Loading...
HomeMy WebLinkAbout07-3217Amy J. Barnette, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. : No. p 7 -- 3 a-17 ~ ~ ~; I Antonie-L. Barnette, Sr., :CIVIL ACTION -CUSTODY Defendant COMPLAINT FOR CUSTODY 1. Plaintiff is Amy J. Barnette, an adult individual whose residence is at 307 Farmington Drive, Shippensburg, Pennsylvania, 17257. 2. Defendant is Antonio L. Barnette, Sr., an adult individual whose residence is at 116A Umberto Avenue, New Cumberland, Pennsylvania, 17257. 3. Plaintiff seeks custody of her children Ashayna R. Barnette, born October 4, 1997, Trayton V. Barnette, born December 8, 2000, and Nevin M. Barnette, born March 15, 2004.. 4. 5. Name The children are presently in the sole custody of Plaintiff.. The children have lived at the following addresses: Address Ashayna R. Barnette Trayton V. Barnette Nevin M. Barnette 308 Shepard Lane Shippensburg, PA 17257 307 Farmington Drive Shippensburg, PA 17257 Dates January 2000 - February, 2004 February 2004- Present 6. The relationship of the plaintiff to the children is that of natural mother. 7. The relationship of the defendant to the children is that of natural father. 8. The plaintiff has not participated as a party or in any other capacity in other litigation concerning the custody of the children in this or any other Court. 9. Plaintiff has no information of a custody proceeding concerning the children pending in a Court of this Commonwealth. 10. No other persons are known to have or claim to have any right to custody or visitation of the child other than the parties to this action. 11. The best interest and permanent welfare of the child will be served by i granting the relief requested because the Plaintiff is the primary care giver with respect '„ to the child. 12. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to 'this action. WHEREFORE, plaintiff requests your Honorable Court schedule a ~, '', conciliation conference and subsequently grant the plaintiffs requests for sole legal ';~ custody and sole physical custody of the child to the plaintiff. Respectfully Submitted TURD LAW OFFICES ~ i ~al~n R. Waltz, Es 28 South Pitt Stre Carlisle, PA 17013 (717) 245-9688 Attorney for Plainitff/Mother ', VERIFICATION I verify that the statements made in the foregoing Custody Complaint 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. `~ `rJ 1 ~~ Date Amy J. ette CERTIFICATE OF SERVICE I, Galen R. Waltz, Esquire hereby certify that I served a true and correct copy of the Custody Complaint, by first class, postage pre-paid, certified return receipt requested and depositing same in the United States Mail, first class, postage pre-paid on the ~~i~~day of ~~ , 2007, from Carlisle, Pennsylvania, addressed as follows: Timothy J. O'Connell Turner and O'Connell 4415 North Front Street Harrisburg, PA 17110 And Antonip L. Barnette, Sr. 116A Umberto Avenue New Cumberland, PA 17070 TURO LAW OFFICE Galen R. Waltz, uire 28 South Pitt S Carlisle, PA 17013 (717) 245-9688; FAX 717.245.2165 _w ° pp '~ ~~ ~"' < ~ ~ t ~~ _ ~~~ -~,--- ter; -c w CYO ~ G ~ ~ ' ~.+, s i i '.; ~i3 ~ , ~ ~ • ~" C ~ J t't'1 Amy J. Barnette, Plaintiff v. Antoni:pL. Barnette, Sr., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-3 ll7 c~~,! CIVIL ACTION -CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Amy J. Barnette, Plaintiff to proceed in forma pauperis. I, Galen R. Waltz, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Galen R. Waltz Attorney for P intii Turo Law Office 28 S. Pitt Street Carlisle, PA 17013 (717) 245-9688 t"3 ~"' ~, O ~; -sir ~~ ~~" o yy.. D ~ -© ~ ~ ~ ~~ ~'• -t ~ w JUN 011fla1 ~ ~ Amy J. Barnette, Plaintiff v. Antonia L. Barnette, Sr., Defendant i ~y .~ `' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.U ~32~? CIVIL ACTION -CUSTODY CUSTODY STIPULATION/ORDER ANA NSW, this ~ day of , 2007, it is hereby Ordered, stipulated and agreed between the parties as follows: 1. Ashayna R. Barnette, born October 4, 1997, Trayton V. Barnette, born December 8, 2000, and Nevin M. Barnette, born March 15, 2004 are the natural children of Amy J. Barnette (Mother) and Antonio L. Barnette, Sr. (Father). 2. Mother, Amy J. Barnette, shall have sole legal custody of the children. 3. The mother, Amy J. Barnette shall have sole physical custody of the children. 4. Antonio L. Barnette, Sr. currently is under Order for child support of the children and shall continue to provide for the child support for the above named children. The Stipulation/Order can be modified when the parties mutually agree for that modification or in the event a party elects to file a formal modification complaint with the Court. s~~ - Date ~~ ~~ Dat ~ 6~ i Date Antonio L. Barnette, Sr. sir, ~. i. ~ f'1 rn i "S 6Z .Z d S- ~~1f tOQI A~iC,~tiC~~-~:~~~ ~~ ~a