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HomeMy WebLinkAbout03-1169AUDREY R. KENES and BARRY L. KENES, Plaintiffs V. MONICA NADINE PINARD and MARK ALLEN PINARD, Defendant · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA · CIVIL ACTION - CUSTODY CC)IV[PI.AINT FOR CI ISTODY o Plaintiffs are Audrey R. Kenes and Barry L. Kenes, adult individuals whose residence is at 410 4th Street, New Cumberland, Cumberland County, Pennsylvania. Defendant, Monica N. Pinard, is an adult individual whose residence is at 1811 Ranstead Street, Philadelphia, Philadelphia County, Pennsylvania. Defendant, Mark A. Pinard, is an adult individual whose residence is at 7251-B Union Deposit Road, Hummelstown, County of Dauphin, Pennsylvania. Plaintiffs seek custody of their grandchild, Ariel Marie Pinard, currently residing at 410 4th Street, New Cumberland, Cumberland County, Pennsylvania, whose date of birth is February 20, 1988. The child is presently in the custody of Plaintiffs. Since the child's birth, the child has resided with the following over the past five years: Monica & Mark Pinard Monica Pinard & Petitioners Monica & Mark Pinard Monica Pinard Petitioners ~ Time Period 1330 Valley Road, Etters, PA 1998-1999 410 4t~ Street, New Cumberland, PA 1999-2000 21 lA Enola Street, Enola, PA 2000-2002 1811 Ranstead Street, Philadelphia, PA 9/02- 3/03 410 Sth Street, New Cumberland, PA 3/03-Present 7. The natural mother of the child is Monica N. Pinard, currently residing at the above-stated address. 8. The natural father of the child is Mark A. Pinard, currently residing at the above-stated address. 9. The relationship of the Plaintiffs to the child is that of maternal grandparents. 10. The relationship of Defendant, Monica N. Pinard, to the child is that of natural mother. 11. The relationship of Defendant, Mark A. Pinard, to the child is that of natural father. 12. The Plaintiffs have 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. 13. Plaintiff has no information of a custody proceeding concerning the child pending in any Court of this Commonwealth. 14. Plaintiffs request that Legal and Physical Custody be placed with them subject to reasonable visitation by Defendants. 15. The best interests and permanent welfare of the child will be served by granting the relief requested because the Plaintiffs are the primary care giver with respect to the child at this time and can provide a safe and stable environment for the child. 16. Each parent whose parental rights to the child have not been terminated and the persons who have 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 action. 17. Each parent whose parental rights have not been terminated and the persons who have physical custody of the child have signed a Stipulation that Legal and Physical Custody should be in the Petitioners. WHEREFORE, Plaintiff requests your Honorable Court to order custody rights of Legal and Physical Custody with the Plaintiffs in accordance with the attached Stipulations. Respectfully submitted, Date BRIAN C. BORNMAN, ESQUIRE 714 Bridge Street Post Office Box 461 New Cumberland, PA 17070-0461 (717) 770-2540 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Custody 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 unswom falsification to authorities. Date AUDREY I~lqES AUDREY R. KENES and BARRY L. KENES, Plaintiffs VS. MONICA NADINE PINARD and MARK ALLEN PINARD, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION- CUSTODY STIPULATION AND NOW, this ! ~' '/% day of March, 2003, it is hereby stipulated and agreed between the parties as follows: 1. Ariel Marie Pinard is the natural child of Monica Pinard and Mark Pinard. 2. Audrey Kenes and Barry Kenes are the maternal grandparents of Ariel Marie Pinard. 3. 4. Legal custody of Ariel Made Pinard shall be in Audrey Kenes and Barry Kenes. Primary physical custody of said child shall be in Audrey Kenes and Barry Kenes subject to such periods of partial physical custody as the parties may mutually agree upon. WHEREFORE, the parties respectfully request that this Court enter an Order of Custody consistent with the terms of this Stipulation. AUDREY R. KENES and BARRY L. KENES, Plaintiffs VS. MONICA NADINE PINARD and MARK ALLEN PINARD, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. O..? . //~q ~ ORDER OF COURT AND NOW, this I ~ ~ day of March, 2003, upon consideration of the attached Stipulation, it is hereby Ordered as follows: 1. Legal custody of Ariel Marie Pinard shall be in Audrey Kenes and Barry Kenes. 2. Primary physical custody of said child shall be in Audrey Kenes and Barry Kenes subject to such periods of partial physical custody as the parties may mutually agree upon. Jo