The URL can be used to link to this page

Home My WebLink About03-1928 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES E. FOREST, Plaintiff, VS. CHRISTINA L. NORRIS, Defendant· : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is James E. Forest, presently residing at 23 Cleversburg Road, Shippensburg, Cumberland County, Pennsylvania 17257, with a mailing address of PO Box 568, Shippensburg, Pennsylvania 17257. 2. The Defendant is Christina L. Non'is, presently residing at 218 East King Street, Shippensburg, Cumberland County, Pennsylvania 17257. 3. Plaintiff seeks custody of the following child: NAME PRESENT RESIDENCE AGE Kayla Marie Forest 23 Cleversburg Road, Shippensburg, 8 years Cumberland County, PA 17257 (DOB 6-16-94) The child was bom out of wedlock. The child is presently in the custody of James E. Forest, who resides at 23 Cleversburg Road, Shippensburg, Cumberland County, Pennsylvania 17257. During the past five years, the child has resided with the following persons and at the following addresses: NAME James E. Forest, Father ADDRESS 16 Dead End Lane, Shippensburg, PA 17257 DATE 10/96 to 7/97 James E. Forest, Father 1215 W. Pecan Avenue Duncan, OK 73533 7/97 to 3/98 James E. Forest, Father 132 Holtry Road Shippensburg, PA 17257 3/98 to 2/99 WEIGLE & ASSOCIATES, P.C.-- ATTORNEYS AT LAW -- 126 EAST KING STREET --SHIPPENSBURG, PA 47257-1397 James E. Forest, Father Budget Host Inn Shippensburg, PA 17257 2/99 to 8/99 James E. Forest, Father Lisa Kelly, fianc6e Alicia Kelly Patrick Kelly Jessica Kelly 132 Holtry Road Shippensburg, PA 17257 8/99 to 12/99 James E. Forest, Father Lisa Kelly, fianc6e Alicia Kelly Patrick Kelly Jessica Kelly 114 Timber Lane Shippensburg, PA 17257 12/99 to 6/00 James E. Forest, Father Lisa Kelly, fianc6e 23 Cleversburg Road Shippensburg, PA 17257 6/00 to present The mother of the child is Christina L. Norris, currently residing at 218 East King Street, Shippensburg, Cumberland County, Pennsylvania 17257. She is married. The father of the child is James E. Forest, currently residing at 23 Cleversburg Road, Shippensburg, Cumberland County, Pennsylvania 17257, with a mailing address of PO Box 568, Shippensburg, Pennsylvania 17257. He is single. 4. The relationship of Plaintiff to the child is that of father. The Plaintiff currently resides with the following persons: NAME RELATIONSHIP Lisa Kelly fianc6e 5. The relationship of Defendant to the child is that of mother. The Defendant currently resides with the following persons: NAME RELATIONSHIP James Norris husband Tyler Mackey son 6. 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 another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. WEIGLE & ASSOCIATES, P-C.-- ATTORNEYS AT LAW -- 126 EAST KING STREET --SHIPPENSBURG, PA 17257-1397 Plaintiff does not know of a person, not a party to the proceedings, who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because the Plaintiff has been the primary custodian of the child since October 1996. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: NAME ADDRESS NONE BASIS OF CLAIM WHEREFORE, Plaintiff requests the Court to grant shared legal custody and primary physical custody of the minor child to the Plaintiff. WEIGLE & ASSOCIATES, P.C. By: Cseph ~. Ruane, Esquire ~ttom)~y for Plaintiff I.'154(71577 126 East King Street Shippensburg, PA 17257 717-532-7388 WEIGLE & ASSOCIATES, P-C.-- ATTORNEYS AT LAW -- 126 EAST KING STREET --SHIPPENSBURG, PA 17257-1397 VERIFICATION I verify that the statements made in the foregoing Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unswom falsification to authorities. Dated: g//(,,//0 ~ es~O,.,.,¥..~ Jm . Forest WEIGLE & ASSOCIATES, RC, -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES E. FOREST, Plaintiff, VS. CHRISTINA L. NORRIS, Defendant. CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT NOW, /~-fio~v)~ ~ ~' ' ,2003, upon consideration of the within Stipulation and Agreement, it is hereby ordered as follows: 1. James E. Forest ("James") and Christina L. Norris ("Christina") shall have shared legal custody of the child, Kayla Marie Forest, bom June 16, 1994 ("the child"). 2. James shall have primary physical custody of the child and Christina shall exercise partial custody every other weekend from Friday at 7:00 p.m. through Sunday at 7:00 p.m. 3. In addition to the rights of partial custody set forth above, Christina shall exercise rights of partial custody for two (2) weeks during the summer months, the dates of which to be mutually agreed upon by the parties in advance. Said two (2) weeks of partial custody in the summer may, but shall not necessarily, be exercised consecutively. 4. The parties shall altemate exercising rights of custody on the following holidays: New Year's Day, Easter Sunday, Memorial Day, Independence Day (July 4) and Labor Day. 5. James shall exercise rights of custody on Father's Day and Christina shall exercise rights of custody on Mother's Day. 6. In odd numbered years commencing in 2003, Christina shall exercise partial custody commencing at 2:00 p.m. on Thanksgiving Day and ending at 8:30 p.m. on Thanksgiving Day and Christina shall exercise partial custody commencing at 6:00 p.m. on Christmas Eve and ending at 2:00 p.m. on Christmas Day. 7. In even numbered years commencing in 2004, Christina shall exercise partial custody commencing at 6:00 p.m. on the Wednesday before Thanksgiving and ending at 2:00 p.m. on Thanksgiving Day, and Christina shall exercise partial custody commencing at 2:00 p.m. on Christmas Day and ending at 2:00 p.m. on December 26. WEIGLE & ASSOCIATES, P.E.-- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397 8. Christina shall have partial custody of the child in addition to that set forth herein as shall be mutually agreed upon by the parties. 9. In the event James is deemed incompetent or dies before the child reaches the age of majority, primary physical custody of the child shall be with Christina. 10. The welfare and convenience of the child shall be the prime consideration of the parties in any application of the provisions of this agreement. Neither party shall make negative or disparaging statements concerning the other party in the presence of the child. Neither party shall alienate or attempt to alienate or destroy the affection of the child for the other parent, but shall exert every reasonable effort to promote a feeling of affection between the child and both parents. 11. Neither party shall relocate and/or move out of the Commonwealth of Pennsylvania taking the child with them without the other parent's written consent or without further Order of Court. By the Court, WEIGLE & ASSOCIATES, RC. -- ATTORNEYS AT LAW -- 126 EAST KINg STREET -- SHIPPENSBURG, PA 17257-1397