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Home My WebLink About99-03227 jt 1 •V ? ` .1 .... JAMES AND BARBARA COX, Plaintiffs V. REBECCA L. COX, DANIEL W. AZEN Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVILTEPSf'\ 9i4- 3awl : CHILD CUSTODY ORDER OF COURT AND NOW, this d 7thday of /)IW, 1999, upon presentation and consideration of the Agreement of the Parties, the terms and conditions of the Custody Agreement and Stipulation are incorporated herein and made an Order of Court. w JAMES AND BARBARA COX, Plaintiffs V IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL TER(Yl REBECCA L. COX, DANIEL W. AZEN Defendants : CHILD CUSTODY CUSTODY AGREEMENT AND STIPULATION AND NOW, this day of °i 1 , 1999, the Plaintiff's and Defendants to this proceeding agree as follows: 1. Plaintiffs are the maternal grandparents of Daniel James Cox, born 1/3/93. 2. Defendants are the biological parents of Daniel James Cox. 3. Alfred and Linda Azen are the paternal grandparents of Daniel James Cox. 4. Without the need for court appearances or further legal proceedings in this case, the Plaintiffs and Defendants agree that a Custody Order regarding the child, Daniel James Cox, may be entered, providing as follows: a. Legal custody shall be shared by Plaintiffs, Defendants, and Alfred and Linda Azen. b. Plaintiffs shall have primary physical custody of the child. c. Defendants shall have partial physical custody of the child, at times agreed upon by Plaintiffs and Defendants. d. Alfred and Linda Azen shall have partial physical custody of the child, at times agreed upon by Plaintiffs and Alfred and Linda Azen. e. The child shall be enrolled in the school district where Plaintiffs reside, as this is the location where the child primarily resides. f. This Order may be modified only by written agreement of the parties, as well as Alfred and Linda Azen, or by further Order of Court, after petition by either parent or by maternal or paternal grandparents. WHEREFORE, the parties request that an Order be entered, providing for the above agreement. Respectfully Submitted, Date: stg 9 LWAt ON REBECCA L. COX, Mother DANIEL W. AZEN, Father c4AMES COX, Maternal Grandfather BY: Samuel W. Milkes, Esq. JACOBSEN & MILKES 52 E. High Street Carlisle, PA 17013 (717) 249-6427 (717) 249-8427 Fax Attorney No. 30130 Attorney for Paternal Grandparents BARBARA COX, Maternal Grandmother e. The child shall be enrolled in the school district where Plaintiffs reside, as this is the location where the child primarily resides, f. This Order may be modified only by written agreement of the parties, as well as Alfred and Linda Azen, or by further Order of Court, after petition by either parent or by maternal or paternal grandparents. WHEREFORE, the parties request that an Order be entered, providing for the above agreement. Respectfully Submitted, Date: REBECCA L. COX, Mother DANIEL AZ N, er JAMES COX, Maternal Grandfather IBY: emus! W. Milker, Esq. JACOBSEN & MILKES 52 E. High Street Carlisle, PA 17013 (717) 249-6427 (717) 249-8427 Fax Attorney No. 30130 Attorney for Paternal Grandparents BARBARA COX, Maternal Grandmother ic: a ? ,-- 1 f" _ i:= ?.i! ?. . i;; ?: ? ? '-? - i. r'.. G. "".i [ 7 i-, C?`,' CJ t1i - t _.?. ' ? ? l ii.. ' ! I C: l,'? C,l ,, ?, JAMES AND BARBARA COX, Plaintiffs V. REBECCA L. COX, DANIEL W. AZEN Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO.C?q_3aagCIVILTERPI : CHILD CUSTODY 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 attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without further notice for any money claimed in the complaint or for any other claim or relief requested 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 TELEPHONE: 717.249-3166 Samuel W. Milkes, Esquire Attorney for Paternal Grandparents JAMES AND BARBARA COX, : IN THE COURT OF COMMON PLEAS Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. CIVIL T£R.tn REBECCA L. COY, qq- 3aa`? DANIEL W. AZEN Defendants : CHILD CUSTODY CUSTODY COMPLAINT PETITION AND JOINDER AND NOW COME, JAMES AND BARBARA COX, who by agreement with the birth parents, seek an Order granting them legal and physical custody of their minor grandson, Daniel James Cox, born 1/3/93. In support hereof Plaintiffs assert as follows: 1. Plaintiffs are the maternal grandparents, JAMES AND BARBARA COX, residing at 212 Belle Vista Drive, Marysville, Cumberland County, Pennsylvania, 17053. 2. Defendants are REBECCA L. COX and DANIEL W. AZEN, the birth mother and birth father of Daniel James Cox. Mother resides at 125 Wheatfield Lane, Shermans Dale, Perry County, Pennsylvania, 17090. Father resides at 454 Victoria Avenue, Piscataway, New Jersey 08854. 3. Plaintiffs seek primary physical custody of their grandson, DANIEL JAMES COX, born January 3, 1993. The child was born out of wedlock. The child is presently in the physical custody of mother. Since his birth, the child has resided with the following persons and at the following addresses: From birth through August 27, 1998, the child resided with the maternal grandparents at 212 Belle Vista Drive, Marysville, Cumberland County, Pennsylvania, 17053. Until late 1995, the child also resided with mother at this address; From August 28, 1998 through the present, the child has resided with mother and her male friend at 125 Wheatfield Lane, Shermans Dale, Perry County, Pennsylvania, 17090, Pennsylvania. 4. The mother of the child is defendant, REBECCA L. COX. She is not currently married. 5. The father of the child is defendant, DANIEL W. AZEN. He is unmarried. 6. The plaintiffs are the child's maternal grandparents. 7. The defendant REBECCA L. COX is the child's biological mother. 8. The defendant DANIEL W. AZEN is the child's biological father. 9. Plaintiffs have not participated as a party or witnesses, or in another capacity, in other litigation concerning the custody of the child in this or another court. 10. Plaintiffs have no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 11. Plaintiffs do not know of a person not a party to the proceedings who has physical custody of the child or claims at this time to have custody or visitation rights r with respect to the child, except that the paternal grandparents, ALFRED AND LINDA AZEN, residing at 816 Appletree Lane, Mechanicsburg, Pennsylvania 17055 have played and continue to play a significant role in this child's life and as a part of the agreement entered in this case, provisions are being made for their continued contact with the child. 12. The best interests and permanent welfare of the child will be served by entering the attached proposed Order, which the parties to this Custody Complaint agree may be entered as an Order of Court. WHEREFORE, plaintiffs request this Honorable Court grant the Order stipulated to by the parties. Respectfully submitted, IN- Samuel . Milkes, Esq. JACOBSEN & MILKES 52 E. High Street Carlisle, PA 17013 (717) 249-6427 (717) 249-8427 Fax Attorney No. 30130 We hereby -verify that the statements made in the foregoing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated: Dated: S? 0 6 IES COX BARBARA COX i T I? vl k ZZZ ",