HomeMy WebLinkAbout94-06686
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SHERIFF'S RETURN
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CWBERLAND
Tammy L. Shoemaker In the Court of Common Pleas
Cumberland County, Pennsylvania
VS No. 94-6686 Civil Term
Order of Court and Petition
Clark E. Neal for Special Relief
Philip Baughman, )Ekux Bfx)Dx Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law, says,
order of Court and Petition for
that he served the within Special Relief ,
Upon Clark E. Neal , The defendant at 8t4 O o'clock
A M. EST / jjWjk the 25th day of November , 19 94 at
111 N. Hanover Street , Carlisle Cumberland County,
Pennsylvania, by handing to Ken Eckenrow Borther of Clark E. Neal
a true and attested copy of the Order of Court and Petition
and at the sane time directing his attention to the contents thereof and
the "Notice to Plead" endorsed thereon.
Sheriff's Costs:
Docketing 14.00
Service 2.80
Affidavit
Surcharge
16.80
Sworn and subscribed to before me
this ,!0 M, day of
So answers:
R. Thomas Kline, Sheriff
by ? 1` • ??`
Deputy Sheriff
19 9`/ A. D.
Proth n tary
','!C "V ? 3 1994 C)"'
TAMMY L. SHOEMAKER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
v : CIVIL ACTION - LAW
IN CUSTODY
CLARK E. NGAL, qq' Cs Le C' 1 TE4m
Defendant. : NO. CIVIL 1994
ORDER OF COURT
AND NOW, this J Iday of / o\j, , 1994, on consideration of the attached
petitioner's Affidavit, leave is granted to the petitioner to proceed in forma pauperis to the extent
that she is relieved of all costs in this action.
By the Court,
J.
TRUE COPY FROM RECGRD
In Tuilmmy whored, I :wire unto sit my hard
and It,a s#Fil Of kk ('Mor, at CQill%kf, PA.
f'r;?Mnttntnt},?
TAMMY L. SHOEMAKER,
Plaintiff.
V.
CLARK E. NEAL,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN CUSTODY
NO. CIVIL 1994
PETITION TO PROCEED IN FORMA PA PERIS
Tammy L. Shoemaker, plaintiff in the above titled action, respectfully requests this
Honorable Court to grant her leave pursuant to Pa.R.C.P. 240 proceed in forma pauperis to
the extent that she be relieved of all costs attendant to this action.
Date 17 AI q1 -
TARYN F. GOLDSTEIN
Certified Legal Intern
THOMAS M. PLACE
ROBERT E. RAINS
LINDA E. FISHER
THOMAS L. PEELER
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/243-2968
TAMMY L. SHOEMAKER,
Plaintiff.
V.
CLARK E NEAL,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN CUSTODY
NO. CIVIL 1994
A_I'TOnhrY'S AFI IDAVIT SUPPORTING PETITION
I OR LEAVIs TO PROCErD IN FORMA PAUPERIS
I, Taryn F. Goldstein, of the Family Law Clinic, attorney for the parry petitioning to
proceed in forma pauperis, certify that I believe petitioner is unable to pay the costs of instituting
this action and that I am providing free legal service to petitioner.
Plaintiff'. Affidavit showing inability to pay the costs of litigation is attached hereto.
Date 11 oZ ` I'% .l I\.
Taryn Goldstein
Certified Legal Intern
THOMAS M. PLACE
ROBERT E. RAINS
LINDA E. FISHER
Supervising Attorney
THOMAS L. PEELER
Staff Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/243-2968
TAMMY L. SHOEMAKER,
Plaintiff,
V.
CLARK E. NEAL,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. CIVIL 1994
:CUSTODY
1. I am the plaintiff in the above matter and because of my financial condition am
unable to pay the fees and costs of prosecuting or defending the action or proceeding.
2. I am unable to obtain funds from anyone, including my family and associates, to
pay the costs of litigation.
3. I represent that the information below relating to my ability to pay the fees and
costs is true and correct.
(a) Name: Tammy L. Shoemaker
Address: 1346 Grandview Court, Carlisle, PA 17013
Social Security No.: 173-54-4979
(b) Employment
If you are presently employed, state
Employer: n/a
Address: n/a
Salary or wages per month: n/a
Type of work: n/a
If you are presently unemployed, state
Date of last employment: April 26, 1994
Salary or wages per month: $593.00/month
Type of work:. clerk at the PX, Carlisle Barracks
(c) Other income within the past twelve months
Business or profession:.n/a
Other self-employment: n/a
Interest: n/a
Dividends: n/a
Pension and annuities: n/a
Social security benefits: n/a
Support payments: $40.00/week
Disability payments: n/a
Unemployment compensation and supplemental benefits: $344.00/month
Workman's compensation: n/a
Public Assistance: Food Stamps $302.00/month
Other: n/a
(d) Other contributions to household support
Name: n/a
Employer: n/a
Salary or wages per month: n/a
Type of work: n/a
Contributions from children: n/a
Contributions from parents: n/a
Other contributions: n/a
(e) Property owned
Cash: n/a
Checking account: n/a
Savings account: n/a
Certificates of deposit: n/a
Real estate (including home): n/a
Motor vehicle: Make , Year 1980 Toyota, Corolla
Cost , Amount Owed $00
Stocks; bonds: n/a
Other: Na
(f) Debts and obligations
Mortgage: n/a
Rent: n1a
Loans: n/a
Other: utilities $100.00/month
(g) Persons dependent upon you for support
Name: n/a
Children, if any:
Name: Clark E. Neal, Jr. Age: 4 years
Amber L. Neal 3 years
Other persons:
Name:
Relationship:
4. I understand that I have a continuing obligation to inform the court of
improvement in my financial circumstances which would permit me to pay the
costs incurred herein.
5. I verify that the statements made in this affidavit are true and correct. I
understand that false statements herein are made subject to the • penalties of 18
Pa,C.S. §4904, relating to unworn falsification to authorities.
Date
TAMMY/L. SHOt-MAKER
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NOV 2" 19940
TAMMY L. SHOEMAKER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
v : CIVIL ACTION - LAW
1 CUSTODY
?r/_CaLeRU C':':j Tykm
CLARK E. NEAL,
Defendant. : NO. CIVIL 1994
ORDER OF COURT
AND NOW, this c SVay of /1(0j((nb"', 1994, upon consideration of the attached
complaint, it is hereby directed that the parties and their respective counsel appear before,
t I .sC
1TN 171 it he?conciliator, at f J-r h nX/-, Cumberland County Courthouse,
on the (prbay of .r?b(_'?1995, at P,304M., 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.
FOR THE COURT,
4custoonciliator
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, 4th Floor
CARLISLE, PA 17013
717/240-6200
0-t, -
Nov L9 I? ud
"4t,Y
I I - A qq copy pQa 4' ^
TAMMY L. SHOEMAKER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
V. ; CIVIL ACTION - LAW
IN CUSTODY
CLARK E. NEAL,
Defendant. ; NO. CIVIL 1994
COMPLAINT FOR CUSTODY
COUNT I-CUSTODY
AND NOW, the plaintiff, Tammy L. Shoemaker, by her attorneys, the Family Law
Clinic„ sets forth the following cause of action:
1. The plaintiff is Tammy L. Shoemaker, residing at 1346 Grandview Court,
Carlisle, Cumberland County, Pennsylvania 17013.
2. The defendant is Clark E. Neal, residing at 111 North Hanover Street, Carlisle,
Cumberland County, Pennsylvania 17013.
3. Plaintiff seeks custody of the following children.
Name Present Residence DDB
Clark E. Neal, Jr. 1346 Grandview Court 1/31/91
Carlisle, PA 17013
Amber L. Neal 1346 Grandview Court 2/11/92
Carlisle, PA 17013
The children were born out of wedlock.
The children are presently in the custody of Tammy L. Shoemaker, who resides at 1346
Grandview Court, Carlisle, Cumberland County, Pennsylvania 17013.
During the past five years, the children have resided with the following persons and at
the following addresses:
Persons Addresses Dates
Tammy L. Shoemaker and 106 B. Lincoln Street DOB - Dec. 1993
Clark E. Neal Carlisle, PA 17013
Tammy L. Shoemaker and 1346 Grandview Court Dec. 1993 - July 1994
Clark E. Neal Carlisle, PA 17013
Tammy L. Shoemaker 1346 Grandview Court July 1994 - Present
Carlisle, PA 17013
The mother of the children is Tammy L. Shoemaker, currently residing at 1346
Grandview Court, Carlisle, Cumberland County, Pennsylvania 17013.
She is single.
The father of the children is Clark E. Neal, currently residing at 111 North Hanover
Street, Carlisle, Cumberland County, Pennsylvania 17013.
He is single.
4. The relationship of the defendant to the children is that of father. The defendant
resides with the following persons:
Name
Barbara Ann Neal
Clark F. Neal
Relationship
mother
father
5. The relationship of plaintiff to the children is that of mother. The plaintiff
currently resides with the following persons:
NMM Relationship
Clark E. Neal, Jr, son
Amber L. Neal daughter
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:
a) Plaintiff has been primary caretaker of the children since birth;
b) Plaintiff provides the children with a home with adequate moral, emotional and
physical surroundings as required to meet the children's needs;
C) Plaintiff is willing to accept custody of the children;
d) Plaintiff continues to exercise parental duties and enjoys the love and affection of
the children;
e) Plaintiff has not indicated to plaintiff an interest in accepting custody of the
children.
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 to grant custody of the children.
Date I ?) 94
Taryn Goldstein
Student Attorney
THOMAS M. PLACE
ROBERT E. RAINS
LINDA E, FISHER
• •v
Supervising Attorney
THOMAS L. PEELER
Staff Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/240-5204
COMMONWEALTH OF PENNSYLVANIA :
COUNTY OF CUMBERLAND: SS.
I verify that the statements made in this Custody Complaint are true and correct to the
best of my personal knowledge and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification authorities.
r Tammy Shoemaker
Date 11-1l -V
T
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NOV rl
TAMMY L. SHOEMAKER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
v : CIVIL ACTION - LAW
IN CUSTODY
CLARK E. NEAL, 9q - o (? Cam: etc Tvxryl
Defendant. ; NO. CIVIL 1994
ORDER OF COURT
AND NOW, this 23tc day of jJo.,e-. e), 1994, on consideration of the attached
petitioner's Affidavit, leave is granted to the petitioner to proceed in forma pauperis to the extent
that she is relieved of all costs in this action.
By the Court,
TAMMY L. SHOEMAKER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff. : CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
IN CUSTODY
CLARK E. NEAL,
Defendant. : NO. CIVIL 1994
PETITION TO PROCEED IN FORMA PAUPERTS
Tammy L. Shoemaker, plaintiff in the above titled action, respectfully requests this
Honorable Court to grant her leave pursuant to Pa.R.C.P. 240 proceed in forma pauperis to
the extent that she be relieved of all costs attendant to this action.
Date 1) Al R
TARYN F. GOLDSTEIN
Certified Legal Intern
THOMAS M. PLACE
ROBERT E. RAINS
LINDA E. FISHER
THOMAS L. PEELER
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/243-2968
TAMMY L. SHOEMAKER,
Plaintiff,
V.
CLARK E. NEAL,
Defendant.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
:IN CUSTODY
NO. CIVIL 1994
tVj'TORNFY'S AFFIDAVIT SUPPORTING PETITION
FOR LEAVE, TO PROCEED IN FORMA PAUPERIS
I, Taryn F. Goldstein, of the Family Law Clinic, attorney for the party petitioning to
proceed in forma pauperis, certify that I believe petitioner is unable to pay the costs of instituting
this action and that I am providing free legal service to petitioner.
Plaintiff's Affidavit showing inability to pay the costs of litigation is attached hereto.
Date 11 L-q-z /q+
Taryn F. Goldstein
Certified Legal Intern
ZVYJ45f,t?
THOMAS M. PLACE
ROBERT E. RAINS
LINDA E. FISHER
Supervising Attorney
THOMAS L. PEELER
Staff Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/243-2968
TAMMY L. SHOEMAKER,
Plaintiff,
V.
CLARK E. NEAL,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. CIVIL 1994
CUSTODY
AFFIDAVIT SUPPORTING PETITION FOR LEAVE
TO PROCEED INFORMA PAUPERIS
I. I am the plaintiff in the above matter and because of my financial condition am
unable to pay the fees and costs of prosecuting or defending the action or proceeding.
2. I am unable to obtain funds from anyone, including my family and associates, to
pay the costs of litigation.
3. I represent that the information below relating to my ability to pay the fees and
costs is true and correct.
(a) Name: Tammy L. Shoemaker
Address: 1346 Grandview Court, Carlisle, PA 17013
Social Security No.: 173-54-4979
(b) Employment
If you are presently employed, state
Employer: Na
Address: n/a
Salary or wages per month: n/a
Type of work: n/a
If you are presently unemployed, state
Date of last employment: April 26, 1994
Salary or wages per month: $593.00/month
Type of work: clerk at the PX, Carlisle Barracks
(c) Other income within the past twelve months
Business or profession: Na
Other self-employment: Na
Interest: n/a
Dividends: n/a
Pension and annuities: Na
Social security benefits: n/a
Support payments: $40.00/week
Disability payments: n/a
Unemployment compensation and supplemental benefits: $344.00/month
Workman's compensation: n/a
Public Assistance: Food Stamps $302.00/month
Other: n/a
(d) Other contributions to household support
Name: n/a
Employer: n/a
Salary or wages per month: n/a
Type of work: n/a
Contributions from children: n/a
Contributions from parents: n/a
Other contributions: n/a
(e) Property owned
Cash: n/a
Checking account: n/a
Savings account: n/a
Certificates of deposit: n/a
Real estate (including home): n/a
Motor vehicle: Make , Year 1980 Toyota, Corolla
Cost , Amount Owed $00
Stocks; bonds: n/a
Other: n/a
(f) Debts and obligations
Mortgage: n/a
Rent: n/a
Loans: n/a
Other: utilities $100.00/month
(g) Persons dependent upon you for support
Name: n/a
Children, if any:
Name: Clark E. Neal, Jr. Age: 4 years
Amber L. Neal 3 years
Other persons:
Name:
Relationship:
4. I understand that I have a continuing obligation to inform the court of
improvement in my financial circumstances which would permit me to pay the
costs incurred herein.
5. I verify that the statements made in this affidavit are true and correct. 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
TAMMY . SH M MAKER
-
-7-c
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TAMMY L. SHOEMAKER,
Plaintiff
V.
CLARK E. NEAL,
Defendant
s IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
i
s CIVIL ACTION - LAW
s
NO. 94- 00(o CIVIL TERM
ORDER OF COURT
AND NOW, this ??AtI day of November, 1994, upon consideration
of the attached Petition for Special Relief, a hearing is SCHEDULED
for Thursday, December 22, 1994, at 3:30 p.m., in Courtroom No. 5,
Cumberland County Courthouse, Carlisle, Pennsylvania.
BY THE COURT,
Taryn F. Goldstein
Certified Legal Intern
Family Law Clinic
Linda E. Fisher, Esq.
Supervising Attorney
Family Law Clinic
J Wesley /O e r.
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Hoy 23 2 31
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TAMMY L. SHOEMAKER,
Plaintiff,
V.
CLARK E. NEAL,
Defendant.
NO ? 1094C411-
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN CUSTODY
NO. CIVIL 1994
ADnFD nF rnrtR GRANTING TEMPORARY CUSTODY
AND NOW, this day of
, 1994, upon consideration of the attached
petition of Tammy L. Shoemaker, it is hereby ordered and decreed that temporary physical
custody of the children, Amber L. Neal and Clark E. Neal, Jr., is awarded to petitioner, Tammy
L. Shoemaker, pending a custody conciliation in this matter.
By the Court,
J.
TAMMY L. SHOEMAKER,
Plaintifl\Petitioner,
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN CUSTODY
CLARK E. NEAL,
Defendant\Respondent. : NO. CIVIL 1994
PETITION FOR SPECIAL RELIEF
AND NOW comes the plaintiff, Tammy L. Shoemaker, through her attorneys, the
Family Law Clinic, pursuant to Pa.R.C.P. 1915.13, seeking temporary physical and legal
custody of her minor children, Clark E. Neal, Jr. and Amber L. Neal, and in support thereof
alleges as follows:
i. Petitioner is Tammy L. Shoemaker, residing at 1346 Grandview Court,
Carlisle, Cumberland County, Pennsylvania 17013.
2. Respondent is Clark E. Neal, residing at i t l North Hanover Street, Carlisle,
Cumberland County, Pennsylvania 17013.
3. Petitioner filed a custody action concurrently with this petition, and Petitioner
will be filing a Protection From Abuse Petition.
4. Petitioner is the natural mother of the following children: Clark E. Neal, Jr.
born January 31, 1991, and Amber L. Neal, born February 11, 1992. Respondent is the
children's natural father.
5. The children currently reside with the petitioner at 1346 Grandview Court,
Carlisle, Cumberland County, Pennsylvania 17013.
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6. In November of 1993, following a verbal argument, Respondent brandished his
loaded gun in anger, and he went to get the gun as Petitioner and her young daughter were
trying to escape from the house.
7. Since that time, Respondent has threatened and harassed Petitioner and their
children with continuing verbal threats and verbally abusive behavior.
8. On October 31, 1994, Respondent harassed and threatened Petitioner over the
telephone, saying "I am going to shoot you and everyone else in the house." He repeatedly
called her throughout the evening. Petitioner alerted the police twice, and the police filed
charges against Respondent for harassment.
9. Due to Respondent's unpredictable and violent behavior, Petitioner has evicted
Respondent from the home that they had jointly shared.
WHEREFORE, Petitioner respectfully requests the court to grant her temporary
physical custody of the children until a conciliation can be held in this matter..
Date i `g
_AI J V/ )L
aryn Gol stein
Certified Legal Intern
Z? vvt ? rC? ?
Thomas M. Place
Robert E. Rains
Linda E. Fisher
Supervising Attorney
Thomas L. Peeler
Staff Attorney
The Family Law Clinic
45 North Pitt Street
Carlisle, PA 17013
717/240-5204 or
717/243-2968
COMMONWEALTH OF PENNSYLVANIA :
COUNTY OF CUMBERLAND: SS.
I verify that the statements made in this Petition for Special Relief pursuant to
Pa.R.C.P. 1915.13 are true and correct to the best of my personal knowledge 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: 11-)1-21
TAMMY .SHOEMAKER
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TAMMY L. SHOEMAKER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
V. : IN CUSTODY
CLARK E. NEAL,
Defendant. : NO. 6686 CIVIL 1994
CERTIFICATE OF SERVICE
I, Taryn F. Goldstein, Certified Legal Intern, Family Law Clinic, hereby certify that I
have served a true and correct copy of said Custody Complaint on Clark E. Neal, residing at
111 North Hanover Street, Carlisle, PA 17013, by depositing a copy of the same in the United
States mail, first class, postage prepaid, this second day of December 1994.
jcC /u.k) .. I cLt-uiz?'
Taryn F. Goldstein
Certified Legal Intern
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TAMMY L. SHOEMAKER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
V. ; IN CUSTODY
CLARK E. NEAL,
Defendant. : NO. 6686 CIVIL 1994
C RT FICATE OF SERVICE
I, Taryn F. Goldstein, Certified Legal Intern, Family Law Clinic, hereby certify that I
have served a true and correct copy of said Custody Complaint on Clark E. Neal, residing at
111 North Hanover Street, Carlisle, PA 17013, by depositing a copy of the same in the United
States mail, certified, restricted delivery, return receipt requested, postage prepaid, this second
day of December, 1994.
Taryn F. Goldstein
Certified Legal Intern
it 734 ale 81l2
Certified Mail Receipt
No Insurance Coverage Provided
e Do not use for International Mad
NEAL
Ir.el a nn
111 N. HANOVER STREET
eAjk%j t i PA 17013
$ .52
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• canpkk Items 3, and 4e A It. following sarvit%i tfor aR sxtrs .I
e print your nerve and sddMis on the W-1611e or this form w that we can fee):
nennn this Card to you.
L Attach this form to the front of the mane"e, or on the beak it spew 1. ? Addressee's Address
4 do .s not wrmit• ,1R
iq a Write "Return recakaRentwmd" on tha mallpbeeGlowtheWick number 2. 6Wivory:llt
. The Ratwn Receipt wig show to whom the srecle was rlaerered and the date
I dsivmd. - Consult etmsstar for lee
3. Article Addressed to: 4a. Article Number -
CLARK NEAL P"734297 812
111 N. HANOVER STREET 4b. Servloe Type
I ? Rsglstered ? Insured
it CARLISLE, PA 17013 W Certified ? COD
? Explress Mail ? Return Reeelpt for a
< 5. Signature (Addressee 8. Addressee's Address (Only if requested
i and fee Is paid)
8. Signature (Agent)
PS Form 3811. December 1991 +u.ao?o via-srs+ot DOMESTIC RETURN RECEIPT
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TAMMY L. SHOEMAKER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
V. : IN CUSTODY
CLARK E. NEAL,
Defendant. : NO. 94-6686 CIVIL TERM
AND NOW, this Z(SI day of 1>4cc'ti?v , 1994, upon consideration of the attached
Custody and Partial Physical Custody Agreement, the same is APPROVED and ENTERED
as an Order of Court, and the hearing scheduled for Thursday, December 22, 1994 at 3:30
p.m. is CANCELLED. This Order will remain in effect until further Order of Court after a
conciliation has been held in this matter.
BY THE COURT,
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TAMMY L. SHOEMAKER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA:
V.
: CIVIL ACTION - LAW IN
: CUSTODY
CLARK E. NEAL,
Defendant : NO. 94-6686 CIVIL TERM
CUSTODY AND PARTIAL PHYSICAL CUSTODY AGREEMENT
THIS AGREEMENT, made this 11 V day of 1994, between Plaintiff,
Tammy L. Shoemaker (hereinafter "Mother"), and Defendant, Clark E. Neal (hereinafter
"Father"), concerns the custody and partial custody of their children, Clark E. Neal, Jr.
(D.O.B. 01-31-91) and Amber L. Neal (D.O.B. 02-11-92).
WHEREAS, Mother and Father, desire to resolve amicably custody of their children,
it is agreed as follows:
1. Shared legal custody of the parties' children, Clark E. Neal, Jr. and Amber L.
Neal, will be in both of the parties as natural parents.
2. Primary physical custody of said children shall be in the mother, Tammy L.
Shoemaker, subject to the following periods of partial physical custody for the father, Clark
E. Neal:
a) Every other weekend from Saturday at 10:00 a.m. to Sunday at 8:00 p.m.;
b) One weekday per week, time and day to be agreed upon by the parties;
c) Alternating holidays being New Year's Day, Easter, Memorial Day, Labor
Day, and Thanksgiving from 8:00 a.m. to 8:00 p.m. Father's first such holiday shalt
be New Year's Day, 1995. In addition, every Christmas from 2:00 p.m. to 8:00
p.m.;
d) One month during each and every summer, commencing with the summer of
1995. Father must notify Mother forty-five (45) days in advance as to the weeks
which he wants to schedule for the vacations, with the parties to negotiate the dates in
good faith;
e) Time on the children's birthdays and Father's Day as shall be negotiated in
good faith by the parties no less than seven (T) days preceding the events; and,
f) Such other periods as the parties may from time to time agree.
3. Father will call Mother twenty-four (24) hours in advance to cancel any period
of partial custody for the Father. If Father does not arrive for any scheduled period of
partial custody without notifying Mother in advance, he must reinstate his partial custody
rights by telephoning Mother seven (7) days in advance of the next period which he desires
partial custody to take place.
4. While the children is in the custody of Father, she shall remain under adult
supervision. Father will provide Mother with the name of any and all adult(s) who supervise
the children for any substantial period of time.
5. Father and Mother shall exchange phone numbers so that each can contact the
other concerning custodial arrangements. The parties shall notify each other of any change
in their phone number or address. The parent having physical custody of the children shall
promptly notify the other parent of any medical emergency affecting the children.
6. Each party shall notify the other in as far advance as possible if he or she is
running late for pick up or return of the children.
7. Father understands that the Family Law Clinic represents only Mother's
interests in this matter and has advised him that he should seek the advice of legal counsel.
He has chosen not to do so.
B. This agreement supersedes all previous custody agreements and Orders of
Court in this matter.
9. The parties intend to be legally bound by this agreement and that it be made an
Order of Court.
r
T?:MMY . SHOEMAKER
Plaintiff/Mother
CLARK E. NEAL
Defendant/Father
/)F l i
MICHELL13 B. STOKES
Certified Legal Intern
LINDA E. FISHER
Supervising Attorney
Family Law Clinic
45 North Pitt Street
Carlisle, PA 17013
717/243-2968
Couns.l for Mother
The above is approved and entered as an Order of Court.
By the Court,
J.
FED 2219956+1-
TAMMY L. SHOEMAKER, :IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
s
v :NO. 6686 - CIVIL - 1994
s
CLARK E. NEAL,
Defendant :CIVIL ACTION - CUSTODY
0 COUR??/T ORDER
AND NOW, this 13Y day of Ft-6 , 1995, the Conciliator being
advised that the parties have reached an agreement in the above
case, the Conciliator relinquishes jurisdiction.
ev
??YUO1 4 A • V111 V)',
Custody Conciliat
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Vw ° U
TAMMY L SHOEMAKER
Plaintiff/Respondent
V.
CLARK E. NEAL,
Defendant/Petitioner
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO: 94-6686
CIVIL ACTION - LAW
IN CUSTODY
PETITION TO MODIFY CUSTODY
1. Petitioner is Clark E. Neal, who resides at 73 Ridge Drive, Perry County, Shermansdale,
Pennsylvania 17090.
2. Respondent is Tammy L. Shoemaker, who resides at 519 East Simpson Street,
Cumberland County, Mechanicsburg, Pennsylvania 17055.
3. On December 21, 2004, the Honorable J. Wesley Oler, Jr., entered a Custody Order
attached as Exhibit "A".
4. Since the entry of said Order, there has been a significant change in circumstances in that:
a) Plaintiff/Respondent refuses to abide by the Custody and Partial Custody Agreement
of December 21, 1994 as reinforced by the Order of the Honorable J. Wesley Oler, Jr.,
on December 21, 1994.
b) Defendant/Petitioner is ready, willing and able to exercise his custodial periods and is
fit to do so.
c) The best interests of the children will be served by adhering to the Partial Custody
Agreement and further granting Petitioner primary physical custody.
5. The best interest of the children will be served by the Court modifying said Order.
WHEREFORE, Petitioner prays this Court to grant the modification of the Custody
Order as follows: Primary physical custody of the children to Defendant/Petitioner with
structured visitation in Respondent as agreed upon by the parties.
Date:
Respectfully submitted,
ROMINGER & ASSOCIATES
Michael O. Palermo, P'3, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 93334
Attorney for Defendant/Petitioner
VERIFICATION
I verify that I am the petitioner and that the statements made in the foregoing Petition are
true and correct. I understand that false statements herein are made subject to the penalties of 18
Pa. C. S. § 4904, relating to unworn falsification to authorities.
Bate: / 6alel e n2- a
Clark E. Neal/P titioner
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Template: Prothonotary_7 > Civil Dockets > 1994 Dockets > 94.8801 thru 94-6700 > 94-06686
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Powered by Laserfiche WabLink version 7.0.5. Laserfiche is a registered trademark of Compulink Management Center, Inc.
This copy is registered to: County of Cumberland - Commissioners
http://records.ccpa.net/weblink_public/DocView.aspx?id=90803&dbid=0 1/14/2008
TAMMY L. SHOEMAKER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA:
.
V.
• CIVIL ACTION - LAW IN
CUSTODY
CLARK E. NEAL, t ,
Defendant : NO. 94.6686 CIVIL TERM -
^ffT0nMf%1MV AWn DA DWAi_ VTTVRT!'AT. VTT-1QVnnV ?[:RFF.M i.N' "ti -
THIS AGREEMENT, made this,,., day of / ? -t, 1994, between Plaintiff,
Tammy L. Shoemaker (hereinafter "Mother'), and Defendant, Clark E. Neal (hereinafter
"Father"), concerns the custody and partial custody of their children, Clark E. Neal, Jr.
(D.O.B. 01-31-91) and Amber L. Neal (D.O.B. 02-11-92).
WHEREAS, Mother and Father, desire to resolve amicably custody of their children,
it is agreed as follows:
1. Shared legal custody of the parties' children, Clark E. Neal, Jr. and Amber L.
Neal, will be in both of the parties as natural parents.
2. Primary physical custody of said children shall be in the mother, Tammy L.
Shoemaker, subject to the following periods of partial physical custody for the father, Clark
E. Neal:
a) Every other weekend from Saturday at 10:00 a.m. to Sunday at 8:00 p.m.;
b) One weekday per week, time and day to be agreed upon by the parties;
r
c) Alternating holidays being New Year's Day, Faster, Memorial Day, Labor
Day, and Thanksgiving from 8:00 a.m. to 8:00 p.m. Father's first such holiday shall
be New Year's Day, 1995. In addition, every Christmas from 2:00 p.m. to 8:00
P.M.;
d) One month during each and every summer, commencing with the summer of
1995. Father must notify Mother forty-five (45) days in advance as to the weeks
which he wants to schedule for the vacations, with the parties to negotiate the dates in
good faith;
e) Time on the children's birthdays and Father's Day as shall be negotiated in
good faith by the parties no less than seven (7) days preceding the events; and,
f) Such other periods as the parties may from time to time agree.
3. Father will call Mother twenty-four (24) hours in advance to cancel any period
of partial custody for the Father. If Father does not arrive for any scheduled period of
partial custody without notifying Mother in advance, he must reinstate his partial custody
rights by telephoning Mother seven (7) days in advance of the next period which he desires
partial custody to take place.
4. While the children is in the custody of Father, she shall remain under adult
supervision. Father will provide Mother with the name of any and all adult(s) who supervise
f
the children for any substantial period of time.
5. Father and Mother shall exchange phone numbers so that each can contact the
other concerning custodial arrangements. The parties shall notify each other of any change
in their phone number or address. The parent having physical custody of the children shall
promptly notify the other parent of any medical emergency affecting the children.
6. Each party shall notify the other in as far advance as possible if he or she is
running late for pick up or return of the children.
7. Father understands that the Family Law Clinic represents only Mother's
interests in this matter and has advised him that he should seek the advice of legal counsel.
He has chosen not to do so.
8. This agreement supersedes all previous custody agreements and Orders of
Court in this matter.
9. The parties intend to be legally bound by this agreement and that it be made an
Order of Court.
T?_MMY . SHOEMAKER
Plaintiff/Mother
CLARK E. NEAL
Defendant/Father
MICHELL11 B. STOKES
Certified Legal Intern
LINDA E. FISHER
Supervising Attorney
Family Law Clinic
45 North Pitt Street
Carlisle, PA 17013
7171243-2968
Counsl for Mother
The above is approved and entered as an Order of Court.
By the Court,
7.
VIC)
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a
TAMMY L. SHOEMAKER IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
1994-6686 CIVIL ACTION LAW
CLARK E. NEAL IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Tuesday, February 05, 2008 , 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, Cumberland County Courthouse, Carlisle on Thursday, March 06, 2008 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. 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. GAro Es q.
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
OZ 'ZIRd 9- 93J G90Z
1,dvio ll'-)P l' ?c1 3Hl JO
311j", i2??-111911A
Tammy L. Shoemaker,
Plaintiff
V.
Clark E. Neal,
Defendant
To the Prothonotary:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DOMESTIC RELATIONS SECTION
: CIVIL ACTION - 1994 - 6686
PRAECIPE TO ENTER APPEARANCE
Please enter the appearance of the Family Law Clinic on behalf of Tammy L. Shoemaker,
the Plaintiff, in the above captioned matter.
February 19, 2008
Ann Dimitriou Pipkin
'fled Legal Intern
Anne nald-Fox
Supervising Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
,i
CIO -C
fiEB 10 1008
TAMMY L. SHOEMAKER, IN THE l'URT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v CIVIL ACTION - LAW
CLARK E. NEAL, NO. 1994-6686
Defendant IN CUSTODY
COURT ORDER
r?
AND NOW, this /? day of February, 2008, the Conciliator having been advised that
the parties are attempting to resolve differences without need for a Conciliation, the Conciliation
scheduled for March 6, 2008 is cancelled and the Conciliator relinquishes jurisdiction.
??13 \?J/
Hubert X. roy, Esquire
Custody onciliator