3792 and 05-3990 are hereby consolidated. 2. The prior Order of Court at Docket No. 05-3990 dated September 22, 2005 is hereby vacated. 3. The Stepmother, Gerlinda Shoff shall have sole legal custody of Madisen Shoff, born August 2, 1999. child. 4. Stepmother, Gerlinda Shoff shall have primary physical custody of the 5. Grandmother, Joyce Miller, shall have periods of partial physical custody on alternating weekends beginning Friday, August 11, 2006 from Friday at 5:00 p.m. to Sunday at 5:00 p.m. 6. Stepmother shall be responsible for obtaining counseling for the child. 7. Grandmother shall be responsible for obtaining family counseling for the child, stepmother and grandmother. 8. Transportation shall be shared such that the receiving party shall transport. 9. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terns of this Order shall control. Another Custody Conciliation Conference is scheduled for November 7, 2006 at 8:30 a.m. BY THE COURT, 1,51 Kevin A. Hess, J. cc: Matthew A. McKnight, Esquire, Counsel for Stepmother Kara W. Haggerty, Esquire, Counsel for Grandmother rRUE COPY FROM RECORD Testimony whereof, I here unto set my hand -4 the seal of said Court at Carlisle, ft cos day o? ProthonoW# GERLINDA SHOFF, Plaintiff V. JOYCE MILLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 06-3792 CIVIL ACTION - LAW IN CUSTODY JOYCE MILLER, Plaintiff V. GERLINDA SHOFF, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 05-3990 CIVIL ACTION - LAW IN CUSTODY VERIFICATION I, Joyce A. Miller, Petitioner in this matter, do hereby depose and state that the statements contained in the foregoing petition are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date 0 Miller CERTIFICATE OF SERVICE I, Galen R. Waltz, Esquire hereby certify that I served a true and correct copy of the Petition to Modify Custody, by depositing same in the United States Mail, first class, postage pre-paid on the q?A day of March 2007, from Carlisle, Pennsylvania, addressed as follows: Gerlinda Shoff 243 Redwood Lane Carlisle, PA 17013 TURO LAW OFFICES Galen R. Waltz,'Es e 28 South Pitt Stre Carlisle, PA 17013 (717) 245-9688; FAX 717.245.2165 ?" ? L ?3 C , 7' '"?..? f ?.y..1 ?-^? ? ? .. ? .. '.'t . ` t '? ? ? t l ,. ?r+.? i t • ?'}? {; GERLINDA SHOFF IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. JOYCE MILLER DEFENDANT 06-3792 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Monday, March 12, 2007 , 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 Tuesday, April 10, 2007 at 9:30 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/ Jacqueline M. Verne , Esq. /yl 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. 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 60-hl 2 11 L 0 a Z c : - ti J 0 a GERLINDA SHOFF, Plaintiff V. JOYCE MILLER, Defendant V. JOHN SHOFF & BARBARA SHOFF, Interveners IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. STANLEY RICHWINE, Intervener NO. 06-3792 CIVIL TERM I/ JOYCE MILLER, Plaintiff V. ROBBIE SHOFF, Defendant V. JOHN SHOFF and BARBARA SHOFF, Interveners IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. STANLEY RICHWINE, Intervener NO. 05-3990 CIVIL TERM ?; t? ?, h? ? ?? :;i 31 :.??% i-,-?+_? 10 i ORDER OF COURT AND NOW, this 19th day of July, 2007, upon consideration of custody stipulation filed in the above matters, the stipulation is approved and the terms of the stipulation are hereby made an order of court. The above custody cases are hereby consolidated to No. 06-3792, to the extent not previously consolidated. ,Galen R. Waltz, Esq. 28 South Pitt Street Carlisle, PA 17013 Attorney for Joyce A. Miller ?iVlatthew A. McKnight, Esq. Marcus A. McKnight, III, Esq. 60 West Pomfret Street Carlisle, PA 17013 Attorneys for Gerlinda Shoff Xarold S. Irwin, II 64 South Pitt Street Carlisle, PA 17013 Attorney for Stanley E. Richwine Kane M. Alexander 148 South Baltimore Street P.O. Box 421 Dillsburg, PA 17019-0421 Attorney for John W. and Barbara A. Shoff rc BY THE COURT, NOV 0 b 1DOi GERLINDA SHOFF, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-3792 CIVIL ACTION - LAW JOYCE MILLER, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 2°d day of November, 2007, the parties having reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, cq line M. Verney, Esquire, Cus dy Conciliator rt `I Ir' Ablv