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Home My WebLink About00-05907 . ''''''~~''''--': THOMAS A. STEVENS, Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NUMBER: tHJ" 5'10 7 ~ -r.b- KELLY A. MILLER, Defendant IN CUSTODY ORDER AND NOW, this30~ay of ~ 2000, upon consideration of the within Motion, Stipulation, and Complaint, it is hereby Ordered as follows: 1. Mother, KELLY A. MILLER, shall have primary physical and legal custody of MICHAEL THOMAS STEVENS, born October 11, 1984. 2. Father, THOMAS A. STEVENS, SR., sha11 have no rights of temporary physical custody without further Order of Court, J. .-,",'~' < ~-"','~"- ~-, ! ~( \l! 1,1 ~ ~l ~1 " ~ "- "0'--'",,-,,,,- - ~' ,,~... ,-, ,'" "',~'~ .. . \:', ~ 2t 1 } '::):AllY ;1r !r' :~ U f" I"'" ~)A lJ' ','''-' ',',,-,", ~'" ",\!: - ,," ,,<,' '"' ~ ~-,"'-' THOMAS A. STEVENS, Plain tiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NUMBER: t>V - S90 1 ~ ".e-.- IN CUSTODY vs. KELLY A. MILLER, STIPULATION AGREEMENT, made this c1,tl., ':::i:-' day of August, 2000, by and between THOMAS A. STEVENS, hereinafter referred to as "Father;" and KELLY A. MILLER, hereinafter referred to as "Mother;" WITNESSETH: WHEREAS, the parties hereto are the natural parents of a minor child, MICHEAL THOMAS STEVENS, born October 11, 1984; and WHEREAS, the parties have reached an agreement concerning the issues of custody and desire that this Stipulation be entered as Order by the Court of Common Pleas of Cumberland County, Pennsylvania; NOW, THEREFORE, intending to be legally bound, the parties hereby agree as follows: 1. Mother, KELLY A. MILLER, shall have primary physical and legal custody of MICHEAL THOMAS STEVENS, born October 11, 1984. ~",~- ,~-- - C<'J=;""z ,".c.;~.~,,~' < _" '-'-,~~__'-,,',c- '., _ "_~ 2. Father, THOMAS A. STEVENS, SR., shall have no rights of temporary physical custody without further Order of Court. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written. ~~~ WITNESS Lo~ THOMAS A. STEVENS, SR. ~L~~ W TNESS ifi~t :!J,~ '='"~ -,,~.,. . - >'''"'' ,,~, '''<''''''''--~-' " THOMAS A. STEVENS, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NUMBER: dtl_S9'f)7 d;::.J. -r~ KELLY A. MILLER, Defendant IN CUSTODY MOTION NOW COMES the Plaintiff, THOMAS A. STEVENS, SR., by and through his attorney, Charles E. Petrie, and respectfully represents as follows: 1. That Plaintiff is THOMAS A. STEVENS, SR., an adult individual currently residing at 27 South Second Street, Wormleysburg, County of Cumberland, Pennsylvania. 2. That Defendant is KELLY A. MILLER, an adult individual currently residing at 421 Locust Street, Second Floor, Hanover, County of York, Pennsylvania. 3, That Plaintiff and Defendant are the natural parents of a minor child, MICHEAL THOMAS STEVENS, born October 11, 1984. 4. That the parties have entered into a Stipulation concerning the matters of custody and visitation with respect to the minor child, and the said Stipulation is attached hereto. ._~,- " '~.'--,,--'" ~,,,. o_~ ,'~,.~ -,_'c.'" <, - ";;'~',k_'",,,_c _",_ '~';,"';;'" '>d.,c.;,~-"",-"'""J"~ ;--",'~", , ' ',;,~ 5. That the parties desire that said Stipulation be entered as an Order of Court. WHEREFORE, Plaintiff respectfully requests that Your Honorable Court enter an Order pursuant to the attached Stipulation. Respectfully submitted ~~~ CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiff - -~, -- ",---,,-~. "'---"""'~'F'='''''__"''''''h''''i' '~'''~o/'--,''--'''~~'-':k-'",,,,;;,-,,,,",--,,,,,u,,,'d.''~';:!i.~';''''''-~P,-"CO '.__,"" ,,(;/ THOMAS A. STEVENS, Plaintiff V8. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NUMBER: (J1) - S90 '7 C~ J..o- KELLY A. MILLER, Defendant IN CUSTODY COMPLAINT FOR CUSTODY NOW COMES the Plaintiff, THOMAS A. STEVENS, by his attorney, Charles E. Petrie, and respectfully represents as follows: 1. Plaintiff is THOMAS A. STEVENS, who currently resides at 27 South Second Street, Wormleysburg, County of Cumberland, Pennsylvania. 2. Defendant is KELLY A. MILLER, who currently resides at 421 Locust Street, Second Floor, Hanover, County of York, Pennsylvania. 3. Plaintiff seeks to grant all rights of primary physical and legal custody with respect to MICHEAL THOMAS STEVENS, born October 11, 1984, to Defendant. The child was not born out of wedlock. The child is presently in the custody of Defendant, KELLY A. MILLER. During the past five years, the child has resided at the following addresses with the following individuals: From August, 1995, until July 24, 1996, with Defendant at 239 Eagle Avenue, Hanover, Pennsylvania; from July 24, 1996, until November 15, 1997, in the custody of York County Probation; from November 15,1997, until June 19,2000, with Plaintiff in Wormleysburg, c_ ,,'__=<.~~_' _ _"=,_,__~~,'~__~__,_" <':..,',,,,~,=,,,",,,,,",,,,,,.-,,,,,:,"_" '~~ Pennsylvania; from June 19,2000, until the present with Defendant at 421 Locust Street, Second Floor, Hanover, Pennsylvania. The mother of the child is KELLY A. MILLER, who currently resides at 421 Locust Street, Second Floor, Hanover, Pennsylvania. She is married. The father of the child is THOMAS A. STEVENS, SR" who currently resides at 27 South Second Street, Wormleysburg, Pennsylvania. He is married. 4. The relationship of the Plaintiff to the child is that of father. The Plaintiff currently resides with his wife, Patricia, their son, Thomas Stevens, Jr., and their daughter, Monica Stevens. 5. The relationship of the Defendant to the child is that of mother. She currently resides with her husband, David Miller, and her sons, Christopher and Michael. 6. The 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 in another court. The Plaintiff has no information of a custody proceeding concerning the custody of the child in this or in another court. Plaintiff does not know of a person not a party to these proceedings who has physical custody of the child or who claims to have custody or visitation rights with respect to the child. ,,, -;, ~-' -W"-' --, ~ '''''---''''''''-'~'' "'''~~ -, '-,' ~''':''~",' ',-- '- -''''';'_-'->i','",'' ",<,;- "':":"'i;;';;;"'~,, -"fi,'_c, ,. ,_ *'-";' '-, 7. The best interest and permanent welfare of the child will be served by confirming rights of primary physical legal custody in Defendant. 8. 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. 9. The parties have entered into a Stipulation, attached hereto, setting forth their agreement concerning custody of the minor child. WHEREFORE, Plaintiff requests the Court enter an Order confirming rights of primary physical and legal custody in Defendant. Respectfully submitted, ~ ~II .4 ~.A2~ CHARLES E. PETRIE 3528 Brisban Street Harrisburg, P A 17111 (717) 561-1939 Attorney for Plaintiff ~ ~ '~. ,~--,-," -- -, .>";-'~--..',~- - -"'--'-'"" COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I verify that the statements in the foregoing Motion and 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 unsworn falsification to authorities. 8' !.7,;J./oo DATE tLQ~, THOMAS A. STEVENS ~",' ~1IiBir'""'. ' " ill I ',. "-~";'" ,- '" -, -~, () (- :::? [Fir' Li ;:::~~ ~" '-~ .' r..].~ u-:." ~,~ ~,,~ ):; (-, 5~~~ '-- 2:. -1 -< t,,"; c:) (Al ;:;=; :S.J -< ~ r Jt I '" Ir ..(.' (r ~ ~ . , . ; '" ~~ d ~ v ~ "" c c f r , "" ~ <> , ,>> -..\> ~ " V\ "',,,- ",' '. - - ,._~