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HomeMy WebLinkAbout99-06930 I I A* JOSEPH BARRICK, SR. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. : CIVIL ACTION - LAW NO. 99- 6 436 CIVIL TERM MARLENE MURPHY Defendant : IN CUSTODY ORDER AND NOW THIS day of kq4' 1999, the attached agreement is hereby made an order of Court. BY THE COURT. -,: ? .,, ?' . ?' . . _ .;'J JOSEPH BARRICK, SR. Plaintiff Vs. MARLENE MURPHY Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.99-4-930 CIVIL TERM IN CUSTODY CUSTODY AGREEMENT The parties hereto, Joseph Barrick, Sr. and Marlene Murphy, are the maternal uncle and paternal grandmother of Christopher Micha Leroy Jipson, born November 13, 1985. The parties agree that Joseph Barrick, Sr. and Susan Barrick, husband and wife, shall have primary legal and physical custody of the minor child, Christopher Micha Leroy Jipson. The parties agree that this custody Agreement shall be entered as an Order of Court. In witness whereof, the undersigned parties have executed this Agreement this ?0 - day of October, 1999. Witness: GL , LL .LLB ///] M?A?RLENE MURPHH7 -'n/ JOSEPH BARRICK, SR JOSEPH BARRICK, SR. Plaintiff Vs. MARLENE MURPHY Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-030 CIVIL TERM IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Joseph Barrick, Sr., an adult individual, currently residing at 651 Alexander Spring Rd., Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Marlene Murphy, an adult individual, currently residing at 1136 Vine St., #C-12, Liverpool, NY 13088. 3. Plaintiff seeks custody of the following child : Christopher Micha Leroy Jipson, age 13, born 11/13/85. The child was not born out of wedlock. The child is presently in the custody of the Plaintiff and his wife Susan Barrick. They have had custody of the child since early November of 1998. A copy of the agreement to transfer custody is attached. The natural mother of the child is Nancy Lee Jipson and she is deceased. The natural father of the child is John M. Jipson, Jr., 120 Riverdale Dr., Apt. F-3, Syracuse, NY 13207. 4. The relationship of the Plaintiff to the child is that of maternal uncle. The Plaintiff currently resides with his wife Susan and two minor children. The relationship of the Defendant to child is that of paternal grandmother. She was granted custody of Christopher and his siblings after his mother's death. The Father has not had custody of the children for the past six years and was reported to have abused Christopher and the other children. Christopher is very afraid of his father and wishes to have no contact with him. A copy of the Court Order granting custody of Christopher to his Grandmother is attached hereto. 5. Plaintiff has not participated as a party concerning the custody of the child in this Court. Plaintiff has information of a custody proceeding concerning the child pending in the court of the State of New York. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 6. The best interest and permanent welfare of the child will be served by granting the relief requested because: Christopher is satisfied with the living arrangements with his uncle and aunt and wishes to remain in their custody. The consent of his Grandmother Marlene Murphy confirming her agreement with the continued custody is attached hereto. WHEREFORE, Plaintiff requests your Honorable Court to: A) grant full legal and physical custody of the child to the plaintiff; B) grant such other relief as is just and in the best interest of the child. Date: k tie Respectfully submitted, Robert L. O'Brien, Esquire O'BRIEN, BARIC & SCHERER 17 West South Street Carlisle, PA 17013 (717) 249-6873 If I verify that the statements made in the foregoing Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 PQ. C.S. § 4904, relating to unsworn falsification to authorities. !> ` ) n ??JOSEPH,SR. DATE: 10 Z°) F 04/06/1999 15:57 4714238 Secs. 467, 549, 651, 652, 654 P.C.A.; 240 D.R.L. ';G1 CE0;E'14my 383 S.S.L q ;.a STAK?v.^,T tawivr ? i ;••:c ; .pv 'e a,- ' .?' :1 n1^'F.7 it NOV - 5 1993 P R E S E N T ,,..P. r"r.n -1 Hon. Anthony Paris Judge ;a-the-Matter of -& -Proceeding for (Custody) (VaidK=1=0 under Article. 6 . of the Family Court Act Marlene C. Murphy, Petitioner -against- John M. Jipson, Jr., Respondent QA'd O==ICES PAGE 01 General Form 18 (Order-Cus t:ody- oisi'tati.on) 9/81 At a term of the Tastily Court of the State of New York, held in and for the County of Onoudasa at Syracuse, :law York on November 5, 1993 Docket No. V-1159-1162-93 ORDER DIRECTING (CUSTODY ) (1 00) The Petitioner heroin having filed a petition on July 14, 19 93 . pursuant to section 651 of the Family Court Act, requesting an order awarding (custody) Ge3ixjjncLnx) of the minor child(ran) named therein; and petition, Respondent afore this Court to answer the and The matter having duly come on to be heard before this Court; 11057, after examination and inquiry into the facts and circumstances of the case and after hearing the proofs and testimony offered in relation thereto; it is hereby ADJUD-IED that Petitioner be granted custody of the minor children. ; (and it is further) .. __. ,.. _AA E 02 04/06/1999 1= 57 4714238 Or-'ICES ?43 General Form 18 (page 2) A4?6IDilttx XECaaf(XYIL9ec 9fauE}?stl0oc i xahamg! %idk7G7CTIILmei7taAOOtx A imCe %bRx nm,;( wdxXkK)6aotfEE)kMxegmmaYJ;NimYxxxxxxxxxxxxxxxxxx)ampxxxx ?Ziaxt?Efoaat=dRk:(xicx?c?'kinxabmoe . ; and it is further ADJUDGED that it would be in the best interests of the child(ren) named herein to have (custody) 6af8attamboalt awarded to petitioner ; and it is therefore {" ORDERED that petitioner, Marlene *C. Murphy, be awarded •jcustody of the minor children; Christopher M. Jipson, D.O.B. 11-13-85, John R. Jipson, D.O.B. 4-26-87, Angel L. Jipson, D.O.B. 10-28-88, and Brandon S. Jipson, D.O.B. 4-7-90. ; and it is further ORDERED Dated: November 5, 19 93 uwp? Anthony his J.F.C. Ae41* tatU-j'd 1W yof.•.x?Yd'I+1YAi1? :tKJ: ri fa?:} e Y1.Wq:,C:Mnr.r.• . ^s-•rr.?nwvs cre+e+vreart : .:e• eeKOFU„u.r.., ohm l //S/73 C?-JL"; ?sd ? at: ;::ae .-tea. ! 3 G??,? ?? ik--?e?a-. -e_e,? ?Ju>of /u,/?2crxe `f`c,ca 7y/ 6&W a0e1jr??ar+a.x,? OJ d5QainOr?d ¦caNo.42M C MW OM Ion ?I. York S?teRepartment of Health .Albany, N. Y. 12237 Ter#ift Oaf ? tr 4 ?Regis#ratwi tt This certifies that a certificatXri birth has been filed under the name of. Christopcha Ler oy Jipson Maiden name of mother: Nancy Lee Brinton Sex: Male Born on: November 13, 1985 At. Syracuse Name of father: John Di. Jipson Date filed: December 2, 1985 Date issued' February 18, 1986 ??yG 131-85-127830 Director This notice is void if it contains any erasures or corrections. New York AFFIDAVIT RE PUPIL STATUS (NON-PARENT RESIDENT) TO: SECRETARY, CARLISLE AREA SCHOOL DISTRICT, BOARD OF DIRECTORS 623 WEST PENN STREET, CARLISLE PA 17013 COMMONWEALTH OF PENNSYLVANIA) . SS. COUNTY OF CUMBERLAND ) I/We d /l?t/)a i2 li k_beingduly sworn acc ding by law depose and say: 1. That I/We reside in the Carlisle Area School District at the -• - (Post ?office Address, including & S act number) township of _O.\ C KQ n-"Soln 2. That Ci c , ' • f-4-N -% C /R r who was bom (Full Name o Pupil: first, middle, last) on t 1nt ,,e 44ce C I ga, resides with me/us at the above address, which named child +s no, my/our own child. 3.- That Uwe am/are supporting the above named child gratis as if said child were my/our own child. 4. That IAve will assume all personal obligations for the above named child relative tot he school requirements of the Carlisle Area School District. 5. That Uwe intend to so keep and support the above named child continuously and not merely through the school term. 6. That this affidavit is made in compliance with Section 1302 of the Public School Code of 1349, ass amended, and as an inducement to the Carlisle Area School District to accept the above named child as pupi. in said school district.* ?^ Q• 6244',( and subscr'bed before _day of-Okf DAWN SM f*. Nowv pd* Signature of Notary Publi6l My commission expires: 'The district reserves the right to share the above information with governmental agencies; i.e., Internal Revenue Service, particularly when questions of legal guardianship occur.