HomeMy WebLinkAbout08-1654JAIME N. LONG,
V.
NO. 2008 - 166-Y CIVIL
BRIAN K. LONG, JR., CIVIL ACTION - LAW
Defendant
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CUSTODY COMPLAINT
1. The Plaintiff is Jaime N. Long (hereinafter re?erred to as "Mother"), an
adult individual who currently resides at, 303 Sandbank Road, Mount Holly Springs,
Cumberland County, Pennsylvania.
2. The Defendant is Brian K. Long, Jr. (hereinafter referred to as "Father"),
an adult individual who currently resides at 147 North Eas? Street, Carlisle, Cumberland
County, Pennsylvania.
3. The parties are the parents of one minor
born February 6, 2005 (hereinafter referred to as "Child")
The child was born in wedlock
The child is currently in the custody of P
During the past five years, the child has
at the following addresses:
Persons
Residences
d, namely, Katlyn M. Long,
ed with the following persons
Dates
Jaime N. Long 303 Sandbank Road 2005 to 2007
Brian K. Long, Jr. Mt. Holly Springs, PA 1 065_
Jamie N. Long 303 Sandbank Road 2007 to Present
Mt. Holly Springs, PA 17065
The natural father of the child is Brian K. Lang, Jr., currently residing at 28
Coventry at Waterford, York, York County, Pennsylvania
IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
He is married to the Plaintiff.
The natural mother of the child is Jaime N. Long, currently residing at 303
Sandbank Road, Mount Holly Springs, Cumberland County, Pennsylvania.
She is married to the Defendant.
(
4. The relationship of the Plaintiff to the child is that of natural mother. The
Plaintiff currently resides with the following persons:
Names Relationship
Katlyn N. Long Daughter
Roy Shenk Father
Margie Shenk Mother
5. The relationship of the Defendant to the child is that of natural father. The
Defendant currently resides with the following persons:
Names
Brandi L. Snyder
Relationship
Friend
6. Plaintiff has not participated as a party or wi0ess, or in another capacity,
in other litigation concerning the custody of the child in this or another court.
Plaintiff has no information of a custody proceeding concerning the child
pending in a court of this Commonwealth or any other
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 parties shared legal and the Plaintiff primary physical custody.
t.r
8. Each parent whose parental rights to the child have 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 your Honorable Court to grant her primary
physical custody of the child with Defendant having partial ?ustody at such times as the
parties may mutually agree.
Ily submitted,
O'BRIEN, BARIC & SCHERER
.. T,
Date: Z- L? - A
Mic el A. Scherer, Esquire
I.D. 61974
19 West South Street
Carli le, Pennsylvania 17013
(717 249-6873
VERIFICATION
verify that the statements made in the foregoing Cust
and correct. I understand that false statements herein are
penalties of 18 Pa. C.S. § 4904, relating to unsworn falsificat'
-ody Complaint are true
ade subject to the
on to authorities.
2 cq-nom 7
Date:
J i . Long
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JAIME N. LONG ,
Plaintiff
V.
BRIAN K. LONG, JR.,
Defendant
IN THE COURT F COMMON PLEAS OF
CUMBERLAND OUNTY, PENNSYLVANIA
NO. 2008 - /G CIVIL
CIVIL ACTION - W
CUSTODY STIPULATION AND AGR?EMENT
THIS STIPULATION AND AGREEMENT entered into this lQ?? day of
2008, by and between Jaime N. long (hereinafter referred to
"Mother") and Brian K. Long, Jr. (hereinafter referred to as "Father");
The parties are the natural parents of Katlyn M. Lo g, born February 6, 2005,
(hereinafter referred to as "child"); and,
WHEREAS, the natural parents are separated and I,living in separate residences;
and,
WHEREAS, the parties believe it to be in the best interest of the child that the
parties share legal custody of the child at this time; and,
WHEREAS, Mother shall have primary physical custody of the child and Father
shall have partial physical custody of the child at such times as the parties may mutually
agree.
WHEREAS, the parties wish enter into this Agreement relative to the custody of
the child.
NOW THEREFORE, in consideration of the mutual) covenants, promises and
agreements as hereinafter set forth, the parties agree as follows:
1. The parties shall share legal custody of the child, Katlyn M. Long, born
February 6, 2005, (hereinafter referred to as "child"). Shared legal custody means the
right of both parents to control and to share in making decisions of importance in the life
of their child. Each parent shall have an equal right, to be exercised jointly with the
other parent, to make all major non-emergency decisions affecting the child's general
well-being, including, but not limited to, all decisions regarding their health, education
and religion. Each parent shall notify the other parent of any medical, dental, optical,
counseling and other appointments of the child with health] care providers, sufficiently in
advance thereof so that the other party may attend, if he or she so chooses.
Pursuant to the terms of 23 Pa. C.S.A.§5309, each parent shall be entitled to
equal access to all medical records and information pertaining to the child; including,
but not limited to, the child's school, medical, dental, religious and other important
records and the residence address of the other parent.
2. Mother shall have primary physical custody of the child.
3. Father shall have partial physical custody of the child at such times as the
parties may mutually agree.
4. The parties shall share physical custody of the child on holidays at such
times and under such circumstances as the parties from time to time agree.
5. The parties shall not do anything which may strange the child from the
other party, or injure the opinion of the child as to the othe? parties or which may
hamper the free and natural development of the child's love or affection for the other
parties.
6. The parties desire that this Stipulation and Agreement be made an Order
of Court to the Court of Common Pleas of Cumberland County, and further
acknowledge that the Court of Common Pleas of Cumberland County does, in fact,
have jurisdiction over the issue of custody and the minor child and shall retain
jurisdiction should circumstances change and any party d sires or requires modification
of said Order.
8. The parties acknowledge that they have
provisions of this Agreement.
WITNESS:
Date: 2 Fb"N
Date:
and understand the
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Jaim N.
n K. Long, Jr.
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u5t
MAR 14 2008 ,0s
JAIME N. LONG IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2008 - J105V CIVIL
BRIAN K. LONG, JR., CIVIL ACTION - LAW
Defendant
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ORDER OF COURT r AND NOW, this the If uay of P%» CA 2008, ups
?= c y
consideration of the within Stipulation, the following Custody Agreement is, rely
adopted as an Order of Court:
1. The parties shall share legal custody of the child, Katlyn M. Long, born
February 6, 2005, (hereinafter referred to as "child"). Shared legal custody means the
right of both parents to control and to share in making decisions of importance in the life
of their child. Each parent shall have an equal right, to be exercised jointly with the
other parent, to make all major non-emergency decisions affecting the child's general
well-being, including, but not limited to, all decisions regarding their health, education
and religion. Each parent shall notify the other parent of any medical, dental, optical,
counseling and other appointments of the child with health care providers, sufficiently in
advance thereof so that the other party may attend, if he or she so chooses.
Pursuant to the terms of 23 Pa. C.S.A.§5309, each parent shall be entitled to
equal access to all medical records and information pertaining to the child; including,
but not limited to, the child's school, medical, dental, religious and other important
records and the residence address of the other parent.
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2. Mother shall have primary physical custody of the child.
3. Father shall have partial physical custody of the child at such times as the
parties may mutually agree.
4. The parties shall share physical custody of the child on holidays at such
times and under such circumstances as the parties from time to time agree.
BY THE COURT,
" Michael A. Scherer Esquire
O'Brien, Baric & Scherer
19 West South Street
Carlisle, Pennsylvania 17013
?Brian K. Long, Jr.
28 Coventry at Waterford
York, Pennsylvania 17402
Cop«s .n& lCEr.I.
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