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HomeMy WebLinkAbout00-02855 ~ , - -" . I;- ~" ,," ,'_,_ , .-; - Becki 1. King, Plaintiff : IN THE COURT OF COMMON PLEAS OF vs. : CUMBERLAND COUNTY, PENNSYLVANIA : 00' ~'iJ5S : NO. CIVIL TERM Braden R. King, Defendant : PR8+ECTION FReM ABUSE AND NOW, this ~day of CUSTODY ORDER Hay, 2000, the following Order is entered by consent of the parties with regard to custody of the parties' children, Taylor King (DOB 3/24/91) and Noah King (DOB 7/15/96) . 1. The Plaintiff, hereinafter referred to as the mother, and the Defendant, hereinafter referred to as the father, shall share legal custody of the children. 2. The father shall have primary physical custody of the children. 3. The mother shall have partial custody of the children according to the following schedule: a) Every other weekend beginning on February 12,2000, from Friday at 5:00 p.m. until Sunday at 7:00 p.m. b) Every Wednesday from 5:00 p.m. until 8:00 p.m. c) Other mutually agreed upon dates and times. 4. Custody exchange shall occur at the father's residence where the mother shall drop-off and pick-up the children. The mother has the option to bring a third party along for the custody exchange. 5. The parties shall alternate the following holidays from 9:00 a.m. until 8:00 p.m.: New Years, Easter, Memorial Day, July 4th, and Labor Day. The mother shall commence the schedule having the children on Easter 2000. -;1;')-~_,,:;:}"':;';t;\~~ " . ,_~ "0 C' _- Oliol_ 6. The parties shall share the Thanksgiving Day holiday with the mother having the children from Wednesday at 2:00 p.m .until Thanksgiving Day at 2:00 p.m. and the father having the children from Thanksgiving Day at 2:00 p.m. and for the remainder of the day. 7. The father and mother shall alternate the Christmas holiday with one parent having the children for Segment A, from Christmas Eve at noon until Christmas Day at noon, and the other parent having the children for Segment B, from Christmas Day at noon until December 26th at noon. The mother shall have the children for Segment A and the father for Segment B in 2000 and even years thereafter, and the father shall have the children for Segment A and the mother for Segment Bin 2001 and odd years thereafter. 8. The mother shall have the children on Mother's Day and the father on Father's Day from 9:00 a.m. until 7:00 p.m. 9. The mother shall have the right to partial custody of the children for 3 weeks including weekends of each summer. The mother shall give the father two weeks notice as to when her periods of summer custody will take place. 10. Both parties shall continue with their scheduled counseling sessions unless the counselor recommends otherwise. 11. Neither party shall drink alcohol in excess while the children are in that parent's custody. 12. The mother and father, by mutual agreement, may vary from this schedule at any time, but the Order shall remain in effect until further Order of Court. 13. There shall be reasonable notice given to the other parent if a scheduled period of custody needs to be canceled or modified and a make-up period shall be offered within a reasonable time frame. 14. The mother and father agree that each shall notify the other immediately of medical emergencies which arise while the children are in that parent's care. "< -"';," 15. 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 e other parent. ~6_I()-OO R~ BY THE COURT, This Order is entered pursuant to (he consent of Plaintiff and Defendant: ~ I - ,.""".<f...,~../ /-.,~::=~:i;:~~~~6) 141 East North Street Carlisle, PA 17013 Joan Carey, Attorney Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 TRUE COPY FROM RECORD In Testimony whereof, I here u"to set my hand and the seal of said Court at riisle, Pa. Tr.y,..lc2.....,:v" or... ,...., 9ft ~xu.J.~.JdIL~~;y-,..MT ~ '-'r Ioili!li" ~~- >','" , -~" ,~..." ,~-" ~i~iill~ :itM~ , _,~,"" 1 ,-,,<,-: "':':JMaJW:Lil&Il '-<llllloJ ~ - '"~ C) C <- -elei; fTln1 Ii Z =< ;;.,."..,,~-,~~-~ "'1 o (.;:) :!!: ':~ '...: I co q -:;:I ;;:J;; ,., '''p::i '-'''In' ;i{Cj:l ~~;t~ <5:D 20 (Sin ...... ~ ""0 .~" "'""'''' j::-' (n tIi ,- '-~---,' '-;"'--,,,';';;:, lL : IN THE COURT OF COMMON PLEAS OF Becki J. King, Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. -!J.D- 2. Ss'/ CIVIL TERM Braden R. King, Defendant CUSTODY COMPLAINT FOR CUSTODY I. The Plaintiff and Mother of the children is Becki J. King, who resides at 1875 Reservoir Drive, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant and Father of the children is Braden R. King, who resides at 141 East North Street, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff seeks custody of the following children: Name Present Residence Age Taylor R. King 141 East North Street, Carlisle 8 Noah J. King 141 East North Street, Carlisle 3 The children were not born out of wedlock. The children are presently in the custody of the Defendant. During the children's lifetime, they have resided with the following persons and at the following address: Name Address Date Plaintiff and Defendant 141 East North Street, Carlisle 1991 to Oct. 1999 , '~ ",,;:.., ,,",--" ",'':' ,,:';',-_'.'0 "_'"'.. ,_ ~. " Defendant 141 East North Street, Carlisle Oct. 1999 to present The Plaintiff and the Defendant are currently married to each other, but separated. 4. The Plaintiff currently resides with the following persons: Name Ronald Shughart Adam Shughart Relationship Friend Friend's son Rhiarmon Hall Daughter 5. The Defendant currently resides with the following persons: Name Relationship Taylor R. King Son Noah J. King Son 6. The Plaintiff requested temporary custody of the children through a protection from abuse action in the Common Pleas Court of Cumberland County at docket number 00-483. Judge Oler denied this request. 7. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 8. The 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. 9. The best interest and permanent welfare of the children will be served by granting the relief requested and agreed to by both the Plaintiff and the Defendant in the attached Consent Order signed by both parties. .'- - --i ~,' 10. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, the Plaintiff requests this Court to: (1) grant her partial physical custody and shared legal custody of the children in the manner specified in the attached Consent Order signed by the parties. Respectfully submitted, ~,~ Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 .. _ . -..." , "~' '"r,-~ _f --', VERIFICATION I verify that I am the Plaintiff as designated in the present action and that the facts and statements contained in the above Custody Complaint are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. Dated: ,"r- L/ ~OO . /~~~.(/ -,;< -~ ," -;.., "';"''il:~'; : IN THE COURT OF COMMON PLEAS OF Becki J. King, Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. - CNIL TERM Braden R. King, Defendant CUSTODY CERTIFICATE OF SERVICE I, Joan Carey, Esquire, hereby certify that on May ~ 2000 I served a copy of the foregoing Custody Complaint and the Consent Order, in the above-referenced case on the Defendant Braden R, King by mailing a copy of same addressed to him at 141 East North Street, Carlisle, P A 17013 via first class mail, postage prepaid. Joan Carey, Esquire Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 . ~iiliiW___If5II~~jt.j~, -rf'~;'<i~-_" .. =~'""-"'w-.~~I ,-, C5 '''0 ~. -",. a " ..J ~,-,:n ',' r- :TI9~ 0,.... ",-l"::...-J: -1- n ~:-- :J] '.c?O tyn ~ '< ~ \J;: 9' ~ ~ C) ~:.; -vcr; n1\,"l --7--"-" ,0::- _-'~" :~~; !:Ceo :I; () ~:~ z _...~ -< 3~ T:tJI =< I CO ,;:- <.11 ->:1' ~~ \" ~;->u~ "<~ ~~~ , ~"'~' ,0 ,"~_, - ,~"" ",_" h" -," - ,., ~ BECKI J. KING Plaintiff IN THE COURT OF COMMON PLEAS OF v. CUMBERLAND COUNTY, PENNSYLVANIA NO. 00- ~5S CIVIL TERM BRADEN R. KING Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Beeki J. King, Plaintiff, to proceed in forma pauperis. I, Andrea Levy, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. c2LQ Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 n "-:1 0 j r:.:: :_.:.1 'T1 --;;-:"" , :",;.1 , " I ,-.,..- " -,.~ ;"', ,:;q L '~ ~:,~t3 , ""c. I (i , c:) - ~;,~,~~{ r '0 r .... (:-5 ~,., I m-l'5 tv 6rn f :< ~ --j .- ,:0 -< en -< ~ ' ,', ,"~-, , .,,,, ,'~, ,,~___,;, -_ ,.-,_'}_' v > ,_: ., 'h BECK! J. KING, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. BRADEN R. KING, : NO. 00- CNIL TERM Defendant AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am the plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the inforrnation below relating to my ability to pay the fees and costs is true and correct. (a) Name: Been J. King Address: 1875 Resevoir Drive Carlisle. PA 17013 (b) Social Security Number: 192-56-0766 If you are presently employed, state Employer: CPARC Address: 117 North Hanover Street Carlisle. PA 17013 Salary or wages per month: $1159 (net) Type of work: Residential supervisor If you are presently unemployed, state Date of last employment: Salary or wages per month: Type of work: (c) Other income within the past twelve months Business or profession: N/A Other self-employment: N/A Interest: N/A Dividends: N/A Pension and annuities: N/A Social Security benefits: NIIA Support payments: N/A Disability payments: N/A Unemployment compensation and supplemental benefits: NI A Workman's compensation: N/A Public Assistance: N/A Other: N/A (d) Other contributions to household support (Wife)(Husband) Name: If your (husband) (wife) is employed, state Employer: Salary or wages per month: Type of work: ',._,,_ - u" '~-.,,-,,' -,-"- -, '-- " ,- 11"-; ~ ,~ - ~' " ~'. ~'_~n_ _ 0,' '~ ',_ J-__' _'" ~L, '-I I:' Contributions from children: Checking Account: N/A u i: I. I i: i' I " !: (e) Property owned Cash: $22.00 Savings Account: $84.00 Certificates of Deposit: N/ A Real Estate (including home): yes *in foreclosure Motor vehicle: Make Volkswagon Fox Year 1991 Cost $1500.00 Amount owed $0 Stocks; bonds: N/A Other: N/A (t) Debts and obligations Mortgage: Rent: $2oo/month Loans: N/A Monthly Expenses: Child supoort $480: Groceries $80.00: Telephone $15.00 Car insurance $45.00: Clothing $75.00: Gas $40.00: Miscellaneous exoenses $10.00 (g) Persons dependent upon you for support (Wife) (Husband) Name: Children, if any: Name: Rhiarmon Hall Age: 16 years Ui . ~ "_ ,_ ,~." " '''. -, o__"'_~_-) j , '~ !- 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit 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. I Date::;=: '1~O() , i: , '~= ..... ,~ ~'ti"'._~l!l~W~I...l!IIi,...~~.A~..iilL 'f''"~fill/li:j ~,~.~, " ~ ",",' " ~-, "., 0 C) 0 C C) ~'rJ~ ~T1 3: ::;::1 IT'r.,.-, .~ t~~ '"'" F1'; :JJ I ' .- ~Q~ CO .--1- 0 <-\..~) -"tJ -~I :.J ~~R ::r:-r, '~- ":n ~ ':J "::-,..0 :C>c~ ""'m 0 ~ ::- ~ <- -< ~