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HomeMy WebLinkAbout03-3070JAMES A. HIGH and BRENDA L. HIGH, husband and wife, Plaintiffs VS. GRACE C. HIGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. CUSTODY CUSTODY COMPLAINT AND NOW, comes plaintiffs, JAMES A. HIGH and BRENDA L. HIGH, by and through their attorney, MURREL R. WALTERS, III, ESQUIRE, who represents as follows: 1. The plaintiffs are James A. High and Brenda L. High, husband and wife, who reside at 929 Nixon Drive, Mechanicsburg, Cumberland County, Pennsylvania. Plaintiffs are the parents of defendant, Grace C. High. 2. The defendant is Grace C. High, who resides at 115 Dorseys Lane, Dillsburg, York County, Peunsylvania 17019. 1998. 3. Grace C. High is the mother of Deanna Irene High, who was bom November 3, 4. The natural father of the child is not definitively known. No one has identified himself as the father, made any claims for custody or visitation or has paid support during the lifetime of the child. 5. Deanna Irene High presently resides with her grandparents, the plaintiffs, James A. High and Brenda L. High, husband and wife, at their home at 929 Nixon Drive, Meehanicsburg, 3. Pennsylvania. 6. The best interests of Deanna Irene High will be served by establishing legal and primary physical custody with plaintiffs, while granting temporary physical custody to defendant. 7. An agreement has been reached between plaintiffs and defendant relative to custody of Deanna Irene High and is attached hereto. WHEREFORE, Plaintiffs request this Honorable Court to enter an order confi~the terms of that custody agreement. Res e~'tted,/ MURREL R. WALTERS, III, ESQUIRE Attorney for Plaintiffs 2 VERIFICATION I verify that the statements made in this complaint are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Ann § 4904 relating to unsworn falsification to authorities. Date; 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. Ann § 4904 relating to unsworn falsification to authorities. Date: Brenda L. High JAMES A. HIGH and BRENDA L. HIGH, husband and wife, Petitioners VS. GRACE C. HIGH, Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CUSTODY AGREEMENT FOR CUSTODY AND NOW, this [ ~dJ~- day of June, 2003, petitioners James A. High and Brenda L. High, husband and wife, and their attorney, Murrel R. Walters, 111, Esquire, and respondent Grace C. High, with regard to custody and visitation of Deanna Irene High, a minor child, stipulate and agree as follows: 1. The petitioners are James A. High and Brenda L. High, husband and wife, who reside at 929 Nixon Drive, Mechardcsburg, Cumberland County, Pennsylvania. Petitioners are the parents of respondent, Grace C. High. 2. The respondent is Grace C. High, who resides at 115 Dorseys Lane, Dillsburg, York County, Pennsylvania. 3. Grace C. High is the mother of Deanna Irene High, bom November 3, 1998. 4. The natural father of the child is not definitively known. No one has identified himself as the father, made any claims for custody or visitation or has paid support during the lifetime of the child. 5. The parties desire to enter into an amicable agreement for custody and visitation of Deanna Irene High. 6. Deanna Irene high presently resides with her grandparents, the petitioners, James A. High and Brenda L. High, husband and wife, at their home at 929 Nixon Drive, Mechahicsburg, Pennsylvania. 7. The parties have reached an agreement with regard to the custody of the minor child and they do hereby stipulate and agree as follows: James A. High and Brenda L. High, husband and wife, shall have legal custody ao of the child. b. child. C. James A. High and Brenda L. High shall have primary physical custody of the Respondent, Grace C. High, shall have temporary physical custody of the child as the parties may from time to time agree. WHEREFORE, Petitioners request this Court to enter an order confirming full legal, as well as primary physical custody of Deanna Irene High, with them, subject to temporary physical custody with Respondent, Grace C. High. rrel R.'Walters, 12I, Esq. Attorney for Petitioners Attorney No. 24849 54 East Main Street Mechanicsburg, PA 17055 (717) 6974650 I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Ann § 4904 relating to unsworn falsification to authorities. Date: I verify that the statements made in this Petition are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Ann § 4904 relating to unswom falsification to authorities. Date: Brenda L. High I verify that the statements made in this Petition are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Ann § 4904 relating to unswom falsification to authorities. Date: Grace C. High JAMES A. HIGH and BRENDA L. HIGH, husband and wife, Plaintiffs VS. GRACE C. HIGH, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. CUSTODY ORDER OF COURT AND NOW, this day of ~ ., 2003, upon consideration of the foregoing Complaint, along with attached Agreement of all parties, it is hereby ordered that JAMES A. HIGH and BRENDA L. HIGH, husband and wife, shall have full legal custody, as well as primary physical custody of DEANNE IRENE HIGH, subject to temporary physical custody with GRACE C. HIGH, as the parties may from time to time agree.