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Home My WebLink About99-06228 s 4 r ?" ,[ y H f Y ?5-. . . t a a x _ f 19a F? -. ?` R 1 ! l Fr S+v; Y ? .. . s ... .. .. .... f ?• i Y > N ggi rc " M ? \% rat N?iT • 9?t S F; Tl ??CI:YReji d T S t Y _ zb u: e n+ ?- h ? f 4 g`^fp ? t y r ? !' s fi ? ? ? tl?:3 t Ilk' }cr Y' t Y Fx !1 Z ? 5 Y ? x tld' . i S Fi , i r i y '1Y ,pA - e fYVti 1- 0 •Rob Y f a[ • fib e• f C*i is o- - o kr .?d CONSTANCE C. WEBB, Plaintiff VS. ELAINE M. WEBB BOYD, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTIK, PENNSYL . NO. -lq CIVIL ACTION-LAW CUSTODY ORDER OF COURT AND NOW, this eday of O Z}}`? , 1999, upon consideration of the Complaint for Custody in the above matter, and die Stipulation for Custody of Minor Child of the parties, it is hereby ORDERED and DECREED that legal and physical custody of Qte minor child, Stephanie A. Frye, shall be granted to the Plaintiff Constance C. Webb, until further Order of Court, or agreement of the parties. The Defendant may have such visitation as the parties, from time to time, mutually agree. By the Court, Judge KLMOD C 6',d ',rln? 6C:8114'1 6I1'jUGG F1LE0.OrTr.F- OF THC PIOTHIONOTFAY 99 OCT 19 AM 8o 38 C"N COUNTY Pe"YLVl 9: CONSTANCE C. WEBB, Plaintiff VS. ELAINE M. WEBB BOYD, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW : NO. 99 - G -7,S ?wl TG" _ CUSTODY AND NOW, comes Constance C. Webb, by her attorneys, Purcell, Krug & Haller and files the following Complaint for Custody. 1. The Plaintiff is Constance C. Webb, residing at 1191 Letchworth Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant is Elaine M. Webb Boyd, residing at 90 Springer Lane, New Cumberland, PA County, Pennsylvania 17070. 3. The Plaintiff seeks custody of the following child: Name Present Residence Age Stephanie A. Frye 90 Springer Lane 14 New Cumberland, PA Stephanie A. Frye was born out of wedlock. The child is presently in the custody of the Defendant who resides at 90 Springer Lane, New Cumberland, Cumberland County, Pennsylvania. During the past year, the child has resided with the following persons and at the following addresses: • t Name Elaine M. Webb Boyd Address 90 Springer Lane New Cumberland, PA Date Nov, 1984 to present The mother of the child is the Defendant Elaine M. Webb Boyd, currently residing at 90 Springer Lane, New Cumberland, Pennsylvania. The Defendant is the daughter of the Plaintiff. 4. The relationship of Plaintiff to Stephanie A. Frye is that of Grandmother. The Plaintiff currently resides with the following persons: Bobby Hurley 5. The relationship of Defendant Elaine M. Webb Boyd and Stephanie A. Frye is that of mother and daughter. The Defendant currently resides with the following persons: Martin Wesley Boyd. 6. The 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. The Plaintiff has no information of a custody action concerning the child pending in a Court of this Commonwealth. The Plaintiff doe not know of a person not a party to the proceeding who has physical custody of the child or claims to have custody of the child. 7. The best interest and permanent welfare of the Stephanie A. Frye will he served by granting the relief requested because the Plaintiff and the natural mother Defendant Elaine M. Webb Boyd have executed a Stipulation which is attached as Exhibit "A". 8. The parent whose parental rights to the child has not been terminated and the person who has physical custody of the child has been named as party to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: (A) The natural father, Paul Frye who resides at 1516 Allison Street, Harrisburg, Pennsylvania 17101. 9. The parties have executed a Stipulation for the Custody of the Minor Child which is attached as Exhibit "A". The natural father, Paul Frye, has executed a Joinder which is attached hereto as Exhibit "B". WHEREFORE, the Plaintiff requests the Court to grant her custody of Stephanie A. Frye. Respectfully submitted, PURCEL KRUG & HALLER BY n Purcell, r. o. ( 1 .29955 719 North Front Street Harrisburg, PA 17102 E`. (717) 234-4178 ?t? CONSTANCE C. WEBB, Plaintiff VS. ELAINE M. WEBB BOYD, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW . NO. : CUSTODY STIPULATION FOR CUSTODY OF MINOR CHILDREN We, Elaine M. Webb Boyd, the Defendant and Constance C. Webb, the Plaintiff, in the above captioned matter, hereby stipulate and consent to the transfer of custody of Stephanie A. Frye, born November 19, 1984, to the Plaintiff, Constance C. Webb. WE VERIFY THAT THE STATEMENTS IN THE FOREGOING STIPULATION FOR CUSTODY ARE TRUE AND CORRECT. WE UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF IS PA. C.S.A. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. WITNESS: Qc_? 61 ?Ia Constance C. Webb i..1 "Z" ?1,,& -,k/ Elaine M. Webb Boyd EXHIBIT "A" CONSTANCE C. WEBB, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. ELAINE M. WEBB BOYD, : CIVIL ACTION-LAW Defendant : IN CUSTODY WITNESS: JOINDER I, Paul Frey, father of Stephanie A. Frye, bom November 19, 1984, join in the attached Stipulation for Custody, and agree to the transfer of physical and legal custody of my daughter, Stephanie A. Frye, to the Plaintiff, Constance C. Webb. I VERIFY THAT THE STATEMENTS IN THE FOREGOING STIPULATION FOR CUSTODY ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA. C.S.A. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Paul Frye Exhibit "B" VERIFICATION 1 verify that the statements made in the foregoing Complaint for Custody with Stipulation are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA C.S. § 4904 relating to unsworn falsification to authorities. j?-??i-9? Dated: Constance C. Webb . ;A r CIO li u_ rv i z w W W u q ? `? 7 ? pp ? 7 U 0 M ?oy l C F Y q O l r Pq a KI -H 41 ca ::) S4 9 E O ? A po d ?w [ 04 > F-4 z ° ~ H? i zc 8 w wMUwo.uu••w du.•.onG• ? • arro? oa.w.m AOI•llr1.1F OCT 12 ;tya 'f LAW OFFICES X v Lam. y? ?? '9iE " JOHN w. PURCELL 1719 NORTH FRONT STREET HOWARD A. KRUG HARRISBURG PENNSYLVANIA 17102.2392 LEON P. HALLER , JOHN W. PURCELL. JR. TELEPHONE (717) 234.4178 VALERIE A. GUNN FAX (717) 233.1149 JILL M WINEKA BRIAN J. TYLER E-MAIL 1aw0pkh.com NICHOLE M STALEY October 14, 1999 The Honorable Edward Guido Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Attn: Sandy Re: Constance C. Webb v. Elaine M. Webb Boyd Dear Sandy: NU15NCY 17191 533-3636 JO6[PN NIMEY 11010.16681 Enclosed is an original and two copies of the last page of the Complaint for Custody with the added paragraph concerning the natural father and signed Verification to be attached to the Complaint in the above referenced matter which you requested. If there is anything else you need, give me a call. Very W. Purcell, Jr. JWP,JR:cm Enclosure /7 • 1% - LAW OFFICES JOHN W. PURCELL 1719 NORTH FRONT STREET HOWARD 6 KRUG ER LEON P. HALLlR HARRISBURG, PENNSYLVANIA 17102.2392 JOHN W. PURCELL JR. TELEPHONE (717) 234.4176 VALERIE A GUNN FAX (717) 233.1149 JILL LL WINEKA BRIAN J. TYLER E-MAIL Iawopkhcoln NICHOLE M STALEY October 18, 1999 The Honorable Edward Guido Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Attn: Sandy Re: Constance C. Webb v. Elaine M. Webb Boyd Dear Sandy: ME117MET 17171 533-3830 JOSE" MG SLET 11510-15031 Enclosed is the Joinder of the natural father to the custody of his daughter, along with a second revised third page of the Complaint to be attached to the original. If the Judge needs anything further, please feel free to contact me. W. Purcell, Jr. Enclosures