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Home My WebLink About03-0663MONICA L. HAND, Plaintiff JEFFERY A. BOONE, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C1VIL ACTION - LAW IN CUSTODY NO. ~::>.~ - ~, ~o ~ CIVIL TERM COMPLAINT FOR CUSTODY The Plaintiff, Monica L. Hand, by her attorneys, the Family Law Clinic, seeks shared legal and primary physical custody of the parties' child, Alyssa L.G. Boone, born September 2, 2000, and avers in support thereof as follows: 1. The Plaintiff is Monica L. Hand, residing at 1108 Yverdon Drive Apartment B 1, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. The Defendant is Jeffery A. Boone, residing at 600 North Second Street, Wormleysburg, Cumberland County, Pennsylvania, 17043. 3. Plaintiff seeks custody of the following child: Name Present Residence Date of Birth Alyssa L.G. Boone 1108 Yverdon Drive Apartment B1 September 2, 2000 Camp Hill, Cumberland County, Pennsylvania 17043 The child was bom out of wedlock. The child is presently in the custody ofMonica L. Hand, who resides at 1108 Yverdon Drive Apartment B 1, Camp Hill, Cumberland County, Pennsylvania, 17011. During the past two years, the child has resided with the following persons and at the following addresses: Persons Monica L. Hand Address 1108 Yverdon Drive Apartment B1 Camp Hill, Cumberland County, Pennsylvania 17043 Dates Jan. 2002 - Present Monica L. Hand, Brenda Connoloy (Mother) 210 Ninth Street, Second Floor New Cumberland, Cumberland County, Pennsylvania 17070 Sept. 2000 - Jan. 2002 The mother of the child is currently residing at, 1108 Yverdon Drive Apartment B 1, Camp Hill, Cumberland County, Pennsylvania, 17011. She is single. The father of the child is currently residing at 600 North Second Steet, Wormleysburg, Cumberland County, Pennsylvania, 17043 He is single. 4. The relationship of the Plaintiff to the child is that of Mother. The Plaintiff resides with the following persons: Name Alyssa L.G. Boone Relationship Daughter resides with the following persons: Name Unknown to Plaintiff The relationship of Defendant to the child is that of Father. The Defendant currently Relationship 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child 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 child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: a) Mother has been the sole caretaker of the child since September 2, 2000; b) Mother continues to exercise parental duties and enjoys the love and affection of the child; c) Mother is willing to grant Father periods of partial custody in order for child to develop a stronger parent/child relationship with both parents; d) Mother provides child with a home with adequate moral, emotional and physical surroundings as to meet the child's needs. 8. 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. WHEREFORE, Plaintiff requests the court to grant to mother shared legal and primary physical custody of the child, with periods of pm-rial custody to be exercised by father. Date: Leah M. Davenport / Certified Legal Intern TffO t 4. PLACE ROBERT E. RAINS LUCY JOHNSTON-WALSH Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 VERIFICATION I verify that the statements made in this Custody Complaint are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date:)~[i q ((~ ~ MONICA L. HAND, Plaintiff JEFFERY A. BOONE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY NO. O.~- {>6 J CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Monica L. Hand, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date I~::~ 14/o~ Leah M. Davtenl~ort I Certified Legal Intern THOMA~M. I~LACE ' ROBERT E. RAINS LUCY JOHNSTON-WALSH Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 MONICA L. HAND, - Plaintiff . JEFFERY A. BOONE, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CiVIL ACTION- LAW 1N CUSTODY NO. 0 .~ -- (,, 4~.Y CWIL TERM CUSTODY AND VISITATION AGREEMENT THE FOLLOWING AGREEMENT, made this ~4~ day of ~, 2002, between Plaintiff, Monica L. Hand, (hereinafter "Mother") and Defendant, Jeffery A. Boone, (hereinafter "Father") concerns the custody and visitation of their child, Alyssa L.G Boone (hereinafter "Child"), bom September 2, 2000. Mother and Father agree to the following: 1. Mother and Father shall have shared legal custody of the child. 2. Mother shall have primary physical custody of the child. 3. Father shall have partial physical custody of the child according to the following custody schedule: Father shall have partial custody every weekend from Friday at 6:00 P.M. through Sunday at 6:00 P.M. Absent a place of residence, Mother retains custody of the child. 4. Holidays: Mother and Father shall share custody of the child during Thanksgiving, Christmas Day, Easter Sunday, and the child's birthday, by mutual consent, so that each parent has substantial time with the child on each of those days. 5. Mother shall have custody of the child during Mother's Day. 6. Father shall have custody of the child during Father's Day. 7. The custodial parent shall allow the noncustodial parent to have reasonable telephone communication with the child. 8. Father shall be responsible for all transportation of the child to and from mother's residence. 9. Mother shall keep father informed of the child's dietary and medical needs. 10. Neither parent shall do anything which may estrange the child from the other party, or injure the opinion of the child as to the other parent, or which may hamper the free and natural development of the child's love and respect for the other parent. 11. Mother and Father desire to make this agreement a Court Order. They may modify this agreement by mutual consent. In the absence of such mutual consent, the terms of this Order shall control. 12. The Father understands that the Family Law Clinic represents only the Mother's interests in this matter and has advised him that he should seek the advice of legal counsel. Mo~ica L. Hand, Plaintiff la Io 4/n '1 '/ - Date Le[ah m. Davtenport / Certified Legal Intem Lucy J~h~stc~n-Walsh Staff AtVomey FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Counsel for Plaintiff Date FEB Z 8 2O03 MONICA L. HAND, Plaintiff V. JEFFERY A. BOONE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW IN CUSTODY NO. 03-663 CIVIL TERM AND NOW, this '~r4 ORDER OF COURT dayof ., 2003, with the consent of the parties, the attached Custody and Visitation Agreement is hereby made an Order of Court. BY THE COURT, Jo cc: Family Law Clinic, Attorneys for Plaintiff Jeffery A. Boone, Defendant