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Home My WebLink About98-01143 '-;p ""0 t.,.. d 3 -g' ~.3 / f: '- .~ ;, .---- ,- " '7 ;0 " c<) , -:::r ,,:' - - .. , I '(}O CJ i . ~ DANIELLE C. WOODWARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 98- 1/ L/ 3 CIVIL TERM CUSTODY MICHAEL E, ALGOSO, Defendant COMPLAINT FOR CUSTODY AND NOW, comes plaintiff, DANIELLE C. WOODWARD, by her attorney, MURREL R, WALTERS, III, ESQUIRE, who avers as follows: 1. The Plaintiff is Danielle C. Woodward, an adult individual who resides at 2414 New York Avenue, camp Hill, cumberland county, Pennsylvania 17011, 2. The Defendant is Michael E. Algoso, an adult individual who resides at 4614 Berkley Street, Harrisburg, Pennsylvania 17109. 3. plaintiff seeks custody of the following children: KAITLYN M, ALGOSO, born November 12, 1994 MICHAEL A. ALGOSO, born September 28, 1996 The children were born out of wedlock. 4. The children currently reside with plaintiff, Danielle C. Woodward, at 2414 New York Avenue, Camp Hill, Pennsylvania. From her birth until October 1995, Kaitlyn resided with Plaintiff and Defendant at Williamsburg Drive, Harrisburg, Pennsylvania. From October 1995 until April 1996, Kaitlyn resided with plaintiff and Plaintiff's father (maternal grandfather) at 38 E. Keller Street, Mechanicsburg, Pennsylvania. From April 1996 until March 1997, Kaitlyn resided with plaintiff and Defendant at 2414 New York Avenue, Camp Hill, Pennsylvania, when Defendant moved from the residence. From his birth until March 1997, Michael resided with Plaintiff and Defendant at 2414 New York Avenue, Camp Hill, until Defendant moved from the residence. The mother of the children is Danielle C, Woodward, Plaintiff herein, who is currently residing at 2414 New York Avenue, Camp Hill, Cumberland County, Pennsylvania. currently not married, The father of the children is Michael E, Algoso, She is Defendant herein, who is currently residing at 4614 Berkley street, Harrisburg, Pennsylvania. He is currently not married. Plaintiff and Defendant were never married to each other. 5. The relationship of Plaintiff to the children is that of natural mother. Plaintiff currently resides with the children, Kaitlyn and Michael. 6. The relationship of Defendant to the children is that of natural father, 7. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 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. 8. The best interests and permanent welfare of the children will be served by granting full legal custody to Plaintiff, subject to periods of visitation with Defendant. " ~. , ,~' :(( I'! VERIFICATION ~: . I I verify that the statements made in this Complaint for Custody are true and correct. I understand that false statements herein are made subj ect to the penal ties of 18 Pa. C. S. S4 904, relating to unsworn falsification to authorities. , .- r... (, r. J./'J. qg' Date QOvni UJt C lOr,orJ-.VJCunlJ Danielle C. Woodward .' J. 1 ,\ , ! , j I \ , I : I I I I' } ~, ( ;} \i " :( .; I ! i; ! , j; , I I', _I 't ~~ ~~ ~, ~ ~ ~ ~ ~' n f; -ci: r.;.' ~ , " ':"\l% V'> 0 :"'0 "11 -.- --} ~:-oo, :-, ""-'_1') .,'J I :::!p.J (...~ '~3c; ,-'-1"1 :.."': '11 :;?;~ri \:) '.) -;-J ~.j :..} ~ ~ :<: ~.::.' ..: C';. , ..";" I~ j I : f I "", I 'I' i ;.j< I \I, I :1" DANIELLE C, WOODWARD Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 98 - 114-3 CIVIL TERM MICHAEL E. ALGOSO, Defendant CUSTODY CERTIFICATE OF SERVICE I, MURREL R. WALTERS, III, ESQUIRE, being duly sworn according to law, depose and say that on March 18 1998, Defendant Michael E. Algoso personally accepted service of the Complaint for custody filed by Plaintiff Danielle C. Woodward. An / Acceptance of Service is attached hereto. Murrel R. Walters, III, Esquire Attorney for plaintiff 54 E, Main Street Mechanicsburg, PA 17055 (717) 697-4650 1.0.# 24849 Sworn to and subscribed before me tllis I &i-i- day of (/'7ClA.c1\. 1998. J\~ ')11. J,l1A.TL Notary Public Notarial Soal Diana M, Smith, Notary Public Mechanlcsbur~ Boro. Cumberland County My Commission Expiros Juno 22, 2000 ,) ,':'" 1.>'1 . '\:1\ I,~ 1(( ~\: \~~ ~! ,. :, ,i e \D 0 ) CO -n :;~ - ::;J .i .-0- -0 (iJ ..". ji;~ ! al!:!J :;0 Z_'-o' N ....)m ::;:t;:: 36 U}";.. U1 ct~ --0 ~:B j ::r-;c~ ::-G ~~C) ~f~ .6l-rn 9, ~ :..:> ..".. ::q \,0 .... 0 1.0 0 c: 0:. -" -~. :v: -l ~ft "0' ==u ..,. nln, :0 hi~ ::~::ti N 'oE9 r~S.:: '1J u, S}r,) r:-;rJ -0 ~4~1 ::.. ::1:: Q", ~;C) :l::fl '--m - 0 .. 'j;! ~ ~') -. ::0 , 10 -< f " I' r ...... < . 'I' '. ~~,'\-t ...'~ " t I ~ l.,. . ~ "'i'~' :, ~"'1, " ' '.1 .... '. . . , . ", " ., .' , '. DANIELLE C. WOODWARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VB. MICHAEL E. ALGOSO, Defendant NO. 98- II ~I '5 CIVIL TERM CUSTODY AliI) ~Do.J 1(,( "'(o.f~~R ~ COu:,TL~ I 17U I UPON consIderation of a wr~ten stipulation signed by Plaintiff, Danielle C. Woodward, and her attorney, Murrel R. Walters, III, Esquire, and Defendant, Michael E. AIgoso, IT IS HEREBY ORDERED AND DECREED that legal and physical custody of Kaitlyn M. Algoso, born November 12, 1994, and Michael A. Algoso, born September 28, 1996, is hereby awarded to Danielle C. Woodward. Michael E, Algoso shall have visitation with the children at times and places as can be arranged between the parties. Danielle C. Woodward may move with the children to California or other area outside of Central Pennsylvania without further order of Court. Such a move will not affect the custody and visitation provisions established by this order, By the Court, '~'.' .' -, , ~'I " I )J~~;l:,},_, ~ ~ Ikfo/( - , "JI '''' ~~ '..,"" ; I . C; ,. -1(", )- .... /,, ~U ... "-..."" "'.1.1 :11.11 -',) .._.,..1 ,. a. Danielle C, Woodward shall have legal and physical custody of the children, b. Danielle C, Woodward may move with the children to California or any other location outside of Central Pennsylvania. c. Michael E. Algoso shall have regular visitation with the children. This visitation will be as frequent as possible and at the convenience of both parents. However, it is acknowledged that visitation will not be on a regular basis if mother moves out of the Central Pennsylvania area. S. It is the desire and intention of the parties hereto that this stipulation be entered in the Court of Common Pleas of CUmberland County, Pennsylvania, and that it be endorsed as an ~der~?fij( have the full effect thereof. Murrel R. Walters, III, Attorney for Plaintiff ;(t;;;tl'~ Esq. (') \....":') 0 c.: c:J "" :~', ::!: ~~;n "'P_' :-.... CUp. :.~, "" I .,.,r'!:J ~i:;: "IC. L) :) ':l ""IL ;~:': "," "'J ~-.,.. :l.~C" ,',_.. .... ~-~h~ ~~~~i m u .. -, ' ~."" :OJ :..) ~J:J ""- IJ1 -~ ~ I I , !