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Home My WebLink About01-03513 ~ ... ",. vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CIVIL TERM 2001 _ 3513 ~ ~ KRISTEN L. THOMPSON, plaintiff GEORGE R. THOMPSON, JR., Defendant IN DIVORCE AND CHILD CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS You have. been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counselling. A list of marriage counselors is available in the Office of the Prothonotary at Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 'W;,< _",,~,",~;o~_,-~,_,j_," "" ," _~'" "","'"_~,< _~ ~~~" "" , ,~-. ... ,,' vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW CIVIL TERM 2001-35n3d..;..:J 1..<- KRISTEN L. THOMPSON Plaintiff GEORGE R. THOMPSON, JR., Defendant IN DIVORCE AND CHILD CUSTODY COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE COUNT I - DIVORCE 1. Plaintiff is Kristen L. Thompson, an adult individual, who currently resides at 1119 Nanroc Drive, Mechanicsburg, Lower Allen Township, Pennsylvania 17055, since December, 1999. 2. Defendant is George R. Thompson, Jr., an adult individual, who currently resides at 5269 East Trindle Road, No.1, Hampden Township, Mechanicsburg, Pennsylvania 17055, since April, 200l. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 17, 1996, at Churchtown, Cumberland County, Pennsylvania. 5. The parties separated on April 20, 2001. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised of the availability of marriage counselling and that the Plaintiff may have the right to request that the court require the parties to participate in counselling. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. " " ",,-- . ", ':""" ';'1'!;<!:I~rj ,'!- , f", ,- i, - "--'-_ '?',\",~',N--l."'_'" '_~_"''''''~;'__.'''''d".'o'_. .'" 1,~'",~, _ n ~-_', '" - .F, , ".--' --~">,,",,-, ~ .' _, ._c, ."" ". ' .,~, > ',-,", " , 't" COUNT II - CHILD CUSTODY 9. The averments of Paragraphs 1 through 8 of Count I are incorporated herein by reference thereto. 10. Plaintiff seeks shared legal custody and primary physical custody of the following children: George R. Thompson, 1119 Nanroc Drive, Mechanicsburg, PA 17055, age 4, born February 20, 1997. William B. Thompson, 1119 Nanroc Drive, Mechanicsburg, PA 17055, age 3, born May 19, 1998. 11. Plaintiff, Kristen L. Thompson, is the Mother of the children. The Defendant, George R. Thompson, Jr., is the Father of the children. The children reside with the Plaintiff. 12. The parties have not participated in any other litigation regarding the custody of these children in this or any other Court. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 13. The best interest and permanent welfare of the children will be served by entering an Order of Court consistent with the written Agreement of the parties. 14. The written Agreement of the parties is attached hereto, made a part hereof and marked Exhibit "A". WHEREFORE, the Plaintiff requests the Court enter an Order awarding shared legal custody to the Plaintiff and the Defendant, primary physical custody to the Plaintiff, and partial custody "-'1-, '".<- ,~-~"-~'Y'",__",,,,_,",,"_'>~""~" ".*" "",iIY;'J,;f,_fl"~'~_"?>~'~""-!'-"i""'~~ _","" .~, '. ."'"',.",-'" "r;,'~' '" .~ -~,,,, " - ."' "~" . .., " and visitation to the Defendant as set forth in the Agreement of the parties. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. 1/N4!;,XJ M.' r; l DAJ I/) A /rU ) Kr1sten L. ~~~~~r~ DATE: May 3/, 2001 By: 1f Dale F. Shugh Attorney for Attorney I.D. 19373 35 East High Street, Suite 203 Carlisle, PA 17013 (717) 241-4311 -"", ,,~'-'-~',<^ , ,- ~"~.~"c,"-,"""'_-_,_ ,~~ 0_ _L'_,~ ",-,',", "' . ~"_~, ._~ ~.~,~< _ ___ ~,=_ "_ _ _~,' ,~, ~ vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CIVIL TERM 2001 - 3 5/ 3 c..;;:..e II-<- KRISTEN L. THOMPSON, plaintiff GEORGE R. THOMPSON, JR., Defendant IN DIVORCE AND CHILD CUSTODY TH! S AGREEMENT, CHILD CUSTODY AGREEMENT (~Of made this May, 2001, by and between KRISTEN L. THOMPSON, of 1119 Nanroc Drive, Mechanicsburg, Pennsylvania, 17055, hereinafter MOTHER and GEORGE R. THOMPSON, JR., of 5269 East Trindle Road, No.1, Mechanicsburg, Pennsylvania, 17055, hereinafter FATHER, WITNESSETH: WHEREAS, the parties are husband and wife, who married on August 17, 1996, separated on April 20, 2001, and are the natural parents of two minor children, George R. Thompson, born February 20, 1997 and William B. Thompson, born May 19, 1998; and WHEREAS, the parties have reached an agreement regarding custody arrangements for their minor children and desire to place ~~c- agreement 1.:1 "t-.'riti.-ng a!ld tr) b?ve it entered a~ an Ordel:" or Court; and WHEREAS, the parties contemplate completion of a No-Fault Divorce and that this Agreement be entered as an Order of Court in conjunction with said divorce proceedings, above captioned. NOW, THEREFORE, the parties hereto, intending to be legally bound hereby, do covenant and agree as follows: ,.~~ ,. '_,_7_,", .' . "':\;'"','_?_j~~ W~, ~""_~.>,,, :--y,~-",!';'_ '~' :_,;,-._"",!~"7"hl',~t""'~'{7:'-::,~'''~'~!''::''',:,-"",,,,, ,,",!,.;,",,-'"'' ".;4._ .--'"- ';"'T__ '." '-'~',>c -~'", ~,,,.,. ;0'__0' t_,_. 'H. ~_'"',o_.. ~.. , <" 1. The Mother and Father shall have shared legal custody of their two minor children, George R. Thompson, born February 20, 1997 and William B. Thompson, born May 19, 1998. 2. The Mother shall have primary physical custody of the two minor children. 3. The Father shall have frequent and extensive partial custody of and visitation with the two minor children, as follows: 3. One or two days a week on the day or days, when the Father shall not be working, from 4:00 p.m. to 5:00 p.m. until 8: 00 p. m. Father shall pick up children at babysitter's home. b. One weekend per month from Friday evening at 4:00 p.m. to 5:00 p.m. until Sunday evening at 8:00 p.m. Father shall pick up children at babysitter's home. The Father shall provide Mother two weeks advance notice which days and weekend he will have partial custody of the children. c. An equal share of holidays. d. Such other times as the parties shall agree. 4. The Father shall be responsible for providing transportation for the children for purposes of his periods of partial custody/visitation. 5. The parties desire that this Agreement shall be made an Order of Court in the Court of Common Pleas, Cumberland County, Pennsylvania, further acknowledge that the Court of Common pleas of Cumberland County, Pennsylvania, does in fact have jurisdiction over the issue of the custody of the parties' minor children and '--}:J"1_, ~>" ~':--;'_""~ ",;"",_,.' ",0, > ",_",_""",__,,- __'.'k'" ,--, ""-_",,,'<','''''7':'l'h'--' --^ ,~;,,,<, ~, ~'-; ~- _.~ ~, <,' -, , " [ ,.< . . . shall retain such jurisdiction should circumstances change and either party request a modification of said Order. IN WITNESS WHEREOF, the parties hereto set their hands and seals the day and date first above written. Witness: ~tuv,C\\\~^ [SEAL] Kristen L: ~h~~~~~~v' - [SEAL] '''~ - 7,_~_,. ';'''",F"-r;-''''.:'oc'_'-.' ";'''- ~ o,'~ . ~,< ,;.' ~,- " ,<, _'. _",,';y,,__-""''',_'O-",_. ',_ _ .' , ,: - ": '~'---.' >" 'co- o~_.. ,~_, ~'. _,_. " ~ . '-~-~"~ ~, ~ ""= ~" ~ (:) ~ -0 CD S2f.T1 -;r:.Ll .?_ r-- (fJ-:;'-:" --<:7 ~C) ~C) --0 Pc: Z =< ~=, ~:!> :3: o ',;,,:-n ~.-j i~ ~(~ (!,S;J ~2!'M o ~'.'i ~ -< ~ ~~ I .~J ~, t-S 10 I , I , I; I, I la " ]1 I! l !1' ,., II ~ !I Ii Jf !I 11 !I '-.l ~t ~, ~ ,,,,\ ~~ --.I "'\ ':'i v, ~ 'd Do 0 d ,-, ..... ~ f '" " '" ..... "'l '., '" ,~. ., ,w," 'C__',,,_;.,,, -.'~, '. . '" "~,.;-r:~":;10''-' ',' "",-,- ' ~~~~,*~jjff;":",:-~:"~,,?,;,,,, ,'.~,~ 1"'""-1\. --':'-':'.'-~~ j _ ____,_'_:O,'}"( .<-".;':'"""'~:"-:"'n:,~ " , .n- )- \ . , ~oo~ I. 0 Nor ()lJ\ KRISTEN L. THOMPSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. CIVIL TERM 2001- 3~-J:.3 GEORGE R. THOMPSON, JR., Defendant IN DIVORCE AND CHILD CUSTODY ORDER OF COURT AND NOW, this ~ J.&t day of "j ~ , 2001, upon review of the attached Agreement of the parties and on motion of Dale F. Shughart, Jr., Esquire, attorney for Plaintiff, Kristen L. Thompson, IT IS HEREBY ORDERED AND DECREED: 1. The Mother, Kristen L. Thompson, and the Father, George R. Thompson, Jr., shall have shared legal custody of the parties two minor children, George R. Thompson, born February 20, 1997 and William B. Thompson, born May 19, 1998. 2. The Mother, Kristen L. Thompson, shall have primary physical custody of the parties' two minor children. 3. The Father shall have extensive partial custody of and visitation with the parties' minor children, as follows: a. One or two days a week on the day or days, when the Father shall not be working, from 4:00 p.m. to 5:00 p.m. until 8:00 p.m. Father shall pick up children at babysitter's home. b. One weekend per month from Friday evening at 4:00 p.m. to 5:00 p.m. Sunday evening at 8:00 p.m. shall pick up children at babysitter's home. Father The Father shall provide Mother two weeks advance notice which days and weekend he will have partial custody of the children. "',GI_ -- - "";~ _"",*;;"o'~_ """,",,,,,,'~,~,", ",~~,_ ,"__ __ ~,--<, ~, ""'1" _, .^ ~_" ____ ..' ~~~~~ , .., '~ '..', c. An equal share of holidays. d. Such other times as the parties shall agree. 4. The Father shall be responsible for providing transportation for the children for purposes of his periods of partial custody/visitation. 5. The Court shall retain jurisdiction of this matter. Should circumstances change, either party may request a modification of this Order. This Order shall remain in force and effect until further Order of this Court. y ~~ (j.O\ l;1l J. ~'1- , . , "r:'!"""-",~"'",'~"m<,'_,,.~,.,~o,, "F- __,_, ,~,'t"";,:".'!'_-"""",C'''^'''''''''' --, ."'_",_..'"_,__''_, ,,_0- .lid'" -.i t~ni'~'IiIIlIllMi':' ,-:<,!--," - \- '"~~lt_Wmt~,...;, , ," ~-"- , '~'-_,"''':''-'f<' - ~~ ,-=--- OF 'F':LFC}-Cl~F\CE '_'7',' r-r;'~..,;nl\\(1T L,-RV "",. .,,."'-,Ll\I\ 01 JUN-8 Pi; 3:0! CUMBERu\f~D COUNTY PENNSYLVANIA 05 C73 ~ I , f, ,. KRISTEN L. THOMPSON Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW vs. CIVIL TERM 2001-35"13 GEORGE R. THOMPSON, JR., Defendant IN DIVORCE AND CHILD CUSTODY MOTION FOR ENTRY OF CUSTODY ORDER AND NOW, comes the Plaintiff above captioned, Kristen L. Thompson, by her attorney, Dale F. Shughart, Jr., Esquire, and respectfully represents as follows: 1. Plaintiff is Kristen L. Thompson, and the Defendant is George R. Thompson, Jr. 2. The parties have entered a Custody Agreement for custody of their two minor children, George R. Thompson, born February 20, 1997 and William B. Thompson, born May 19, 1998, a copy of which is attached hereto, made a part hereof and marked Exhibit "A". 3. This Motion is being filed contemporaneously with the filing the above captioned divorce action which contains a Custody Count to which the aforementioned Agreement is also attached as an Exhibit. WHEREFORE, Plaintiff prays Your Honorable Court to enter an Order providing for shared legal custody, primary physical custody in the Plaintiff, and partial custody and visitation in ,,}, ,1 ',',- ^ '__-",5;;-;-~"",?_,~,~i,'_'~,?-_,, "',' .~""-'_'"":'_,_O<--_"'--'" '-'-"'~""',' _""__, ;"'__ '" '" ___, '0 c.'~_. _ " _" .<. . : t'. the Defendant, in accordance with the attached Agreement of the parties, in form attached hereto. Respectfully gh rt, Jr. Court I. . 19373 35 East High Street, Suite 203 Carlisle, PA 17013 (717) 241-4311 Attorney for plaintiff Kristen L. Thompson ,- ~;,h,,_"",-''I'''''''''_' _~ ~,,~~_ __"'" <,""''''"''-"'',_ ""~, .,,,",,.= __" ",,~ -', ' "___" _'"', '. .. ^" ~M , . , KRISTEN L. THOMPSON, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. CIVIL TERM 2001 GEORGE R. THOMPSON, JR., Defendant IN DIVORCE AND CHILD CUSTODY THI S AGREEMENT, CHILD CUSTODY AGREEMENT made this ~ay of May, 2001, by and between KRISTEN L. THOMPSON, of 1119 Nanroc Drive, Mechanicsburg, Pennsylvania, 17055, hereinafter MOTHER and GEORGE R. THOMPSON, JR., of 5269 East Trindle Road, No.1, Mechanicsburg, pennsylvania, 17055, hereinafter FATHER, WITNESSETH: WHEREAS, the parties are husband and wife, who married on August 17, 1996, separated on April 20, 2001, and are the natural parents of two minor children, George R. Thompson, born February 20, 1997 and William B. Thompson, born May 19, 1998; and WHEREAS, the parties have reached an agreement regarding custody arrangements for their minor children and desire to place the agreement in writi.ng and to have it. entered as all Order of Court; and WHEREAS, the parties contemplate completion of a No-Fault Divorce and that this Agreement be entered as an Order of Court in conjunction with said divorce proceedings, above captioned. NOW, THEREFORE, the parties hereto, intending to be legally bound hereby, do covenant and agree as follows: '~."._,~ --. '" ...",,~,R:; ,*,,,_,~-,,,;,,~,,--. . ,"'" ' ,?,,~,,}. -"~,,, '_'t,,~-, 'I'- ~_",:, ''''-'_Tn--<c~-_''''';: ,;~~\""P;~-" '- -- , -, - " '_"0 ' -~ ..-",. ~" -. '- ,,)', --~, ',,' "-".,,".,.-' .. , ~, . . 1. The Mother and Father shall have shared legal custody of their two minor children, George R. Thompson, born February 20, 1997 and William B. Thompson, born May 19, 1998. 2. The Mother shall have primary physical custody of the two minor children. 3. The Father shall have frequent and extensive partial custody of and visitation with the two minor children, as follows: a. One or two days a week on the day or days, when the Father shall not be working, from 4:00 p.m. to 5:00 p.m. until 8:00 p.m. Father shall pick up children at babysitter's home. b. One weekend per month from Friday evening at 4:00 p.m. to 5:00 p.m. until Sunday evening at 8:00 p.m. Father shall pick up children at babysitter's home. The Father shall provide Mother two weeks advance notice which days and weekend he will have partial custody of the children. c. An equal share of holidays. d. Such other times as the parties shall agree. 4. The Father shall be responsible for providing transportation for the children for purposes of his periods of partial cUDtody!vigitati~~. 5. The parties desire that this Agreement shall be made an Order of Court in the Court of Common Pleas, Cumberland County, Pennsylvania, further acknowledge that the Court of Common Pleas of Cumberland County, Pennsylvania, does in fact have jurisdiction over the issue of the custody of the parties' minor children and '," "',,,,-'OJ'_~-'J'-c,,,,,__ _,~,,;,~___",),,"~'(,J-, '_"':\('_;'''_':'~ ;'^,' \, -< 8', ,. 'n,- _-, !_'".:>:?,'_' ',,,," ,~"i- ;"'-'," "",,'~," ,,_.Oc" . ":__ ~~__ "',,~-'- ~-_, _. ,< , "H,,!., 'r--, - , "<--", .- :"'1 , , , shall retain such jurisdiction should circumstances change and either party request a modification of said Order. IN WITNESS WHEREOF, the parties hereto set their hands and seals the day and date first above written. Witness: vJ^~ ~[SEAL] Kristen L. Thompso ~ ~78EAL] George . Tho~son, Jr. ';;;.m:" - .,Ii '_.'lif"!;')'~""t.~.'tc~','$m'7"3",,';'::'??";")' '~_'_~~"'-;':'-" , !~'~'~'''1: ,:,~;,->]},-.""c,)" ,,' --" - -'-r,--8',"",:' ., 0"'" "''> '" "c"'" __"','~.'" ,,_ '-;.0'. ., KRISTEN L. THOMPSON Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW vs. CIVIL TERM 2001 GEORGE R. THOMPSON, JR., Defendant IN DIVORCE AND CHILD CUSTODY CERTIFICATE OF SERVICE AND NOW, this 7~ day of June, 2001, I, Dale F. Shughart, Jr., Esquire, attorney for Kristen L. Thompson, Plaintiff, hereby certify that I have served a copy of the Motion for Custody Order by mailing a copy of the same by United States mail, postage prepaid, addressed as follows: George R. Thompson, Jr. 5269 East Trindle Road, No. 1 Mechanicsburg, PA 17055 203 ~ '-,- - _;"f"'_~~_'~''''!}-~'0'~~;c_,~_;",,,,~,!,,;,;e_l'''''7<''' '-;"'"~'''o::"' - ,~, -,", ,--.,-,~." '---I ~~, '",", ~,' _,. ." 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