Loading...
HomeMy WebLinkAbout06-5120 Suzanne Souders Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. No. Civil Action - Law David Souders Defendant IN CUSTODY CUSTODY COMPLAINT 1. Your Petitioner is Suzanne Souders, who resides at 7 Pine Road, Apt. 106, Mt. Holly Springs, Pa. 17065. 2. Defendant is David Souders, who resides at 118 Springfield Road, NeWville, Pa 17241. 3, Plaintiff seeks Primary custody of the following children: Name Shannon Souders Present Residence 7 Pine Road, Apt. 106 Mt. Holly Springs, Pa 17065 118 Springfield Road Newville, Pa 17241 Age 12 years old Kevin Souders 13 years old The child Shannon Souders was not born out of wedlock. The child Kevin Souders was born out of wedlock. 4. The child Shannon Souders is presently in the custody of Suzanne Souders who resides at 7 Pine Road, Mt. Holly Springs, Pa 17065 and child Kevin Souders who is currently residing at 118 Springfield Road, Newville, Pa 17241. During the past five years, the children have resided with the following persons and at the following addresses: List All Persons List All Addresses Suzanne Souders 7 Pine Road Shannon Souders Mt. Holly Springs, Pa 17065 Kevin Souders (until recently) Dates 8/04 to present Suzanne Souders Shannon Souders Kevin Souders 3115 Ritner Highway Newville, Pa 17241 2/01 to 8/04 5. The mother of the children is Suzanne Souders who resides at 7 Pine Road, Mt. Holly Springs, Pa 17065. She is unmarried. The father of the children is David Souders, who resides at 118 Springfield Road, Newville, Pa. 17241. He is married. 6. The relationship of plaintiff to the children is that of Mother. The plaintiff currently resides with the following persons; Name Relationship Shannon Souders Daughter 7. The relationship of defendant to the children is that of Father. The Defendant currently resides with the following persons; Name Relationship Kathy Souders Tyler Sherman Kevin Souders Wife Wife's son Son 8. 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 or any other state. 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. 9. Reasons for granting relief: Plaintiff is best able to provide the care and nurture which the children needs for healthy development and has been the primary caregiver. Court ordered determination of custody is required to avoid continuing conflict between the parties regarding parental responsibility for custody. 10. 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. All other persons, named below, who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim None WHEREFORE, plaintiff requests the court grant primary custody of the children to her, with visitation to the father. Respectfully Submitted, ROMINGER & WHARE Date: /l f./J 10 7 () 0 { 7 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pa 17013 Court Id No. 81924 Attorney for Plaintiff Suzanne Souders Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. No. Civil Action - Law David Souders Defendant IN CUSTODY VERIFICATION Karl E. Rominger, Esquire, states that he is the attorney for, Suzanne Souders, Plaintiff in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. Pa.C.S. ~4904, relating to unsworn falsification to authorities. Date: f)&j 3 ~ )06' t ? Kari E. Rominger, Esquire Attorney for Plaintiff . . Suzanne Souders Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. No. Civil Action - Law David Souders Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Karl E. Rominger, 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: David Souders ] ] 8 Springfield Road Newville, Pa ] 724] Dated: (7VC It; 2t::JoC r ~ Karl E. Rominger, Esquire ]55 South Hanover Street Carlisle, Pa ] 70 13 Court Id NO.8] 924 Attorney for Plaintiff (") ,..., .~ = ~ It> ~ C C.:l 7 cr> f ~:r;, :P' :r!:n .. c.:: ^" "'..;c-,_ en rne ......-j w :x . ~ is ~ 0- l.:.~~ ---'! :> CN ~~-- ~;.-.1 \) ,,'" ..-, -0 ~f) ::.ll: ~.".. (') ~ ~ ~ 'i! csm ~ -I s:- ;e: ~ 0"' ~ ~ -<. Suzanne Souders Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. No. Civil Action. Law David Souders Defendant IN CUSTODY EMERGENCY PETITION FOR SPECIAL RELIEF NOW COMES, Karl E. Rominger, Esquire, for Petitioner, Suzanne Souders, and in support of this Emergency Petition for Special Relief avers as follows: I. Your Petitioner is Suzanne Souders, who resides at 7 Pine Road, Apt. 106, Mt. Holly Springs, Pa. 17065. 2. Respondent is David Souders who resides at 118 Springfield Road, Newville, Pa 17241. 3. Minor child is David Souders, Petitioner, by agreement, allowed Respondent to have the minor child for the summer. 4. Respondent currently has transferred the rnioor child, Kevin Souders school records from his school in Mt. Holly Springs to Newville without consulting the Petitioner. 5. Mother is and has been the primary caregiver. WHEREFORE, Your Petitioner respectfully requests that this Honorable Court, grant a temporary order granting primary physical custody of the children to the mother pending the scheduling of a hearing on the matters alleged herein. Respectfully Submitted, ROMINGER & WHARE Date: ~/..Y II' P l KarlE. Rominger, Esquire 155 South Hanover Street Carlisle, Pa 17013 Court Id No. 81924 Attorney for Plaintiff Suzanne Souders Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. No. Civil Action - Law David Souders Defendant IN CUSTODY VERIFICATION Karl E. Rominger, Esquire, states that he is the attorney for, Suzanne Souders, PllIintiff in this action; that he makes this affidavit as attorney because he has sufficient knowledge or infonnation and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. Pa.C.S. *4904, relating to unsworn falsification to authorities. Date: t /9/o~ ) Kat1'E. Rominger, Esquire Attorney for Plaintiff \ . . Suzanne Souders Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. No. Civil Action - Law David Souders Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Karl E. Rominger, 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: David Souders 118 Springfield Road Newville, Pa 17241 Dated: cJh/11/2 J Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pa 17013 Court Id No. 81924 Attorney for Plaintiff iA. 1-\~ CJ.J \j ~ ~ 1- - ""'1:;\ )....> ~ ....c:: ~ ~ ~ ~; ~~~ v _ J " :: ~:~ <)~ :;;; <5 ---\ (, <i? -;s ~~. s:- .:< ::2 cD SUZANNE SOUDERS PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA V. 06-5120 CIVIL ACTION LAW DAVID SOUDERS DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, September 06, 2~~__, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at___._4th Floor, ~_~_mb~rland Coul!!L~.ourthouse, CaE~!~__ on Thurs~ay, October 12~1!l.06 ____.__ at 8:3~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 penn anent 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 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 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 . trI ~-~ ->r~ ~ lJvcb _ :-;Jr ~ ~ rn;:'u, 10-L'6 .;r?~r:7 fr' ~ ~ i/,k; p?J dJOL b c,~; \ \ ~, :'\ f(!,'?J ' ..----------------- SUZANNE SOUDERS, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5120 CIVIL DAVID SOUDERS, Defendant IN CUSTODY ORDER OF COURT AND NOW, this 11th day of September, 2006, upon consideration of the Emergency Petition for Special Relief filed by the Plaintiff, the Petition is DENIED. The matter will be resolved at the custody conciliation previously scheduled with Attorney Gilroy on October 12, 2006 at 8:30 a.m. By the Court, ,~~ J. M. L. Ebert, Jr., /arl E. Rominger, Esquire Attorney for Plaintiff Aavid Souders, Defendant bas ~ :v ,\0 ex' o g ,,", .., .:,' t, -(., SUZANNE SOUDERS, Plaintiff 5 Z 9 2UUyI IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v NO. 2006-5120 CIVIL ACTION - LAW DAVID SOUDERS, Defendant IN CUSTODY COURT ORDER AND NOW, this h"~ day of January, 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Suzanne Souders, and the Father, David Souders, shall enjoy shared legal custody of Shannon F. Souders, born July 27, 1994, and Kevin G. Souders, born June 18, 1993. 2. The Mother shall enjoy primary physical of Shannon, and the Father shall enjoy primary physical custody of Kevin. 3. On alternating weekends and pursuant to a schedule that both children are together on the weekends, the parties shall alternate custody of the children from Friday at 4:30 p.m. until Sunday at 7:00 p.m. On the weekends Father will have custody of Shannon, Father shall handle transportation for exchange of custody. On the weekends Mother has custody of Kevin, Mother shall handle transportation for exchange of custody. 4. During the summer months, the parties shall set up a schedule so that each parent has four (4) consecutive weeks with both children. The parties shall work out that schedule by April of each year. 5. The holiday schedule shall be handled as follows: A. On Christmas Eve, the minor children shall be with the Father, and on Christmas Day the children shall be with the Mother. B. Father shall have custody on New Year's Eve and New Year's Day. C. For the Thanksgiving holiday, Mother shall have custody from 9:00 a.m. until 3:00 p.m., and Father shall have custody from 3:00 p.m. until 9:00 p.m. D. The parties may modify this schedule as they agree. Absent an agreement, the schedule set forth above shall control. In the event either party desires to modify this schedule and can't reach an agreement with the other parent, that party may petition the Court to have the case again scheduled with the Custody Conciliator for a conference. BY THE COURT, ,,,~ Judge