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Home My WebLink About01-05370 JILL E. BEAM, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. RICHARD L. BEAM, Defendant. No. ~l-J37C~ ~i1ri. IN CUSTODY ORDER OF COURT AND NOW, this 68r day of Yc..,Gv 2001, it is hereby ORDERED and DECREED that the attached Custody Stipulation is entered as an Order of this Court. BY THE COURT: ~~ :. . r • ~ ~,.;';' '~- C7 `~ r c~ ;~ "` ~ a; ;7.?> ~`: v ~~ a c JII.L E. BEAM, vs. IN THE COURT OF COMMON PLEAS Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA RICHARD L. BEAM, Defendant. : No. 6l-~~~~ a'c'v-~` IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before ,Esquire, the Conciliator, at ,Pennsylvania, on the day of , 2001 at _ _. M, for aPre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a temporary order. Either party may bring the children who are the subjects of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. For the Court, By Custody Conciliator 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. LAWYER REFFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166 Michael S. Travis ID No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717)731-9502 JII~L E. BEAM, vs. IN THE COURT OF COMMON PLEAS Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA RICHARD L. BEAM, Defendant. No. 2001- 5~ ~Q ~ c~V o IN CUSTODY COMPLAINT FOR CUSTODY TO THE HONORABLE JUDCTES OF SAID COURT: The Plaintiff is Jill E. Beam residing at 72 Tory Circle, Enola, Cumberland .--- County, Pennsylvania 17025. 2. The Defendant is Richard L. Beam residing at 1407 Yorktowne Road, Cumberland County, Mechanicsburg, Pennsylvania 17055. Plaintiff seeks shared legal custody and primary custody subject to the father's liberal periods of visitation of the following children: NAME PRESENT RESH)ENCE DOB Sean Mackenzie Beam 72 Tory circle, 1/7/93 Enola, PA 17025 Shaelyn Nicholle Beam 72 Tory Circle 9/21/96 Enola, PA 17025 The children were notborn out of wedlock. The children are presently in the custody of Jill E. Beam who resides at 72 Tory Circle, Enola, PA 17025. The children have resided with the following persons and at the following addresses for the last five years: Persons Addresses Dates Jill and Richard beam 1407 Yorktowne Road 6/93 - 7/1/01 Mechanicsburg, PA 17055 Jill Beam 72 Tory Circle 7/1/01 -date Enola, PA 17025 The mother of the children is Jill E. Beam, currently residing at 72 Tory Circle, Enola , PA 17025. She is married to the father. The father of the children is Richard L. Beam, currently residing at 1407 Yorktowne Road, Mechanicsburg, PA 17055. He is married to the mother. 4. The relationship of plaintiff to the children is that of mother. The Plaintiff currently resides with the children only. 5. The relationship of the defendant to the children is that of father. The defendant currently resides alone. 6. Neither party has participated as a parry or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 7. 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 children. 8. The best interest and permanent welfare of the children will be served by granting the relief requested because: A. Plaintiff has participated in the primary care of the children throughout their lives. B. Plaintiff can provide a stable environment. C. Plaintiff can provide a loving home. 9. Each parent whose parental rights to the children has not been terminated and the person who has physical custody of the child has been named as parties to this action. 10. The parties hereto have reached agreement with respect to custody. A copy of the parties Custody Stipulation and Agreement is attached hereto as Exhibit A. 11. The parties request that the Stipulation and Agreement be entered as an Order of Court. WHEREFORE, Plaintiff requests this Honorable Court to grant her shared legal custody and primary physical custody of the children subject to the father's periods of liberal visitation according to the custody stipulation attached hereto. Respec submitted, chael S. Travis Attorney for Plaintiff Supreme court ID No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717)731-9502 c~ ,~ r~ fi Vii.'; ~ r,T ' -_~ .z ~ - ~- r.- ~-' " ~~~ Wit' ~ -• ~_i ~ _y <.., .~ Michael S. Travis ID No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717)731-9502 JII.L E. BEAlO~I, Plaintifff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. RICHARD L. BEAM, Defendant. : IN CUSTODY CUSTODY STIPULATION AND AGREEMENT AND NOW, come the parties hereto, Plaintiff, Jill E. Beam ("Mother") and Defendant, Richazd L. Beam, ("Father") as said parties have reached mutual agreement as to the custody of their children Sean M. Beam, born January 7, 1993, and Shaelyn N. Beam, born September 21, 1996, and hereby stipulate to the following custody agreement, and hereby request the Court to enter the same as an Order of Court: Mother and Father shall share legal custody of said children, as to all matters regarding the children's health, education, and welfare. 2. Mother shall have primary physical custody of said children. Father's visitation schedule shall be as follows: Father shall have physical custody of the children on alternating weekends beginning and ending times as the parties may agree from Friday through Sunday begimung on August 27 , 2001. The parties shall share transportation of the children. Father shall have additional periods of visitation with the children during the week as the parties may agree. The non-custodial parent shall have liberal telephone contact with the children. 3. Holidays: Mother and Father shall shaze holidays as they may agree. 4. Father shall have one week of uninterrupted period of visitation during the summer, after having given at least thirty (30) days' notice to Mother. Faxhibit A r 5: - Father shall have visitation on Father's Day each year; Mother shall have visitation on Mother's Day each year. These days shall supersede the parties' regular schedule. If either parent is unable to keep their scheduled times of visitation, they shall provide at least twenty-four (24) hours' notice. 7. The parties shall have the right to modify any provision of the custody schedule hereto upon mutual agreement by both parties. In the event a proposed modification is not agreed to, the schedule as stated shall be complied with by the parties. The parties reserve the right to modify this Stipulation and Agreement through the court pursuant to Pennsylvania Law, as Cumberland County, Pennsylvania, shall retain jurisdiction. ~~ ~ ~~ Richard L. Beam, Defendant 6 x --..4 r . ,: a .. «:Adan~~-r ' ~°"''?~ VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements made herein aze made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: q'-(p -C?~ ~~~ ~=~ z r r"ri ~ _. G -- ~, r ~~: . 7 ~ , -. 3"`~ ~~ti 1 ~ -< G7 ..~