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Home My WebLink About00-05335 BARRY A. LEONARD and BARBARA 1. LEONARD, Plaintiffs v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. tJ-o. 6336' ~ f-lA--... DENNIS L. LEONARD and TINA KARETTA, : CIVIL ACTION - LAW Defendants : IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiffs are BARRY A. LEONARD and BARBARA 1. LEONARD, husband and wife, currently residing at 20 Penn Way Drive, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant, TINA KARETTA, currently resides at 116 North Center Street, C1eonll, Lebanon County, Pennsylvania. 3. The Defendant, DENNIS L. LEONARD, currently resides at 4201 Gettysburg Road, Lot #9, Camp Hill, Cumberland County, Pennsylvania. 4. The Plaintiffs seek custody of the following children: Name Present Address Age Kristina Marie Leonard Amber Lynn Leonard 20 Penn Way Drive Carlisle, P A 17013 12 (DOB 6-20-87) 10 (DOB 8-17-89) .,",""'<~, ~,-- f" . . -" ~~, '""",,'" 5. The children are presently in the custody of their paternal aunt and uncle, BARRY A. LEONARD and BARBARA J. LEONARD, who reside at 20 Penn Way Drive, Carlisle, Cumberland County, Pennsylvania. 6. During the past five years they resided with the following persons at the following addresses: Name(s) Address Dates Dennis Leonard Tina Leonard (Stepmother) Kristina M. Leonard Amber L. Leonard Surfside Beach, SC May 1995 - June 26, 1999 Barry A. Leonard Barbara J. Leonard Kristina M. Leonard Amber L. Leonard 108 East Locust Street June 26,1999 - Jan. 5,2000 Mechanicsburg, P A 17055 Barry A. Leonard Barbara J. Leonard Kristina M. Leonard Amber L. Leonard 20 Penn Way Drive Jan. 5,2000 - Present Carlisle, PA 17013 7. The mother of the children is TINA KARETT A who is currently residing at 116 North 2 !'''"''!'-''''~-' ., ~," ~~ Center Street, Cleona, Lebanon County, Pennsylvania. 8. The father of the children is DENNIS L. LEONARD currently residing at 4201 Gettysburg Road, Lot #9, Camp Hill, Cumberland County, Pennsylvania. 9. The relationship of the Plaintiffs to the children is that of Paternal Aunt and Uncle. Specifically, BARRY A. LEONARD is the Brother of the Father of the children, DENNIS L. LEONARD. The Plaintiffs currently reside with the following persons: Name Relationship Kristina M. Leonard Amber L. Leonard Niece Niece 10. The relationship of Defendant, TINA KARETTA, to the children is that of Mother. The Defendant currently resides with the following persons: Name Relationship Unknown 11. The relationship of Defendant, DENNIS L. LEONARD, to the children is that of Father. The Defendant currently resides with the following persons: 3 ^f'i""n~ Name Unknown Relationship 12. These children were the subject of a custody proceeding between the Defendants, DENNIS L. LEONARD and TINA KARETTA, filed in Dauphin County to Docket No. 3073-S- 1989. The last Order entered concerning the children was dated February 10, 1994. That Order established that the Defendants were to have shared legal custody of the minor children and that the Defendant, DENNIS L. LEONARD, was to have primary physical custody of the children with visitation periods established for the Defendant, TINA KARETTA. The children have not 1iwd in Dauphin County for the past five years. 13. Plaintiffs have no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 14. Plaintiffs do not know of a person not a party to the proceedings who has physical custody of the children or who claims to have custody or visitation rights with respect to the children. 15. The best interest and permanent welfare of the children will be served by granting the 4 ,,~_.<\ "" . Wl relief requested. 16. 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, Plaintiffs request the Court to grant custody of the children to them and request that the Court establish a schedule wherein they would have custody of the children. Respectfully submitted, By: ~cl.~./ Jenmfer L. Lehman, Esquire Attorney I. D. #52784 27 South Arlene Street P.O. Box 6130 Harrisburg, PA 17112 (717) 671-1200 Date: 7-3/-00 5 '~m~" '" ~ ,'> VERIFICATION I verify that the statements made in the foregoing Complaint in Custody are true and correct to the best of my knowledge, information 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: to I :J-D / 06 If , ~. v.-..c1 "~"I"-, v_ "" VERIFICATION I verify that the statements made in the foregoing Complaint in Custody are true and correct to the best of my knowledge, information 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. B A. LEONARD Date: l.p 1;"'01 aU """""", >='~i. ~ ~ " . "' rt ~'" ",l-> ~ w "',- , '-- - ~~, ~~-~ .,., ~ ""< ~- ~. , "'- ~_ ~_~~!'Jl_. "q""!!l:JM! !>Ill ~_ '.' m1?'L, _ '-^~-!~,III- c::, ,- < ""-"'" :~,") ',_'-,C ,T: , -' ,- -::,~;) --., ., t~~l~ ::;:.j :5 -' , ;3 >'w' :;::J :.:, ()') ~ j ~ ~ ..c: .. ~ ~\ .c v. & e ~ p d ~ '8 f t r , -~><= ','-' BARRY A. LEONARD and BARBARA J. LEONARD, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO. 00- 5335 - CiVIL. Tf:RH v. DENNIS L. LEONARD and TINA KARETTA, : CIVIL ACTION - LAW Defendants : IN CUSTODY ORDER OF COURT AND NOW, this ~daYOf~~"""'- , 2000, upon review of the attached Stipulation dated July 31, 2000, it is hereby ORDERED and DECREED that the said Stipulation is made and entered as an Order of this Court. "", BY THE.c6l1R.T:jj:j .'/,1'/ ;/'<,/~:,/ ~ ,../", It l ..:<;.f f</" , i Ie " "," JJ/i'UA.1 . t . , ,~~ i > ,l fJ ",,,,,' Vq ~ <t,.\O~ ~ J. ""~, " i -_.... --.. ~ . :::~......,,~. L,. i.~"-~.iJi!ij_li ", '-'~-~~J_ -' "-[~&IJ~n:~i..1@t~~1J;; """:1~~~ ,-," , ~~ ,~.~ .~ ._,~.. ,~"",~"~",,,-~".~,~> -,,~"~- ",'~ ^,,- ~- l~~iIlMUil'!I.:f:Il.~"---~' rILED-4Jj7FICE "1[' i"',. r",r"'!.!(jNO"AAY .....<1 "" ,,'._ ,I",. Ii 00 AUG I 0 PN I: I 8 CUlIv/BERLAND COUNTY PENNSYLVANIA "",> '\ ,;-,~ ., ~~" "I ~.jilli.d.i'-" '. 51 " BARRY A. LEONARD and BARBARA J. LEONARD, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. DENNIS L. LEONARD and TINA KARETTA, : CIVIL ACTION - LAW Defendants : IN CUSTODY STIPULATION ANDNOW,this 3/~ day of Juft , 2000, comes the Plaintiffs, BARRY A. LEONARD and BARBARA J. LEONARD, who currently reside at 20 Penn Way Drive, Carlisle, Cumberland County, Pennsylvania 17013 (hereinafter referred to as "Uncle and Aunt"), the Defendant, DENNIS L. LEONARD, of 4201 Gettysburg Road, Lot #9, Camp Hill, Cumberland County, Pennsylvania 17011 (hereinafter referred to as "Father"), the Defendant, TINA KARETTA, of 116 North Center Street, C1eona, Lebanon County, Pennsylvania 17042 (hereinafter referred to as "Mother"), who together stipulate as follows: WITNESSETH: WHEREAS, Mother and Father are the parents of two minor children, KRISTINA MARIE LEONARD, bom June 20, 1987; and AMBER LYNN LEONARD, born August 17, 1989; and WHEREAS, Uncle and Aunt have been caring for the said children continuously since June 26, 1999; and ,"e.,,,,,,,,,,,,,,,,,,,,,."l . WHEREAS, the parties are desirous of the entry of a Court Order confirming that Uncle and Aunt have had, and will continue to have, physical and legal custody of the children until such a time as further Order of Court or agreement of the parties. AND NOW, THEREFORE, the parties hereto intending to be legally bound hereby agree as follows: 1. Mother, Father, and Uncle lmd Aunt shall continue to share joint legal custody of the children as such as defined by 23 Pa.C.S.A. ~5301, ~ This means that all the parties shall have equal access to the children's school and medical records and that each party shall have the right to be informed and consulted concerning any major decisions concerning the children. Minor day-to-day decisions shall be up to the discretion of Uncle and Aunt. 2. The parties acknowledge that Uncle and Aunt have had primary physical custody of the children since June 26, 1999 and agree that Uncle and Aunt shall continue to have physical custody of the children. 3. Mother and Father shall each independently have the right to visit with the children at such times as agreed to between the respective parent and Uncle and Aunt. 4. Uncle and Aunt shall make every effort to provide medical insurance coverage for the children at little or no cost to them. In the event they are unable to provide such coverage, it shall be the responsibility of Mother and Father to provide medical coverage. 2 '1""~"1'., . . 5. The parties agree that this Stipulation may be entered as a Court Order and waive their right to be present at the time it is submitted to the Court for signature. (f;:/H't' J;J. tUn,AA<J J nnifer . Lehman, Esquire ~ Jb/~ / BARRY ~1EONARD Q ~~! . '.(gA ~~ I BARBARA J. ONARD ~/HIJ,,'jJ~ .J . er r:. Lehman, Esquire Witness TINA KARETTA Witness ~L~ ' DENNIS LEONARD 3 -"""',",~"l"",. "~ 5. The parties agree that this Stipulation may be entered as a Court Order and waive their right to be present at the time it is submitted to the Court for signature. BARRY A. LEONARD Jennifer L. Lehman, Esquire Jennifer L. Lehman, Esquire BARBARA J. LEONARD Witness . 4' . v/. --i-=- U[I1..~ ;fi-Uq:,e-<-C,~ TINA KARETTA Witness DENNIS LEONARD 3 ''''~y - ,.., mwr[, "'~~~! c' _:E:-/ ~~~!r: ('s. !i:~~~.~_ !:~~ /~' ~::o,; :::2 r':.....~/ .:;::~ :_',-) .-:--'" ::-:~ ;; --- ~ 'Il..~!7'_~-^"',==" "~ 1"!"Jf\~~~l'!I!i!f'~~f!1"''''''''''ffi1r,~'''it!,.jq!l)Il'i-w.;"'J:o\;~''-~''''-''''''~',""f1~!t~~~~~~~