HomeMy WebLinkAbout07-4013DANIEL S. CHUBB,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
vs.
LINDSAY A. COLSON,
Defendant
TO DEFENDANTS NAMED HEREIN;
YOU HAVE BEEN SUED IN C
FOLLOWING PAGES, YOU MUST TP
NOTICE ARE SERVED, BY ENTERING
WRITING WITH THE COURT YOUR D
ARE WARNED THAT IF YOU FAIL TO
MAY BE ENTERED AGAINST YOU Bl~
~ THE COMPLAINT OR FOR ANY OTF
MONEY OR PROPERTY OR OTHER
NO. D7 - ~D/,3
1N CUSTODY
NOTICE
IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE
'ION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND
TEEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN
S OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU
-, THE CASE MAY PROCEED WITHOUT YOU, AND A JUDGMENT
DURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN
AIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE
IMPORTANT TO YOU.
YOU SHOULD TAKE THIS PA ~R O YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TOO I,TE EPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
11~/IB BLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
C RLISLE, PENNSYLVANIA 17013
', ELEPHONE; (71 7) 249-3166
DANIEL S. CHUBB,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION -LAW
NO. ~ ~- ye /3
LINDSAY A, COLSON,
IN CUSTODY
AND NOW comes the
Andes, and makes the follov+
1. The Plaintiff is DAN
Crescent in Suffolk, Virginia.
2. The Defendant is L
Harding Street in New Cumb
3. The Plaintiff and a
Rodenhaber, presently age
4. Plaintiff seeks an c
based upon the agreement;
arrangement will be in the cl
5. The child was born
married. Nevertheless, both
life.
6. During the past fiv
at the following addresses:
2002 to present vi
7. The father of the c
8. The mother of the
above.
9. The Plaintiff is the r
girlfriend, Casey Shaver and
COMPLAINT IN CUSTODY
Miff, DANIEL S. CHUBB, by his attorney, Samuel L.
Complaint for Custody:
.CHUBS, an adult individual who resides at 415 Waterwheel
iAY A. COLSON, an adult individual who resides at 518
id, Cumberland County, Pennsylvania.
dant are the parents of one minor child, Joshua P.
porn 4 December 1991.
~ of shared legal custody and primary physical custody
he parties and the belief of both parties that such an
best interest.
of wedlock and Plaintiff and Defendant were never
ants have been extensively involved with the child ail his
the minor child has resided with the following persons
addresses in New Cumberland, PA Defendant only
the Plaintiff who resides at the address set above.
is the Defendant who resides at the address set out
al father of the child. Plaintiff currently resides with his
minor child, Cal Chubb, now age 8 months.
10. The Defendant is
with her husband, Michael C
Marcus Colson, age 1.
11. The Plaintiff has r
concerning the custody of tt
The Plaintiff has no info
pending in a court of this or
Plaintiff knows of no o'
custody of or claims to have
12. Each parent whc
the person who has physical
action.
WHEREFORE, DANIEL S
request therein.
natural mother of the child. Defendant currentry resides
n and their two children, Madison Colson, age 3, and
anticipated as a party or in any other way in any litigation
hild in this or any other court.
rtion of a custody proceeding concerning the child
other jurisdiction.
person not a party to this action already who has physical
tody or visitation rights to the said child.
>arental rights to the child have not been terminated and
tody of the child have been named as parties to this
requests this Court to grant him the above relifef
el L. An s
Attorney for Plaintiff
Supreme Court ID # 17225
525 North 12m Street
Lemoyne, Pa 17043
(717) 761-5361
~i
verify that the stater
that any false statements in
(unsworn falsification to auti
Date:
in this document are true and correct. I understand
ant are subject to the penames of 18 Pa. C.S, 4904
~~~,~~{
DANIEL S. CHUBB
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DANIEL S. CHUBB,
Plaintiff
vs.
LINDSAY A. COLSON,
AND NOW this ) 4 =~
named parties, being the p
December 4, 1991, hereby
Order to resolve legal and I
enter such order.
Daniel S. Chubb
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
)
CIVIL ACTION -LAW
NO.
)
IN CUSTODY
STIPULATION
of `~~ ~ , 2007, the above-
of the minor child, Joshua P. Rodenhaber, born
to and agree that the court may enter the attached
~I custody of their child and jointly request the court to
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JUL 0 8200E R'~y
DANIEL S. CHUBB,
Plaintiff
vs.
LINDSAY A. COLSON,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
,,e~
IN CUSTODY
ORDER OF COURT
AND NOW this ~ ` day of ~~, , 2007, upon the
written Stipulation of the parties, we hereby order and decree as follows:
1. Legal custody of the minor child Joshua P. Rodenhaber, born December 4, 1991, shall
be shazed by his father, the Plaintiff Daniel S. Chubb ("Father") and his mother, the Defendant
Lindsay A. Colson ("Mother"}. The parties shall cooperate to exchange information regarding
the child's education, health care, religious training and all other major matters in the child's life
and shall cooperate to make all decisions regarding important matters in the child's life by mutual
agreement. Nevertheless, either party is authorized to make emergency medical or health care
decisions for the treatment of the child in the absence of the other parry, on the condition that they
shall contact the other party as promptly thereafter as possible.
2. Primary physical custody of the child shall be with Father who is hereby authorized to
move the child to live with him in Suffolk, Virginia.
3. The Mother shall have such periods of temporary or partial custody as the parties may
hereafter agree, keeping in mind the importance of the child maintaining a close relationship with
both pazents. In the event that the parties cannot agree, either parry may petition the court to set a
formal schedule of custody and temporary custody for the child.
BY THE COURT,
~" ~f
J.
Distribution:
Samuel L. Andes, Attorney for Plai iff, P.O. Box 168, Lemoyne, PA 17043 ~.c.w ~-~-~-
Lindsay A. Colson, pro se, 518 Harding Street, New Cumberland, Pa 17070 ~ i~. o ?
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