HomeMy WebLinkAbout01-06853
BETHA. WOGAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL A<;:nON LAW
No. Ol-~ro
DAVID A. WOGAN,
Defendant
IN CUSTODY
ORDER
AND NOW, this
1,2"'"
day of
"2>~
2001, in consideration of the attached Stipulation Regarding Custody and Visitation, and signatures
therein, it is hereby ordered that:
(I) Shared legal custody of Josey Leanne Wogan as contemplated by the Act of November 5,
1984, P .S. S 1 00 1, et seq., is awarded to Mother and Father.
(2) Physical custody of the Child, Josey Leanne Wogan, is awarded to Mother subject to
visitation by Father at Mother's discretion.
BY THE COURT:
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BETH A. WOGAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION LAW
No. 0 (- (p f55J
DAVID A. WOGAN,
Defendant
IN CUSTODY
STIPULATION REGARDING CUSTODY-VISITATION
Plaintiff, Beth A. Wogan, hereinafter referenced as Mother, and Defendant, David A. Wogan,
hereinafter referred to as Father, hereby agree to the entry of the following terms in a Court Order
defining custody and visitation in relation to the parties' minor child: Josey Leanne Wogan, born,
December 15, 1998, hereinafter referenced as Child:
(1) Shared legal custody of Josey Leanne Wogan as contemplated by the Act of November 5,
1984, P.S. SlOOl, et seq., is awarded to Mother and Father.
(2) Physical custody of the Child, Josey Leanne Wogan, is awarded to Mother subject to
visitation by Father at Mother's discretion.
B~~~ntiff
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BETH A. WOGAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION LAW
No.
DAVID A. WOGAN,
Defendant
IN CUSTODY
CERTIFICATE OF SERVICE
1, Karl E. Rominger, Esquire, attorney for Plaintiff, do hereby certifY that I this day served a
copy ofthe Stipulation Regarding CustodyMsitation upon the following by depositing same in the
United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows:
David Wogan
96 Cold Springs Road
Carlisle, P A 17013
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Karl E. Rominger, Esquire
Attorney for Plaintiff
Dated: November 6, 2001
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BETH A. WOGAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION LAW
No. 01- 0853
DAVID A. WOGAN,
Defendant
IN CUSTODY
COMPLAINT FOR CUSTODY
1. The plaintiff is Beth A. Wogan, residing at 542A Criswell Drive, Cumberland County,
Boiling Springs, Pennsylvania.
2. The defendant is David A. Wogan, residing at 96 Cold Springs Road, Cumberland
County, Carlisle, Pennsylvania.
3. Plaintiff seeks custody of the following child:
Name
Josey Leanne Wogan
Present Residence
542A Criswell Drive, Boiling Springs, PA
Age
2 yrs. 11 mos.
The child was not born out of wedlock
The child is presently in the custody of mother who resides at 542A Criswell Drive,
Cumberland County, Pennsylvania.
During the past five years, the children have resided with the following persons and at the
following addresses:
List All Persons
David and Beth Wogan
List All Addresses
26 McBride Ave., Carlisle, P A
Dates
12/98 -11/99
David and Beth Wogan
96 Cold Springs Road, Carlisle, PA
11/99-12/00
Beth Wogan
542A Criswell Drive, Boiling Springs, PA 12/00-present
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The mother of the child is Beth Wogan, currently residing at 542A Criswell Drive, Boiling
Springs, P A.
She is married.
The father of the child is David Wogan, currently residing at 96 Cold Spring Road,
Carlisle, P A.
He is married.
4. The relationship of plaintiffto the child is that of mother.
The plaintiff currently resides with the following persons.
Name
Josey Leanne Wogan
Relationship
Daughter
5. The relationship of defendant to the child is that off ather.
The defendant currently resides with the following persons.
Name
No one
Relationship
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 children pending in a
court of this Commonwealth.
Plaintiff does not know of a person not a party to the proceedings who has physical
custody of the child and claims to have custody or visitation rights with respect to the
child.
7. The best interest and permanent welfare ofthe child will be served by granting the relief
request because:
Plaintiff has undertaken and performed the primary parental responsibilities for the child.
Plaintiff is best able to provide the care and nurture which the child needs for healthy
development.
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WHEREFORE, Plaintiff requests that this Honorable Court enter the attached Stipulation
in regards to Custody, as the parties have come to a mutually agreeable custody agreement and no
further hearing is required in this matter.
Respectfully submitted,
Date:
~
Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, P A 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Plaintiff
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. Cons. Stat. S 4904 relating to
unsworn falsification to authorities.
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Beth WagaR, Plaiffiiff
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