Loading...
HomeMy WebLinkAbout96-06080 -0 . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO;{~ ll.l.:'~L> CIVIL TERM IN CUSTODY BRENT K. BARROWS, Plaintiff v. DONNA M. BARROWS, Defendant COMPLAINT FOR CUSTODY 1. Plaintiff is Brent K. Barrows, an adult individual currently residing at 1381 Zimmerman Road, Carlisle, cumberland county, Pennsylvania. 2. Defendant is Donna M. Barrows, an adult individual currently residing at 7 pine Road, Apartment 603, Mt. Holly springs, Cumberland County, Pennsylvania. 3. The Plaintiff is the natural father of the children, Gregory A. Barrows, born September 1, 1982, and Holly A. Barrows, born November 24, 1989; The children were not born out of wedlock. For the past five years, the children have resided with the following persons at the fOllowing addresses for the following periods of time. ~ ADDRESS l2An Brent K. Barrows 1381 Zimmerman Rd. 1989 Donna Barrows carliSle, PA Aug. 5, 1996 Brian Barrows Brent Barrows 1381 Zimmerman Rd. Aug. 5, 1996 Brian Barrows Carlisle, PA to present The natural mother of the children is Donna M. Barrows, who resides as aforesaid. She is married. The natural father of the children is Brent K. Barrows, who resides as aforesaid. He is married. \ . 4. The relationship of the Defendant to the child is that of natural mother. Plaintiff is unaware of the individuals with whom Defendant resides. 5. The relationship of the Plaintiff to the children is that of natural father. The Plaintiff currently resides with his children, Brian Barrows, Gregory Barrows, and Holly Barrows. 6. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning custody of the children. 7. Plaintiff has no information of a custody proceeding concerning the children pending in any Court of this Commonwealth. 8. The best interest and permanent welfare of the children will be best served by granting the relief requested because Plaintiff is best able to provide for the children's emotional and physical well-being and provide stability for them. 9. Plaintiff does not know of any person not a party to the proceedings who claims to have custody or visitation rights with respect to the children. WHEREFORE, Plaintiff requests your Honorable Court to grant to him primary physical custody and shared legal custody of the minor children and grant to Defendant partial custody. Respectfully submitted, . GRlFFIE & ASSOCI~ES I fl. II. "i .I,' \ . , , .' I '.~ l., , J ( f . .Anne M. Shepard, Esquire Attorney for Plaintiff 200 North Hanover street Carlisle, Pennsylvania 17013 (717) 243-5551 January 23, 1997, and endlng Sunday, January 26, 1997; the per10ds of custody shall alternate in like fashlon thereafter. b. The noncustodlal parent shall have the first right to exercise child care In the event that the custodial parent is unable to he with the chlldren during hlS or her period of custody. c. Each party is entitled to one un1nterrupted two week period of custody during the children's summer vacation from school. Each party shall give the other at least 30 days notice as to when this two week period will take place. 3. Each party shall notify the other party of his or her work schedule for the following week as soon as it is made available to him or her. 4. The mother and father shall share holidays according to the following schedule: a. The Christmas Holiday shall be divided into two custody periods which will be alternated by the mother and father each year. The f1rst period of custody will be from December 24, at noon until December 25, at noon. The second period of custody shall be from December 25, at noon until December 26, at noon, with the mother having the first custody period in 1997. b. The mother and father shall share Thanksgiving Day at times to be mutually agreed upon by the parties. c. The mother .lnd father shall illternate New Years Day, Easter, Memorial Day, Independence OilY and Labor Day. The perlods of custody for these hOlidays shall be from 7:00 p.m. the ddY before thH tlolulay until 7:00 p.m. the day lOf the holiday, except Independence Day when the period of custody shall end at 10:30 p.m., unless otherwise agreed upon by the parties. 5. Transportation shall be handled in the follOWing manner: a. The noncustodial parent shall be responsible for picking up the children at the time of custody transfer unless otherwise agreed upon by the parties, b. The custody transfers shall take place at the custodial parent's residence, unless otherwise agreed upon by the parties. 6. The mother and father, by mutual agreement, may vary from this schedule at any time. 7, The parties agree to provide each other with reasonable telephone access to the children at all times. 8. Each party shall notify the other Immediately of medical emergencies which arise while the child is In that parent's care. 9. The parties acknowledge that the ra.slng of children when the parties live separately carrles With It special problems and obllgations and each party hereby agrees to cooperate with the other to the maximum extent pOSSible to assure that the best BRENT K.BARROWS, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF . . CUMBERLAND COUNTY, PENNSYLVANIA v. . . . . NO. 96 -6080 CIVIL TERM DONNA M. BARROWS, DEFENDANT CUSTODY CONSENT AGREEMENT This Agreement is entered on this day of 1997, by the defendant, DONNA M. BARROWS, and the plaintiff, BRENT K. BARROWS. The defendant is represented by Joan Carey of Legal Services, Inc.; the plaintiff is represented by Anne Sheppard of Griffie and Associates. The defendant, DONNA M. BARROWS, and the plaintiff, BRENT K. BARROWS, agree to the entry of the following Order regarding custody of their children, GREGORY A. BARROWS, date of birth, September 1, 1982, and HOLLY A. BARROWS, date of birth November 24, 1989: 1. The defendant, DONNA M. BARROWS, hereinafter referred to as the mother and the plaintiff, BRENT K. BARROWS, hereinafter referred to as the father, shall have shared legal custody. 2. The mother and father shall have shared physical custody of the children according to the following schedule: a. The mother and father shall have alternating periods of custody on a four day/three day schedule as follows: the mother shall have the minor children for four (4) days beginning Monday, Janaary 13, 1997, and ending on Thursday, January 16, 1997; the father shall have the children for three (3) days beginning Friday, January 17, 1997, and ending Sunday, January 19, 1997; the mother shall then have the children for a three day period beginning Monday, January 20, 1997, and ending Wednesday, Januar~1' 22, 1997; the father shall then have the children for a four. day period beginning Thursday, January 23, 1997, and ending sunday, January 26, 1997; the periods of custody shall alternate in like fashion thereafter. b. The noncustodial parent shall have the first right to exercise child care in the event that the custodial parent is unable to be with the children during his or her period of custody. c. Each party is entitled to one uninterrupted two week period of custody during the children's summer vacation from school. Each party shall give the other at least 30 days notice as to when this two week period will take place. 3. Each party shall notify the other party of his or her work schedule for the following week as soon as it is made available to him or her. 4. The mother and father shall share holidays according to the following schedule: a. The Christmas Holiday shall be divided into two custody periods which will be alternated by the mother and father each year. The first period of custo~y will be from December 24, at noon until December 25, at noon. The second period of custody shall be from December 25, at noon until December 26, at noon, with the mother having the first custody period in 1997. b. The mother and father shall share Thanksgiving Day at times to be mutually agreed upon by the parties. c. The mother and father shall alternate New Years Day, Easter, Memorial Day, Independence Day and Labor Day. The periods of custody for these holidays shall be from 7:00 p.m. the day before the holiday until 7:00 p.m. the day of the holiday, except Independence Day when the period of custody shall end at 10:30 p.m., unless otherwise agreed upon by the parties. 5. Transportation shall be handled in the following manner: a. The noncustodial parent shall be responsible for piCking up the children at the time of custody transfer unless otherwise agreed upon by the parties. b. The custody transfers shall take place at the custodial parent's residence, unless otherwise agreed upon by the parties. 6. The mother and father, by mutual agreement, may vary from this schedule at any time. 7. The parties agree to provide each other with reasonable telephone access to the children at all times. 8. Each party shall notify the other immediately of medical emergencies which arise while the child is in that parent's care. 9. The parties acknowledge that the raising of children when the parties live separately carries with it special problems and obligations and each party hereby agrees to cooperate with the other to the maximum extent possible to assure that the best interests and welfare of the children are served. 10. The intent of this Custody Order is to encourage both parents to share the rights, pleasures, and responsibilities of child rearing and to maintain a meaningful relationship with their children. 11. Neither party shall do anything which may estrange the children from the other parent, or injure the opinion of the children as to the other parent or which may hamper the free and natural development of the children's love or respect for the other parent. 12. The parties agree that the matter of custody be rescheduled for conciliation conference approximately two months from the entry of this Order. WHEREFORE, the parties request that an Order of Court be entered to reflect the above terms. 1)(\")"')0' f.I \lV1no.\... I~ 9- Donna M. Barrows, Defendant /)J t 6"~,, Brent K. Barrows, Plaintiff ~ ~~,~ , oan Carey I Attorney for Defendant LEGAL SERVICES, INC. a Irvine Row Carlisle, PA 17013 Anne Sheppar Attorney for Plaintiff GRIFFIE AND ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 "" ".:) , . , I, , ~ '.' f;-' 1 . (; 1 ' ....., ' '. I, .' ,. " ij. I 1,'_ - . V ,...... L~' ~,