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HomeMy WebLinkAbout07-7166W LAURA L. SAUER, V. Plaintiff TIMOTHY A. SAUER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.)'? - '7rCalo l.: ivi l Ter?nn CIVIL ACTION - LAW IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, LAURA L. SAUER, through her attorney, Mindy S. Goodman, and avers the following: 1. Plaintiff is an adult individual residing at 960 Baltimore Pike, Gardners, Cumberland County, Pennsylvania. 2. Defendant is an adult individual residing at 300 Fairview Street, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff is the mother and Defendant is the father of the minor child whose name and date of birth are as follows: LOGAN TIMOTHY SAUER DoB July 16, 2007 4. Since the child's birth, Plaintiff has been the sole caretaker for the minor child, and Defendant has had minimal contact with the minor child. 5. As a result of the parties' desire to do what is best for their son, they have come to an agreement with regard to the issues of child custody and have entered into a stipulation, which is filed simultaneously with this Complaint. r" WHEREFORE, Plaintiff requests this Court enter an Order adopting the stipulation that is filed simultaneously herewith. Respectfully submitted, Mindy S. Goodman Attorney at Law ID No. 78407 2215 Forest Hills Drive - Suite 35 Harrisburg, PA 17112 (717) 540-8742 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. im? Li Laura L. Sauer sr O 7` T -77 i . W b • ::.. .. > r 0 LAURA L. SAUER, V. IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA TIMOTHY A. SAUER, Defendant NO. CIVIL ACTION - LAW IN CUSTODY STIPULATION FOR AN AGREED ORDER OF CUSTODY AGREEMENT, made this day of WMP2btf , 2007, by and between LAURA L. SAUER, hereinafter referred to as "Mother," and TIMOTHY A. SAUER, hereinafter referred to as "Father." WITNESSETH WHEREAS, Plaintiff and Defendant are the natural parents of LOGAN MATTHEW SAUER, whose date of birth is July 16, 2007; and WHEREAS, Plaintiff and Defendant have come to an agreement concerning the issues of child 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, the parties hereby stipulate and agree as follows: LEGAL CUSTODY 1. Mother shall have primary legal custody of the minor child, legal custody being defined as the legal right to make major decisions affecting the upbringing of the child, including but not limited to medical, religious, and educational decisions. 2. Father has the right to be kept informed of the child's educational and medical development, and shall have a right of access to the child's educational and medical records. Father shall be entitled to complete and full information concerning the child from Mother and from any doctor, dentist, teacher or similar authority, and to have copies of any reports, notices or other communications given to Mother as the individual having primary physical custody of the minor child. 3. Mother and Father will be securing a divorce, after which Mother intends to resume her maiden name. Father and Mother agree that it will be easier for the minor child if his last name is the same as that of his Mother and therefore Father hereby consents to Mother petitioning the court to change the minor child's name from Logan Matthew Sauer to Logan Matthew Mann. 4. Mother shall notify Father of any matter relating to the child, which could reasonably be expected to be of significant concern to Father. 2 PHYSICAL CUSTODY 5. Mother shall have primary physical custody of the minor child, primary physical custody being defined as actual physical possession and control of the child. 6. The parties do not intend to be bound by a rigid custodial schedule and therefore Father shall have partial custody rights with the minor child at such times as the parties mutually agree. 7. The parties understand that situations and circumstances in their lives and the life of their child require them to make changes in their schedule to accommodate the other and the child's schedule. Consequently, each party agrees to work with one another to accommodate changes in the other party's schedules with regard to physical custody and well-being of the minor child without the need to seek a formal change to this custodial schedule. 8. Neither party shall disparage the other party or the other party's family in front of the child, whether the child is "sleeping" or "awake," nor shall either party attempt to alienate the affections of the child from the other party or the other party's family, or allow third parties to attempt to alienate the affections of the child from the other party. 9. Neither party shall drink alcoholic beverages to the point of intoxication, nor shall either party allow third parties to drink alcoholic beverages to the point of intoxication while in the presence of the minor child. 3 10. Neither party shall use drugs, other than prescribed or over-the- counter medication, nor shall either party allow third parties to use drugs, other than prescribed or over-the-counter medication, while in the presence of the minor child. WHEREFORE, the parties request that this Stipulation be entered as an Order of the Court. 6" a,, - - - Wi s "k0a,J I A r?7d I aura L. Sauer, Plaintiff .1.4wor Ao /I "t n ss Timothy A. uer, Defendant 4 C") rNa CZD m -. e co i DEC 0 5 20011„ V LAURA L. SAUER, Plaintiff V. TIMOTHY A. SAUER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 0'1- 'lf loV Civil `?rrq :NO. CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this th day of Q 4. (- awe V , 2007, it is hereby ORDERED AND DECREED that the attached Stipulation for an Agreed Order of Custody is made an Order of Court and said Stipulation is adopted in its entirety and incorporated herein as an Order of Court. Dated: tL 1 0 5 BY THE COURT: Ck, wr**dt Xll? VIN', d kNflor` ? C =LEI R L- 31G ROZ -- 41-cl ntJb' ar-i.t J()