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Home My WebLink About07-7004NICOLE R. BEAM, Plaintiff V. NATHAN J. BEAM, SR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07 - .70 Q y CIO i +e-c?" CUSTODY NOTICE Defendant, Nathan J. Beam, Sr., you have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a temporary or permanent custody order may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose rights important to you, including custody or visitation of your children. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 AMERICAN WITH DISABILITIES 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 accessible facilities and reasonable accommodations available to disabled 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. NICOLE R. BEAM, Plaintiff ) V. ) NATHAN J. BEAM, SR., ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07 - 106 y c tv, I -f ,et,,, CUSTODY COMPLAINT FOR CUSTODY The Plaintiff, Nicole R. Beam, by and through her attorneys, the Neuharth Law Offices, respectfully submits this Complaint for Custody and avers the following: 1. Plaintiff, Nicole R. Beam, hereinafter "Mother," is an adult individual currently residing at 13 Dykeman Road, Shippensburg, Cumberland County, Pennsylvania 17257. 2. Defendant, Nathan J. Beam, Sr., hereinafter "Father," is an adult individual currently residing at 1870 Orchard Road, Chambersburg, Franklin County, Pennsylvania 17201. 3. Mother and Father are the natural parents of the following children: Nathan James Beam, Jr., born January 28, 2004, and Riley Nicole Beam, born July 12, 2006, hereinafter "children." The eldest child was born out of wedlock; the youngest child was not born out of wedlock. The parties married November 13, 2004 and separated on October 17, 2007. The children presently reside with Mother at 13 Dykeman Road, Shippensburg, Pennsylvania. Since birth, the children have resided with the following persons and at the following addresses: Persons Address Date Mother 13 Dykeman Road October 2007 to Shippensburg, PA 17257 Present 8. Mother believes Father is unrepresented. Therefore, a copy of this Complaint for Custody will be served on 1870 Orchard Road, Chambersburg, Pennsylvania, Father's current address, via U.S. First Class Mail, on Wednesday, November 21, 2007. 9. 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. No other persons are known to have or claim a right to custody or visitation of the children. WHEREFORE, Plaintiff Nicole R. Beam respectfully requests this Honorable Court grant the parties custody of the children according to the provisions of the attached stipulation of the parties. Respectfully submitted, Paul M. Ferguson Supreme Ct. ID #: 203293 Attorney for Plaintiff Nicole R. Beam Neuharth Law Offices P.O. Box 359 232 Lincoln Way East Chambersburg, PA 17201 (717) 264-2939 NICOLE R. BEAM, Plaintiff V. NATHAN J. BEAM, SR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07 - CUSTODY CERTIFICATION OF SERVICE I, Paul M. Ferguson, Esquire hereby certify that I am on this day serving a true and correct copy of the attached Complaint for Custody to the following individual by First Class U.S. mail, postage prepaid addressed as follows: Nathan J. Beam, Sr. 1870 Orchard Road Chambersburg, PA 17201 a/ 6`7 Dat Respectfully submitted, Paul M. Ferguson Attorney for Plaintiff Nicole R. Beam Supreme Ct. ID #: 203293 Neuharth Law Offices P.O. Box 359 232 Lincoln Way East Chambersburg, PA 17201 (717) 264-2939 $1 J, C Q W W n _ ? cox f m A f 7- E n 1 NICOLE R. BEAM, Plaintiff ) V. ) NATHAN J. BEAM, SR., ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.07- wQt-( Cau+i CUSTODY STIPULATION 1. Plaintiff, Nicole R. Beam, hereinafter "Mother," is an adult individual currently residing at 13 Dykeman Road, Shippensburg, Cumberland County, Pennsylvania 17257. 2. Defendant, Nathan J. Beam, Sr., hereinafter "Father," is an adult individual currently residing at 1870 Orchard Road, Chambersburg, Franklin County, Pennsylvania 17201. 3. Plaintiff is the natural mother of the following children: Nathan James Beam, Jr., born January 28, 2004, and Riley Nicole Beam, born July 12, 2006, hereinafter "children." 4. Defendant is the natural father of the children. 5. The eldest child was born out of wedlock; the youngest child was not born out of wedlock. The parties married November 13, 2004 and separated in October 17, 2007. 6. The relationship of Plaintiff to the children is that of mother. Mother resides with the children. 7. The relationship of Defendant to the child is that of father. Father resides with his mother, Trish Keifman, stepfather, Paul Keifrnan, and two sisters, Maryann Steenstra and Corene Steenstra. 8. Since birth, the children have resided at the following addresses with the following persons: Persons Address Date Mother 13 Dykeman Road October 2007 to Shippensburg, PA 17257 Present Mother 13 Dykeman Road January 2004 to Father Shippensburg, PA 17257 October 2007 9. Plaintiff has no knowledge of any other custody proceedings concerning the children pending in this Court or any other court of this Commonwealth. Plaintiff does not know of another person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 10. The parties agree it is in the best interest of the children for the Court to enter the attached Order of Court. 11. Plaintiff has been represented by Paul M. Ferguson, Esquire. Father has been given the opportunity to seek counsel; however, he has decided to proceed pro se. WHEREFORE, this day of , 2007, the parties, intending to be legally bound and waiving their right to be present when this agreement and order are presented and executed, hereby stipulate and agree that the Court may enter the following order in the above-captioned case: ORDER OF COURT AND NOW, this day of , 2007, based on the stipulation of the parties, the Court hereby Orders as follows: 1. Legal Custody. The parties shall have joint legal custody of the minor children, Nathan James Beam, Jr., born January 28, 2004, and Riley Nicole Beam, born July 12, 2006. 2. Physical Custody. Plaintiff shall exercise primary physical custody of the children subject to Defendant's periods of partial physical custody on alternating weekends from Friday morning until Sunday at 5:00 p.m. and every week from Wednesday morning until Thursday afternoon. Defendant shall exercise physical custody at other times as the parties agree. 3. Holidays and Birthdays. Custody arrangements for holidays and birthdays shall be at times as the parties agree. By the Court, J. IN WITNESS WHEREOF, the parties, intending to be legally bound, have signed hereunto. WITNESS Nicole R. Beam Nathan J. Beam, Sr. VERIFICATION I verify that the statements made in the foregoing Stipulation are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date Nicole R. Beam VERIFICATION I verify that the statements made in the foregoing Stipulation are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. I I /1? to-, Dat Nathan J. Beam, Sr. C N <Y ? O i-?' -? ?J, ?? _ ?;} ? r .? ,? ""? _? d .?" -,C NICOLE R. BEAM, ) Plaintiff ) V. ) NATHAN J. BEAM, SR., ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.07 - _700q cl ai 1 CUSTODY ORDER OF COURT t/ / NoYalvti AND NOW, this day of 2007, based on the stipulation of the parties, the Court hereby Orders as follows: 1. Legal Custody. The parties shall have joint legal custody of the minor children, Nathan James Beam, Jr., born January 28, 2004, and Riley Nicole Beam, born July 12, 2006. 2. Physical Custody. Plaintiff shall exercise primary physical custody of the children subject to Defendant's periods of partial physical custody on alternating weekends from Friday morning until Sunday at 5:00 p.m. and every week from Wednesday morning until Thursday afternoon. Defendant shall exercise physical custody at other times as the parties agree. 3. Holidays and Birthdays. Custody arrangements for holidays and birthdays shall be at times as the parties agree. By the Court, J soh 4 LI_, r- C? C t