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Home My WebLink About07-6230IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JACK BRIGHTBILL LISA LAGLE v. . Plaintiff Defendant N0. G I- G .~3o CIVIL TERM CIVIL ACTION -LAW I N CUSTODY CUSTODY COMPLAINT 1. The Plaintiff is Jack Brightbill, residing at 6023 Mockingbird Drive, Mechanicsburg, PA 17050. 2. The Defendant is Lisa Lagle, residing at 6023 Mockingbird Drive, Mechanicsburg, PA 17050. 3. Plaintiff seeks custody of the following child: NAME PLACE OF RESIDENCE AGE D.O.B. Jared Brightbill 6023 Mockingbird Drive Mechanicsburg, PA 17050 11 3/1 /1996 4. The child was born out of wedlock. 5. The child is presently in the custody of the Plaintiff, Jack Brightbill, who resides at 6023 Mockingbird Drive, Mechanicsburg, PA 17050. b. During the past five years, the child has resided with the following persons and at the following addresses: 7. PERSONS ADDRESSES DATES Jack Brightbill 6023 Mockingbird Drive 9/1997 Lisa Lagle Mechanicsburg, PA 17050 to Cheyenne Lagle Present The mother of the child is Lisa Lagle currently residing at 6023 Mockingbird Drive, Mechanicsburg, PA 17050. - 1 - 8. The mother is [ x ]single [ ]divorced. 9. The father of the child is Jack Brightbill currently residing at 6023 Mockingbird Drive, Mechanicsburg, PA 17050. 10. The father is [ x ]single [ ]divorced . 11. The relationship of Plaintiff to the child is that of father. 12. The Plaintiff currently resides with the following persons: NAMES RELATIONSHIP Jared Brightbill Child's Lisa Lagle Child's Mother Cheyenne Lagle Child's Half Sister 13. The relationship of Defendant to the child is that of Mother. 14. The Defendant currently resides with the following persons: NAMES RELATIONSHIP Jared Brightbill Child's Jack Brightbill Child's Father Cheyenne Lagle Child's Half Sister 15. Plaintiff has 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. 16. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 17. 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. 18. The best interest and permanent welfare of the child will be served by granting shared legal custody of the child to the parties and primary physical custody of the child to Plaintiff and partial physical custody of the child to Defendant in accordance with the - 2 - Custody Agreement entered into by the parties and dated October 12. 2007, a true and correct copy of which is attached hereto, marked Exhibit "A" and made a part hereof. 19. 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 in accordance with the Custody Agreement entered into by the parties and dated October 12. 2007, a true and correct copy of which is attached hereto, marked Exhibit "A and made a part hereof, requests the Court to grant: A. Shared legal custody of the child to the parties; B. Primary physical custody of the child to Plaintiff; C. Partial physical custody of the child to Defendant. Respectfully submitted, ~B1'A'RE-G' DCLI FF, ESQUIRE e Road Camp Hill, PA 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 ID No. 32112 Date: October 23, 2007 - 3 - VERIFICATION I verify that the statements made in this 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. _~_o~ ~~ Date: 0 ~ JA BRIGHTBILL EXHIBIT "A" CUSTODY AGREEMENT CUSTODY AGREEMENT -~ THIS CUSTODY AGREEMENT made thisE? `day of %, 2007, by and between Lisa Lagle, ("Mother") and Jack Brightbill, ("Father"), both of 6023 Mockingbird Drive, Mechanicsburg, PA 17050, regarding their child, Jared Brightbill, born on March 1, 1996 ("the Child) 1. The parties shall have shared legal custody of the Child. Each Parent shall have an equal right, to be exercised jointly with the other Parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding their health, educa ll be entditled~to all Pursuant to the terms of 23 PA. C.S.A. X5309, each Parent sha 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 of the other Parent. To the extent one Parent has possession of any such records or information, that Parent shall be required to share the same, or copies thereof, with the other Parent within such reasonable time as to make the records and information of reasonable use to the other Parent. 2. Father shall have primary physical custody of the Child. 3. Mother shall have partial physical custody of the Child at such times as the parties shall hereafter mutually agree. 4. The parties authorize any Court of competent jurisdiction to enter an Order incorporating the terms of this Custody Agreement upon request of either party. IN WITNESS WHEREOF the parties, intending to be legally bound hereby, have set their hands and seals the day and year below written. y WITNESS: ( ~~ ~~, ~~ ` {SEAL} ACK BRIGHTB L Date: ~~` ~~'~ -U~~ ~% -~ {SEAL} .r ~ ~`"~~LISA LAGLE f Date: ~c,-~~-~~~ `~~\\. `w_T Al w ~~ /\ J C7 ,-- -= i::.ai ~. ._f, , r: ,.:. :~. L ,' •, ~... ./' f _ ...+ r-~ ~~ C'.~ 7 -...{ .~"" ~,,I~l W -rt ~:'..i '- __~ T t. -~"• ~! ~- t~~ K'~•-~ r d7~ !oa-3 ~ c.r~~~ t~h CUSTODY AGREEMENT THIS CUSTODY AGREEMENT made this~?~`day of J, 2007, by and between Lisa Lagle, ("Mother") and Jack Brightbill, ("Father"), both of 6 born onkMarbc~ha D1996 Mechanicsburg, PA 17050, regarding their child, Jared Br~ghtbil , ("the Child) 1. The parties shall have shared legal custody of the Child. enthtoamakesalllmajor an equal right, to be exercised jointly with the other Par , non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding their health, ed shall be entditled~to all Pursuant to the terms of 23 PA. C.S.A. 85309, each Parent records and information pertaining to the Child includi ad~dbess of thle Ch ld and medical, dental, religious or extent one Parent has~possession of any such records of the other Parent. To the or information, that Parent shall be required to share the samake thepreco ds a~ d with the other Parent within such reasonable time as to m information of reasonable use to the other Parent. 2. Father shall have primary physical custody of the Child. 3. Mother shall have partial physical custody of the Child at such times as the parties shall hereafter mutually agree. 4. The parties authorize any Court of competent jurisdiction to enter an Order incorporating the terms of this Custody Agreement upon request of either party. IN WITNESS WHEREOF the parties, intending to be legally bound hereby, have set their hands and seals the day and year below written. WITNESS: , {SEAL} ACK BRIGHT L Date: l0 '/x-6'1' . ~ i~~ ~ {SEAL} --~. LISA LAGLE Date: ~-e-1Z-~="~ r.a ~' ~'. - ` _ c z ~ ~, -~? c ., ; ~:, =^ n .. ^' ''~ ~'t'1 ~ l ~ .~ y, _ T1 f,~ ~ -C r 1 I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JACK BRIGHTBILL ~ Plaintiff N0. ~ ~~~ CIVIL TERM v. CIVIL ACTION -LAW LISA LAGLE IN CUSTODY Defendant CUSTODY ORDER AND NOW, this ~" day of G~c,~-~ , 20 ,upon consideration of the within Stipulated Custody Agreement, IT IS HEREBY ORDERED AND DECREED that the Parents' Stipulated Custody Agreement is incorporated into this Order and entered as an Order of this Court the same of if fully set forth herein. BY THE COURT: Dis ribution To: ttorney for Plaintiff: Diane G. Radcliff, Esquire, 3448 Trindle Road, Camp Hill, PA 17011 ,defendant (Pro Se): Lisa Lagle, 6023 Mockingbird Drive, Mechanicsburg, PA 17050 J ~ _c~ ~ boo .o/ C~ ~~~~ ~ '` ~,,iq `i ~r~~~"'~~ ~ trl rr~~ ,~,. J ~,~~