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Home My WebLink About07-0441 REBECCA D. REED, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA vs. ; NO. O~ - "''II Cu~L ~eA...m PATRICK M. BLAINE, Defendant : CNIL ACTION - LAW : CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Rebecca D. Reed, residing at 13308 US 24, Cecil, Ohio 45821. 2. The defendant is Patrick M. Blaine, residing at 16 Annendale Drive, Carlisle, Pennsylvania 17015. 3. Plaintiff seeks custody of Jonathan Philip Blaine, born March 20, 1990, and Zachary Michael Blaine, born AprilS, 1993. 4. The children were not born out of wedlock. The children are presently in the custody of Rebecca D. Reed who has had custody ofthe children since August, 2004. 5. For the past five years, the child has resided with the following persons at the following addresses: Custodian Address Dates Patrick M. Blaine 14107 W. Cadmus Road Hudson, MI 49247 2001 to July, 2004 Rebecca D. Reed Jay L. Reed 174 1/2 E. Penn Street Carlisle, P A 17013 August, 2004, to September, 2004 .,r Rebecca D. Reed Jay L. Reed 309 N. East Street Carlisle, PA 17013 September, 2004, to December 29,2006 Rebecca D. Reed Jay L. Reed 13308 US 24 Cecil,OH 45821 December 29,2006, to present 6. The mother ofthe children is Rebecca D. Reed who currently resides at 13308 US 24, Cecil, Ohio. She is married. 7. The father of the children is Patrick M. Blaine currently residing at 15 Annendale Drive, Carlisle, Pennsylvania. He is single. 8. The plaintiff currently resides with her husband, and her two children, Jonathan Philip Blaine and Zachary Michael Blaine. 9. The defendant currently resides alone. 10. 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. 11. The plaintiff has no information of a custody proceeding concerning the children pending in a court in this Commonwealth or in any other court. 12. 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. ." 13. The best interest and permanent welfare of the children will be served because plaintiff is better able to provide for the needs of the children. 14. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, plaintiff requests this Court to award herprimary physical custody of Jonathan Philip Blaine and Zachary Michael Blaine. Timo~squire Turner and O'Connell 4415 North Front Street Harrisburg, P A 17110 (717) 232-4551 .. ..- Verification I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Date: Oi/!()7 ~dJ~ R caD. Reed ~ -4Q. 0 r--..> 0 ;c) <=> "" c = -0 7ft. '- ;.:.:<>" --.J #. 10 ....oi"";} <- :r-n rrq ::P- . Z n,;~ W D C/} c-"-. --1 --- 0 -<: \.0 (') - ~ ~ ~;:: :~:B ~ if! ';... -0 G :.>,c \ :x :,-;.C) ,-:.....,. ,"..". -\() :.;. s:-:~ w Om .-1 ~ /~ ~ ......i CJ1 -<. N -< $ REBECCA D. REED PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 07-441 CIVIL ACTION LAW PATRICK M. BLAINE DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, January 24, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. at 4th Floor, Cumberland County Courthouse, Carlis~ on Friday, February 23, 2007 , the conciliator, at 1:00 PM 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 tbe 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 hearin2. FOR THE COURT. By: Isl The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For infomlation about accessible facilities and reasonable accommodations available to disabled individuals having business before the COUlt, 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 . ~o:~ $p --.~ ~1 ((J/,C'./ .-rM ~ ~ ~ co.pe.; ~;J, tJ r 7 /7T?/ 1(/ ~ 'P1J ~ tJ.j, e./ ZS :8 l,,!d +lZ Nvr LOOl . tj\ .., o" ,.. ,,' .' I "Y , f -"Hl' ..l0 ^ ./." II"". "'''''1' ''''''''1 ~, . 1 IV "j",,1> 1............,....1-<... _I _ -- ~:Ji.Hn-O::lll:J -J.-oJ ,__,.... On . .. REBECCA D. REED, Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. C>;Y~J.(J.(I ~i(.>~LT~ PATRICK M. BLAINE, Defendant : CIVIL ACTION - LAW : CUSTODY CUSTODY STIPULATION AND NOW, this _ day of , 2007, the parties hereto, Rebecca D. Reed and Patrick M. Blaine, parents of the minor children Jonathan Philip Blaine, born March 20, 1990, and Zachary Michael Blaine, born AprilS, 1993, hereby stipulate and agree to the entry of an Order of Court as follows: 1. Primary physical custody of Jonathan Philip Blaine and Zachary Michael Blaine be in Rebecca D. Reed. 2. Primary legal custody of Jonathan Philip Blaine and Zachary Michael Blaine be shared. 3. Patrick M. Blaine shall be entitled to reasonable periods of temporary physical custody as the parties shall agree. Witness: Rebecca D. Reed Date 7'fi?}~~ _~ s;L" ~ --?6-,;0? Patrick M. Blaine . Date ; , .. REBECCA D. REED, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 0 ~ - 4l.f I e; C> LL '-r ~"'\ : CIVIL ACTION - LA W : CUSTODY vs. PATRICK M. BLAINE, Defendant CUSTODY STIPULATION AND NOW, this _ day of , 2007, the parties hereto, Rebecca D. Reed and Patrick M. Blaine, parents of the minor children Jonathan Philip Blaine, born March 20, 1990, and Zachary Michael Blaine, born April 5, 1993, hereby stipulate and agree to the entry of an Order of Court as follows: 1. Primary physical custody of Jonathan Philip Blaine and Zachary Michael Blaine be in Rebecca D. Reed. 2. Primary legal custody of Jonathan Philip Blaine and Zachary Michael Blaine be shared. 3. Patrick M. Blaine shall be entitled to reasonable periods of temporary physical custody as the parties shall agree. Witness: Patrick M. Blaine Date "', c:~:) (..":.:) ---J .." rrl C"0 o .1 ~-n rllF ~~~ ..};~; "~~ :D ....." I -..I -~ (.~) U1 CC REBECCA D. REED, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 07-441 PATRICK M. BLAINE, Defendant : CIVIL ACTION - LA W : CUSTODY ACCEPTANCE OF SERVICE I hereby accept service of the Complaint for Custody and Order of Court dated January 24, 2007, in the above captioned action. Date: ~~? x:fb.-i .:?/ #-- Patrick M. Blaine ~ c;.~ ......,..i -n t-\"''i 0-' , --l ~ :? -.- ..,. ''''''r '-0 P:; -I~~J~S! ;:-':) --;::j :2. ~1'1 .....", -~. 76 :...::. (:f? c..J'i co ( ~ , FEe 0 9 2007 ) REBECCA D. REED, Plaintiff vs. PATRICK M. BLAINE, Defendant ORDER AND NOW, this ~ day of F t1t\ln.lI"'i ' 2007, upon stipulation ofthe parties, it is hereby ordered that: 1. Primary physical custody of Jonathan Philip Blaine and Zachary Michael Blaine be in Rebecca D. Reed. 2. Primary legal custody of Jonathan Philip Blaine and Zachary Michael Blaine be shared. 3. Patrick M. Blaine shall be entitled to reasonable periods of temporary physical custody as the parties shall agree. onable periods of temporary physical custody as the parties shall agree. By the Court: ~~~r J. 'VIf'N/\lASNN3d A1.NnO~" CJfJI/IH38~no SO :g U\f C I 83.:1l00Z ^tfVIONOH10tkJ 3Hl:.lO 30/:130-031H