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HomeMy WebLinkAbout03-6647L. JEAN and JERRY C. PHILLIPS, Plaintiffs CYNTHIA HILL, Defendant :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW :CUSTODY CUSTODY STIPULATION AND NOW, this day of ~ ec~,,~[~---F' ,2003, L. Jean and Jerry C. Phillips and Cynthia Hill, intending to be legally bound, agree as follows: 1. L. Jean and Jerry C. Phillips shall have primary physical and legal custody of the minor child, Justin C. Bretz. 2. Cynthia Hill shall have visitation with Justin C. Bretz at all times that the parties may agree. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the date and year first above written. WITNESS · L. JEAN and JERRY C. PHILLIPS, Plaintiffs CYNTHIA HILL and JOHN T. BRETZ, Defendants :iN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW :CUSTODY CUSTODY COMPLAINT WITH REQUEST FOR STIPULATED ORDER 1. Plaintiffs are L. Jean and Jerry C. Phillips (herein referred to as Grandparents) who reside at 208 Locust Street, Camp Hill, Pennsylvania 17011. 2. Defendants are Cynthia Hill (hereinafter "Mother") of 728 N. West 15~ Street, Moore, Oklahoma and John T Bretz of 208 Locust Street, Camp Hill, Pennsylvania (hereinafter "Father"). Plaintiffs seek custody of Justin C. Bretz, born on February 24, 1986. 4. The child was born during the marriage~ The child is presently in the custody of the Grandparents and Father. 5. During the past seventeen (17) years, the child has primarily resided with the following persons at the following addresses: Sallie L. Jean Phillips Jerry Phillips John Bretz Address 208 Locust Street Camp Hill, Pennsylvania 17011 Approx. Dates since 15 years ago The mother of the child is Cynthia Hill. The father of the child is John T. Bretz. The relationship of Plaintiffs to the child is Grandchild. Plaintiffs have not participated as a party or a witness, or in any other capacity in other litigation concerning the custody of the child in this or any other Court. 10. Plaintiffs have no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 11. 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 respect to the child. 13. The best interest and permanent welfare of the child will be served by granting the relief requested. 14. Each parent whose parental rights to the child has not been terminated have been named as parties to this action. 15. The parties agreed on the custody of the minor child and entered into the stipulation attached hereto and incorporated herein and marked as Exhibit "A". WHEREFORE, Plaintiff requests the Court to grant them custody of the minor child. Respectfully submitted, E HOFFMAN, ESQUIRE Supreme Court I.D.# 66307 105 North Front Street Post Office Box 11475 Harrisburg, PA 17108-1475 (717) 233-1112 Attorney for Plaintiff DATED: 12/30/03 L. JEAN and JERRY C. PHILLIPS, Plaintiffs CYNTHIA HILL, Defendant :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA NO. :CIVIL ACTION ~ LAW :CUSTODY CUSTODY STIPULATION AND NOW, this day of ~dec~b-'--~- ,2003, L. Jean and Jerry C. Phillips and Cynthia Hill, intending to be legally bound, agree as follows: 1. L. Jean and Jerry C. Phillips shall have primary physical and legal custody of the minor child, Justin C. Bretz. 2. Cynthia Hill shall have visitation with Justin C. Bretz at all times that the parties may agree. 1N WITNESS WHEREOF, the parties hereto have set their hands and seals the date and year first above written. WITNESS PHILLIPS WI~SS -~THIA HILL L. JEAN and JERRY C. PHILLIPS, Plaintiffs CYNTHIA HILL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW CUSTODY VERIFICATION We, L. JEAN PHILLIPS and JERRY C. PHILLIPS, upon our personal knowledge, information and belief, aver that the facts and statements made in the foregoing document are true and correct to the best of our knowledge. We understand that false statements will subject us to the criminal penalties of 18 PACS, Section 4904, relating to unsworn falsification to authorities. Date: December~(~ , 2003 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the attached document was served on the person below on this day by depositing into U.S. Mail at Harrisburg, Pennsylvania, first-class postage prepaid on this day addressed as follows: Cynthia Hill 728 North West 15t~ Street Moore, Oklahoma 73160 John Bretz 208 Locust Street Camp Hill, PA 17011 By: R~.lly submitted, Emily Long Hoffman, Esquire Sup. Ct. 1D # 66307 105 North Front Street P.O. Box 11475 Harrisburg, PA 17108 (717)233-1112 Attorney for Petitioner Date: December 30, 2003 L. JEAN AND JERRY PHILLIPS, Plaintiff CYNTHIA HILL and JOHN T. BRETZ, Defendants :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW :CUSTODY ORDER OFCOURT AND NOW, this __....~/~ day of_._~__2 ~DM~>~ 'n ___, 2o~, it is hereby ORDERED that the Custody Stipulation, attached hereto, executed by the parties a~ad dated December 22, 2003, is entered as an Order of this Court.