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Home My WebLink About07-1058 ,. KARA E. DOHRMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LA W JEFFREY P. DOHRMAN, Defendant ; NO. Di- IDSf : IN CUSTODY CIVIL TERM COMPLAINT FOR CUSTODY 1. Plaintiff is Kara E. Dohrman, an adult individual currently residing at 798 Mount Rock Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Jeffrey P. Dohrman, an adult individual currently residing at 298 Mount Rock Road, Newville, Cumberland County, Pennsylvania. 3. The parties are the natural parents of two (2) children, namely, Audra Elizabeth Dohrman, born July 19,1997, and Nathan Aaron Dohrman, born April 3, 2004. The children were not born out of wedlock. 4. For the past five (5) years, or since the children's birth, the children have resided with the following persons at the following addresses for the following periods of time: NAME ADDRESS DATES Kara E. Dohrman 798 Mount Rock Road June 2006 to Carlisle, P A 17013 Present Kara E. Dohrman 298 Mount Rock Road 1996 to Jeffrey P. Dohrman Newville, P A 17241 June 2006 The natural mother of the children is Kara E. Dohrman who resides as aforesaid. She is married. The natural father of the children is Jeffrey P. Dohrman who resides as aforesaid. He is married. 5. The relationship of the Plaintiff to the child is that of natural mother. The Plaintiff currently resides alone with the children. 6. The relationship of the Defendant to the child is that of natural father. Defendant currently resides alone. 7. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning custody of the child. 8. Plaintiff has no information of any custody proceedings concerning the child pending in any Court of this Commonwealth. 9. It is in the best interest and permanent welfare of the child to grant the relief requested because: a) Plaintiff has been and continues to be the primary custodian for the parties' children from the time of their birth through present; b) Plaintiff can provide a stable home for the children; and c) Plaintiff can provide for the day to day needs of the children. " ,- 10. Plaintiff does not know any person not a party to these proceedings who claims to have custody or visitation rights with respect to the child. 11. The parties have reached an agreement in this matter and ask that the Court sign the Stipulation and Agreement, being filed concurrently with the Custody Complaint, as an Order. WHEREFORE, Plaintiff requests your Honorable Court to enter the Order regarding the parties Custody Stipulation and Agreement, which is being filed concurrently with the Custody Complaint. Respectfully submitted, ~"ahJe~~-~~'; E~:tt. .~ Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 .. ;.. VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. DATE: ~,~~- t\l ". ~()dung__ ~ . DOHRMAN, Plaintiff ~ ~ ""'- ~ 0.() \ () 1 ~ ~ AJ . () () ~ ~ --Z::' - f"- eZ n c ~. ~~f; '-7 . -<. N ~ g =- .. -...I --f -:"l I-n ~ ili,~ ~ l-': -1~ -t' v (;~ ~ '-""'..) -'- r"')rn - :'=-1 ... > ~ ~ '". KARA E. DOHRMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW ; NO. 07 - lOr-, CIVIL TERM : IN CUSTODY JEFFREY P. DOHRMAN, Defendant CUSTODY STIPULATION AND AGREEMENT THIS STIPULATION AND AGREEMENT entered into the day and year hereinafter set forth, by and between Kara E. Dohrman, (hereinafter referred to as "Mother") and Jeffrey P. Dohrman, (hereinafter referred to as "Father"). WHEREAS, the parties are the natural parents of two children, namely, Audra Elizabeth Dohrman, born July 19, 1997, and Nathan Aaron Dohrman, born April 3, 2004 (hereinafter referred to as "Children"); WHEREAS, the parties live separate and apart and wish to enter into a Comprehensive Stipulation and Agreement relative to physical and legal custody of their Child. NOW THEREFORE, in consideration of mutual covenants, promises and agreements as hereinafter set forth, the parties stipulate and agree as follows: 1. Mother shall exercise sole legal custody of the children. Mother shall have sole discretion in regards to decisions regarding the children's education, medical decisions, and religious upbringing. Mother will make an effort to inform Father of major decisions and involve him as necessary. ~ . 2. Mother shall exercise primary physical custody of the children. 3. Father shall exercise periods of partial physical custody of the children at times as agreed upon by both parties. 4. Father must have the permission of Mother and the school to see the children at any time during school hours on school property. 5. Neither party shall be entitled to exercise custody of the children ifhe!she do not have proper sleeping arrangements for the children with proper sleeping arrangements being defined as each child having his or her own bed in a room other than with the parent's room. This should not be construed such that each child must have his or her own room, but only that there should be at least one bedroom in the residence other than the parent's bedroom. The children shall always have a room available to them, which they can share free and clear of any other occupants of said room, unless agreed upon by the parties. 6. Should there be a serious illness or medical emergency while the children are in the care of Father, Father shall immediately notify Mother, who shall make all medical decisions. 7. Neither parent shall do anything which may estrange the child from the other party, injure the opinion of the child as to the other party, or which may hamper .-- .-... . ' the free and natural development of the child's love and affection for the other party. 8. Father shall not travel out of the jurisdiction of Pennsylvania without written permission from Mother and Father shall obtain that permission no later than forty-eight (48) hours prior to his scheduled trip out of state. Father shall also provide Mother with a telephone number and address of the location at which he plans to be when he leaves the state of Pennsylvania. 9. It is affirmed that the Court of Common Pleas of Pennsylvania, Cumberland County Branch, had jurisdiction over the issue of custody of the child in this case at the time the proceedings were initiated and, further, by agreement of the parties and Order of Court, the Court has retained jurisdiction over these matters so that it is appropriate for the Court to enter an Order of Court. Further, the parties request that the Court of Common Pleas of Pennsylvania, Cumberland County Branch, enter this as an Order of Court. IN WI1NESS WHEREOF, The parties hereto intending to be legally bound by the terms hereof, set forth their hands and seals the day and year hereinafter mentioned. WI1NESSETH: I' Qb ?!5J2fJ01 d{~OrL~ Dme KARAE.DOHRMAN ... .~-~,..... ~ j? (J4M10/Yl ~;~/J 3<M7 ~.. ..~:DOHRMAN /. Dak J. .. ,.,---' --.. - . COMMONWEAL TH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this cJ?L4 day of officer, personally appeared the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. No lAIfA&. lEAl -ANY. FlflOS ~--~c~ _C---~.,on..... New 3,2010 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this l~ day of ~~~ , 2007, before me, the undersigned officer, personally appeared JEFFREY P. DOHRMAN, known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. q WI. OA <M_~ Q.~\ ~ otary Public N01'MIM.1EAL USA.fII MIG....... MnMYPUaIC CARUSLE BOROUGH, CUMBERLAND COUNTY flV COMMISSION EXPIRE8 AUG. 20, 2009 >"l~ }N,,.tewt ~(\ 1'*,1 . ...",,.1;\ ,.....t,,") . ,'Cl,oM ~ 'J' .. 1" '...01' ; ...;;)UOlIOI ..- ..,""'U., , v.....;,,~.... atlmmo:J...-_ ,. . . ..~1 '.W~.J f'Ot O~.!~ ' ....' .... o ~ l..'l~~' 9;1.; (-1; r~' ...- ':; ~ ;;..;.)-....::.._.> ~;~ -< G:!~AV~,. Hl'JAlWl!m"~Jim~_'_l JAB JAlRATOM ' . t7t.tmttt VRAT~M ,~AJHtlIH ~A ~~u 1 ,YTWJO:) l'HiIA.JR3AMb:) .H')tlCflQ~ j J,Jt'lA''l, l' r"""t'~f." ~H' ,,:Jp....1.i3 ,~(\~~, :n:'.'01 ," ~ ! . ..._",.,..._;': " ~~..'-~.,.;.~....V.~~~:..~""::""':'~'__..~>...~~_~,;..,., '..... ... t f">-) = (~ -.... -'Tl fTl OJ N -.I (:) It ~ m~ 3J.p:j 6,1 :~1.~ "5-'1 '-.,..0 (:> rn --1 1> :0 -< -0 :x .+;.' -.... - ' lED J 8 200~ f'y KARA E. DOHRMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW ~ NO. 67.. I(J r-P : IN CUSTODY CIVIL TERM JEFFREY P. DOHRMAN, Defendant ORDER OF COURT AND NOW, thisAday of~, 2007, the attached Custody Stipulation and Agreement is hereby made an Order of Court. BY THE COURT, u J. ~frey P. Dohrman Pro Se ~ cc: ~ah Herman-Snyder, Esquire Attorney for Plaintiff >- 0:: ~ W.JC ~t ~~~) :::I 0: r-:- lU u...:c I- u_ o .~ ('.J 0:J .ci- a.. tJ') I cr. ne.: :c r-- = = c-..., ;.1 "':"" ...~::: ::J (.)