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JOYCE M. SHEAFFER,
Plaintiff
v
IIN THE COURT OF COMMON PLEAS OF
ICUMBERLAND COUNTY, PENNSYLVANIA
:
:ND. 2895 - CIVIL - 1995
CHRISTINA THAYER AND
TERRANCE THORN,
Defendants,
.
.
.
.
:
:CIVIL ACTION - CUSTODY
AND NOW, t1liS~ ~ay of
the attached Custody
directed as follows:
COURT RDER
, 1995, upon consideration of
~ation Report, it is ordered and
1. Custody of the minor clli.'d, Travis Dud Lawerance Thayer, shall
be handled on a temporary basis as follows:
A. The Mother, Christina Thayer, shall have custody on a
two week schedule starting Monday, August 14, 1995, at
10 A.M. until Tuesday, August 15, 1995, at 8:30 P.M.,
and that same week on Friday, from 10 A.M. until
Sunday at 8:30 P.M. Additionally, the Mother shall
have custody on Wednesdays every other week starting
August 23, 1995, from 10 A.M. until 8:30 P.M. The
above schedule shall be alternated on a two week basis.
B. The Plaintiff, Joyce M. Sheaffer, shall have temporary
custody of the minor child at such times as the child
is not in the custody of the Mother.
C. ~'he parties shall meet for a Custody Conciliation
Conference on the 28th of September, 1995, at 10:30 A.M.
2. This is a temporary Custody Order, and the parties reserve all
claims with respect to contesting standing or other procedural
issues involved in this case. Final ruling on the Mother's
petition to dismiss the custody action for lack of standing
1s postponed pending the second Custody Conciliation
Conference scheduled in this case.
3. For purposes of transportation, the party having custody shall
deliver the minor child to the other party at times of
exchange of custody, except for the Wednesdays when the
Mother will handle all transportation.
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BY THE COURT,
CCI
Joan Carey, Esquire
Thomas J. Williams, Esquire
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VERIFICATION
Thc fhrcgoing Complninl to Conflnn Custody is hnscd upon infimnation which has bccn
gathcrcd by my counscl in thc prcparnlion of the lawsuit. Thc languagc of the documcnt is that of
counsel and not my own I havc rcad thc Complnint nnd to thc cxtcnt thai thc documcnt is hascd
upon information which I havc givcn 10 my l'Ounscl, il is IIlIC nnd correct to thc hcst of my
knowlcdge, intbnnation and hclief Tllthc cxlculthntlhc roulcnl ofthc documcnt is that ofcouusel.
I have relied Upoul'Ouuscl iumakiug Ihis vclifknliou
This slulcmcnl nnd vcritkntiouluC mndc suhjcrllolhc pcnnltics of Illl'n c.S. Scclion4904
reluling to unsworn falsificntion 10 nuthnrilies, which providcs thnt if I makc knowingly false
avermcnls. I may hc subjcrt to criminul pcnalties
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any other court.
WHEREFORE, the peti tioner, chri stina Thayer, requests that
this Court grant upon the respondent, Joyce Sheaffer, a Rule to
Show Cause why the respondent's claim for primary custody should
not be dismissed for lack of standing.
The petitioner, Christina Thayer, I'equeats Bny other relief
that is just and proper.
Respectfully submitted,
j
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,Joan carey "
'Attorney for Petii10ner
LEGAL SERVICES, INC.
a Irvine Row
Carlisle, PA 17013
(717) 243-9400
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1~e above-named petitioner, christina 1~ayer, verifies that
the statements made in the above Petition are true and correct.
1~e petitioner understands that false statements herein are made
subject to penal\:1es of 111 Pa. C.S. S 4904 relating to unsworn
falsification to authoritiee.
Datel
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Christina Thayer,
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Petitio
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JOYCE M. SIIEAffER,
Plaintiff
IN TilE COUHT Of COMMON PI,EAS Of
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-2854 CIVIL TEruM
v.
CHHIS'l'INA THAYER and
TEHHANCE TIIORN,
Defendants
CUS'l'ODY
PETITION TO DISMISS CLAIM FOR
lBIHARY CUBTQDI FOR LACK or 8TAND~
1. The petitioner, Chdstina Thayer, hereinaf...e:' the mother,
resides at RD 2 Box 26 Loysville, Pennsylvania 17047.
2. The respondent, Joyce M. Sheuffer, resides at B 15 Factory
street, Carlisle, Pennsylvania 17013.
3. The petitioner is the mother of the minor child, Travis
Thayer, born February 6, 1995.
4.
The respondent,
Joyce Sheaffer,
hus
fami ly
no
relationship to the child.
5. on June 2, 1995, the respondent filed a compl a int to
Confirm custody requesting primary custody of the child and a
concilation conference is scheduled for August 10, 1995, at 10:30
ft,m.
6. Third parties may seek primary custody of a child only if
they have stood in ~ Wlr.!l1lili or it the child has been declared
dependent. Gradwell v~_~tr.ftY~, 610 A.2d 999 (I'a. super. 1992).
7. from February 6, 1995, unt i 1 May 24, 1995, the child
lived with the petitionel', christina Thayer. On May 24,1995, the
petitioner, without legal representation, granted premiesion for
the child to stay temporarily with the respondent until she found
housing.
8. The chi Id has never beon declared dependent by this or
any other coUt't.
WHERE.FORE, thf' peti tioner, christina Thayer, requests that
this Court grant upon the respondent, Joyce Sheaffer, a Rule to
Show Cauee why the respondent's claim for primary custody should
not be dismissed for lack of standing.
The peti t:ionet', Chr i sti l1a Thayer, requeet:a allY other relief
that is just al1d proper.
Respectfully submitted,
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(Joan Carey ~'
'Attorney for Petitioner
LEGAL BERVICES, INC.
a Irvins Row
Carlisle, PA 17013
(717) 243-9400
The above-named petitionor, Christina Thayer, verifies that
the statements made in the abovo Petition are true and correct.
The petitioner understands that false statements heroin are made
subject to penalties of 10 Pa. C.S. S 4904 relating to unsworn
falsification to authorities.
Date:
t Ii' ,/',
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Christine Thayer,
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JOYCE M. SHEAFFER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-2854 CIVIL TERM
v.
CHRISTINA THAYER and
TERRANCE THORN,
Defendants
CUSTODY
PETITION TO DISHISS CLAIH FOR
PRIMARY CUSTODY FOR LACK OF STANDING
1. The petitioner, Christina Thayer. hereinafter the mother,
resides at RD 2 Box 26 Loysvills, Pennsylvania 17047.
2. The respondent, Joyce M. Sheaffer, resides at 815 Factory
Street, carlisle, Pennsylvania 17013.
3. The petitioner is the mother of the minor child, Travis
Thayer. born February 6, 1995.
4 .
The respondent,
no
family
Joyce
Sheaffer,
has
relationship to the child.
5. On June 2, 1995, the respondent filed a Complaint to
Confirm Custody requesting primary custody of the child and a
concilation conference is scheduled for August 10, 1995, at 10:30
a.m.
6. Third parties may seek primary custody of a child only if
they have stood in ~ parentis or if the child has been declared
dependent. Gradwell v. Strauser, 610 A.2d 999 (pa. Super. 1992).
7. From February 6, 1995, until May 24, 1995, the child
lived with the petitioner, Christina Thayer. On May 24, 1995. the
petitioner, without legal representation, granted premiss ion for
the child to stay temporarily with the respondent until she found
housing.
8. The child has never been declared dependent by this or
eny other court.
WIIEREFORE, the pet! tioner, Christina Thayer, requests that
this Court grant upon the respondent, Joyce Sheaffer, a Rule to
Show Cause why the respondent's claim for primary custody should
not be dismissed for lack of standing.
The petitioner, Christina Thayer, requests any other relief
that is just and proper.
Respectfully submitted,
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oan Carey
'Attorney for Peti. oner
LEGAL SERVICES, INC.
a Irvine Row
Carlisle, PA 17013
(717) 243-9400
The above-named petitioner, christina Thayer, verifies that
the statements made in the above Petition are true and correct.
The petitioner understands that false statements herein are made
subject to penalties of 16 Pa. C.S. S 4904 relating to unsworn
falsification to authorities.
Date:
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Petitio
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JOYCE M. SUEAFFER,
Plaintiff
IN 1'UE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CURIS1'INA THAYER end
TERHANCE 1'HORN,
Defendants
NO. 95-2854 CIVIL TERM
CUS1'ODY
RULI TO SHOW CAU~
AND NOW, thie _______ day of August, 1995, upon consideration
of the Petition to Dismiss Claim for Primary custody for Lack of
Standing, a Rule is hereby granted on Joyce M. Sheaffer to show
cause why her claim tor custody should not be dismissed.
The rule is returnable twenty days from the entry of this
Order.
By the Court,
JUdge
Joan Cerey
Attorney for Petitioner
Thomas J. Williams
Attorney for Respondent
JOYCE M. SHEAFFER,
Plaintiff
IN TilE COURT OF' COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-2854 CIVIL TERM
v.
CIlRISTINA THAYER and
TERRANCE THORN,
Defendants
CUSTODY
PETITION TO DISMISS CLAIM FOR
PRIMARY CUSTODY FOR LAC~ OF STANDING
1. The petitioner, Chdstina Thayer, hereinafter the mother,
resides ut RD 2 Box 26 Loysville, Pennsylvania 17047.
2. The respondent, Joyce M. Sheaffer, resides at 815 Factory
Street, Carlisle, Pennsylvania 17013.
3. The petitioner is the mother of the minor child, Travis
Thayer, born F'ebruury 6, 1995.
4 .
The respondent,
Joyce Sheaffer,
has
no
fumily
relationship to the child.
5. On June 2,1995, the respondent filed u Complaint to
Conf irm custody requesting primary custody of the child and a
concilation conference is scheduled for August 10, 1995, at 10130
a.m.
6. Third parties Inay seek primary custody of a child only if
they have stood in l2.I;,Q PlIrentis 01" it the child has been declared
dependent. Gradwell v. StrllU2.tl, 610 A.2d 999 (I'a. Super. 1992).
7. From I'ebruary 6, 1995, until May 24, 1995, the child
lived with the petitioner, Christina Thayer. On May 24, 1995, the
petitioner, without legal representation, granted premission for
the child to stay temporarily with the respondent until she found
housing.
8. The chi ld has never been declared dependent by this or
any other court.
WIIEREFORE, the petitioner, Christina Thayer, requests that
this Court grant upon the respondent, Joyce Sheaffer, a Rule to
Show Cause why the respondent's claim for primary custody should
not be dismissed for lack of standing.
The petitioner, Chi" istina Thayel", l"eqlloats any other re lief
that is just and proper.
Respectfully submitted,
,
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Joan Carey
'Attorney for Peti oner
LEGAL SERVICES, INC.
a Irvine Row
Carlisle, PA 17013
(717) 243-9400
The above-named petitioner, Christ ina 'I'hayer, verities thet
the statements made in the above Petition are true and correct.
The petitioner understands that talse statements herein are made
subject to penalties ot 18 I'a. C.S. S 4904 relating to unswOl'n
falsification to authorities.
Date:
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JOYCE M. SIIEAFFER,
Pleintiff
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIlRISTINA TIIAYER And
TERRANCE TIlORN,
Defendants
NO. 95-2854 CIVIL TERM
CUSTODY
RULE TO SHOW CAUSe
AND NOW, this
_ day of August, 1995, upon consideration
of the Petition to Dismiss Claim for Primary custody for Lack of
Standing, a Rule is hereby granted on Joyce M. Sheaffer to show
cause why her claim for custody should not be dismissed.
The rule is returnable twenty days from the entry of this
Order.
By the Court,
Judge
Joan Cerey
Attorney for Petitioner
Thomas J. Williams
Attorney for Respondent
JOYCE M. SIIEAFFER,
Plaintiff
IN TilE COURT 0.' COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-2854 CIVIL TERM
v.
CHRISTINA THAYER and
TERRANCE THORN,
Defendants
CUSTODY
PETITION TO DISMISS CLAIH FOR
fBIMARY CUSTODY FOR LACK OF STANDING
1. The petitioner, Christina Thayer, hereinaftel" the mother,
resides at RO 2 Box 26 Loysville, Pennsylvania 17047.
2. The respondent, Joyce M. Sheaffer, resides at 815 Factory
Street, Carlisle, Pennsylvania 1701J.
J. The petitioner is the mother of the minor child, Travis
Thayer, born February 6, 1995.
4 .
The respondent,
Joyce
Sheaffer,
has
no
family
relationship to the child.
5. On June 2,1995, the respondent filed a Complaint to
Confirm Custody requesting primary custody of the child and a
concilation conference is scheduled for August 10, 1995, at 10:JO
a.m,
6. Third parties may Beek primary custody of a child only if
they have stood ..In ~ parentis or if the child has been declared
dependent. Gradwell v. Strauser, 610 A.2d 999 (Pa. Super. 1992).
7. From February 6, 1995, until May 24, 1995, the child
lived with the petitioner, ChriBtinu Thayer. On May 24, 1995, the
petitioner, without legal representation, granted premission for
the child to stay temporarily with the respondent until she found
housing.
8. The child has nevel' been declared dependent by this 01"
The above-named pet i tioller, christina Thayer, veri f ies that
the statements made in the above Petition are true and correct.
The petitioner understands that false statemento herein are made
SUbject to penalties of 18 Pa. C.B. S 4904 relating to unsworn
falsification to authorities.
Date:
" f( 'I',
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JOYCE M. SHEAFFER,
Plaintiff
IN TilE COURT OF COMMON J~EAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CllRISTINA THAYER and
TERRANCE THORN,
Defendants
NO. 95-2854 CIVIL TERM
CUSTODY
RULE TO SHOW CAUSE
AND NOW, this
day L.. ~ugust, 1995, upon consideration
of the Petition to Dismiss Claim for primary custody for Lack of
Standing, a Rule is hereby granted on Joyce M. Sheaffer to show
cause why her claim for custody should not be dismissed.
The rule is returnable twenty days from the entry of this
Order.
By the Court,
Judge
Joan Carey
Attorney for Petitioner
Thomas J. Williams
Attorney for Rsspondent
v.
CHRISTINA THAYER and
TERRANCE THORN,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERI.J\ND COUNTY, PENNSYLVANIA
NO. 95-2854 CIVIL TERM
JOYCE M. SHEAFFER,
Plaintiff
CUSTODY
PBTITION TO DISMISS CLAIM FOR
PRIMARY CUSTODY FOR LACK OF STANDING
1. The petitior,,,r, Christina Thuyer, hereinafter the blother,
resides at RD 2 Oox 26 Loysville, Pennsylvania 17047.
2. The respondent, Joyce M. Sheaffer, resides at 815 Factory
street, Carlisle, Pennsylvania 17013.
3. The petitioner is the mother of the minor child, Travis
Thayer, born February 6, 1995.
4.
The respondent,
Joyce
Sheaffer,
has
no
family
relationship to the child.
5. On June 2, 1995, the respondent filed /I Complaint to
Conf irm custody requesting primary custody of the child and a
concilation conference is scheduled for August 10, 1995, at 10130
a,m.
6. Third parties may seek primary custody of a child only if
they have stood in ~ parentia or if the child has been declared
dependent. Gradwell v. Strauser, 610 A.2d 999 (pa. super. 199~).
7. From February 6, 1995, unti I Muy 24, 1995, the child
lived with the petitioner, chriatina Thayer. On May 24, 1995, the
petitioner, without legal represontation, granted premiss ion for
the child to stay temporarily with the respondent until ahe found
housing.
8. The child has n~ver boen declared dependent by thia or
eny other court.
WIlEREFORE, the peti tl oner, Chr1Btina Thayer, requeBts that
thie Court grant upon the reBpondent, Joyce Sheaffer, a Rule to
Show Cause why the respondent's claim for primary custody should
not be dismissed for lack of standing.
The petitioner, Chr lstina Thaysl", requests any other reliet
that is just and proper.
Respectfully submitted,
I !
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IJoan Carey /;
'Attorney for Petitioner
LEGAL SERVICES, INC.
a Irvine Row
Carlisle, PA 17013
(717) 243-9400
The above-named petitioner, Christina Thayer, verifies that
the statements mude in the above Petition are true and correct.
The petitioner understands that false statements herein are made
subject to pennlties of 18 Pa, C.S. S 4904 relating to unsworn
falsification to uuthorities.
Date:
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JOYCE M. SHEAFFER,
Plaintiff
I IN THE COURT OF COMMON PLEAS OF
'CUMBERLAND COUNTY, PENNSYLVANIA
I
INO. 2895 - CIVIL - 1995
I
,
I
ICIVIL ACTION - CUSTODY
v
CHRISTINA THAYER AND
TERRANCE THORN,
Defendants
COURT ORDER
AND NOW, this ,:/;'\.! day of 0 c. r, ,1995, the Conciliator
being advised that the child who is the subject of this Custody
Action has been adopted, the Conciliator relinquishes jurisdiction.
v)i ~sf
Hubert X. Gilroy, Esquir
Custody Conciliator