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Home My WebLink About00-01855 JEFFREY L. PRINDLE and JODI L. PRINDLE, his wife Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY PENNSYLVANIA : CIVlL ACTION - LAW vs WILLIAM C. LOUTHIAN ReANNA K. LOUTHIAN, his wife, Defendants NUMBER: 2000;Zss CIVIL TERM CUSTODY ORDER AND NOW, this 2it!iay ofrl12Jc.~, 2000, upon consideration of the within Motion, Stipulation, and Complaint, it is hereby Ordered as follows: 1. That full physical and legal custody of JESSE CHARLES LOUTHIAN, born April 14, 1999, shall be in his Custodial Parents, JEFFREY L. PRINDLE and JODI L. PRINDLE. Said Custodial Parents shall have full authority to obtain health insurance coverage for the child, to enroll the child in a school within their school district, and to authorize all medical treatment. 2. That the natural parents of the minor child, WILLIAM C. LOUTHIAN and ReANNA K. LOUTHIAN, his wife, shall have such rights of visitation from time to time as the parties shall agree. ii,,- ," ,_._. _ >"~'''__'"'_~_''_ .~"',_. <<"_,ry-_'_, ",_~".,.., _~,~~~"', ~_ _ '"'-' -"~,,.,,-<-,,_. ._-^' - ,,",=,"p, -" "" - 'l;j lfiN\i^lASj\!N3d I 'NI"1nr) 0i\!'c('li-POlw,'...., l\J.. ,j~. ,", '_."..' ."_ _Jl,.~ 'oj I\,,) , 7 II' 6"' 'I~'j ",n t']:" "'e] ((, (j,,,,,Ud AHiJ. ()/:' :!i) ~~~ :1-:-:Ct-{'E.:-1U ,I . , 'u~.-" "'. '.u""" , \~I::, ,-- ~, ~ '-~""' .-- ~-~ ~~ ,- \l!fl" ,.,.._,,11I. <'~ 3. That the Court of Common Pleas of Cumberland County, Pennsylvania, shall assume and maintain jurisdiction over the issues of child custody in this case. BY THE COURT: ~~_J' '<, _,~,~_.c"_,__~____", ,. _ _-<"', ,~ - - - - . - -~~ ,- JEFFREY 1. PRINDLE and JODI 1. PRINDLE, his wife Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY PENNSYLVANIA : CIVIL ACTION - LAW vs NUMBER: 2000-1f55'CIVILTERM WILLIAM C. LOUTHIAN ReANNA K. LOUTHIAN, his wife, Defendants CUSTODY MOTION NOW COME the Plaintiffs, JEFFREY 1. PRINDLE and JODI 1. PRINDLE, by and through their attorney, Charles E. Petrie, and respectfully represents as follows: 1. That Plaintiffs are JEFFREY L. PRINDLE and JODI 1. PRINDLE, adult individuals currently residing at 20-B Cassatt Street, Enola, County of Cumberland, Pennsylvania. 2. That Defendants are WILLIAM C. LOUTH IAN and ReANNA K. LOUTHIAN, adult individuals currently residing at Lancaster County Prison, County of Lancaster, Pennsylvania. 3. That Plaintiffs are the Custodial Parents and Defendants are the natural parents of a minor child, JESSE CHARLES LOUTHIAN, born April 14, 1999. 4. That the parties have entered into a Stipulation concerning the matters of custody and visitation with respect to the minor child, and the said Stipulation is attached hereto. I I I i I I \1, " - '_""'"~",_^,, __!-'~,._.","",-,7.-, '<'"-_~_ ." ,-5 _.'. _ ',,~_ -"q", .'." --,-~,-,,-, .-, ~~ 5. That the parties desire that said Stipulation be entered as an Order of Court. WHEREFORE, Plaintiffs respectfully request that Your Honorable Court enter an Order pursuant to the attached Stipulation. Respectfully submitted ft~~&~ CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiffs n ~ ~""',,",,,,~,-r-""-__, ~ ,~",-,., '_""'""""-'>.""'_,.<,'" "'.' ". JEFFREY 1. PRINDLE and JODI 1. PRINDLE, his wife Plaintiffs vs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY PENNSYLVANIA : CIVIL ACTION - LAW NUMBER: 2000 - / t5<f CIVIL TERM WILLIAM C. LOUTH IAN ReANNA K. LOUTHIAN, his wife, Defendants CUSTODY COMPLAINT FOR CUSTODY NOW COME the Plaintiffs, JEFFREY 1. PRINDLE and JODI 1. PRINDLE, his wife, by their attorney, Charles E. Petrie, and respectfully represent as follows: 1. Plaintiffs are JEFFREY 1. PRINDLE and JODI 1. PRINDLE, his wife, who currently reside at 20-B Cassatt Street, Enola, County of Cumberland, Pennsylvania. 2. Defendants are WILLIAM C. LOUTHIAN and ReANNA K. LOUTHIAN, his wife, who currently reside at Lancaster County Prison, Lancaster, County of Lancaster, Pennsylvania. 3. Plaintiffs seek to have rights of full physical and legal custody with respect to JESSE CHARLES LOUTHIAN, born April 14, 1999. The child was not born out of wedlock. The child is presently in the custody of Plaintiffs, JEFFREY 1. PRINDLE and JODI 1. PRINDLE. ~_.'-".~,,,,"o,,.,,',,,.-" _ ,''-. _~",,""'" ,'''_ __,,~",,~_ "' .~" .', - ,~-~, "--, -. -~, - " " - ~, -' -" ,,,, - Since birth the child has resided with the following persons and at the following addresses: From birth until January 29,2000, with Defendants in Lancaster, Pennsylvania; from January 29,2000, until the present with Plaintiffs at 20-B Cassatt Street, Enola, Pennsylvania. The mother of the child is ReANNA K. LOUTHIAN, who currently resides at Lancaster County Prison, Lancaster, Pennsylvania. She is married. The father of the child is WILLIAM C. LOUTHIAN, who currently resides at Lancaster County Prison, Lancaster, Pennsylvania. He is married. 4. The relationship of the Plaintiffs to the child is that of Custodial Parents. The Plaintiffs currently resides with the child. 5. The relationship of the Defendants to the child is that of natural parents. They currently reside in Lancaster Prison. 6. The Plaintiffs have not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or in another court. The Plaintiffs have no information of a custody proceeding concerning the custody of the child in this or in another court. c "~-''^ <-ce, 'c::-~-^::'~-"-~-" y,"~' _,~,_ .''.,'!.,_'c- . -,'-'::"'-',,-" ",,,",,", . - . u.>. ...~ - - --~ Plaintiffs do not know of a person not a party to these proceedings who has physical custody of the child or who claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by confirming rights of full physical and legal custody in Plaintiffs. 8. Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the child have been named as parties to this action. 9. The parties have entered into a Stipulation, attached hereto, setting forth their agreement concerning custody of the minor child. WHEREFORE, Plaintiffs request the Court enter an Order confirming rights of full physical and legal custody in Plaintiff. Respectfully submitted, /' ...4- ~ 1:_ ~ CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiffs ~_,c c '-'." ~, _'c." -- ., .-, 'k ,_, "" _,"_~ ~"_., ,,___ _"- ~,' , -~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN Upon information and belief, I verify that the statements in the foregoing Motion and Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. O~-.2I-ao DATE ~~,...(~ CHARLES E. PETRIE, ATIORNEY FOR PLAINTIFFS . ,----,~ '"'.' ',' - -~-- - . JEFFREY L. PRINDLE and JODI L. PRINDLE, his wife Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY PENNSYLVANIA : CIVIL ACTION - LAW vs NUMBER: 2000./yG5' CIVIL TERM WILLIAM C. LOUTHIAN ReANNA K. LOUTHIAN, his wife, Defendants CUSTODY STIPULATION AGREEMENT, made this day of March, 2000, by and between WILLIAM C. LOUTHIAN and ReANNA K. LOUTHIAN, his wife, hereinafter referred to as "Natural Parents;" and JEFFREY L. PRINDLE and JODI L. PRINDLE, his wife, hereinafter referred to as "Custodial Parents;" WITNESSETH: WHEREAS, Natural Parents are the biological parents of a minor child, JESSE CHARLES LOUTHIAN, born April 14, 1999, and WHEREAS, the parties have reached an agreement concerning the issues of custody and visitation with respect to the minor child, and said agreement is set forth in the Stipulation executed by all of the parties and attached hereto; and WHEREAS, the parties desire that this Stipulation be entered an Order by the Court of Common Pleas of Cumberland County, Pennsylvania; NOW, THEREFORE, intending to be legally bound, the parties hereby agree as follows: ,'o~ ",_'i'-'~- " ,.,_ "=N_O,~"'T__~,'C~~,,.,_ ", - _~",,^, 'd'-""''_.' -'''IC-__'",-, "d'" '. .,. " I k- ",' "~ 1. That full physical and legal custody of JESSE CHARLES . LOUTHIAN, born April 14, 1999, shall be in his Custodial Parents, JEFFREY L. PRINDLE and JODI L. PRINDLE. Said Custodial Parents shall have full authority to obtain health insurance coverage for the child, to enroll the child in a school within their school district, and to authorize all medical treatment. 2. That the natural parents of the minor child, WILLIAM C. LOUTHIAN and ReANNA K. LOUTHIAN, his wife, shall have such rights of visitation from time to time as the parties shall agree. 3. That the Court of Common Pleas of Cumberland County, Pennsylvania, shall assume and maintain jurisdiction over the issues of child custody in this case. IN WITNESS WHEREOF, the parties have hereunto set their hands =d ~aJ, tho day and yea, lIT,' abOVO~ /' ~ i~~ WILLIAM C. LOUTHIAN Hd~ WITNESS Ukt/%~) ReANNA K. LOUTHIAN ~a-1{~ &l ,p~~ J Y L. PRINDLE jb~ ,\c , ~ cR.~~Ju J I L. PRINDLE ...".... . ..................... '.0 ." '.' ..... .... " .. , C) C) C1i c: i.::'::' --;--; s: ~:.. -0 tJ; ."" rnt'j'j ~.;; Z:U ;~ Z J~: i'.) ~ CD .......J '"~- -< .-1:.- (L, r::O -n 'j' ~ ~" " $;C n.'" 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