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Home My WebLink About08-1381TREVA J. CRAIG, Plaintiff V. MATTHEW R. CRAIG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08 - 13fl dle?d CUSTODY NOTICE Defendant, Matthew R. Craig, 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. a TREVA J. CRAIG, Plaintiff ) V. ) MATTHEW R. CRAIG, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08 - 136'/ &,erC- -u.•-• CUSTODY COMPLAINT FOR CUSTODY The Plaintiff, Treva J. Craig, by and through her attorneys, the Neuharth Law Offices, respectfully submits this Complaint for Custody and avers the following: 1. Plaintiff, Treva J. Craig, hereinafter "Mother," is an adult individual currently residing at 66 Fox Hill Road, Shippensburg, Cumberland County, Pennsylvania 17257. 2. Defendant, Matthew R. Craig, hereinafter "Father," is an adult individual currently residing at 22 North Queen Street, Shippensburg, Cumberland County, Pennsylvania 17257. 3. Mother and Father are the natural parents of the following children: Courtney Jane Craig, born June 1, 1994, and Karter Matthew Craig, born November 12, 2001, hereinafter "children." The eldest child was born out of wedlock; the youngest child was not born out of wedlock. The parties married March 27, 1998 and separated on August 18, 2004. The children presently reside with both parties at their respective residences. During the past five years, the children have resided with the following persons and at the following addresses: Persons Address Date Mother 66 Fox Hill Road July 1997 to Shippensburg, PA 17257 Present 46 Father 22 North Queen Street October 2007 to Shippensburg, PA 17257 Present The mother of the children is Treva J. Craig, who currently resides at 66 Fox Hill Road, Shippensburg, Pennsylvania. She is separated from Father. The father of the children is Matthew R. Craig, who currently resides at 22 North Queen Street, Shippensburg, Pennsylvania. He is separated from Mother. 4. The relationship of Plaintiff to the children is that of mother. Mother currently resides with the children, on alternating weeks, and her fiance, Dustin Bailey. 5. The relationship of Defendant to the child is that of father. Father currently resides with the children on alternating weeks. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. There have been no other custody actions within this or any other jurisdiction regarding the child or the parties to this action. 7. The parties signed a stipulation providing for a custody arrangement that the parties believe is in the best interests and welfare of the children. Essentially, the arrangement provides the parties with shared legal custody of the children as well as shared physical custody of the children on alternating weeks. The undersigned filed said stipulation and an accompanying proposed custody order concurrently with this Complaint for Custody. 8. Mother believes Father is unrepresented. Therefore, a copy of this Complaint for Custody will be served on 22 North Queen Street, Shippensburg, Pennsylvania, 17257, Father's current address, via U.S. First Class Mail, on Monday, March 3, 2008. 9. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children 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 Treva J. Craig respectfully requests this Honorable Court grant the parties custody of the children according to the provisions of the attached stipulation and agreement of the parties. Respectfully submitted, Paul M. Ferguson ' Supreme Ct. ID #: 203293 Attorney for Plaintiff Neuharth Law Offices P.O. Box 359 232 Lincoln Way East Chambersburg, PA 17201 (717) 264-2939 VERIFICATION I verify that the statements made in this document are true and correct to the best of my knowledge, information and belief. 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. 1 Date TREVA J. CRAIG, ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, Plaintiff ) PENNSYLVANIA V. ) CIVIL ACTION - LAW MATTHEW R. CRAIG, ) N0.08 - Defendant ) 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: Matthew R. Craig 22 North Queen Street Shippensburg, PA 17257 03/03/19j;' Date Respectfully submitted, Paul M. Ferguson Supreme Ct. ID No.: 203293 Attorney for Plaintiff Neuharth Law Offices P.O. Box 359 232 Lincoln Way East Chambersburg, PA 17201 (717) 264-2939 V l ? ? _1 ?l Q' 1? , w V ,? o^ ( `` \?. v T v ? `v ^` ?.1 ?? r": f 4 L. -TA ^ ^ i f..! ? t' !- _? C i ?.? TREVA J. CRAIG, Plaintiff V. MATTHEW R. CRAIG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.08 - /3-F/ C??J rte'' CUSTODY STIPULATION AND AGREEMENT 1. Plaintiff, Treva J. Craig, hereinafter "Mother," is an adult individual currently residing at 66 Fox Hill Road, Shippensburg, Cumberland County, Pennsylvania 17257. 2. Defendant, Matthew R. Craig, hereinafter "Father," is an adult individual currently residing at 22 North Queen Street, Shippensburg, Cumberland County, Pennsylvania 17257. 3. Plaintiff is the natural mother of the following children: Courtney Jane Craig, born June 1, 1994, and Karter Matthew Craig, born November 12, 2001, 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 March 27, 1998 and separated on August 18, 2004. 6. The relationship of Plaintiff to the children is that of mother. Mother resides with the children, on alternating weeks, and her fiance, Dustin Bailey. 7. The relationship of Defendant to the child is that of father. Father resides with the children on alternating weeks. 8. During the past five years, the children have resided at the following addresses with the following persons: Persons Address Date Mother 66 Fox Hill Road July 1997 to Shippensburg, PA 17257 Present Father 22 North Queen Street October 2007 to Shippensburg, PA 17257 Present 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 serves the children's best interest and welfare 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 , 2008, 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 , 2008, 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, Courtney Jane Craig, born June 1, 1994, and Karter Matthew Craig, born November 12, 2001. 2. Physical Custody. The parties shall exercise physical custody of the children on alternating weeks. The parties shall exchange custody of the children every Monday afternoon. 3. Holidays and Birthdays. The parties shall share physical custody of the children on an equal basis for holidays and the children's birthdays at times as the parties agree. 4. Transportation. The party receiving custody shall provide transportation. When school is in session, the party receiving custody shall pick up the children from their school bus stop. When school is not in session, the party receiving custody shall pick up the children from the child care provider. By the Court, J. 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 Treva J. Craig 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 IN WITNESS WHEREOF, the parties, intending to be legally bound, have signed hereunto. WITNESS ' ? = ?, -- i c,? ; ? i .,. ? _Z._. `' ... _. ?.+?.? LJ (.? _.... i -. MAR 0 5 2008 TREVA J. CRAIG, Plaintiff V. MATTHEW R. CRAIG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08 - 1311 4wA,? CUSTODY ORDER OF COURT AND NOW, this day of u:vl , 2008, 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, Courtney Jane Craig, born June 1, 1994, and Karter Matthew Craig, born November 12, 2001. 2. Physical Custody. The parties shall exercise physical custody of the children on alternating weeks. The parties shall exchange custody of the children every Monday afternoon. 3. Holidays and Birthdays. The parties shall share physical custody of the children on an equal basis for holidays and the children's birthdays at times as the parties agree. 4. Transportation. The party receiving custody shall provide transportation. When school is in session, the party receiving custody shall pick up the children from their school bus stop. When school is not in session, the party receiving custody shall pick up the children from the child care provider. ,c , 'o o / By the Court, ZL Q- 117- Cg= r ` nr ?• +. ? -- Cy pr y? V