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Home My WebLink About06-6298 STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF SHARON L. GIBSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. HARRY L. GIBSON, SR., Defendant : CIVIL ACTION -LAW : NO. 2006- C;71I'CML TERM : CUSTODY COMPLAINT FOR CUSTODY NOW comes the plaintiff, Sharon 1. Gibson, by her attorney, Stacy B. Wolf, Esquire, and presents the following complaint for custody, representing as follows: 1. The plaintiff is Sharon 1. Gibson, an adult individual residing at 23 Betty Nelson Court, Carlisle, Cumberland County, Pennsylvania 17015. 2. The defendant is Harry 1. Gibson, Sr., an adult individual residing at 75 Bonnybrook Road, Lot 33, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks custody of the following child: Name Present Residence Age Brandee 1. Gibson 23 Betty Nelson Court Carlisle, PA 17015 10 years D.G.B.7/28/1996 4. Plaintiff and defendant are the natural parents of the child. 5. The child was born during the marriage of the parties. 6. The child is presently in the custody of plaintiff but resided with both parents from the .. time of birth until Januaty, 2006 when the parties separated. Since that time, the child has been in the custody of Mother. 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. 8. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 9. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 10. Mother has been the primary caregiver of the child since the child's birth. 11. Father has threatened to harm himself several times, including in the presence of the child. Such statements and behavior present a detriment to the child's physical and emotional well-being. 12. The best interests and permanent welfare of the child will be served by granting the relief requested herein. 13. Plaintiff acknowledges the need for the child to have a relationship with defendant and will, if given the opportunity, work to reinforce that relationship provided protection is in place for the welfare of the child in the form of supervised visitation and! or an agreement by Father to attend counseling. WHEREFORE, for the reasons set forth herein, Plaintiff, Sharon L. Gibson, respectfully requests that the Court enter an order granting primary physical custody of the child to the plaintiff. Respectfully submitted, Dated: October d;], 2006 ---J!Ja 1B .1JJjJ~ Stacy B. ~squire ~ r 10 West High Street Carlisle, PA 17013 Supreme Court LD. No. 88732 (717) 241-4436 Attorney for Plaintiff VERIFICATION I do hereby verify that the facts set forth in this complaint are true and correct to the best of my infonnation 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. October d 7 , 2006 ~;/~ - Sharon L. Gibson , . STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF SHARON L. GIBSON, Plaintiff v. HARRY L. GIBSON, SR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2006- CIVIL TERM : CUSTODY CERTIFICATE OF SERVICE I, Stacy B. Wolf, Esquire, have served a true and correct copy of Complaint for GJstody upon the following person and in the matter indicated: SERVICE BY U.S. MAIL: Harry 1. Gibson, Sr. 75 Bonnybrook Road, Lot 33 Carlisle, P A 17013 October ().1, 2006 By: WOLF & WOLF dt:~?3:~~1I: Attorney for Plaintiff 10 West High Street Carlisle, Pennsylvania 17013 (717) 241-4436 Supreme Court LD. No. 88732 ~ ~ Y\ ~ C) f'-." ~ ~ c = 0 ~ '-= <"""'"' 0" 11 . ~ ~ f - <::) '\ ~ <..-) --, '\ ~~ ;'V ~ -.J "- '\ , \.. ~ "- . ""T) I -"Y"- ~ 0J ~ --"'.. . (.) ~ ~ r,.J '-0 ~ SHARON L. GIBSON PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. 06-6298 CIVIL ACTION LAW HARRY L. GIBSON, SR. DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, November 01, 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, November 30,2006 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: Isl Jacqueline M. Verney, Esq. .)VrJ Custody Conciliator -:P--- 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 .~ ~ ~ ~ ~-:p rvt' ~ .~. ~t< *7~~~ ~ -f/P j!- ~ ~ --rJ 92 :S Hd Z- I,ml SIJOl 3H.L :10 :nl3;:00311::J "70- e';1 'JCJ- ell 'cl' e'-1/ r . ' -. NOV 30 2006 vi ~ .... SHARON L. GIBSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ~"'(p~'S : NO.--i66~-62'8-CIVIL ACTION - LAW V. HARRY L. GIBSON, SR., Defendant IN CUSTODY ORDER OF COURT AND NOW, this S.Jr. 'r\ day of {) 1:.<" t.'H'. \Hl , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Sharon L. Gibson and the Father, Harry L. Gibson, Sr., shall have shared legal custody of Brandee L. Gibson, born July 28, 1996. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of 23 Pa.C.S. 95309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full alld complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 2. Mother shall have primary physical custody of the child. 3. Beginning December 2,2006, Father shall have periods of supervised visitation on alternating Saturdays for four hours at times agreed by the parties. The supervisor shall be Father's brother, Richard Gibson. 4. Father shall also have four hours of supervised visitation on Christmas Eve at times agreed by the parties ''r/\I\lV/\lASNf~3d A' l",'n"""'" (","'l '-~'^ln'" J.J'~' ;f),}' j',. -!>~.""::~\L vi S S :9 WV 9- J30 900Z AtIVIONUH"U}3d 3Hl :10 3:JL:HC---a311:l .. ~r ^. ...... 5. Transportation shall be shared such that the parties will exchange custody at the Sheetz gas station on Route 11 in Carlisle. 6. 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 terms of this Order shall control. Another Custody Conciliation Conference is scheduled for February 28, 2007 at 8:30 a.m. BY THE COURT, ~~ cc: Stacy B. Wolf, Esquire, Counsel for Mother Harry L. Gibson, Sf., pro se .MdJ-I.i4 ~ / ~ . oC ()" 75 Bonnybrook Road, Lot 33 . . u--- Carlisle, P A 170 13 ~ ',. - J' SHARON L. GIBSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : NO. 2006-6298 CIVIL ACTION - LA" HARRY L. GIBSON, SR., Defendant : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIl. PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTL Y IN CUSTODY OF Brandee L. Gibson July 28, 1996 Mother 2. A Conciliation Conference was held in this matter on November 30, 2006, with the following in attendance: The Mother, Sharon L. Gibson, with her counsel, Stacy B. Wolf, Esquire, and the Father, Harry L. Gibson, Sr., pro se. 3. The parties agreed to an Order in the form as attached. 1/ - 3 D --O(p Date ~~~ 'r~ tfJ.. Y-~/ acq ine M. Verney, Esquire Custody Conciliator V. : IN THE COURT OF COMMON P : CUMBERLAND COUNTY, PENN : U : NO. 20~6298 CIVIL ACTION - L ) .. ~ SHARON L. GIBSON, Plaintiff HARRY L. GIBSON, SR., Defendant IN CUSTODY ORDER OF COURT AND NOW, this 1.1 t~ day of \'\ \.("t;~ ,2007, u consideration of the attached Custody Conciliation Report, it is ordered and di follows: 2. Paragraph 3 shall be deleted in its entirety and replaced with th following: Beginning March 24,2007, Father shall have periods of supervise on alternating Saturdays, from 1 :00 p.m. to 5:00 p.m. The supervisor shall be Mother, Shirley Gibson, or such other person as the parties agree. 1. The prior Order of Court dated December 6, 2006 shall remain force Clud effect with the following modifications and additions: 3. Father shall have liberal telephone contact with the child every ning at 7:30 p.m. except Wednesdays when the child attends a church function. In the e ent that the child is unavailable to speak to Father, Mother shall insure that the child gi Father a return call when she is available. 5. This Order is entered pursuant to an agreement ofthe parties at Conciliation Conference. The parties may modify the provisions of this Order consent. In the absence of mutual consent, the terms of this Order shall control. ustody mutual 4. If a holiday falls on the weekend of Father's visitation, Father's aturday visit shall occur on the holiday instead of Saturday. Father shall have his visita i n period on Father's Day instead of on Saturday of the same weekend. BY THE COURT, \'l J. 60 : 11 I"JV LZ {lVW LODZ AtfvlONUi-UCXid 3Hl ::10 301.::!:io--031l:1 ------- " cc: Stacy B. Wolf, Esquire, Counsel for Mother Harry L. Gibson, Sf., pro se 75 Bonnybrook Road, Lot 33 Carlisle, P A 17013 ~.~~ 3- 7- 6-7 , SHARON L. GIBSON, Plaintiff : IN THE COURT OF COMMON P : CUMBERLAND COUNTY, PENN AS OF LV ANIA V. : NO. 2006-6298 CIVIL ACTIO LAW HARRY L. GIBSON, SR., Defendant : IN CUSTODY PRIOR JUDGE: M.L. Ebert, Jr., J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE 0 PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the fI report: NAME DATE OF BIRTH CURRENTLY IN CUST 1. The pertinent information concerning the Child who is the subj t of this litigation is as follows: Brandee L. Gibson July 28, 1996 Mother 2. A Conciliation Conference was held in this matter on March 13 with the following in attendance: The Mother, Sharon L. Gibson, with her cou B. Wolf, Esquire, and the Father, Harry L. Gibson, Sr., pro se. 007, 1, Stacy 3. The Honorable M.L. Ebert, Jr. previously entered an Order of December 6,2006 providing for shared legal custody, Mother having primary custody and Father having periods of supervised visitation. 4. The parties agreed to an Order in the form as attached. 3 ~-, 3 -0 7 Date '--4' f\ V~ acq eJine M. Verney, Esquire Custody Conciliator