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Home My WebLink About07-5412~`.a CUSTODY STIPULATION Adam and Erica Jonas and Kevin and Brenda Cooney, hereinafter referred to as the custodians and the natural parents respectively, desire to enter into an agreement concerning legal and physical custody of Kevin P. Cooney, DOB 9/15/92, the natural son of Kevin and $renda Cooney. The parties agree as follows; 1. Legal custody of the child shall be with the custodians. 2. the child shall continue to reside with Adam and Erica Jonas. 3. The child shall attend school in the district where the custodians reside. 4. The natural parents shall have frequent and liberal contact with the child as agreed- upon by the parties and the child. 5. This agreement shall be entered as an order of Court. Adam Jonas Erica Jonas ~.~c.~ Kevin Cooney ~~/~~ Brenda Cooney Date: ~G~ ~ Z~~ ~~ d~ Vic./K( 7.. /'~L~c~f;c ..- `t i k ~,. ,.._ .._ t Marianne E. Rudebusch, Esquire 4711 Locust Lane Harrisburg, PA 17109 717-657-0632 Id. No. 63522 Attorney for Plaintiffs ADAM AND ERICA JONAS, : IN THE COURT OF COMMON PLEAS Plaintiffs :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. D 7 - 5y/a, ~~/ ~.~-~ KEVIN AND BRENDA GOONEY, : CIVII. ACTION -LAW Defendants : IN CUSTODY NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are serve, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or obj ections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNT BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Se usted desea defenderse de las dernandas que se prsentan mas adelante en las siguientes paginas, debe tomar action dentro de los proximos veinte (20) dies despues de la notification de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defenses de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted fella de tomar action Como se describe anteriormente, el caso puede proceder sin usted y un fall por cualquier soma de dinero reclamada en la demands o cualquier otra reclamation o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mss aviso aditional. Used puede perder dinero o propiedad u otms derechos importantes pars usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME O VAYA A LA SIGUIENTE OFICINA PARR AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. CUMBERLAND COUNT BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 AMERICANS WTTH DISABII.ITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about assessable facilities and reasonable accommodations available to disable individuals having. business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. CUMBERLAND COUNT BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 ADAM AND ERICA JONAS, Plaintiffs v. KEVIN AND BRENDA GOONEY, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. o7-S'y~2 Cc.~.t ~~-- CIVIL ACTION -LAW IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiffs are Adam and Erica Jonas, adult individuals who reside at 15 Hemlock Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The Defendants aze Kevin and Brenda Cooney, adult individuals who reside at 38 S. Enola Drive, Enola, and 23 Acri Meadow Drive, Enola, Cumberland County, Pennsylvania, 17025, respectively. 3. The Plaintiffs seek custody of the following child: Name Date of Birth Awe Kevin P. Cooney 9/15/92 14 The child is presently in the physical custody of the Plaintiffs, who reside at the address above. The child was born in wedlock. 4. During the past five yeazs the child has lived with the following persons at the following addresses: a. With both pazents 120 East Locust Street Mechanicsburg, PA b. With mother and grandparents 23 Acri Meadow Drive Enola, PA 10/16 to 1/0'7 c. With Plaintiffs 15 Hemlock Drive Mechanicsburg, PA 5. The Mother of the child is Brenda Cooney and the Father of the child is Kevin Cooney, currently residing at the above addresses. 6. The Plaintiff/Custodians of the child aze Adam and Erica Jonas, currently residing at 15 Hemlock Drive, Mechanicsburg, Cumberland County, Pennsylvania. 7. The relationship of the Plaintiffs to the child is that of Custodians. Plaintiffs currently resides with their son, Niko, their daughter Elaina, and the subject minor child, Kevin Cooney. Plaintiffs have 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. Plaintiffs have no information of the custody proceedings of the child pending in a Court of this Commonwealth. Plaintiffs do 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 the child. 9. The best interest and permanent welfare of the child will be served by granting the relief requested because: a. Plaintiffs have been the primary Gaze givers of the child and have provided the child with consistent and loving caze. b. Plaintiffs are willing and able to continue to provide proper caze and supervision of the child. c. Plaintiffs can provide a stable and loving environment to the child. 10. Each pazent whose pazental rights of the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. There are no other persons who aze known to have a claim or right to custody or visitation in this matter. 'WHEREFORE, Plaintiffs request the Court to grant primary physical and legal custody of the child to the Plaintiffs as per the attached Custody Stipulation signed by the parties. Respectfully Submitted, /~ ~ d~~~ Marianne E. Rudebusch, Esquire 4711 Locust Lane Harrisburg, PA 17109 (717) 657-0632 Id. No. 63522 Dated: ~- ~ f " ~ VERIFICATION I verify that the statements made in the foregoing are true and corr~t. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. ~L-cam-- ~ U'-~- Adam Jonas Erica 3onas .~ Date: ~~e,~-~.m.~e~ ~zl.~- E~:HIBIT A ,' CUSTODY STIPULATION Adam and Erica Jonas and Kevin and Brenda Cooney, hereinafter referred to as the custodians and the natural parents respectively, desire to enter into an agreement concerning legal and physical custody of Kevin P. Cooney, DOB 9/15/92, the natural son of Kevin and Brenda Cooney. The parties agree as follows; 1. Legal custody of the child shall be with the custodians. 2. the child shall continue to reside with Adam and Erica Jonas. 3. The child shall attend school in the district where the custodians reside. 4. The natural parents shall have frequent and liberal contact with the child as agreed upon by the parties and the child 5. This agreement shall be entered as an order of Court. Adam Jonas ~ ,~i Erica Jonas ~~ Kevin Cooney ~t~ Brenda Cooney Date: U' ~~~~ s s c~ ~: t~ -GA- ns ~ ~ ~ ~ .°.a O ~ ~ -'D ~ 1 ~~ 4 ~w ~ ~rryy~R~ w~~ .• ~ ~~ ^ ' f ~ ` ~ W j . A ~,~ Marianne E. Rudebusch, Esquire 4711 Locust Lane Harrisburg, PA 17109 717-657-0632 Id. No. 63522 meresquirelg~comcast.net Attorney for Plaintiffs 0 a~av~r- ADAM AND ERICA JONAS, Plaintiffs v. KEVIN AND BRENDA GOONEY, Defendants 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA : NO. 07- 54'la Civil ~~n CIVIL ACTION -LAW IN CUSTODY 1 ! ~ ~ 1: 11n AND NOW, this 1 ~ day of S GD~c~w,,tp br , 2007, it is hereby ORDERED that the attached Custody Stipulation is entered as an Order of this Court. BY THE COURT: J. Distribution: M ianne E. Rudebusch, Esq., 4711 Locust Ln., Hbg., PA 17109 ~in Cooney, 38, S. Enola Dr., P.O. Box 32, Mechanicsburg, PA,17055 ~nda Cooney, 23 Acri Meadow Road, Enola, PA, 17025 V .R P~ if ~~ ~ rv F 1 ~~~ ~ r .~ •~-~ ~ .~ M, ADAM AND ERICA JONAS, Plaintiffs vs. KEVIN AND BRENDA GOONEY, Defendants THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 07-5412 CIVIL ACTION - AT LAW CUSTODY STIPULATION FOR AN AGREED ORDER OF CUSTODY AND NOW, come the parties, Adam and Erica Jonas, Plaintiffs, and Kevin and Brenda Cooney, Defendants, and respectfully request the following Stipulation to be entered as an Order of Court: WHEREAS Kevin Cooney (the Father hereinafter) Brenda Cooney (the Mother hereinafter), have born to them one child, namely Kevin P. Cooney, born September 15, 1992 (the child hereinafter); and, WHEREAS, Adam Jonas and Erica Jonas previously had custody of the child pursuant to an agreed upon order of court dated September 18, 2007; and, WHEREAS, all parties desire to enter into a comprehensive custody stipulation and agreement setting forth the physical and legal custody arrangements for the child; and WHEREAS, all parties have been provided an opportunity to review this Stipulation with counsel prior to signing. THEREFORE, in consideration of the mutual covenants, promises, and agreements as hereinafter set forth, and intending to be legally bound, the parties agree as follows: 1. LEGAL CUSTODY: Mother and Father shall have an equal right, to be exercised 1 jointly with each other, to make all major non-emergency decisions affecting the child's general well-being, including, but not limited to, all decisions regarding his health, education, and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child, including, but not limited to, medical, dental, religious or school records, the residence address of the child and the other parent. Adam Jonas and Erica Jonas hereby relinquish any and all rights to legal custody previously enjoyed regarding the child. 2. PHYSICAL CUSTODY: Father and Mother shall equally share physical custody of the child on an alternating weekly basis or on such as other basis as can be agreed upon between the parties. Although Father and Mother are sharing physical custody, Father's address shall remain the child's primary address for purposes of school, doctors, etc. Adam Jonas and Erica Jonas hereby voluntarily relinquish any and all physical custody or visitation rights previously held regarding the child. 3. VOLUNTARY EXECUTION AND FAIRNESS OF THE AGREEMENT: Each parry acknowledges that this Custody Stipulation has been entered into by his or her own volition, with full knowledge of the facts and full information as to his or her legal rights, each party having been provided ample opportunity to discuss with the counsel of his or her choice the effect of the terms of this Custody Stipulation and that each believes this Custody Stipulation to be reasonable and in the best interest of the children under the circumstances and not the result of any duress or undue influence. 4. SUPERSEDERS OF PRIOR COURT ORDERS: This Stipulation shall supersede all 2 prior Court Orders, Stipulations, or Agreements. 5. ENTRY AS AN ORDER OF COURT: It is the intention of the parties that this Custody Stipulation may be entered as an Order of Court, as if a full hearing had been held thereon and enforced pursuant to the provisions of the Uniform Child Custody Jurisdiction and Enforcement Act. IN WITNESS THEREOF, and intending to be legally bound thereby, the parties hereto have hereunto set their hands and seals and the date of their acknowledgment. Date: `~~ W~ Signature: ~~ //``// Adam Jo s Date: ! T~Q Signature: Erica Jo ' s Date: '~ ? `~ ~ ~9 Signature: evin Cooney Date: ~1~~~IsW Signature: ~~- Brenda Cooney 3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF ~yw.~er'~~ BEFORE ME, the undersigned authority, on this day personally appeared Adam Jonas, known to me to be the person who executed the foregoing instrument, and who acknowledged to me that he executed same for the purposes and considerations therein expressed. GIVEN UNDER MY HAND AND SEAL OF OFFICE this ~~` day of Seca-~M6tr , 2009. Notary Public in and for Comm ~INSY~VAMIA Type a ea~' ~' Daniel J. Morton, Sr., Notary Public Silver Spri Twp„ Cumberland Cou y mm ion Expires Oct. 24, 2010 My co$4ffl1~3S9o~@';~'lY@~~ Association of Notaries COMMONWEALTH OF PENNSYLVANIA COUNTY OF L. u w.,(p~e/'I a.~.~. BEFORE ME, the undersigned authority, on this day personally appeared Erica Jonas, known to me to be the person who executed the foregoing instrument, and who acknowledged to me that she executed same for the purposes and considerations therein expressed. GIVEN UNDER MY HAND AND SEAL OF OFFICE this ~ day of S~,p~-e.,v.~~.e~ , 2009. Ifotary Public in and for Commonwealth of Pennsylvania TYPed ~ NSYLVANIA Notarial Seal Daniel J. Morton, Sr., Notary Publ~ Silver Spring Twp., Cumberland County M Member, Pennsylvania Association of Notaries My commission expires: COMMONWEALTH OF PENNSYLV ~ IA COUNTY OF ~.~ '~ ~~t 1 GEC. BEFORE ME, the undersigned authority, on this day personally appeared Kevin Cooney, known to me to be the person who executed the foregoing instrument, and who acknowledged to me that he executed same for the purposes and considerations therein expressed. GIVEN UNDER MY HAND AND SEAL OF OFFICE this ~~ day of ~~ U ~ ~ , 2009. ,P a ~1 An n~.a1~ COMMONWEALTH OF PENNSYLVANIA Notarial Seal Jennifer N. Grove, Notary Public Silver Spring Twp., CumCeaiancf County My Commission EXpirfS Jar,. 28, 2012 Member, Pennsylvania Association of Notaries COMMONWEALTH OF PENNS`YLVArINIA COUNTY OF ~ ~ 1 ~l,I 1~i"otary )Public in and for ~, Commonwealth of Pennsylvania Typed or printed name of Notary: ~~1 ~1 i ~C1 N G~OV-e My commission expires: ~~-a 0 dV I BEFORE ME, the undersigned authority, on this day personally appeared Brenda Cooney, known to me to be the person who executed the foregoing instrument, and who acknowledged to me that she executed same for the purposes and considerations therein expressed. GIVEN UNDER MY HAND AND SEAL OF OFFICE this ~~ ~~ , 2009. COMMONWEALTH OF PENNSYLVANIA r~~ / v _~- Not ry u c in and for Commonwealth of Pennsylvania Typed or printed name of Notary: i Notarial Seal I Jennrfer N. Grove, Notary Public I Silver Spring Twp., CtrrnEeriand County My Commission ExpirFa Jan. 28, 2012 Member, Pennsylvania Association of Notaries n~~ ~ fir N Cmu~ My commission expires: (^ 0 ~ 5 day of rf ~ ~~r..~n~,aw~E~,RY ZO~l9 SEA' 14 ~ ~- ~~ ~, vE~ti~w , . _ "~~. ~Y SEP ~ 5 2009 ~ ADAM AND ERICA JONAS, :THE COURT OF COMMON PLEAS OF Plaintiffs :CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 07-5412 KEVIN AND BRENDA GOONEY, :CIVIL ACTION - AT LAW Defendants :CUSTODY ORDER OF COURT AND NOW, this ~~~~ day of S e.o~trn~t,~' , 2009, upon consideration of the within STIPULATION FOR CUSTODY, which is incorporated herein by reference, IT IS HEREBY ORDERED AND DECREED that the contents of said Stipulation are hereby adopted as an Order of Court with full weight and effect as if they had been set forth in full hereinafter. Any and all prior Orders in this matter are hereby vacated. BY THE COURT: -~`~'~ Distribution: " J nne B. Costopoulos, Esquire, 5000 Ritter Rd, Ste., 202, Mechanicsbur , PA 17055 g $~enda Cooney, 23 Acri Meadow Dr., Enola, PA 17025 ,/Adam and Eric Jonas, 15 Hemlock Dr., Mechanicsburg, PA 17055 n 1.:~-~ i ps rr~,t~ 4~`~`~ ~~ OF TNT: i-,-:~.: `~-,, ;~~~r:~;. . 2~~4 SEi' 16 ~'~3 i2~ ~