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HomeMy WebLinkAbout00-00235 . " . , . Kristy A Gouse, Plaintiff : I N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v, : No~ -::J.~t:: Civil Term Jeremy M. Gouse, Defendant : CIVIL ACTION - LAW : CUSTODY ORDER OF COURT AND NOW, this /'1 r~ day of .Ja..._-; ,2000, upon agreement of the parties, the attached Custody Stipulation and Agreement is hereby made an Order of Court. BY THE COURT, J, "' ,'. '. i!;" JAN132~ _"-lP;lll_~lilit,'H HiliIUlDl !n~l ~~~:ii-~ A. r~-"",,K~"""i_' I"i' C:[J.4];;CIf'E ,1,-1." "; II'J... (1;: '1'_['. ')'lnTcl(!~nu"'A!RY .,.-, , i ,- ;.,~. _ _ '''''' If'\j 00 J~N 14 Pi'i 2: 34 CUMSE;RLiWD COUN1Y PENNSYLVANiA II _ III ,~~_ ., "'~ '"v._ ,-,-.,. .........- " ~ I, . "':'- "'''. ,~ Kristy A. Gouse, Plaintiff v, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . ) : No. .2.uvv - ./3:> Civil Term Jeremy M, Gouse, Defendant : CUSTODY CUSTODY STIPULATION AND AGREEMENT Made by and between, Kristy A. Gouse, hereinafter "Mother, and Jeremy M. Gouse, hereinafter "Father". WHEREAS, the parents have a child, namely: Name Ramiel D. Gouse Date of Birth 9/2/98 hereinafter "child"" and WHEREAS, the parents wish to enter into an agreement relative to custody, partial custody and visitation of the child: and NOW THEREFORE, the parents agree as follows: I. Mother and Father shall have shared legal custody of the child, meaning that they shall share the legal right to make major decisions affecting the best interest of the child and all of the major matters related to the child, Including, but not limited to, medical, religious and educational decisions. 2, Mother shall have primary physical custody of the child, meaning that this person shall have actual physical possession and control of the child for a majority of the time. - , - --~-'. ,'" , , , .,>-, -, . . Gouse Custody Stipulation and Agreement Page Two 3. The Father shall have partial physical custody ("Partial physlcal custody" means the Father shall have the right to take possession of the child away from the other parent for a certain period of time) as follows: a. ALTERNATING WEEKENDS: From Friday at 6:00pm through Sunday at 6:00pm, beginning Friday, January 22, 2000. b. CHRISTMAS: Alternating each year, from Christmas Eve at 6:00pm through Christmas at 6:00pm, beginning with the Father on December 24, 2000, c. HOLIDAYS: Mother will have physical custody of the child for every New Years, Easter and Memorial Day, Father will have physical custody of the child for every 4th of July, Labor Day and Thanksgiving, d. MOTHER'S DAY IF ATHER'S DAY: The Mother sha 11 have physlcal custody of the child every year on Mother's Day and the Father shall have physical custody of the child every year on Father's Day, e. CHILD'S B1RltlDAY: The parties shall equally share having custody of the child on his birthday each year. f. SUt1t1ER VACATION: Mother agrees to giving the Father the option of having custody of the child for one week during the summer, with the specific schedule to be arranged by agreement of the parties. 4. Neither parent shall do anything which may estrange the child from the other parent or injure the opion of the child as to the other parent, or which may hamper the free and natural development of the child's love and affection for the other parent. 5. Neither parent shall consume alcoholic beverages or unprescribed controlled substances (drugs) whlle the child is in their care, - . ' . . ~ / .: ~.' ~ .< Gouse Custody Stipulation and Agreement Page Three 6, Each parent agrees to provide the other parent with an address and telephone number through which the parent may be contacted during periods of cusody of the child, Each parent further agrees to inform the other parent of any medical emergencies that arise while the child is in the parent's care. 7. The parents agree and desire that this agreement be made an Order of Court of Common Pleas of Cumberland County, Pennsylvania. IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms hereof, request this Court to enter an order to reflect the above terms, DATE: ~A.I().2dY(} o . ~JG ~o , Mothe. . DATE: 11/0/00 ~n~'YY\~ Fer: ~~IlllM~Iill~IjlIIU"' ~ .,~~."" .-"" "'~--- ~~, -..~.~.. '.',..,';" ~ ""', " ~~ - ~ -. ~ " - , , .' ~ " ,\ 6 0 ~ c 0 .~ t.... --{ -UOJ :po ::r: ~r.;J Z nl~ Z~' -o-rn u>5;; N ~lJ? -<L._ ")0 kO -0 -<,.. ~o ~ x:J:j - Q~ $0 ~ ....:.. C 0 ~ w ~ 0 -< - ~ _L_ ~- -rlliiz} , ~ .. ~'s..J'f f) . (l0W;~ vc ~coo -~).S CUt C7~flJ J~1 fYl. ~c YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AG}\II\IST THE CLAIMS SET,.' FORTH IN THE FOi.LOWING, PAGES, YOU MUST T~E ,p.CTION WITHIN 'l'WEN'l;Y(20.), DAYS AFTER THIS COMPLAINT AND NOTICE AfU;:iSF:~VED" BY ENTERING ~AWRI'l'TENAPPEJi'IlANCE 'PERSONALLY ORay AN A'l"l'ORNEY AND FILING IN WRI'l'II'fG wlm.'i'HE COURT YOUR DEFENSES OR OBJECTI()NSTO THE CtAIHS SET FORTH AGAINST YOU. OU ARE WARNED THAT IF YOU FAIL TO 00 SO THE CASE HAY PROCEED W -HOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU B~ THE COURT W T~OU~ FURTHER NOTICE FOR ANY HONEY CLAIMED IN THE COMPLAINT OR R ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU' Y LOS!.': MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. ,I ~ .' YOU SHQULD TAKE THIS PAPER ~ YOUR LAWYER' AT ONCE. IF NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO THE TF.LEPHONE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL YOU 00 OR THE HELP. / a.MBERLAND CXXJNTY BAR ASSOCIATION 2 LffiERl'Y AVENUE CARLISLE PA 17013 717 249 3166 J . , ,. i >>'~" .' " 1.""_,,1.,,,____' "'" ~: .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA KRISTY A GaUSE Plaintiff : No. c2mrt). ;2.'>,., ~ 1,J.b- : Civil Action - Custody JEREMY M, GaUSE Defendant COMPLAINT FOR CUSTODY 1. The Plaintiff is Kristy A Gouse, an adult individual, sui juris, who resides at 341 Gettysburg Pike, City of Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania, 17055, 2. The Defendant is Jeremy M. Gouse, an adult individual, sui juris, who resides at 104 W, Green Street, City of Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania, 17055. 3. Plaintiff seeks custody of the following children: Name Present Residence Age Ramiel D. Gouse 16 months (9/2/98) 341 Gettysburg Pike Mechanicsburg, PA 17055 4. The child was born in wedlock. 5. The child is presently in the custody of Plaintiff. 6. During the past five years, the child has resided with the following persons and at the following addresses: Person Krlsty & Jeremy Gouse Address 115 W. Portland Street Mechanlcsburg, PA Dates Birth to 7/99 - I - lJij~~' ... I ~~ ~-- ,r llilIR!i, '" Kristy Gouse 444 W.Main Street Elizabethville, PA 9/99 to 11/99 Kristy Gouse & Parents 341 Gettysburg Pike Mechanicsburg, PA 7. The mother of the child is Krlsty A Gouse, 11/99 to Present 8, She is married. 9. The father of the child is Jeremy M. Gouse. 10. He is married. 11. The relationship of Plaintiff to the child is that of biological mother. 12. The Plaintiff currently resides with the following persons: Name Ramiel D. Gouse Relationship Son Donald & Rosemary Michels Father & Step-Mother 13. The relationship of Defendant to the child is that of biological father, 14. The Defendant currently resides with the following persons: Name Jennifer L. Walker Relationship Female Friend 15. 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. 16, Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth, -2- -.. f - . - ' __ "' ,'I'~ - -. ' ~, - - -,~ / , . 17, Plaintiff does not know of a person not a party to the proceedings who has Physical custody of the child or claims to have custody or visitation rights with respect to the chl1d. lB. The best interest and permanent welfare of the child wfll be served by granting the relief requested because: a. Since the birth of the child, Plaintiff has provided and continues to provide a stable living environment. b. Plaintiff has been the primary custodian and caregiver of the child since birth, c, Plaintiff has maintained a relationship with the child that has provided a sound and stable envIronment for the physical, intellectual, emotional and spiritual well being of the child, d, Plaintiff has maintained the child's contacts with extended family, friends and other care providers. 19, 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. All other persons named who are known to have or Claim a right to cusody or visitation of the child will be given notIce of the pendency of thIs action and the right to intervene: Name NONE Basis of Claim Address WHEREFORE, PlaintIff, Krlsty A Gouse requests the court to grant her custody of the chi Id. Respectfully Submitted, by: ,~4. ~IJ, Kristy A Gouse 341 Gettysburg Pike Mechanicsburg, PA 17055 (717) 796-9939 KAG/rcm -3- ~ y - ~.~ . . ~ YERIFICATlOtL I verify that upon personall<nowledge or information and belief 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. - 4904, relating to unsworn falsification to authorities, 4A~~. Plaintiff Date:r /O/}Sk)('j ill Ill. . b, ~~ '"~~""''''T:- 1lHim~~ -~... , ~ijpJ!T.T,," ,.', " - fi1l,9;[1J!EL:H-., "__""""" ;_iL,_,4')~,:lL[L, '.' ", ~ ~~~-~ ~~ 'i!I~~~ ." , , ",[1..1. '" "~'_ ~"',"'" ."._,' , -- ' """""""""'~' ~ -.......... ,." - ~ ,'.........."".... ' .- - .~ " ~~ ~ ~ 8 h h~ ~ . 8 a (J 0 ~ (;., 0 0 ~ ., ...() I C 0 s: . ~ G f! fRrD ~ '-. ~ :t~ ("ii ;;e in 2-"1 2~ ~g: o.;~,. N <-. () -. ". -"" 1~---; =--~ ' ~.- -V :0;:'-' ...., $0 :3:: Qii .... ~ ;Ji;O ~ i5 ., ~ w ~ c -< "