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Home My WebLink About08-17381 DJ JUDY IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 0 S, - /73P ,? ??-• MEGAN E. BONETTI CIVIL ACTION - LAW Defendant CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS 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 claim 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 DJ JUDY IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. p S . l'7 3 $ ' `?c.„, MEGAN E. BONETTI CIVIL ACTION - LAW Defendant CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, DJ Judy, by and through his attorney, Charles Rector, Esquire, and respectfully represents as follows: 1. Plaintiff is DJ Judy, an adult individual who resides at 152 Wyoming Avenue, Enola, Cumberland County, Pennsylvania, 17025. 2. Defendant is Megan E. Bonetti, an adult individual who resides at 223 Wood Street, Camp Hill, Cumberland County, Pennsylvania, 17011. 3. Plaintiff is seeking primary physical custody of the minor child: Jack L. Judy, who was born on July 30, 2007. The child was born out of wedlock. The child is presently in the custody of Plaintiff, DJ Judy who resides at 152 Wyoming Avenue, Enola, Cumberland County, Pennsylvania, 17025. Since the child's birth he has resided: a. With the parties at 152 Wyoming Avenue, Enola, Cumberland County, Pennsylvania, 17025, the home of the paternal grandmother, Jody Wheeler. b. With Plaintiff and the paternal grandparents at 152 Wyoming Avenue, Enola, Cumberland County, Pennsylvania, 17025. With Defendant and her aunt, Tracy Miller, at 223 Wood Street, Camp Hill, Cumberland County, Pennsylvania, 17011. 4. The relationship of the Plaintiff to the child is that of Father. The Plaintiff currently resides with his mother, Jody Wheeler. 5. The relationship of the Defendant to the child is that of Mother. The Defendant currently resides with her aunt, Tracy Miller. 6. 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. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 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 Plaintiff primary physical custody. WHEREFORE, Plaintiff requests the Court to grant him primary physical custody to the minor child. RESPECTFULLY SUI,4WTED, Charles Rector, EAquir&----- 1104 Fernwood Avenue, Ste. 203 Camp Hill, PA 17011 (717) 761-8101 Date: 3 / "16 e I verify that the statements made herein 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. udy -R. r U co xj < t4##rn U G DJ JUDY IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008- CIVIL ACTION LAW 17381 MEGAN E. BONETTI DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, March 25, 2008 _, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, April 17, 2008 at 9:00 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ ohn . Man an r. Es . Custody Conciliator ip, The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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. You must attend the scheduled conference or hearing. 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 Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 44, 0 1 :C, Ild 9Z NVW 81701 N `7e' r DJ JUDY IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 0"_ MEGAN E. BONETTI CIVIL ACTION -LAW Defendant CUSTODY STIPULATION FOR AN AGREED ORDER OF CUSTODY AND NOW, come the parties, DJ Judy, Plaintiff, and Megan E. Bonetti, Defendant, and respectfully request that the following Stipulation be entered as an order of court: WHEREAS the parties, DJ Judy (the "Father" hereinafter) and Megan E. Bonetti (the "Mother" hereinafter), have born to them on July 30, 2007, a child, Jack L. Judy (the "Child" hereinafter); and WHEREAS, both parties desire to enter into a comprehensive custody stipulation and agreement setting forth the physical and legal custody arrangements for the child; and WHEREAS, both parties have been provided an opportunity to review this Stipulation with the counsel of their choice prior to signing. NOW THEREFORE, in consideration of the mutual covenants, promises, and agreements as hereinafter set forth, and intending to be legally bound hereby, the parties agree as follows: 1. Mother and Father shall have shared legal custody of the child. The parties agree that major decisions concerning the child including, but not limited to, the child's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the child's best interest. Each party shall notify the other of any activity or circumstance concerning the child that could reasonably be expected to be of concern to the other. Day-to-day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions, which need to be made, the parent having physical custody of the child at the time of the emergency shall be permitted to make any necessary immediate decisions. However, that party shall inform the other of the emergency and consult with her or him as soon as possible. Each party shall be entitled to complete information from any doctor, dentist, teacher, professional or any authority concerning the child and to have copies of any reports given to either party as a parent. 2. Father shall have primary physical custody of the Child and Mother shall exercise periods of temporary physical custody from time to time as the parties agree. 3. The parties shall share custody of the child on major holidays as follows: A. Christmas: The Christmas holiday shall be divided into segments a follows: Segment A - Christmas Eve at Noon through Christmas Day at noon. Segment B - Christmas Day at noon through December 26`h at noon. In even numbered years, Father shall have custody of the child during Segment A and Mother shall have custody during Segment B. B. EASTER/MEMORIAL DAY / LABOR DAY /July 4TH/ THANKSGIVING: The parties shall alternate these holidays. Holiday time shall be from 4:00 a.m. through 7:00 p.m. unless otherwise agreed upon by the parties. The holiday schedule shall begin with Father having custody on Easter 2008. C. SUMMER VACATION: Each party shall enjoy seven (7) consecutive days of Summer vacation each Summer with the Child and to the extent possible, shall provide thirty (30) days notice of their intended week of vacation. 4. All exchanges of custody shall take place at Father's residence. 5. Neither party shall drink alcohol to the point of intoxication or use illegal drugs during his or her periods of custody. The parties shall ensure that third parties having contact with the child comply with this provision. 6. Neither party shall do or say anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent. Both parties shall ensure that third parties having contact with the child comply with this provision. 7. Each party shall grant liberal telephone contact with the other parent which may include one telephone call per day with the non-custodial parent. 8. The parties may modify the provisions of this Stipulation by mutual consent and shall attempt to work out their differences without the necessity of litigation to the extent possible. In the absence of mutual consent, the terms of this Stipulation shall control. 9. This Stipulation shall supersede all prior Court Orders, Stipulations, or Agreements. WHEREFORE, the parties, intending to be legally bound, and with the desire that this Stipulation be entered as an order of court at the request of either party, hereby set their hands and seals and the date of their acknowledgement. Date: Signature: D Judy Date Signature: M-141 in F_ PM M anE. Bonetti COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF CUMBERLAND ) On this day of 2008, before me a notary public, the undersigned .2n , officer, personally appeared DJ Judy and Megan Bonetti, known to me (or satisfactorily proven) to be the persons whose names are subscribed to the within instrument, and acknowledged that they executed same for the purposes therein contained. In witness whereof, I hereunto set my hand and official seal. Tammv S. F t, Notary Public NOTARIAL SEMI. TAMMY & FAUST, Ndary Miie Lower Allee Twp., Cimbarlnd linty . My Commimin Expim July 5, 2111 (T, e-j W =4 To, ?ppg OS 2008 DJ JUDY IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY,, PENNSYLVANIA V. :NO. p$ - I'13$ 0'1 vi( Te, MEGAN E. BONETTI CIVIL ACTION -LAW Defendant CUSTODY ORDER OF COURT AND NOW, this Lt*\ day of , 2008, upon consideration of the attached Stipulation for an Agreed Order of Custody which is incorporated herein by reference, IT IS HEREBY ORDERED AND DECREED that said Stipulation is hereby approved and adopted as an Order of Court with full weight and effect as if it had been set forth in full hereinafter. It is binding and enforceable upon the parties hereto. B' J. • '3Q VNVA'V%#. kmW ? .939 9 C _ ! Nd h- HA MOZ M91Q?ki.QcF" p1t Ylb