Loading...
HomeMy WebLinkAbout08-1615 JULIE N. CLUCK, Plaintiff V. RAYMOND M. BIRCH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA NO.06 - l `I S CIVIL TERM CIVIL ACTION - LAW IN CUSTODY PITT A T nnV PIT` TT 'A m'rQ T 9.V0xVLS 0 LVV4"%.L1Vi9 1Z THIS STIPULATION, made this P-7 day of .2008, by and between JULIE N. CLUCK, (hereinafter referred to as Mother), and RAYMOND M. BIRCH, (hereinafter referred to as Father). WITNESSETH: WHEREAS, Mother is the biological parent of AIDAN M. BIRCH, born June 12,. 2007, hereinafter referred to as Aidan. WHEREAS, Father is the biological parent of Aidan. WHEREAS, Mother and Father, for the best interest of the Aidan, wish to amicably resolve the custody of AIDAN. AND NOW, the parties intending to be legally bound hereby agree that: 1. Mother shall have legal and primary physical custody of Aidan subject to visitation by Father as the parents may agree are in the best interest of Aidan. 2. Each parent shall inform the other of significant events that occur in the Aidan's life. 3. Each party is to inform the other of any changes in their employment, health, residence or telephone number. 4. The parties intend that the terms of this Custody Stipulation be made an order of court. /9.,, n 411,? wit es W i t n P S I A I z U L illc bat r- JULIE N.. LUC L L7 U1j Date RAYMOND M. BIRCH Commonwealth Qf Pennsylvania: ss County of x'06146,4 4,#t 1, PERSONALLY APPEARED BEFORE ME, this 41 day of A15 , 2008, a notary public, in and for the Commonwealth of Pennsylvania, JULIE N. CLUCK, known to me (or satisfactorily proven to be) the person whose name is subscribed to the within custody stipulation and acknowledged that she executed the same for the purposes herein contained. CCmmonwetelth n• Pe tins I nia NOTARIAL SEAL BRYAN J. KOLB, Notary Public East Pennsboro Twp., County of Cumberland 1my Commission Expires January 13, 2010 Commonwealth of Pennsylvania: County of ss 4 Notary Pu li PERSONALLY APPEARED BEFORE ME, this 2-1 day of //??l3 , 2008, a notary public, in and for the Commonwealth of Pennsylvania, RAYMOND M. BIRCH, known to me (or satisfactorily proven to be) the person whose name is subscribed to the within custody stipulation and acknowledged that he executed the same for the purposes herein contained. _ Commonwealth Pennsylvania NOTARIAL SEAL BRYAN J. KOLB, Notary Public East Pennsboro Twp., County of Cumberland My Commissior ?? .. January 13, 2010. - /E"", n A?'jz Notary P (Li i 0 a ? 73 -? F % .. THOMAS D. GOULD, ESQUIRE 2 EAST MAIN STREET SHIREMANSTOWN, PA 17011 (717) 731-1461 JULIE N. CLUCK, Plaintiff V. RAYMOND M. BIRCH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.OG -11.19 CIVIL TERM CIVIL ACTION - LAW CUSTODY ACTION CUSTODY COMPLAINT TO THE HONORABLE JUDGES OF SAID COURT: 1. The Plaintiff is Julie N. Cluck residing at 171 S. Enola Drive, Enola, Cumberland County, Pennsylvania 17025. 2. The Defendant is Raymond M. Birch who resides at 1324 Mountain Road, Harrisburg, Dauphin County, Pennsylvania 17112. 3. Plaintiff seeks legal and physical custody of the following child: NAME PRESENT RESIDENCE DOB Aidan M. Birch 171 S. Enola Drive 06/12/07 Enola, PA The child was not born in wedlock. The child is presently in the physical custody of Julie N. Cluck who resides at 171 S. Enola Drive, Enola, Pennsylvania. The child has resided with the following persons and at the following addresses: Person Address Mother 171 S. Enola Drive Enola, PA Date 06/07 - present The mother of the child is Julie N. Cluck who resides at 171 S. Enola Drive, Enola, Pennsylvania 17025. She is not married. The father of the child is Raymond M. Birch who lives at 1324 Mountain Road, Harrisburg, Pennsylvania 17112. He is not married. 4. The relationship of Plaintiff to the child is that of Mother. The Plaintiff currently resides with the following persons: Name Relationship Sandra Cluck Mother Daniel Albright Stepfather Stacey Cluck Sister Danielle Albright Sister 5. The relationship of Defendant to the child is that of Father. The Defendant currently resides with the following persons: Unknown 6. Neither party has participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: A. Plaintiff has been the only caretaker for the child. B. ,Defendant does not want to be part of child's life. 2 8. 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. Plaintiff requests this Honorable Court to grant hiiii joint legal custody and partial physical custody of his child, at times determined to be in the child's best interest. Respectfully submitted, '7 oe b. >6"44e- Thomas D. Gould, Esquire ID #36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 VERIFICATION I, Julie N. Cluck, hereby certify that the foregoing CUSTODY COMPLAINT is 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 unsworn falsification to authorities. DATED: '3 1 o Julie N. Cluck Plaintiff 3 1"' W ?+ W r 6' V l all hV c? MAR 12 2008 , JULIE N. CLUCK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO, as-l?o?S C?UL? RAYMOND M. BIRCH, CIVIL ACTION - LAW Defendant CUSTODY ACTION ORDER OF COURT AND NOW this 'f 9' day of i1)nacA , 200, the terms and conditions of the attached CUSTODY STIPULATION dated February 27, 2008, is hereby incorporated and made an Order of this Honorable Court. xo?? BY THE COURT: rn?