HomeMy WebLinkAbout06-5005
SONDRA L. HERSIlEY,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY PENNSYLANIA
v.
TROY M. SHATZER,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
COMPLAINT FOR CUSTODY
I. The plaintiff is Sondra Hershey, residing at 16 Mountain View Terrace, Newville,
Cwnberland County, Pennsylvania 17241.
.-
2. The defendant is Troy M. Shatzer, residing at Federal Corrections Institute McKean, P.O.
Box 8000, Bradford, Pennsylvania 16701.
3. Plaintiff seeks custody of the following children:
Name
Kacey Shatzer
Present Residence
16 Mountain View Terrace
Newville, P A
DOB
8/9/98
Age
7 years
Matthew Shatzer
16 Mountain View Terrace
Newville, P A
WI 0/2001
4 years
The children were born out of wedlock
The children are presently in the custody of Sondra Hershey who resides at 16 Mountain
View Terrace, Newville, Cwnberland County, Pennsylvania.
.-
During the past five years, the children have resided with the following persons and at the
following addresses:
List All Persons
Sondra Hershey
List All Addresses
16 Mountain View Terrace
Newville, P A
Dates
7/6/06-present
Gladys Hershey
503 Meadow Drive
Shippensburg, P A
Birth-7/6/06
The mother of the children is Sondra Hershey, currently residing at 16 Mountain View
Terrace, Newville Pennsylvania
She is not married.
The father of the children is Troy Shatzer, currently residing at FCI McKean, P.O.B.
8000, Bradford, Pennsylvania.
He is not married.
4. The relationship of plaintiff to the children is that of mother.
The plaintiff currently resides with the following persons.
Name
Dale Morton
Relationship
Roommate
5. The relationship of defendant to the children is that of father.
The'defendant currently resides with the following persons.
Name
Troy Shatzer
Relationship
Prison
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 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 child and 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
request because:
Plaintiff has undertaken and performed the primary parental responsibilities for the
children.
Plaintiff is best able to provide the care and nurture which the children need for healthy
development.
8. Each parent whose parental rights to the child have not been tenninated and the person
who has physical custody of the child have been named below, who are known to have or
claim aright to custody or visitation of the child will be given notice of the pendency of
this action and the right to intervene:
Name
N/A
Address
Basis of Claim
WHEREFO~ Plaintiff requests this Court gnmt Plaintiff primary physical custody in
the Plaintiff with agreed upon visitation in Defendant. .
Respectfully submitted,
ROMINGER & WHARE
Date: i?-~ f -() (,
1f/1--J ~t- A
Michael J. Whare(, Esquire
155 South Hanover Street
Carlisle, P A 17013
(717) 241-6070
Supreme Court ID # 89028
Attorney for Plaintiff
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. Cons. Stat. g 4904 relating to
unswom falsification to authorities.
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SONDRA L. HERSHEY
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
v.
06-5005
CIVIL ACTION LAW
TROY M. SHATZER
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW.
Wednesday, September 06,2006
, upon consideration of the attached Complaint,
it is hereby directed that paliies and their respective counsel appear before Hubert X. Gilroy, Esq.
. the conciliator,
at_____.._4th Eloo~!~~_'!lberland <;:~!!..'!!)' Courthous<<:L.<=~El!.s_~ on __!.~_l!!:_~_~ay, October _!~~}006 at .!!l..:~_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 pennanent 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 Gilrov, Esq.
Custody Conciliator
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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 cOllli, 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 OFF]CE 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
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NOY to 2006 ~
SONDRA L. HERSHEY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
vs.
: NO. 06-5005
CIVIL ACTION - LAW
TROY M. SHATZER,
Defendant
IN CUSTODY
ORDER
)1
AND NOW, this _Ill day of November, 2006, the Conciliator appearing for a
custody conciliation conference scheduled on November 16,2006 and the parties not being
in attendance except for Attorney Leslie Tomeo on behalf of the Plaintiff, the Conciliator
relinquishes jurisdiction.
Hubert X ilroy, Esquire
Custod)) onciliator
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