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Home My WebLink About07-7396Todd J. Grinaway IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY PENNSYLVANIA VS. CIVIL ACTION - CUSTODY LaRe B. Grinaway, Joshua Parham, (minor), Stephanie Vokes, (mother of Joshua Parham) Defendants NO. U 7 -13 $ C ;,_,( -'-.- N O T I C E T O D E F E N D 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 served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections 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. 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 COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE PA 17013 717-249-3166 Mary A Etter Dissinger 67 Attorney for Plaintiff (Todd J. Grinaway Plaintiff vs. LaRe B. Grinaway, Joshua Parham (minor) Stephanie Vokes Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - CUSTODY NO. 0'2- '7.3 96 &t j COMPLAINT FOR CUSTODY 1. Plaintiff Todd J. Grinaway, maternal grandfather, residing at 1028 Teakwood Lane, Enola, Cumberland County, Pennsylvania. 2. The first Defendant is LaRe B. Grinaway, natural mother, residing at 1028 Teakwood Lane, Enola, Cumberland County, Pennsylvania. 3. The second Defendant is Joshua Parham, natural father, a minor, residing at 148 Salem Church Road, Mechanicsburg, Cumberland County, Pennsylvania. 4. The third Defendant is Stephanie Vokes, paternal grandmother, residing at 148 Salem Church Road, Mechanicsburg, Cumberland County, Pennsylvania. 5. Plaintiff seeks custody of the following child: Name Levi A. Grinaway 6. 7. Present Residence Age 1028 Teakwood Lane, Enola DOB- 10/23/07 The child was born out of wedlock. The child is presently in the custody of Plaintiff and Defendant Mother, who reside at 1028 Teakwood Lane, Enola, Cumberland County, Pennsylvania. 8. The child is only days old and has resided only with Plaintiff and Defendant Mother at 1028 Teakwood Lane, Enola, Cumberland County, Pennsylvania since date of birth on October 23, 2007. 9. The mother of residing at 1028 Pennsylvania. the child is Defendant, LaRe B. Grinaway, Teakwood Lane, Enola, Cumberland County, 10. She is unmarried. 11. The father of the child is Defendant, Joshua Parham, a minor, who currently resides at 148 Salem Church Road, Mechanicsburg, Cumberland County, Pennsylvania. 12. He is unmarried and is a minor. 13. The relationship of Plaintiff, Todd J. Grinaway, to the child is that of maternal grandfather. 14. The Plaintiff currently resides with Defendant, LaRe B. Grinaway, and the child, Levi A. Grinaway. 15. The relationship of Defendant, LaRe B. Grinaway to the child is that of natural Mother. The Defendant currently resides with Plaintiff, Todd J. Grinaway, and the child, Levi A. Grinaway. 16. The relationship of Defendant, Joshua Parham, to the child is that of natural Father. The Defendant currently resides with )efendant Stephanie Vokes, his mother. _7. The relationship of Defendant, Stephanie Vokes, to the child .s that of paternal grandmother. The Defendant currently resides rith Defendant Joshua Parham, her son. 18. 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. 19. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 20. 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. 21. The best interest and permanent welfare of the child will be served by granting the relief requested because Plaintiff can provide a stable environment within which the child will grow and flourish. 22. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named below who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: NONE. WHEREFORE, Plaintiff requests the Court to grant custody of the child, Levi A. Grinaway, to Plaintiff, Todd J. Grinaway, maternal grandfather. Respectfully Submitted: DISSINGER AND DISSINGER By: Mary A' Etter Dissinger Attorney for Plaintiffs Supreme Court I.D. #27736 28 N. 32nd Street Camp Hill, PA 17011 (717) 975-2840 (717) 975-3924 VERIFICATION I, Todd J. Grinaway, verify that the statements made in the Complaint for Custody 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. odd J. Gr' away, Pl ntiff C) C) r7 I ?. r 1 LT ,? 019 cr, c Todd J. Grinaway Plaintiff VS. LaRe B. Grinaway, Joshua Parham, (minor), Stephanie Vokes, (mother of Joshua Parham) Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - CUSTODY NO. U7-130ju STIPULATION and AGREEMENT AND NOW this C>?d day of A)kYW/-VK2007, the undersigned agree as follows: 1. LaRe B. Grinaway is the mother of the minor child, Levi A. Grinaway, who was born October 23, 2007. 2. Joshua Parham is the father of the minor child, Levi A. Grinaway, who was born October 23, 2007. 3. Joshua Parham is a minor. 4. The mother of Joshua Parham are Stephanie Vokes. 5. The parties agree Todd J. Grinaway, LaRe B. Grinaway and Joshua Parham shall have shared legal custody of Levi A. Grinaway. 6. Stephanie Vokes agrees that Todd J. Grinaway, the maternal grandfather shall have primary physical custody of Levi A. Grinaway. 7. LaRe B. Grinaway agrees that Todd J. Grinaway shall have primary physical custody of Levi A. Grinaway. 8. Joshua Parham, although a minor, agrees that it is in the best interest of Levi A. Grinaway that Todd J. Grinaway have primary physical custody of the infant. 9. The parties agree that LaRe B. Grinaway and Joshua Parham shall have periods of partial physical custody as the parties may agree and they may agree that the paternal grandparents and other individuals may have periods of partial physical custody. 10. The parties agree this Stipulation and Agreement shall be made an Order of Court. ??Y 120 D Date \ 123 c-A Date I rte-- O'?- Date Date LaRe B. Grinaway Joshua Parham Stephanie Vokes COMMONWEALTH OF PENNSYLVANIA ss NTY OF C1P -Ian nzv COU On this c.? day of /V?i?C/T2Kr 2007, before me a Notary Public, personally appeared Todd Grinaway, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. In witness whereof, I hereunto Notary Public set my hand and seal. NOTARIAL SEAL ANNETTE PERKINS Notary Public CAMP HILL BOROUGH, CUMBERLAND COUNTY My Commission Expires Jul 22, 2009 COMMONWEALTH OF PENNSYLVANIA . / /_ /J s s COUNTY OF t/-llj &rh" 2 o -- On this c-?7 day of lY//r`Flf/ Ki- 2007, before me a Notary Public, personally appeared LaRe B. Grinaway, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. In witness whereof, I hereunto set my hand and seal. Notary Public „ ... NZ iZAL SEAL ANNETTE PERKINS Notary Public CAMP HILL BOROUGH, CUINAERtAND Cotm My Commission EWkW Jul 22, 2009 COMMONWEALTH OF PENNSYLVANIA . l) ss COUNTY OF C?f.tln&r(CCP J On this day of Oalrp I-q" 2007, before me a Notary Public, personally appeared Joshua Parham, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. In witness whereof, I hereunto set my hand and seal. Notary Pu lic NOTARIAL SEAL ANNETTE PERKIN$ Notary kd*C CAWHIU. BOROUGH. CUMBSNAND COUNTY My COtm*don ExpkW Jul 22.2009 COMMONWEALTH OF PENNSYLVANIA . COUNTY OF ss On this day of 1a"Vy 2007, before me a Notary Public, personally appeared Stephanie Vokes, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. In witness whereof, I hereunto set my hand and seal. Notary Pu lic NOV M, SM ANNETTE PERKMLS t No" PJAC ,p&V HILL BOROUGH. C PABERLAND COUNTti' s My Commisafon Expirm Jul 22.2009 r A. ..4 l C ? t..) rmn tn??? JV yC3 t ` Todd J. Grinaway Plaintiff VS. LaRe B. Grinaway, Joshua Parham, (minor), Stephanie Vokes, (mother of Joshua Parham) Defendants : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - CUSTODY NO. .? 7,3 ?14 AFFIDAVIT OF NAILING COMMONWEALTH OF PENNSYLVANIA . ss .. COUNTY OF CUMBERLAND Mary A. Etter Dissinger, attorney for Plaintiff, being duly sworn according to law, says that she mailed by United States Certified Mail, Restricted Delivery, a true and correct copy of the Custody Complaint in this action to the Defendants at their residences, and that Defendants did receive same as evidenced by the signed receipts dated and ? 1 -7 attached hereto as Exhibit "A". ` - ---?? /`, r A . Mary A. fitter Dissinger Attorney for Plaintiff Supreme Court ID #27736 28 N. 32nd Street Camp Hill, PA 17011 (717) 975-2840 Sworn to and subscribed before me this day of December, 2007. Notary Public NOM?AK SEAL F NWM PERKM Nokxy Fum 0UQKCWAW&A DCOIMiY MY COMMMOn Expires Jul 22.2009 ¦? ¦ Complete items 1, 2, and 3. Also complete Item 4 if Restricted Delivery Is. desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, nor on the front if space permits. 1. Article Addressed to: % T *ICTEDa?s ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery Is desired. ¦ Print your name and address on the reverse so th-rtt we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front If space permits. 1. ArticleAcidrewt-STRICT ( 7037) Signature Addressee Recoiv d by Printed Name) It. Dgfdof Delivery Iri fl Is delivery address d' 0 Yes if YES, enter delivery address below: 0 No DEC 11 v? 3 Ice :6S?aM jZ Ulu" j Registered Return Receipt for Merchandise 0 Insured Mail 0 C.O.D. 4. Restricted DaNwry't Fxba Fie) Yes A. ? agent by (Printed Name) I C. Dat oral f Delivery h D. Is Wivery?1 /rom it A If YES, enter delivery address bet o a? DEC 17 2007 ?X\ Ir 3 Service Type (1 ' lzpfl aIA6 Xpec, Merch: 0 insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 2. ArtlcleNunrbar 7006 0100 0007 1054 7293 (iFaneter ftm eyrvlas ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we dart return the card to you. ¦ Attach this 1?,1le c f thee maalipleece, 7" r or on the frohiiilt P 1. Article Addreshe dft ,EL I p?,; Y qajjv& FCL?" eq r70S0 A. Signah" 0 Agent X ? Addressee B. t?ved by (Printed Name) C. Date of Delivery 1% %op D. Is delivery address efsl 0 Yes If YES, enter d address below. s No w? , 'XW DES i 9 20Q7 1AW 3 rce Type LISPS rtified Mail ? Express Mail Registered 0 Return Receipt-for Merchandise 0 Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fes) Yes 2. Article Number ^7 (bansfer from swvke f,abei) /0ce 6-5c-go L0 021 0 3's_/ Y & 1f' PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 _I EXHIBIT "A" Oil i n . o n 3 CP! ` i C DEC 2 6200700 Todd J. Grinaway Plaintiff VS. LaRe B. Grinaway, Joshua Parham, (minor), Stephanie Vokes, (mother of Joshua Parham) Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - CUSTODY NO. ,. 10 7 - 0'7 39 ORDER And now this -?14 day of -t.o,.4r Zftl, it is hereby Ordered and Decreed that Todd J. Grinaway, LaRe B. Grinaway, and Joshua Parham shall have shared legal custody, that Todd J. Grinaway shall have primary physical custody of Levi A. Grinaway (DOB 10/23/07), LaRe B. Grinaway and Joshua Parham, biological parents of Levi A. Grinaway, shall have periods of partial physical custody as the parties may agree. Al. w ,SIP o. ' 1N ?, r llllsitl --3d 6 J :11 WV 1 £ 33O LUDI AddlO?aOH,, C;dd :31HI n Todd J. Grinaway IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY PENNSYLVANIA VS. CIVIL ACTION - CUSTODY LaRe B. Grinaway, Joshua Parham, Defendants NO. 2007-07396 AFFIDAVIT OF MAILING COMMONWEALTH OF PENNSYLVANIA . ss .. COUNTY OF CUMBERLAND Mary A. Etter Dissinger, attorney for Plaintiff, being duly sworn according to law, says that she mailed by United States Certified Mail, Restricted Delivery, a true and correct copy of the Custody Complaint in this action to the Defendant at their residence, and that Defendant did receive same as evidenced by the signed receipt dated U W1 lac( , attached hereto as Exhibit "A". yc 1 ? ` Mary A.'Etter Dissinger Attorney for Plaintiff Supreme Court ID #27736 28 N. 32nd Street Camp Hill, PA 17011 (717) 975-2840 Sworn to and subscribed before me this laq day of June, 2009. N ary c WTARUII UK ASK& GMUM Na" Poft ANF Nu sm.. CUMURLM CNW raoy Co1iNiftif011 ExOme Aw 20.2013 . :-'--w ¦ Complete items 1, 2, and 3. Also complete M¦n 4 if Restricted Delivery Is desired. ¦ Prlrtt your name and address on the reverse so that return the card to you. ¦ Al och to the back of the malipiece, or on If space permits. -t. Article ARLsed to: t-7(D730 A. SOMb" X r A Addr?sese B. Received by (RIMed Nerve) 0. Date of DMwry D. ladeliveryadcheasd 1--ti fart ff YES, ender delivery address 9?g Jl!N IE ?4 Regbtered Return Rw w for MerdMufte ? Insured ma O C.O.D. 4. RestrieNd DeltvW (Extra Fee) 2. ArdeNumber 7006. 0100 0007 1055 2914 (Aarrsfbr ftm service bb4 PS Form 3811, February 2oo4 Domestic Retum Recelpt 1025MW-WJW EXHIBIT "A" _- , . 2009 JUNI 18 AIN S. 4! '.,?_, cu rT.? Todd J. Grinaway : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY : PENNSYLVANIA VS. LaRe B. Grinaway, : CIVIL ACTION - CUSTODY Joshua Parham, Defendants NO. 2007-07396 AFFIDAVIT OF MAILING COMMONWEALTH OF PENNSYLVANIA . ss .. COUNTY OF CUMBERLAND Mary A. Etter Dissinger, attorney for Plaintiff, being duly sworn according to law, says that she mailed by United States Certified Mail, Restricted Delivery, a true and correct copy of the Custody Complaint in this action to the Defendant at their residence, and that Defendant did receive same as evidenced by the signed receipt dated JO CI_, attached hereto as Exhibit "A". Mary A. Etter Dissinger Attorney for Plaintiff Supreme Court ID #27736 28 N. 32nd Street Camp Hill, PA 17011 (717) 975-2840 Sworn to and subscribed before me this 19 day of June, 2009. jNrr yy P c MOTAIMAI:EAI ANNLIr iM1?81 CW 1L CO 0U Peft =" •.Complets Item 1, 2, and 3. Also complete A sig to ttirn 4 H Restricted Delivery is desired. X ? Agerrt ¦ Print your name and address on the reverse Adds, Ag? 8o that we can return the card to you. B. Rom ed by (Printed NWO) of ¦ Attach this card to the back of the mailpiece, or on the front If space permits. ?- fT,r C D. item 17 ? 1. Article Addressed to: low. ' No T too"? J EAC -v C."G9 CLA - 3Ve.gletered c? ? Return Receipt for Mert wmfte ? insured man ? C.O.D. 4. Restricted Deiivery/t p ft Fee) " Tes I ArtldfaNumber 7006 0100 0007 1055 2907 (transfer from service ftW ?PS Farm 3811, February 2004 Don stb Return Receipt 1=.12-M-11w EXHIBIT "A" Y . ALEUT- ' i iCE 2099 JIVIN 18 Al 8• L 8