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HomeMy WebLinkAbout03-0097LaW OFFICES SNELBAKER, BrEnNEMAn & SPAre ANGELA L. GREENWALD, Plaintiff V. BRUCE A. GREENWALD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. ~) 23-0/ CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY OF MINOR CHII,DREN AND NOW, comes the Plaintiff, ANGELA L. GREENWALD, by her attorneys, Snelbaker, Brenneman & Spare, P. C., and avers the following: 1. Plaintiff is ANGELA L. GREENWALD residing at 414 South York Street, (Second Floor) Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is BRUCE A. GREENWALD residing at 166 Wyoming Avenue (Second Floor) Enola, Cumberland County, Pennsylvania, 17025. 3. Plaintiff seeks custody for the following two minor children: NAME Hannah Marie Greenwald Seth Alan Greenwald PRESENT RESIDENCE 414 South York Street (Second Floor) Mechanicsburg, PA 17055 414 South York Street (Second Floor) Mechanicsburg, PA 17055 AGE (D.O.B. 9/13/98) Age 4 (D.O.B. 7/5/99) Age 3 The children were bom during the marriage. The children are presently in the custody of Plaintiff ANGELA L. GREENWALD who resides at 414 South York Street (Second Floor) Mechanicsburg, Pennsylvania 17055. Since birth, the children have resided with PlaintiffANGELA L. GREENWALD and Defendant BRUCE A. GREENWALD and various relatives at several different locations including, but not limited to: LaW OFFICES SNELBAKER, BRENNEMAN & SPARE (a) with Angela's parents at 7033 Wertzville Road, Mechanicsburg, Pennsylvania. 17055; (b) with Bruce's parents on Hummel Avenue in Lemoyne, Pennsylvania 17043; (c) with Bruce's parents on Third Avenue South in Myrtle Beach in South Carolina; and (d) with Plaintiff and Defendant at 414 South York Street (Second Floor) Mechanicsburg, Pennsylvania 17055. During this time frame, the parties remained together with their children but moved in and out of various residences with other persons. The mother of the child is ANGELA L. GREENWALD, currently residing at 414 South York Street (Second Floor) Mechanicsburg, Pennsylvania 17055. She is married to Defendant. The father of the children is BRUCE A. GREENWALD residing at 166 Wyoming Avenue (Second Floor) Enola, Pennsylvania 17025. He is married to Plaintiff. 4. The relationship of Plaintiff to the children is that of Mother. The Plaintiff currently resides with the following persons: Nalne Hannah Marie Greenwald daughter Seth Alan Greenwald son Dominique Katherine Clouser (age 5) daughter. Defendant currently resides with the following persons: Name Melissa Hensley Relationship The relationship of Defendant to the children is that of Father. The Relationship sister LAW OFFICES SNELBAKER, BRENNEMAN & SPARE 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. 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. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because Mother has been the primary caretaker of the children since birth and provides a stable and loving home environment for the children. 8. 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. 9. The parties have agreed to the custody arrangements set forth in a Custody Agreement executed by both parties in mid-December, 2002, a copy of which is attached hereto as Exhibit A and incorporated herein by reference. 10. The parties intend to have the attached Custody Agreement entered as an Order of Court. 11. The best interests of the children will be served by entering the Custody Agreement as an Order of Court. LAW OFFICES SNELBAKER, BRENNEMAN & SPare WHEREFORE, PlaintiffANGELA L. GREENWALD respectfully requests your Honorable Cottrt to enter an Order of Court adopting and incorporating the terms of the attached Custody Agreement. Date: January 7 ,2003 Respectfully submitted, SNELBAKER, BRENNEMAN & SPARE, P. C. PhilipVH. SpaYe, Esquire Pa. Supreme Court I.D. #65200 44 West Main Street P.O. Box 318 Mechanicsburg, PA 17055-0318 Attorneys for Plaintiff, ANGELA L. GREENWALD CUSTODY AGREEMENT THIS AGREEMENT is made between ANGELA L. GREENWALD, of 414 S. York Street, (second floor), Mechanicsburg, Cumberland County, Pennsylvania and BRUCE A. GREENWALD, of ILaO /-oc/or-nl~rl~ ,,~D(~ 2k-~d ~hoo(- ~no[o_ [2~, 1. The parties to this Agreement, Angela L. Greenwald and Bruce A. Greenwald, were married on August 22, 1998. 2. The parties have two children born of the marriage; namely, Hannah Marie Greenwald, born Septembe~1998; and Seth Alan Greenwald, born July $, 1999. apart. 3. Due to various reasons, Angela and Bruce have separated and are living separate and 4. The parties enter into this Agreement to resolve the issue of custody of the children. 5. The parties shall share legal custody of the children, meaning they shall each have a right to make important decisions regarding the children's education, medical and religious matters. 6. Angela L. Greenwald shall have primary physical custody of the children subject to reasonable visitation and partial custody rights of Bruce A. Greenwald as can be agreed by the parties. 7. The parties intend to have this Custody Agreement entered as an Order of Court in a child custody action to be filed in the Court of Common Pleas of Cumberland County, Pennsylvania. Exhibit A Page 1 of 2 8. Angela L. Greenwald is represented by Philip H. Spare, of the law firm of Snelbaker, Brenneman & Spare, P. C. Bruce A. Greenwald has not received any legal advice from Angela's attorney and is aware that he has a right to obtain legal advice from an attorney of his choice before signing this Agreement. Angela L. Greenwald and Bruce A. Greenwald, intending to be legally bound hereby, sign their names below indicating that they agree to the terms set forth in this Custody Agreement. WITNESS: AngbJ~ L. Greenwald Bruce A. Greenwald -2- Exhibit A Page 2 of 2 LAW OFFICES SNELBAKER, BrENNEMAN & Spare VERIFICATION I verify that the statements made in the foregoing 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. ~n-g~ L. Greenwald Date: January 7, 2003 LAW OFFICES SNELbAKER, BrENNEMAN & SPAre ANGELA L. GREENWALD, Plaintiff V. BRUCE A. GREENWALD, Defendant · IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 0!5 -~'~ CIVIL TERM CIVIL .ACTION - LAW IN CUSTODY ORDER k Custody Agreement is hereby adopted as an Order of Court. ,20C~, the attached B