The URL can be used to link to this page

Home My WebLink About00-07940 v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000 - 7't4D Gu~( '-r~ CIVIL ACTION - LAW ACTION IN CUSTODY MOLLY A. BRENNAN, Plaintiff RANDALL MAIER, Defendant NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by an attomey and filing in writing with the Court your defenses or objections to the claims set forth against you. You are wamed that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief required by the Plaintiff. You may lose money or property or other rights important to you. 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. Office of the Court Administrator Courthouse, 4th Floor Carlisle, PA 17013 (717) 240-6200 --'.",,~ '1' ._~ . .~ Elizabeth A. Hoffman, Esquire 106 Walnut Street Harrisburg, PA 17101 (717) 236-2956 MOLLY A. BRENNAN, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000 - '79'10 ~ T..u-v.- CIVIL ACTION - LAW ACTION IN CUSTODY RANDALL MAIER, Defendant COMPLAINT IN CUSTODY 1. Molly A. Brennan (hereinafter "Mother") is an adult individual whose current address is 126 East Green Street, Shiremanstown, Cumberland County, Pennsylvania 17011. 2. Randall Maier (hereinafter "Father") is an adult individual whose current address IS 104 Citadel Court, North Wales, Pennsylvania 19454-1645-04. 3. Mother and Father are the natural parents of the following minor child: Child DOB 12/6/98 Samuel Brennan 4. A custody order involving the aforesaid persons and minor child was entered in Perry County on July 27, 1999. (See Exhibit "A"). 5. During his lifetime, the minor child has lived in the following places: Place R.R. 2 - Box 182 New Bloomfield, PA 17068 Dates Birth to 5/99 . 126 East Green Street Shiremanstown, PA 17011 5/99 to present 6. Each parent is being notified of this action. There are no other persons known to have or claim to have a right to custody or visitation of the child, and therefore no further notice of the pendency of this action and the right to intervene shall be given, other than to the parties named herein. 7. Mother seeks a custody order for the following reasons: ,':;;.1". ,~ ~>" ,__ ',~ ~. a. Mother wishes to modify the current custody order so that Father can receive overnight visitations on alternating weekends. b. Mother is filing a complaint in Cumberland County because the minor child has been living in said county more than six months. WHEREFORE, Mother seeks a Custody Order which grants her primary physical custody of the minor child and more liberal partial custody to Father. Respectfully submitted, Eliza th A. Hoffman, Es Attorney for Plaintiff 106 Walnut Street Harrisburg, PA 17101 717-236-2956 Attorney ID #71000 ""'lllI . v. IN THE COURT OF COMMON PLEAS PERRY COUNTY, PENNSYLVANIA NO. f?9 .IJJ~~' MOLLY A. BRENNAN, Plaintiff RANDALL MAIER, Defendant CIVIL ACTION - LAW ACTION IN CUSTODY ORDER AND NOW, this ,J 7 t!J day of ~ , 1999, the parties having executed the attached Custody Agreement, said agreement is hereby entered as an order. BY THE COURT J~I }(~Il~ 6 ct. '3Je,v J. > I.C5 '.0 -' ,'~ -0 Distribution:,." E!i2.Cibeth A. Hoffman, Esquire, 2201 North Front Street,'Harrisburg, PA 17110 (717-236-2956) Jennifer Hall, Esquire, 430 Main Street, Haneysville, Pennsylvania 19438 k.YHIJ3rr 4 ^,t"!i~ v. IN THE COURT OF COMMON PLEAS PERRY COUNTY, PENNSYLVANIA NO. 99.t?<?t MOLLY A. BRENNAN, Plaintiff RANDALL MAIER, Defendant CIVIL ACTION - LAW ACTION IN CUSTODY CUSTODY AGREEMENT AND NOW, the parties named in the above-cited action have reached an agreement regarding the custody of the minor child, Samuel Brennan (hereinafter "the child"), born December 6, 1998, and the following order is hereby entered: 1. Molly A. Brennan (hereinafter "Mother"), the natural mother of the child, and Randall Maier (hereinafter "Father"), the natural father, shall share joint legal custody of the child. 2. Mother shall have primary physical custody, and Father shall have partial physical custody of child. l> o 3. Until the child reaches eighteen months Fath~r's viS'itatio~hall be pursuant to the r--:c. ---1 ::::::~ following schedule: :::_' r-: ~ .- a. Alternating Sundays from 12 noon untiI7:p.m. ~~ ~ v b. On other occasions by mutual agreement.oUhe p8;ities. .., .~ .....,,) c. Visits shall be at Mother's home unless otherwise arranged by mutual agreement of the parties. 4. On those occasions when either parent finds that Father's visit with the child at the designated time is not feasible, that parent shall notify the other as soon as possible so that alternate arrangements may be made. 5. The parties agree to take whatever steps are necessary to ensure that the child resides in an environment free from the excessive use of alcoholic beverages. The parties further acknowledge that a failure to adhere to this provision will constitute a direct violation of , '"4'~l'HIlft ~. . __,' ~ this Order. 6. The parties agree to act always in the best interests of the child by cooperating fully with each other in the implementation of the Custody Order. IN WITNESS WHEREOF, the parties hereto have set their hands and seals. (7)~j/ ,;( ,/5-~~ Witness l '<.r. . -f)tl--tlwf!{;LvlC!(tlc,-- , MollyA Brennan ij;}cJ,~J!~ j Randall Maier ~",A ~ &i2oc ~. itness YJ-(e 1 (1<6 ( 99 2 !"~~" -" ..~-~ ,..-, '" CERTIFICATE OF SERVICE I, Elizabeth A. Hoffman, Esquire, do hereby certify that a true and correct copy of the attached Complaint in Custody was personally delivered to: Randall Maier 104 Citadel Court North Wales, PA 19454-1645-04 Date: 1//<6/00 ,j Eliz eth A. Hoffman, E Attomey for Plaintiff Supreme Ct. ID #71000 106 Walnut Street Harrisburg, PA 17101 717-236-2956 , '\-~ ,-',,," --, .- .. v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000 - 7?l.fb CiviL '7-0'UY) CIVIL ACTION - LAW ACTION IN CUSTODY MOLLY A_ BRENNAN, Plaintiff RANDALL MAIER, Defendant ORDER AND NOW, this I("~ day of JJ~ , 2000, upon consideration of the attached Stipulation for Entry of Custody Order, IT IS HEREBY ORDERED AND DECREED that the terms thereof are approved and that custody is awarded as set forth in the Stipulation with the same force and effect as if the terms had been decreed by the Court following an evidentiary hearing. !.~ rrpj. //-/IP -()O ~KS ;.~ ~ -, -'~" " ,__,~, ,~_-,.,!-,,_, 7"~_","r..""~ __,' "'~_ .1.~"__'~ -, -- e,>>..".",', "- 7'"',,,= _~ '1- l'jlilr...:.-i~iI2iIIlI~~~!RMIil~~~~~;!;!llilf'" --~/imfll' ,', ~.<h'".*,Iit. ~<~ ,^ il' '-~ '.cO.".".. :.I.U 1I1111111111!Jl. h. " .. . '"~ 'd'_ <. '"-,' ." " -l.ijl>, ii!.1l" ,-",.,,-, ...""""-~",-~~~=-,' ..... ., (",r:: ',_..-! r:q ~~n-nl:H ~j: i ,-:-..1 '-, 'r~~:-,\-,..ny :'\~I,\::".)L"-\n 11 !. S OfHm, - Pic! ': 10 I" U CUMBERLr\J!L) COUi\.'TY PENNSYLVANiA .. ~ ~. v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000 - CIVIL ACTION - LAW ACTION IN CUSTODY MOLLY A. BRENNAN, Plaintiff RANDALL MAIER, Defendant STIPULATION FOR ENTRY OF CUSTODY ORDER AND NOW, the undersigned parties, Molly A. Brennan (hereinafter "Mother") and Randall Maier (hereinafter "Father"), having reached an agreement regarding the custody of their minor child, Samuel Michael Brennan (hereinafter "the child"), born December 6, 1998, hereby stipulate and agree to the entry of an Order of Court awarding custody of the child as follows: 1. Mother and Father agree to share legal custody of the minor child. Major decisions affecting the child's growth and development shall be made by the parents jointly. These decisions include but are not limited to religious, educational, and medical matters. In an emergency, the parent having physical custody at the time shall be permitted to make any decisions necessitated by the emergency without consulting the other parent in advance. However, the parent making the emergency decision shall inform the other parent of the emergency and consult with him or her as soon as possible. Day-to-day decisions of a routine nature, including those related to medical care, shall be the responsibility of the parent having physical custody at the time. Each parent shall be entitled to complete and full information about the child from any doctor, dentist, teacher or other school authority. Each parent has the right to receive copies of any reports from the aforesaid persons. 2. Mother and Father agree that Mother shall have primary physical custody of the child and Father shall have partial physical custody. Father shall have the following visitation schedule: Alternating weekends, with the custodial period beginning on Saturday at 2:00 p.m. Page 1 of 3 U~,,"p<r._ - >-{-,". --","=~,'>"--~ ,_.."", ~-'" ,: ,~-,,--''', ~ ,'" .,,~~ ., -'-~.' ."~. *, 0"-1 - ",-~ -.' =~.-- " ,- 'n._._ ". - '" ~ . and ending on Monday at noon. Father shall have the sole responsibility for the transportation. 3. With the exception of Christmas Eve and Christmas day, custody of the child on holidays will be arranged by mutual agreement of the parties. Mother shall have child on Christmas Eves, and Father shall have custody on Christmas day at a time to be arranged by mutual agreement of the parties. This Christmas holiday schedule will supersede the regular custodial schedule. The parties agree that when the child reaches the age of five years, the aforesaid schedule can be changed so that the parties will alternate custody of the minor child on Christmas Eves. 4. Father shall have child on child's birthday whenever the child's birthday falls during Father's custodial period. 5. Mother shall have child on every Mother's Day, and Father shall have child on every Father's Day. 6. Father shall have two weeks of custody of the minor child each year. The weeks may be taken consecutively or individually. Father will give Mother 30 days notice of his intent to exercise this right. 7. The parties agree to take whatever steps are necessary to ensure that the child resides in an environment free from the excessive use of alcoholic beverages. The parties further acknowledge that a failure to adhere to this provision will constitute a direct violation of this Order. 8. The parties agree to act always in the best interests of the child by cooperating fully with each other in the implementation of the Custody Order. Page 2 of 3 J~TIIf '-'c,'f_~"_ _, .,~.,"._",>",_,,,,__S", ,,..,'p,'._. ' . '"",_,""= ,0' ~,-- _H"_'f~~_+ - - , "~, --, - ,'_'.,A .'."=. - IN WITNESS WHEREOF, the parties have executed this Stipulation for Entry of a Custody Order. /O-{t .(/lJ Date 10. ftrrAJ Date i-'I)---"" ," - , -'c-~'T,A'"F'~~' . ,'_,H" ~~ Witness ~ ",- -"~--,,.-'hf_':'''''_''~_,_ '.-'_.' " .' '" "" _._,,---,- -'-.' .', 1.,':--' Page 3 of 3 , ., ~lrlrtUv/~ f!p.Jf/J/~ Molly A. Brenna f(a..._~a/ Me:. Randall Maier . _ ._,~_,"__ ~-',,_,"__, ,._. ".__~. 0 c_.___~ -