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HomeMy WebLinkAbout08-2210MEGAN DECKER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN CUSTODY DANIEL TRIMMER, Defendant. : NO. C~~ ~ a?d /a CIVIL TERM CUSTODY AGREEMENT THIS AGREEMENT, made this ~ day of April, 2008, between Megan Decker, hereinafter Mother, and Daniel Trimmer, hereinafter Father, concerns the custody of their child: Cayden Trimmer, born November 2, 2006. Mother and Father desire to enter into an agreement as to the custody of the child. Mother and Father agree to the following. 1. Mother and Father shall share legal custody of the child. 2. Mother shall have primary physical custody of the child. 3. Father shall have periods of partial physical custody of the child consisting of: a.) Every other weekend beginning at 5:00 p.m. on Friday and ending at 5:00 p.m. on Sunday. b.) Every Wednesday beginning at 3:00 p.m. and ending at 7:00 p.m. 4. Mother and Father shall arrange drop off and pick up locations as mutually agreed. 5. Mother and Father shall share holidays with the child as mutually agreed. 6. Mother and Father will notify each other of all medical care the child receives while in the parent's care. Mother and Father will notify the other immediately of medical emergencies which arise while the child is in that parent's care. 7. Neither parent will do anything which may estrange the child from the other party, or injure the opinion of the child as to the other parent or which may hamper the free and natural development of the child's love and respect for the other parent. 8. Father acknowledges that the Family Law Clinic represents only Mother's interest in this matter and has given him no legal advice other than that he should seek the advice of his own legal counsel. 9. The parties intend to be bound by the terms of this agreement and intend for this Agreement to be made an Order of Court. Megan ecker, Plaintiff aniel Trimmer, Defendant ~~~ ~~ icole Berman Certified Legal Intern Counsel for Plai ~ff ROB INS THO M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Counsel for Plaintiff FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 Fax (717)243-3639 ~~ ti ~~~~ ~ ~: ,r` ~ .~ ~~ ,~r~ r ,,, fr~ ~ ~ ~C ~~ ~; -.y c .c. ~~ `~' MEGAN DECKER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v :CIVIL ACTION -LAW IN CUSTODY DANIEL TRIMMER, ~ &,~ a ,~ ~ o Defendant. : NO. CIVIL TERM COMPLAINT FOR CUSTODY Plaintiff, Megan Decker, by her attorneys, the Family Law Clinic, sets forth the following cause of action in custody. 1. Plaintiff is Megan Decker, residing at 56 Regency Woods North, Carlisle, Cumberland County, Pennsylvania 17015. 2. Defendant is Daniel Trimmer, residing at 79 North Corporation Street, Newville, Cumberland County, Pennsylvania 1724.1. 3. Plaintiff seeks primary custody of: Name Present Residence Age Cayden Trimmer 56 Regency Woods North 17 Months Carlisle, PA 17015 The child was born out of wedlock. The child is presently in the custody of Plaintiff, who resides at 56 Regency Woods North, Carlisle, PA 17015. During the past five years the child has resided with the following persons at the following addresses: Persons Address Megan Decker 56 Regency Woods North Carlisle, PA 17015 Megan Decker 56 Regency Woods North Daniel Trimmer Carlisle, PA 17015 Megan Decker 767 B Roxbury Road Daniel Trimmer Shippensburg, PA 17257 Megan Decker 2258 Ritner Highway Daniel Trimmer Shippensburg, PA 17257 Dates December 26, 2007 - Present November 2007 - December 26, 2007 May 2007 - November 2007 November 2006- May 2007 The mother of the child is Plaintiff. She is single. The father of the child is Defendant. He is single 4. The relationship of Plaintiff to the child is that of mother. Plaintiff currently resides with the following persons: Name Judy Mainhart Relationship to the Plaintiff Mother 5. The relationship of Defendant to the child is that of father. Defendant currently resides with the following persons: Name Eric Trimmer John Trimmer Relationship to the Defendant Father Brother 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. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth, or any other state. Plaintiff does not know of a 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: a. Plaintiff has been the child's primary caretaker for all of the child's life; b. Plaintiff provides the child with a stable home and environment with adequate moral, emotional, and physical surroundings as required to meet the child's. needs; c. Plaintiff has encouraged contact between Defendant and the child and will continue to do so; d. Plaintiff is willing to accept custody of the child. 8. Each parent whose parental rights to the children have not been terminated and the. person who has physical custody to the child have been named as parties to this action. WHEREFORE, plaintiff requests the court enter as an order of the court the custody agreement signed by the parties' on April 3, 2008. Date: ~ 7 d ~ Respectfully submitted, Nicole Berman Certified Legal Intern Cz THO ACE ROBERT .RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. ~--~4~-- '~C-~~-- Meg ecker ~ ~ ~ .~. _ ~ : ~„ ~ .,,, ,~ -n ~;~- ~ ~ -~ ~~ Y i ,7~3 `' +~ i ~~ ~ ^} `_ ~~~ w ~ ~ z~ :{ MEGAN DECKER, Plaintiff v. DANIEL TRIMMER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IN CUSTODY NO. 08-,haw CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To The Prothonotary: Kindly allow Megan Decker, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date ~ G~ Respectfully submitted, i ole Berman Certified Legal Intern ~~, ROBER THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 sus ~- `~ ©, ` ~ n ; fa r': ~ ~ ' ~ ~- ~ Cn ` . ~ =T ' .~ j ' ,~ r...- ~ ~ Y .....w ' i%• `= '" < t~ r •• --{ ;,.~~ f„,~ ~ty7 1 I APR 0 9 2008 ~~ MEGAN DECKER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN CUSTODY DANIEL TRIMMER, Defendant. : NO. d F' ~ ~ ~~ CIVIL TERM ORDER OF COURT AND NOW, this ~b day of , 2008, upon receipt of the parties' Custody Agreement signed Apri13, 2008, the Court enters the following order. 1. Mother and Father shall share legal custody of the child, Cayden Trimmer, born November, 2007. 2. Mother shall have primary physical custody of the child. 3. Father shall have periods of partial physical custody of the child consisting of: a.) Every other weekend beginning at 5:00 p.m. on Friday and ending at 5:00 p.m. on Sunday. b.) Every Wednesday beginning at 3:00 p.m. and ending at 7:00 p.m. 4. Mother and Father shall arrange drop off and pick up locations as mutually agreed. 5. Mother and Father shall share holidays with the child as mutually agreed. 6. Mother and Father will notify each other of all medical care the child receives while in the parent's care. Mother and Father will notify the other immediately of medical emergencies which arise while the child is in that parent's care. ~' ~. 7. Neither parent will do anything which may estrange the child from the other party, or injure the opinion of the child as to the other parent or which may hamper the free and natural development of the child's love and respect for the other parent. J. ' J (l _ _ ;~ f3+ ~ • r f p r. ff .~~ `~ rr. ! 1 Li'~'a~~!'UL ~~ ~vl ,,,, ~, ~ ~ yds. ~~ ~ !~'~, }I~ gp/rr~h