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Home My WebLink About99-04513 JENNIFER M. THOMPSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. QQ "C/.r?? lJt?i lhc/LrL DONALD L. THOMPSON, JR., CIVIL AC71ON - LAW Defendant CUSTODY CUSTODY COMPLAINT TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW COMM, Jennifer M. Thompson, Plaintiff, and states the following: 1) Plaintiff, Jennifer M. Thompson, is an adult sui juris, who currently resides at 127 Summer Lane, Enola, Cumberland County, Pennsylvania 17025. 2) Defendant, Donald L. Thompson, Jr., is an adult sui juris, who currently resides at 108 Apartment B tad Street, West Fairview, Cumberland County, Pennsylvania 17025. 3) Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4) The parties were married on October 11, 1997, in Enola, Pennsylvania. 5) That on June 5, 1995, Taylor C. Thompson was born of the marriage. 6) That said Child has resided with the following parties as follows: a) Jennifer M. Sheaffer (Thompson) 2001 Red Bank Road Birth to 4/96 Donald L. Thompson, Jr. Dover, PA b) Jennifer M. Sheaffer (Thompson) 94 Pine Street 4/96 to 12198 Donald L. Thompson, Jr. Dillsburg, PA 17019 John W. Sheaffer, Jr. c) Jennifer Ni Thompson 94 Pine Street 12/98 to 3/99 John W. Sheaffer, Jr. Dillsburg, PA 17019 d) Jennifer M. Thompson 127 Summer Lane 3/99 to Present David 0. Olson Enola, PA 17025 Steven C. Olson 7) That a Custody Stipulation executed by the parties evidencing their mutual agreement with respect to the custody of their daughter, Taylor C. Thompson and a proposed Order is being filed contemporaneously herewith and a copy is attached hereto as Exhibit W. 8) Neither party is a member of the Armed Forces of the United States. WHEREFORE, Plaintiff requests that this Honorable Court enter an Order similar to set Order in Exhibit "A". Respectfully submitted, 127 Summer Lane Enola, PA 17025 (717)728-7535 VERIFICATION Jennifer M. Thompson hereby states that she is the Plaintiff in this action and that the statements of fact made in the foregoing Custody Complaint are true and correct to the best of her personal knowledge, information and belief. The undersigned understands statements herein are made subject to the penalties of 18 Pa. Cons. Stat. §4904, relating to unsworn falsification to authorities. Date_E?;)?() ? 95 ife M. mp JENNIFER M. THOMPSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. DONALD L. THOMPSON, JR., CIVIL ACTION - LAW Defea tnt CUSTODY ACCEPTANCE OF SERVICE I, Donald L. Thompson, Jr., Defendant in the above captioned custody matter, hereby accept personal service at J "ID tN1,tYle? ? Gl?c?l A , Pennsylvania, of the Custody Complaint, filed in the Court of Common Pleas of Cumberland County and Docketed to No. and filed Dated: ("*Jlj•`?l(r, Donald L. T mpso Jr., Defendant v (i a? V? of ,;T Q Ot ?J JENNIFER M. THOMPSON, Plaintiff V. DONALD L, THOMPSON, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.Qq- X1513 C ; U1 1 tQ.L%A CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this ? a day of, 1999, upon agreement of the patties, the attached Stipulation and Agreement of Custody is made an Order of Court. BY THE CO T J. J a? o? JENNIFER M. THOMPSON, Plaintiff V. DONALD L. THOMPSON, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. qq_ qs\3 CIVIL ACTION- LAW CUSTODY CUSTODY STIPULATION AND AGREEMENT THIS AGREEMENT and Stipulation entered into the day and year hereinafter set forth, is by and between Jennifer M. Thompson (hereinafter :'Mother') and Donald L. Thompson, Jr. (hereinafter "Father"), who aver as follows: 1) Jemufer M. Thompson, Plaintiff, is the natural mother and an adult SW juris, who resides at 127 Summer Lane, Enola, Cumberland County, Pennsylvania 17025. 2) 3) 4) Donald L. Thompson, Jr., Defendant, is the natural father, and an adult sw juris, who resides at 108 Apartment B, 2i° Street, West Fairview, Cumberland County, Pennsylvania 17025, Mother and Father are the parents of one (1) child, Taylor C. Thompson, born June 5, 1995. The parties, Jennifer M. Thompson and Donald L. Thompson, Jr. agree to the following custody terms regarding custody of the minor child Taylor C. Thompson and request the terms be entered as an Order of Court: a) Plaintiff Jennifer M. Thompson and Defendant Donald L. Thompson, Jr. shall have joint legal custody of the minor child. The parties shall share jointly in major decisions concerning the child's education, medical care and spiritual upbringing. b) The parties hereby agree that Plaintiff Mother shall have primary physical custody and Defendant Father shall have periods of partial temporary custody as follows: i) Every Tuesday and Thursday evening from 5:30 o'clock- p.m. until 9:30 o'clock p.m. ii) Evey other weekend from Friday at 5:30 o'clock p.m. until Sunday at 7:00 o'clock p.m. starting with the weekend of August 6, 1999. iii) A total of four (4) weeks non-consecutivc to be taken throughout the calendar from January through December. iv) On Memorial Day, Labor Day, and Thanksgiving from 9:00 o ,clock am until 9:0() o clock p.m. On Easter and Christmas from 8:00 o'clock p.m. the night before until 9:00 o'clock p.m. the following day. Therefore, in even membered years, Mother shall have physical custody on Memorial Day and Thanksgiving Day. In odd numbered years, Mother shall have physical custody on Easter, Labor Day and Christmas Day. v) Mother shall have physical custody on Mother's Day from 9:00 o'clock a.m. until 9:00 0 "clock p.m. irrespective of any other custody agreement. vi) Father shall have physical custody on Father's Day from 9:00 o'clock a.m. until 9:00 o'clock p.m. irrespective of any other custody agreement vii) Both parties shall have time with Child on Child's birthday, June S, or as agreed upon the day before or the day after. viii)AI all other times as mutually agreed upon by the parties. c) At no time shall Mother nor Father take the Child outside the Commonwealth of Pennsylvania unless the party provides at least thirty (30) days notice in writing, said notification to also provide the following information: i) the enact location to which the Child is to be taken ii) the length of time which the Child is to be out of the Commonwealth iii) A telephone number at which the non-custodial parent can reach the Child. S) HEALTH INSURANCE a) Father shall at all times maintain full health insurance on said child. 6) ENFORCEMENT If either party breaches any provision of this Agreement the other party shall have the right at her or his election, to sue for damages for such breach or to seek other remedies or relief as may be available to her or him, and the party breaching this Agreement shall be responsible for payment of reasonable legal fcz and costs incurred by the other in enforcing her or his rights under this Agreement. Failure to seek a remedy for one or more breaches shall not be deemed a waiver of arty subsequent breach. 6) ORDER OF THE COURT The parties agrm that this Agreement shall be entered as an Order of Court and shall continue in full force and effect until: a) Further Order of Court, or b) Stipulation of the parties. 7) ADDITIONAL INSTRUMENTS Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other any and all further instruments that may be reasonably roquired to give full force and effect to the provisions of this Agreement. 8) ENTIRE AGREEMENT This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements or negotiations between them with respect to Custodv of the minor Child Taylor C. Thompson. IN WITNESS THEREOF, the parties have hereunto set their hands and seals on the day and year rust above written. Donald L. Thompson, Jr. ?- r= c, N L cil U