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HomeMy WebLinkAbout04-0478MICHAEL W. KRAUSE and, JANET M. KRAUSE, Husband and Wife, Plaintiffs VS. AMBER C. KRAUSE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - CUSTODY COMPLAINT OF CUSTODY TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW COMES, the Plaintiffs, MICHAEL W. KRAUSE and JANET M. KRAUSE, by and through their attorneys, Coyne & Coyne, P.C., and avers the following in support of this complaint of custody: 1. Plaintiffs are MICHAEL W. KRAUSE and JANET M. KRAUSE, husband and wife, adult individuals, whose current address is 107 Maple Avenue, Hampden Township, Cumberland County, Pennsylvania. 2. Defendant is AMBER C. KRAUSE, an adult individual, residing at 107 Maple Avenue, Hampden Township, Cumberland County, Pennsylvania. 3. Plaintiffs are the parents of Defendant and the grandparents of the infant child at issue. 4. While Defendant was a full-time student at Catholic University, Washington D.C., Defendant was sexually assaulted and became pregnant and has now given birth to her daughter, TAYLOR MICHELLE KRAUSE, born January 22, 2004. 5. The parties intend for the Plaintiffs, the child's grandparents, to adopt TAYLOR MICHELLE KRAUSE, however, the immediate concern is providing medical insurance coverage for the infant child. 6. The infant child is presently in the custody of the Plaintiffs while Defendant returns to Catholic University to complete her undergraduate studies as a full-time student. 7. The parties desire to enter into a stipulated custody order whereby physical and legal custody is granted to the Plaintiffs who are the infant child's grandparents and who are also the Defendant's parents. See Stipulation attached as Exhibit "A". 8. Plaintiffs were married on January 12, 1982 and are the parents of one child, the Defendant herein. 9. Plaintiffs have not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the infant child, TAYLOR MICHELLE KRAUSE, in this or another court. 10. Plaintiffs have no information of a custody proceeding concerning the infant pending in a court of this Commonwealth or any other state. 11. Plaintiffs do not know of a person not a party to these proceedings that has physical custody of the infant child or claims to have custody or visitation rights with respect to the infant child. 12. The best interest and permanent welfare of the infant child will be served by granting the relief requested because Plaintiffs can provide a stable, nurturing home, as well as provide for appropriate and necessary medical insurance coverage and care for the child. 13. Each parent whose parental rights to the children has not been terminated and the person who has physical custody of the children 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 children will be given notice of the pendancy of this action and the right to intervene: NONE. WHEREFORE, the parties request this Honorable Court to grant Plaintiffs full legal and physical custody of TAYLOR MICHELLE ICRAUSE. Respectfully submitted, Dated: COYNE & COYNE, P.C. 3901 Market Street [ Camp Hill, PA 17011':zg227 (717) 737-0464 Pa. S. Ct. No. 53788 Attorneys for Plaintiffs MICHAEL W. KRAUSE and, JANET M. KRAUSE, Husband and Wife, Plaintiffs VS. AMBER C. KRAUSE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND cOUNTY, PENNSYLVANIA : NO. Oq. '.t 7f CIVIL TERM : CIVIL ACTION - CUSTODY CUSTODY STIPULATION AND AGREEMENT_ This Agreement is entered this ~ day of r~t~rpcr~[ _, 2004, by the Plaintiffs, MICHAEL W. KRAUSE and JANET M. KRAUSE, and the Defendant, AMBER C. KRAUSE as follows: 1. 2. The Plaintiffs are the parents of the Defendant, Amber C. Krause. Defendant gave birth to a daughter, TAYLOR MICHELLE KRAUSE, on January 22, 2004. 3. The parties intend for Plaintiffs to adopt TAYLOR MICHELLE KRAUSE; however, presently, the Defendant-Mother intends and desires that her parents, the Plaintiffs herein, to be awarded full legal and physical custody of TAYLOR MICHELLE KRAUSE. 4. Defendant agrees and stipulates that it is in the infant's best interest for full legal and physical custody of TAYLOR MICHELLE KRAUSE to be awarded and placed with the Plaintiffs and modified as the parties shall agree. WHEREFORE, the parties hereby request that an Order of Court be entered to reflect the above terms concerning custody of the infant child, TAYLOR MICHELLE KRAUSE. ~vlichael W. Krause, Plaintiff X~ber C. Krau~, Defendant Jane0Vl. Krause, Plaintiff © FEB 0 4 2004 MICHAEL W. KRAUSE and, JANET M. KRAUSE, Husband and Wife, Plaintiffs VS. AMBER C. KRAUSE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - CUSTODY ORDER AND NOW this q* day of February, 2004, upon consideration of the parties' Stipulation it is hereby ordered that the primary custody of Taylor Michelle Kranse, bom January 22, 2004 is awarded to the Plaintiffs, Michael W. Krause and Janet M. Krause, maternal grandparents. 1. The parties are awarded primary and legal custody of Taylor Michelle Krause in preparation of adopting Taylor Michelle Krause; 2. The partial custody is awarded to Amber Krause at a time the parties can mutually agree upon pending the adoption; and 3. The Plaintiffs shall execute all the necessary documents to provide medical insurance for the infant child. By the Court: