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HomeMy WebLinkAbout02-6019JENNIFER WEBB, Plaintiff Vo TIMOTHY WEBB, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . : NO. ~)~2 ~o/5 CIVIL TERM : : CIVIL ACTION - CUSTODY COMPl ,AINT FOR CI LqTODY 1. Plaintiff is Jennifer Webb, an adult individual whose residence is at 18 Fargreen Road, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant is Timothy Webb, an adult individual whose residence is at 1 East Factory Street, Apartment 2, Meehanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of her child, Alexander Corbin Webb, curremly residing at 18 Fargreen Road, Camp Hill, Cumberland County, Pennsylvania, whose date of birth is December 20, 1998. 4. The child is presently in the custody of Plaintiffand Defendant jointly. 5. Since the child's birth, the child has resided with the following over the past five years: Name, A dclre~ Date Jennifer Webb (partial physical custody) 18 Fargreen Road, Camp Hill, PA August 2002-Present Timothy Webb (partial physical custody) 1 East Factory Street, Apza'tment 2, Meehaniesburg, PA August2002-Present Jennifer and Timothy Webb (together) 18 Fargreen Road, Camp Hill, PA December 1995~August 2002 6. The natural mother of the child is Jennifer Webb, currently residing at the above-stated address. o address. The natural father of the child is Timothy Webb, currently residing at the above-stated ° 9. 10. The relationship of the Plaintiffto the child is that of natural mother. The relationship of the Defendant to the child is that of natural father. The Plaintiff has not participated as a party or in any other capacity, in other litigation concerning the custody of the child in this or any other court. 11. Plaintiffhas no infom,ation of a custody proceeding concerning the child pending in a court of this Commonwealth. 12. Plaintiff requests that primary physical custody be placed with her subject to reasonable visitation by Defendant. 13. The best interests and permanent welfare of the child will be served by granting the relief requested because the Plaintiff is the primary care giver with respect to the child. 14. 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. No other persons are known to have or claim to have any right to custody or visitation of the child other than the parties to this actior~ WHEREFORE, Plaintiff requests your Honorable Court to order custody rights of Primary Physical Custody with the Plaintiff with visitation by the Defendant and shared Legal Custody. Respectfully submitted, ,, Ig Date BRIAN C. BORNMAN, ESQUIRE 714 Bridge Street Post Office Box 461 New Cumberland, PA 17070-0461 (717) 770-2540 Attorney for Plaintiff VF~RII~I~ ATION I verify that the statements made in the foregoing Custody Complaint are tree and correct. I understand that false statements made herein are subject to the penalties of 18 PA C.S. 4904 relating to unswom falsification to authorities. Date /ENNIFER WEBB PLAINTIFF Vo TIMOTHY WEBB DEFENDANT 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-6019 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, December 23, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. ., the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, January 21, 2003 at 1:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all exisfiug Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sunda'y, Esa. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 JENNIFER WEBB, Plaintiff Vo TIMOTHY WEBB, Defendant : IN THE cOURT OF COMMON PLEAS : CUMBERLAND COI_;NTY, PENNSYLVANIA : : NO. 02-6019 CWIL TERM : CIVIL ACTION - CUSTODY .. ~TIPIII,ATION AND NOW, this parties as follows: 1. 2. day of ~~ , 2003, it is hereby stipulated and agreed between the Alexander Corbin Webb is the natural child of Jennifer Webb and Timothy Webb. Shared legal custody of said child as contemplated by the Act of November 5, 1981, P.L. 322, 23 P.S. Section 1001, et seq., will be in both of the parties, as the natural parents. 3. Primary physical custody of said child shall be in the Mother subject to the following periods of partial custody with the Father: a. Every other weekend from Friday at 5:00 p.m. through Monday at 8:30 a.m., with the Father to have partial custody the weekend of January 18th and 19th and every other weekend thereafter; b. Every Tuesday commencing at 5:30p.m. through Wednesday at 8:30a.m.; c. Every other Thursday commencing at 5:30p.m. through Friday at 8:30a.m. This period of visitation to occur during the weeks preceding the weekends in which Father does not have custody; d. Alternating division of Christmas Day with the Mother to have the child from 6:00 p.m. 'on Christmas Eve through noon on Christmas day in 201)3, and from noon through 8:00 p.m. on Christmas day in 2004, and so on alternating each year thereafter; The Mother shall have partial custody of the child from 8:00a.m through 8:00p.m. on her birthday and the Father shall have partial custody of the child from 8:00a.m. through 8:00p.m. on his birthday; The parties shall altemate custody on Labor Day and Memorial Day each year, with Father to have custody on Labor Day in 2003 and Memon'.al Day in 2004 and Mother to have the alternate holiday each year; All .other holidays 'are to be decided by discussion between the parents. If no mutual agreement can be reached, the party on whose re[~ar period of custody the holiday falls shall have custody; h. The party who does not otherwise have custody of the child under the terms of this agreement shall have the child from 4:00 p.m. to 8:00 p.m. on the birthday of the child; i. Mother shall have partial physical custody of the child from 8:00 a.m. through 8:00 p.m. on Mother's Day; and Father shall have partial physic~d custody of the child from 8:00 a.m. through 8:00 p.m. on Father's Day; and Such other periods of partial physical custody as t~he parties may from time to time agree. 4. The father and mother shall keep the each other informed of all medical appointments and problems pertairdng to said child. Date - Date Je~mife-~ebb Timothy Webb JENNIFER WEBB, Plaintiff Vo TIMOTHY WEBB, Defendant AND NOW, tl Stipulation it is orderer · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 02-6019 CIVIL TERM · CIVIL ACTION - CUSTODY ,is ~}1~1'*1~ dayof~, and decreed as follows: 2003, upon consideration of the within 1. Shared legal custody of said child as contemplated by the Act o:~'November 5, 1981, P.L. 322, 23 P.S. Section 1001, et seq., v~ill be in both of the parties, as the natural parents. 2. Primary physica custody with the Father a. Ever to have partial c~ b. Every c. Every visitat: custod d. Alterr Christmas Christmas custody of said child shall be in the Mother subject to the following periods of partial other weekend from Friday at 5:00 p.m. through Monday at 8:30 a.m., with the Father ;tody the weekend of January 18th and 19th and every other weekend thereafter; Tuesday commencing at 5:30p.m. through Wednesday at 8:30a.m.; other Thursday commencing at 5:30p.m. through Friday at 8:30a.m. This period of on to occur during the weeks preceding the weekends in which Father does not have tting division of Christmas Day with the Mother to have the child from 6:00 p.m. on Eve through noon on Christmas day in 2003, and from noon through 8:00 p.m. on [ay in 2004, and so on alternating each year thereafter; f. TI ha alt g. A1 agl sh, h. agreement shal i. on Mother's Da p.m. on Father' j. 3. The father and pertaining to said child. The Mother shall have partial custody of the child from 8:00a.m through 8:00p.m. on her birthday and the Father shall have partial custo,dy of the child from 8:00a.m. through 8: 90p.m. on his birthday; te parties shall alternate custody on Labor Day and Memorial Day each year, with Father to ye custody on Labor Day in 2003 and Memorial Day in 2004 and Mother to have the emate holiday each year; other holidays are to be decided by discussion between the parents. If no mutual eement can be reached, the party on whose regular period of custody the holiday falls 11 have custody; The party who does not otherwise have custody of the child under the terms of this have the child from 4:00 p.m. to 8:00 p.m. on the birthday of the child; Mother shall have partial physical custody of the child from 8:00 a.m. through 8:00 p.m. y; and Father shall have partial physical custody of the child from 8:00 a.m. through 8:00 Day; and luch other periods of partial physical custody as t;he parties may from time to time agree. mother shall keep the each other informed of all medical appointments and problems JAN 2 7 Ln~3 ~ JENNIFER WEBB VS. TIMOTHY WEBB Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-6019 CIVIL ACTION LAW IN CUSTODY ORDER AND NOW, this 20th day of January 2003 , the conciliator, being advised by the plaintiff's counsel and defendant, that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction. The Custody Conciliation Conference scheduled for January 21, 2003 is cancelled. FOR THE COURT, Custody Conciliator