The URL can be used to link to this page

Home My WebLink About03-0862Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 DAVID A DODSON, Plaintiff REBECCA A. DODSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ~ - at>& ~.~ CIVIL ACTION - LAW IN CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT, if you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody and visitation of your children. When the grounds for a divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Domestic Relations Office at the County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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 (717) 249-3166 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 DAVID A DODSON, Plaintiff REBECCA A. DODSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY CUSTODY COMPLAINT 1. The Plaintiff is David A. Dodson (hereinafter referred to as "Father"), who currently resides at 128 Rolo Court, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is Rebecca A. Dodson (hereinafter referred to as "Mother"), who currently resides at 1 River Street, Archbald, Lackawanna County, Pennsylvania 18403. NAME Mary Kathleen Dodson Plaintiff seeks shared legal and partial physical custody of the following children: PRESENT RESIDENCE David Charles Dodson 1 River Street Archbald, PA 18403 1 River Street Archbald, PA 18403 DATE OF BIRTH 3/31/1988 3/29/1990 4. The children are presently in the custody of the Mother who resides at 1 River Street, Archbald, Lackawanna County, Pennsylvania 18403. the following addresses: DATES During the past five years the children have resided with the following persons at 1998 to January, 2000 ADDRESSES NAMES OF PERSONS IN HOUSEHOLD Mother, Father 9 Bonny Lane Mechanicsburg, PA 17055 January, 2000 to 906 Allenview Drive Mother October, 2002 Mechanicsburg, PA 18050 1 River Street Archbald, PA 18403 October, 2002 to Mother Present 6. The Mother of the children is Rebecca A. Dodson, currently residing at 1 River Street, Archbald, Lackawanna County, Pennsylvania 18403. 7. The Father of the children is David A. Dodson, currently residing at 128 Rolo Court, Mechanicsburg, Cumberland County, Pennsylvania 17055. The parties are presently married but separated. currently resides with the following persons: NAME Self The relationship of the Plaintiff to that of the children is that of Father. Plaintiff RELATIONSHIP 2 resides with the following persons: NAME Mary Kathleen Dodson David Charles Dodson The relationship of the Defendant to the children is Mother. Defendant currently RELATIONSHIP Daughter Son 10. 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. 11. Plaintiff has no information of a custody proceeding concerning the children pending in any court of this Commonwealth. 12. 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. 13. This action is being initiated so a previously agreed upon custody stipulation can be filed of record and be made an enforceable court order. The parties have created a parenting plan whereby Defendant shall maintain primary custody of the children with periods of defined partial custody for the Plaintiff. The parties are also authorizing a relocation by Defendant and the children from Central Pennsylvania to the Scranton area. Defendant wants to confirm specified contact with the children in light of the relocation and to retain jurisdiction of this court over the matter. 3 14. 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. WHEREFORE, the Plaintiff requests the Court to grant shared legal and physical custody of the children to the Plaintiff. DATE: February ~ , 2003 ('d3arbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Plaintiff Barbara Sumpl¢-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 DAVID A DODSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. REBECCA A. DODSON, Defendant CIVIL ACTION - LAW IN CUSTODY VERIFICATION I, David A. Dodson, hereby certify that the facts set forth in the foregoing CUSTODY COMPLAINT are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. CS.A. Section 4904 relating to unsworn falsification to authorities. David A. Dodson Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 DAVID A DODSON, Plaintiff REBECCA A. DODSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN CUSTODY .STIPULATION REGARDING CUSTODY This Agreement is made this/~9 · aay otq:~,,t-ol~,, 2002 by and between David A. Dodson (hereinafter "Father") and Rebecca A. Dodson (hereinafter "Mother"). WHEREAS, the parties are the natural parents of two children being Mary Kathleen Dodson (born March 31, 1988) and David Charles Dodson (born March 29, 1990); WHEREAS, the parties desire to confirm all agreements concerning custody of their children by court order; NOW THEREFORE, the parties, intending to be legally bound, do agree as follows: Custody of the children is set forth as follows: 1. Legal Custody: The parties shall share legal custody of the minor children. The parties agree that major decisions concerning the children, including, but not necessarily limited to, the children's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the children's best interest. Each party agrees not to impair the other party's rights to shared legal custody of the children. Each party agrees not to attempt to alienate the affections of the children from the other party. Each party shall notify the other of any activity or circumstance concerning their children that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the children at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party as a parent; 2. Physical Custody: Primary physical custody of the minor children shall be confirmed in Mother. as follows: Partial Physical Custody: Father shall enjoy periods of partial physical custody A. Alternating Weekends: Each alternating weekends from Friday after school (approximately 4:00 p.m.) through Sunday. However, if the children have a long holiday weekend from school which includes a Friday or Monday, the parties agree that Father shall, at his option, have said extended weekend with the children in lieu of one of his regularly 2 scheduled weekend. These weekends shall be identified on the school calendar and notice of Father's intention to change a scheduled weekend to exercise these periods shall be given at the commencement of the month in which the weekend shall occur. B. ltolidays: The parties will share holidays as they can mutually agree. If no agreement is reached, Father shall have New Year's Eve Day, Easter, Fourth of July in even years and Memorial Day, Labor Day and Thanksgiving Day in odd years. Mother shall have New Year's Day, Easter, Fourth of July in odd years and Memorial Day, Labor Day and Thanksgiving Day in even years. Unless the parties can otherwise agree, Christmas shall be divided between the parties with Father having December 24th at 9:00 a.m. through 12:00 noon on Christmas Day in even years and 12:00 noon on Christmas Day through December 26th at 9:00 p.m. in odd years. periods. School Breaks: Each party shall have one-half of each school vacation D. Vacations: Each party shall have two (2) weeks annually for vacation purposes. A week shall be defined as seven (7) days and shall be combined with the parent's weekend period. agree. E. Other times: Father shall have custody at other times as the parties can 4. Relocation: Father agrees that Mother shall have the right to relocate with the children to Lackawanna County. The parties do, however, stipulate that any and all future custody actions involving these children shall be subject to the jurisdiction and venue of the Court of Common Pleas of Cumberland County. 5. Transportation: Transportation shall be divided between the parties with the party relinquishing custody delivering the children to the other parent's home. 6. Reasonable Telephone Privileges: telephone contact with the children. Each party shall have the fight to reasonable 7. Entry of an Order: The parties desire the terms of this Stipulation to be entered as an Order of Court. NOW, THEREFORE, the parties, intending to be legally bound, do agree to set forth their hands on the date first written above. David A. Dodson 4 COMMONWEALTH OF PENNSYLVANIA COVNZV OF ) )ss. ) Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County, personally appeared REBECCA A. DODSON, who being duly affirmed according to law, deposes and says that the facts and matter set forth in the within and foregoing Stipulation Regarding Custody are true and correct to the best of her knowledge, information and belief. ~~.,dandsubsclibedt°bef°remethis /0rJ~dayof ~)£c:E40(]l, 2002. vMS' ~ommissinn exnir~' - NO?A~AL SE~L I (SEAL) JOSEPH FARINA, Norm7 Public I Atc~m m~ro., L~c~cawam'~ ~ty I COMMO~ALTH OF PENNSYLVANIA ) )ss. COUNTY OF CUMBERLAND ) Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County, personally appeared DAVID A. DODSON, who being duly affirmed according to law, deposes and says that the facts and matter set forth in the within and foregoing Stipulation Regarding Custody are true and correct to the best of his knowledge, information and belief. [rmed and subscribed to before me this )ires: " IIOTARIALSEAL ' ' MECHANICSmJ~ ~F'I~. CUMBERLAND cO. MY COMMISSION EXPfl~S JULY 30, 2006 (SEAL) Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 ~ 774-1445 DAVID A. DODSON, Plaintiff REBECCA A. DODSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY ORDER AND NOW, this /~" day of ~a~d~ j 2003, the parties' Stipulation dated December 16, 2002, the terms thereof are entered as an Order of Court and are binding upon the parties as if entered by this Court after full hearing. BY THE COURT: / Judge