HomeMy WebLinkAbout02-6002KENNETH H. BAER,
PAMELA S. BAER,
Plaintiff :
:
;
..
:
Defendant :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. Oi,~.-
IN CUSTODY
COMPLAINT IN CUSTODY
AND NOW, this/?~- day of ~)~-~-t~ .~_f._~ ,2002, comes the Plaintiff, Kenneth
H. Baer, by and through his attorney, Andrew C. Spears, Esquire, of the law firm of Metzger,
Wickersham, Knauss & Erb, P.C., and files the within Complaint of which the following is a
statement:
1. The Plaintiff, Kenneth H. Baer, is an adult individual currently residing at 4 West
Main Street, Apartment 2, Newville, Cumberland County, Pennsylvania, 17241.
2. The Defendant, Pamela S. Baer, is an adult individual currently residing at 10364
Possum Hollow Road, Shippensburg, Cumberland County, Pennsylvania, 17257.
3. Plaintiff seeks primary physical custody and shared legal custody of the following
minor child:
child.
Sallie
David H. Bear
Present Address Date of Birth
10364 Possum Hollow Road 05/30/1991
Shippensburg, PA 17257
Plaintiff and Defendant are the natural parents of the above mentioned minor
The minor child were born in wedlock.
Document Ii246386
VERIFICATION
I, Kenneth H. Baer, verify that the statements made in the foregoing Complaint for
Custody are true and correct to the best of my knowledge, information and beliefi I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to
unsworn falsification to authorities.
Dated:
Kenneth H. Baer
Document #246386
CERTIFICATE OF SERVICE
I, Andrew C. Spears, Esquire, of the law firm ofMetzger, Wickersham, Knauss & Erb, P.C.,
hereby certify that I served a tree and exact copy of the Complaint for Custody with reference to the
foregoing action by first class mail, prepaid, this ~ day of ,2002, on the
following:
Pamela S. Baer
10364 Possum Hollow Road
Shippensburg, PA 17257
Andrew C. Spears, Esquire
Document #246386
December 17, 2002
Curt Long, Prothonotary
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
SINCE 1888
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
717-238-8187
Fax: 717-234-9478
Other Offices
Colonial Park Mechanicsburg
717-652-7020 717-691-5577
Millersburg Shippensburg
717-692-5810 717-530-7515
Re: Kenneth H. Baer v. Pamela S. Baer
Dear Mr. Long:
Enclosed for filing please find the original and four (4) copies of the Complaint in Custody in the
above matter. Also enclosed is a check in the amount of $110.50 in payment of your filing fee.
Please file and docket the Complaint in Custody. However, in lieu of scheduling a custody
conciliation, please enter the Stipulated Custody Agreement (original and four (4) copies
enclosed) reached by the parties after you have entered the Complaint in Custody. Please
forward it to the appropriate Judge for signature.
Kindly stamp the copies of both documents, mail one copy of the Complaint and one copy of the
Agreement to the Defendant in the stamped, addressed envelopes provided, and return the
additional copies of the Complaint and Stipulated Custody Agreement to me in the enclosed
self-addressed, stamped envelopes. Thank you.
Very truly yours,
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Andrew C. Spears
ACS:cl
Enclosures
cc: Pamela S. Baer (with enclosures)
Document #: 246952.1
James E Carl
Edward E. Knauss, IV*
Jered L. Hock
Steven P. Miner
Clark DeVere
Francis J. Lafferty, IV
David H. Martineau
Andrew W. Norfleet
Melissa L. Van Eck
Andrew C. Spears
Young-Suh Koo
* Board Certified in civil
trial law and advocacy
by the National Board
of Trial Advocacy
KENNETH H. BAER,
PAMELA S. BAER,
Plaintiff ·
Defendant '
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. ~b:l, -
IN CUSTODY
STIPULATED CUSTODY AGREEMENT
WHEREAS, Kenneth H. Baer (hereinafter referred to as "Father") and Pamela S. Baer
(hereinafter referred to as "Mother") are the natural parents of David H. Baer (d.o.b. 05/30/91;
hereinafter referred to as' the "Minor Child"); and
WHEREAS, Father and Mother desire to make arrangements for the custody and
visitation of the Minor Child; and
WHEREAS, both parties have been advised by counsel or have had the opportunity to be
advised by counsel; and
WHEREAS, the parties intend to submit this Stipulated Custody Agreement to the Court
of appropriate jurisdiction for incorporation and merger into a Court Order approving said
Agreement;
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED AS FOLLOWS:
The parties shall share legal custody of the Minor Child·
The parties have agreed that Father shall have primary physical custody of the
2.
Minor Child.
3.
The parties have agreed that Mother shall have visitation of the Minor Child as
agreed by the parties.
Document #245443
4. The parties shall split, as decided by the parties, the time the Minor Child has off
from school for Christmas break, spring break, and Thanksgiving break.
5. Both parties agree to cooperate with one another in the implementation of the
aforesaid Agreement and understand and agree that other changes or modifications in the
aforesaid schedule and/or times specified may be necessary to enable both parents to continue to
foster and develop a good and healthy relationship with the Minor Child. To that end, the parties
agree to cooperate with one another to encourage the Minor Child's relationship with the other
parent and agree to refrain from any and all conduct, activity, or communication which would
adversely affect the Minor Child's relationship with either parent. Neither party shall make
disparaging comments about the other in front of the Minor Child, nor will they permit any other
relative or any other party to do so.
6. Father will provide medical insurance for the Minor Child.
7. Upon the knowledge of pending relocation, temporary or permanent, of either
parent, each parent must inform the other of his/her new address and telephone number within
thirty (30) days.
8. The parties agree that the Minor Child shall have liberal rights of telephone
contact with the non-custodial parent, no matter who is exercising his/her right to physical
custody.
9. The legal residency of the Minor Child, notwithstanding where the Minor Child
might live at various times, shall be the same as that of Father.
Document #245443
-2-
10. Both parties agree that neither party shall remove the Minor Child from the State
of Pennsylvania for an extended period of time without prior notification and approval of the
other party.
11. For tax purposes, Mother will receive the federal tax exemption for the year 2002.
Since the Minor Child will be residing with Father, Father will receive the federal tax exemption
for all years following.
12. Both parties agree that this Agreement may only be modified in writing through
further Order of Court.
13. This Agreement shall be effective immediately upon signature by both parties,
and its validity is not contingent upon Court approval.
WHEREFORE, the parties pray that the Court enter the Order attached hereto.
We verify that the statements made in this Petition or tree and correct. We understand
that false statements herein are made subject to the penalties of 18 Pa.C.S., § 4904 relating to
unswom falsification to authorities.
Date:
Date:
Kenneth H. Baer
Pamela S. Baer
Document #245443
-3-
DEC1
KENNETH H. BAER,
Plaintiff
PAMELA S. BAER, '
Defendant ·
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO.
IN CUSTODY
ORDER OF COURT
AND NOW, this '~'-~~day of __~/~A~,., 200~, upon review and
consideration of the Stipulated Custody Agreement of the parties, a copy of which is attached
hereto, said Agreement is hereby APPROVED, ADOPTED, MERGED and INCORPORATED
herein as the Order of this Court.
CC:
BY THE C T:
Andrew C. Spears, Esquire, Attorney for Plaintiff
Pamela S. Baer, Defendant
Jo
Document #245443