The URL can be used to link to this page

Home My WebLink About07-4064THOMAS L. BIXLER, JR., and ELAINE L. BIXLER, Plaintiff vs. DENISE J. PRITCHARD, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NUMBER: 0 ~ ` `~~~ ~ IN CUSTODY M~TI4N NOW COME the Plaintiffs, THOMAS L. BIXLER, JR., and ELAINE L. BIXLER, by and through their attorney, Charles E. Petrie, and respectfully represents as follows: 1. That Plaintiffs are THOMAS L. BIXLER, JR., and ELAINE L. BIXLER, adult individuals currently residing at 740 Lindenwood Lane, Steelton, County of Dauphin, Pennsylvania. 2. That Defendant is DENISE J. PRITCHARD, an adult individual currently residing at 160 North West Street, Apartment 2, Carlisle, County of Cumberland, Pennsylvania. 3. That Plaintiffs are the maternal aunt and uncle and Defendant is the natural mother of two minor children, SHAWN ANTHONY PALMER, born August 23, 1993, and MICHAEL JAMES PALMER, born August 27, 1994. 4. That the whereabouts of the natural father, ERIC FALMER is unknown to Plaintiffs and Defendant. Natural father last saw the minor children in 2004 and had no regular contact with said minor children prior to his last visit with them. 5. That the parties have entered into a Stipulation concerning the matters of custody and visitation with respect to the minor children, and the said Stipulation is attached hereto. 6. That the parties desire that said Stipulation be entered as an Order of Court. WHEREFORE, Plaintiffs respectfully request that Your Honorable Court enter an Order pursuant to the attached Stipulation. Respectfully submitted G~ CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiffs 'T`HOMAS L. BIXLER, JR., and ELAINE L. BIXLER, Plaintiff vs. DENISE J. PRITCHARD, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NUMBER: 4 ~' - ~dG ~ IN CUSTODY COMPLAINT FOR CUSTODY NOW COME the Plaintiffs, THOMAS L. BIXLER, JR., and ELAINE L. BIXLER, by their attorney, Charles E. Petrie, and respectfully represent as follows: 1. Plaintiffs are THOMAS L. BIXLER, JR., and ELAINE L. BIXLER, who currently reside at 740 Lindenwood Lane, Steelton, County of Dauphin, Pennsylvania. 2. Defendant is DENISE J. PRITCHARD, who currently resides at 160 North West Street, Apartment 2, Carlisle, County of Cumberland, Pennsylvania. 3. Plaintiffs seek to have rights of primary physical and legal custody with respect to SHAWN ANTHONY PALMER, born August 23, 1993; and MICHAEL JAMES PALMER, born August 27, 1994. The children were born out of wedlock. The children are presently in the custody of Plaintiffs, THOMAS L. BIXLER, JR., and ELAINE L. BIXLER. During the past five years the children have resided with the following persons and at the following addresses: From July, 2002, until June, 2004, with Defendant at Eastridge Apartments 101, Worcester Avenue, Apartment 8, Harrisburg, Pennsylvania; from June, 2004, until August 2005, with Defendant at 5909 Fox Street, Harrisburg, Pennsylvania; from August, 2005, until June, 2007, with Defendant at Boiling Springs Apartments, 209 Plaza Drive, Boiling Springs, Pennsylvania; from June, 2007, until the present with the Plaintiffs at 740 Lindenwood Lane, Steelton, Pennsylvania. The mother of the children is DENISE J. PRITCHARD, who currently resides at 160 North West Street, Apartment 2, Carlisle, Pennsylvania. She is single. The father of the children is ERIC PALMER, who currently resides at an address unknown to Plaintiffs and Defendant. His marital status is also unknown. 4. The relationship of the Plaintiffs to the children is that of maternal aunt and uncle. The Plaintiffs currently reside with the children and their children and step-children, Putney, age 16; Allen and Anthony, ages 15; and Nicholas. 5. The relationship of the Defendant to the children is that of natural mother. The natural mother currently resides with Cindy McClucas-Herman. 6. The Plaintiffs have not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or in another court. The Plaintiffs have no information of a custody proceeding concerning the custody of the children in this or in another court. Plaintiffs do not know of a person not a party to these proceedings who has physical custody of the children or who claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by confirming rights of primary physical and legal custody in Plaintiffs. 8. Each parent whose parental rights to the children have not been terminated and the persons who have physical custody of the children have been named as parties to this action. 9. The parties have entered into a Stipulation, attached hereto, setting forth their agreement concerning custody of the minor children. WHEREFORE, Plaintiffs request the Court enter an Order confirming rights of primary physical and legal custody in Plaintiffs. Respectfully submitted, L~ CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiffs COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN We verify that the statements in the foregoing Motion and Complaint are true and correct. We understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ~ o n ~~ DA THOMAS L. BIXL R, ELAINE L. BIXLER THOMAS L. BIXLER, JR., and IN THE COURT OF COMMON PLEAS OF ELAINE L. BIXLER, :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION -LAW vs. NUMBER: o y- yD 4 y DENISE J. PRITCHARD, Defendants IN CUSTODY 8TIPULATION AGREEMENT, made this ~ day of July, 2007, by and between DENISE J. PRITCHARD, hereinafter referred to as "Mother," and THOMAS L. BIXLER, JR., and ELAINE L. BIXLER, hereinafter referred to as KCustodial Parents." WITNFSSETH: WHEREAS, the parties hereto are the natural mother and Custodial Parents of two minor children, SHAWN ANTHONY PALMER, born August 23, 1993, and MICHAEL JAMES FALMER, born August 27, 1994; WHEREAS, the parties have reached an agreement concerning the issues of custody and partial custody; and WHEREAS, the parties desire that this Stipulation be entered as an Order by the Court of Common Pleas of Cumberland County, Pennsylvania; NOW THEREFORE, intending to be legally bound, it is hereby agreed as follows: 1. Custodial Parents, THOMAS L. BIXLER, JR., and ELAINE L. BIXLER, shall have primary physical and legal custody with respect to the subject minor children, SHAWN ANTHONY PALMER, born August 23, 1993; and MICHAEL JAMES PALMER, born August 27, 1994. Said rights of legal custody shall include the right to obtain health insurance coverage and the right to make all decisions and to authorize medical treatment for the minor children, the right to educate the minor children in the public school district of the Custodial Parents, or at such other educational institution as they may deem ht, and to provide a religious upbringing for the children as the Custodial Parents shall deem appropriate. 2. Natural Mother, DENISE J. PRITCHARD, shall have such rights of temporary physical custody of the minor children as the parties shall from time to time agree. IN WITNESS WHEREOF, the parties have hereunto set their hands and official seals. C~ ?~ WI SS x THOMAS L. BIXL J !~ WITES - nRMV~~'1 WIT S ~ . `~ ELAINE L. BIXLER DENISE J. PRITCHARD .~ _~ L.,.,~ :T -7"4 ~ ,~ ~~ ~ ~^ n ~. ` tV1 ~ V V' V ~.il y 4 ~ ~~ .~. ..7 ~/ i ,- ~~ _~ ~~~ ~ THOMAS L. BIXLER, JR., and IN THE COURT OF COMMON PLEAS OF ELAINE L. BIXLER, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION -LAW vs. NUMBER: O 7 - y0 L DENISE J. PRITCHARD, Defendants IN CUSTODY ORDER F COURT AND NOW, this ~ day of , 2007, upon consideration of the within Stipulation, IT IS HEREBY ORDERE AS FOLLOWS: 1. Custodial Parents, THOMAS L. BIXLER, JR., and ELAINE L. BIXLER, shall have primary physical and legal custody with respect to the subject minor children, SHAWN ANTHONY PALMER, born August 23, 1993; and MICHAEL JAMES PALMER, born August 27, 1994. Said rights of legal custody shall include the right to obtain health insurance coverage and the right to make all decisions and to authorize medical treatment for the minor children, the right to educate the minor children in the public school district of the Custodial Parents, or at such other educational institution as they may deem fit, and to provide a religious upbringing for the children as the Custodial Parents shall deem appropriate. 2. Natural Mother, DENISE J. PRITCHARD, shall have such rights of temporary physical custody of the minor children as the parties shall from time to time agree. BY JUDGE Distribution: Charles E. Petrie, Esquire, 3528 Brlsbaa Street, Harrisburg, PA 17111 ir~~ Denise PNtchard, c/o Cindy McClucas-Herman, 1601'1. Went St., Apt. ~Z, Carlisle, PA 17013'd T~/' d ~ ~ ~~.~ a; ;~,~ -- J _ i-- {_~ _ ~ {