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Home My WebLink About95-05471 Ocr 13 9 zu 4,~ '95 ti;,'l . oj, '\:,) I/T ~ t 'f' , , .. STEVEN J. GUTSHALL, plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. 95 - CIVIL TERM BONNIE L. GUTSHALL, Defendant IN CUSTODY COKPLAIKT roa CUSTODY 1. plaintiff is STEVEN J. GUTSHALL, residing at 235 Ewe Road, Mechanicsburg, cumberland county, Pennsylvania 17055. 2. Defendant is BONNIE L. GUTSHALL, residing at 235 Ewe Road, Mechanic.burg, cumberland county, pennsylvania 17055. 3. plaintiff seeks custody of the following childl IWII PRESENT RESIDENCE 235 Ewe Road Dillsburg, PA The child was not born out of wedlock. AliI Zachary J. Gutshall Nine The child is presentlY in the custody of Bonnie L. Gut.hall, who resides at 235 Ewe Road, Mechanicsburg, PA. During the past five years the child has resided with the following persons and at the following addressesl ,...0.. Steven J. Gutshall, Bonnie L. Gutshall and Rachael Gutshall Steven J. Gutshall, Bonnie L. Gutshall and Rachael Gutshall ADDalBI 235 Ewe Road Mechanicsburg, PA OAT.. 7/94 to Preeent 303 Narvian Road Camp Hill, PA 4/86 to 7/94 The mother of the child is Bonnie L. Gutshall, currently residing at 235 Ewe Road, Mechanicsburg, PA. She is married. The father of the child is Steven J. Gutshall, currently residing at 235 Ewe Road, Mechanicsburg, PA. He is married. 4. The relationship of Plaintiff to the child is that of father. The Plaintiff currently resides with the following persons I 11II ..LA~IO...I. Rachael N. Gutshall Daughter 5. The ~elationship of Defendant to the child is that of .other. The Defendant currently resides with the following persons I 11II ..LA~IO...I. Zachary J. Gutshall Son 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 the child 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 or claims to have 2 .i:IU!:~4'r~1;';'~~ ~~~,"'-l_':1.L~,' 1,-"'-""" "F';: ~,'--""", .' """ '~ ", .' __f'...... custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be 8erved by granting the relief requested because: a. Plaintiff has demonstrated by his actions and concerns that he will devote the time, care, nurturing and discipline to raise the child i8 a responsible manner: b. Defendant has put her own interests above the interests of the child by being away from home with her paramour at times when she knew her child was alone; c. Defendant does not discipline the child or try to correot the child'8 behavior; d. Defendant has exposed the child to regularly filthy language and pornographic materials; and e. Defendant uses marijuana on a daily basis. B. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child, have been named as parties to this action. 9. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: NONE 3 WHEREFORE, plaintiff requests the Court to grant custody of the child. Respectfully submitted, Date: I () ); :l.f~ j91tvlPL,~ R. Mark Thomas, Esquire 54 E. Main street Mechanicsburg, PA 17055 (717) 697-4650 I.D. # 41301 4 lr7 ~.!l ;~ I.: ~ .': .. ~. J I.. , , ~ ~~ ~~ ~\ ._~~ j ~I oJ ii~ ~ ~ f ~ ~'1~f ~~ 'it .~~ ~ il I 't f~ , . . . . ~;IIE" H'F'::; RETURIl - "EGULAR CASE NOI l'J'J~l ,'~,J'l1 I' COMMOIlWEAI.TII OF I'ENN:}Yl.V All J A. COUNTY OF' CIJMDERLANt> OUTSHAL\. Sl:!=.yr:!t .L____. VS. GUTSIIALL IllJ)!!)) E. .k___ .__.__.__._ DAVID C. ZErGLF''' . Sher1ff or Deputy Sherlff of CUMBERLAND County, PlH'llLlylvanlil, who belng duly uworn nccording to law, Buya, th" wllhin f;fJl1f'J,j\.nLl.-=-~l1SIQr'Y.___________ w,w lWIVL'd upon GUTSHALL Bornl riLL t.he> defendant, ut _J l:~~,-!..~~. IIIJUIlS, Oil Up, 1 ]l.!t du)' of I]C:.~~E_'t!:____________________.. 1995 nt CUMBERl.AND !=O--,-..s,;9URTI!QllS~_.J-1tl.G_~R..UJ.\LI!PJJSE SQUAll!::. 4TH 1'1-..:...__. CARLIS1.L-j'A 1'1\'113 .__________..__._____._, ~lJJ1I}ERI.AI!P____. County, Pennaylvnnin, by hundllHl to 130Nl'!Jl':. 1,._~1\JTSHA1~_.__._ a true and alteoted copy oj till? COl1fl.AJJlL..::..fUSTQQL____________, together with QR.P..!;;IL.QY.__@ST()[Jy and at the sume tlmL' dll-ectlng !h:~L nlt.C'ntton to the con'PllI.u t.he.",,!, Sheriff's CostR' DlIr:k,,'ting Ser\.'ic~ Aft idav it Surcharge IIl,('l", .11\0 .00 2.\l0 :;O?~1'~ R~---TFioii1iirjn1\ri It.i~'~-" ~neiTrr~-.....u_~._------ lli:0:-0l'l-R. MA"'-; TlllJIW~ ~ Il~/ I:i/ll):q~, W(;.2 'If'--- ""1''1'"'' -I and lJubSel'lbl.;,d tu h"1I)ll~ IrH-' Sworn thill .~_~-:A: dBY "1 (icti~ 19_n'{. A. r'. __\.. L,~", (.'.~lt"u.-- ~;Y' ..~, rri,fhflllUl/.t-I~-f ' STEVEN J. GUTSHALL, plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PEllNSYLVANIA v. . . . . NO. 95- 511)/ CIVIL .~ BONNIE L. GUTSHALL, Defendant IN CUSTODY ORDER OF COURT AND NOW, this ~ day of f9d,tff.~"-- , 1995, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before rfJ..~ S. ~.-...la""L.u4. , the conciliator, at ~ 1YI~ )t'/7W.~.uu.Lw..~ ,eA- on the Itff'h- day of ~~ , 199:), at {a: 30 A.M., for a Pre- Hearing custody Conference, At such Conference, an effort will be made to resolve the issues in dispute I 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. Either party may bring the child who is the subject of this custody action to the conference, but the childlchildren's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR '1'IIE COURT: By: yOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT OHCE. 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 cumberland county courthouse TRUE COP'" FROM RECORD Fourth Floor d carlisle, FA 17013 . In Testimony whereot I I hero unlo sot m~ han ( 717) 240 - 6 2 0 0 , and the seal \11 ~ald COUll at Carlisle, I a,!>_ . T dE t 19 I - -;... STEVEN J. GUTSHALL, plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 95- CIVIL BONNIE L. GUTSHALL, Defendant : IN CUSTODY NOTICI YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you, You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE 4th FLOOR CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717)-240-6200 The mother of the child is Bonnio L. Gutshall, currently residing at 235 Ewe Road, Mechanicsburg, PA. She is married, The father of the child is steven J. Gutshall, currently residing at 235 Ewe Road, Mechanicsburg, PA, He is married. 4. The relationship of Plaintiff to the child is that of father. The plaintiff currently resides with the following persons I HaKI RZL~TION8HIP Rachael N. Gutshall Daughter 5. The relationship of Defendant to the child is that of mother. The Defendant currently resides with the following persons: ~ RBL~TION8HIP Zachary J. Gutshall Son 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 the child pending in a court of this commonwealth. plaintiff does not know of n person not a party to the proceedings who has physical custody of the child or claims to have 2 custody or visitation rights with respect to the child. 7. The best interest and permanent we lfare of the child wi 11 be served by granting the relief requested because: a. Plaintiff has demonstrated by his actions and concerns that he will devote the time, care, nurturing and discipline to raise the child is a responsible manner: b, Defendant has put her own interests above the interests of the child by being away from home with her paramour at times when she knew her child was alone; c, Defendant does not discipline the child or try to correct the child's behavior; d, Defendant has exposed the child to regularly filthy language and pornographic materials I and e. Defendant uses marijuana on a daily basis. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child, have been named as parties to this action. 9, All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: NONE 3 STEVEN J. GUTSHALL, Plaintiff IN TilE cOURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, NO, 95- 51/)1 CIVIL .::h.".. BONNIE L. GUTSHALL, Defendant IN CUSTODY ORDER OF COURT AND NOW, this ~ day of t9ct,~ , 1995, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before ~~ S. ~~ ~. , the conciliator, at ~ ~~'/~~,eA- on the IV-oft- day of ~ , 199~, at (0: 3() A.M., 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. Either party ma~' bring the child who is the subject of this custody action to the conference, but the child/children's attendance is not mandatory. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent order, FOR TilE COURT: By: I~of)~ j, ~ ~, ustody Conciliator . YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPIIONE TilE OFFICE SET FORTII DELOW TO FIND OUT WIIERE YOU CAN GET LEGAL IIELP. Office of the Court Administrator Cumberland County courthouse TRUE COpy FROM RECORD I'ourth 1'1001' h d Carlislo, PA 170lJ In Teltlmonywhereol, I here u"Io sot my an (717) 24 (J-(j200 and the leal 01 said COUll al Carlisle, P 's" T . t!.' 19