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Home My WebLink About08-2239TIM WAGNER AND PATRICIA BROWN-WAGNER Plaintiffs vs. JESSICA L. KANE AND JOSUE R. VALENTIN Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Of-,Z,)-39 Cam,( - CIVIL ACTION -LAW IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiffs, Tim Wagner and Patricia Brown-Wagner, by and through their attorneys, Meyers, Desfor, Saltzgiver & Boyle and files the following Complaint for Custody and in support thereof avers as follows: 1. The Plaintiffs are Tim Wagner and Patricia Brown-Wagner, adult individuals residing at 67 Sussex Road, Shiremanstown, Pennsylvania. 2. The Defendants are Jessica L. Kane, an adult individual residing at 67 Sussex Road, Shiremanstown, Pennsylvania and Josue Valentin, an adult individual residing at 875 Columbus Avenue, Apartment 14-F, New York, New York. 3. Plaintiff seeks legal custody of the following child: Name Present Address Date of Birth Savannah Josephine Valentin 67 Sussex Road September 25, 2006 Shiremanstown, PA The child was born out of wedlock. The child is presently in the custody of Jessica L. Kane, who resides at 67 Sussex Road, Shiremanstown, PA. MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 !7171 93R-QA9A • FAX 17171 99R_9A17 During the past five years, the child has resided with the following persons and at the following addresses: Name Address Dates Plaintiff, Defendant 67 Sussex Road Birth to present and Jessica Kane Shiremanstown, PA The mother of the child is Jessica L. Kane, currently residing at 67 Sussex Road, Shiremanstown, PA. She is single. The father of the child is Josue Valentin, currently residing at 875 Columbus Avenue, Apartment 14-F, New York, New York. He is single. 4. The relationship of Plaintiffs to the child is that of maternal grandparents. The Plaintiffs currently reside with the following persons: Name Relationship Jessica Kane Daughter Savannah Valentin Granddaughter 5. The relationship of the Defendants, to the child is that of natural parents. Defendant, Mother, Jessica L. Kane, currently resides with the following persons: Name Relationship Patricia Brown-Wagner Mother Tom Wagner Step-father Savannah Valentin Daughter Defendant, Father, Josue Valentin, currently resides with the following persons: Name Mother and Sister 3 MEYERS, DESFOR, SALTZGiVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 17171 9ZA.0A9A • FAY /7171 0gA_')A17 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 the relief requested because a Stipulation granting Plaintiffs legal custody of the minor child was executed by all parties and is attached hereto and hereinafter referred to as Exhibit "A." WHEREFORE, Plaintiffs request this Honorable Court to grant them legal custody of the child. Respectfully submitted, atherine A. Boyle, Esquire Attorney I.D. 76328 Meyers, Desfor, Saltzgiver & Boyle 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717)236-9428 Attorney for Plaintiffs 4 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 17171 9ZR_GA9R . FAY 17171 OWZ-0017 TIM WAGNER AND IN THE COURT OF COMMON PLEAS PATRICIA BROWN-WAGNER CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. : NO. JESSICA L. KANE AND JOSUE R. VALENTIN CIVIL ACTION -LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of 2008, it is hereby ORDERED that the attached Custody Stipulation is hereby adopted as an Order of Court as if set forth in full. BY THE COURT: J 7ll f MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 93R-Qd9A • FAY /717% 9qa_0017 TIM WAGNER AND PATRICIA BROWN-WAGNER Plaintiff vs. JESSICA L. KANE AND JOSUE R. VALENTIN Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN CUSTODY CUSTODY STIPULATION WHEREAS, the Plaintiffs, Patricia Brown-Wagner and Tim Wagner, are the maternal Grandparents of the minor child, Savannah Josephine Valentin, date of birth September 25. 2006, and currently reside at 67 Sussex Road. Shiremanstown. Pennsylvania: WHEREAS, the Defendant. Jessica Kane. is the mother of the minor child. and currently resides at 67 Sussex Road, Shiremanstown. Pennsvlvania, WHEREAS. the minor child, Savannah Josephine Valentin, also resides at 67 Sussex Road, Shiremanstown, Pennsylvania, with the maternai grandparents and Mother-, WHEREAS, the Defendant. Josue R. Valentin. is the father of the minor child, and currently resides at 875 Columbus Avenue, Apartment 14-F. Ne?,v York. Netiv York: WHEREAS. the parties agree that it is in the minor child's best interest to enter an agreement regarding legal custody, MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRICRI Mr oe 171n- The parties hereby agree as follows: 1. LEGAL CUSTODY of the minor child. Savannah Josephine Valentin, date of birth. September 25, 2006, shall be with the maternal grandparents, Patricia Brown-Wagner and Tim Wagner, which will include decision making with respect to important matters such as education, medical care, religious training, etc. All parties are allowed j access to any and all records concerning these matters. All parties shall have the opportunity to communicate with the minor child's medical. psychiatric and psychological providers, school officials. teachers. and any other individual andior institution involved in the child's care. treatment. or education. 2. To provide stability for the child. the parties agree that neither Mother or Father shall permanently remove or relocate the minor child from the maternal Grandparents home without first providing thirty (30) days written notice to the maternal Grandparents. 3. The parties agree that this Stipulation x\ ill be entered as an Order of Court in Cumberland County. MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 171 nR WITNESSETH: Boyie. Patricia BrO i-Wa<?ner Tiro WaLmer Witness Jessicai Kane rtness oslie?R. Valentin jI MEYERS, DESFOR, SALTZGIVER 8, BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 VERIFICATION It Patricia Rrnwn-Wagner and Tim Wages, verify that the statements made in this Complaint for Custody are true and correct to the bes of my knowledge, information and belief. I understand that fals statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: 4-7-2008 (X ) Plaintif ( ) Defendant MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 C? -YL -t = J; ad ra f, ?` b ? D TIM WAGNER AND PATRICIA BROWN-WAGNER Plaintiff vs. JESSICA L. KANE AND JOSUE R. VALENTIN Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0S_ .1.739 0)'v,A - Tqr/K CIVIL ACTION -LAW IN CUSTODY CUSTODY STIPULATION WHEREAS, the Plaintiffs, Patricia Brown-Wagner and Tim Wagner, are the maternal Grandparents of the minor child, Savannah Josephine Valentin, date of birth September 25, 2006, and currently reside at 67 Sussex Road, Shiremanstown, Pennsylvania; WHEREAS, the Defendant, Jessica Kane, is the mother of the minor child, and currently resides at 67 Sussex Road, Shiremanstown, Pennsylvania; WHEREAS, the minor child, Savannah Josephine Valentin, also resides at 67 Sussex Road, Shiremanstown, Pennsylvania, with the maternal Grandparents and Mother; WHEREAS, the Defendant, Josue R. Valentin, is the father of the minor child, and currently resides at 875 Columbus Avenue, Apartment 14-F, New York, New York; WHEREAS, the parties agree that it is in the minor child's best interest to enter an agreement regarding legal custody; MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717)236-9428 • FAX (7171 236-2817 .t The parties hereby agree as follows: LEGAL CUSTODY of the minor child, Savannah Josephine Valentin, date of birth, September 25, 2006, shall be with the maternal grandparents, Patricia Brown-Wagner and Tim Wagner, which will include decision making with respect to important matters such as education, medical care, religious training, etc. All parties are allowed access to any and all records concerning these matters. All parties shall have the opportunity to communicate with the minor child's medical, psychiatric and psychological providers, school officials, teachers, and any other individual and/or institution involved in the child's care, treatment, or education. 2. To provide stability for the child, the parties agree that neither Mother or Father shall permanently remove or relocate the minor child from the maternal Grandparent's home without first providing thirty (30) days written notice to the maternal Grandparents. 3. The parties agree that this Stipulation will be entered as an Order of Court in Cumberland County. MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (7171 236-2817 A WITNESSETH: t JA Ax A., Patricia a S G Tim Wagner Witness >tness Jessi . Kane sue R. Valentin MEYERS, DESFOR, SALTZGIVER 8, BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717)236-9428 • FAX (717)9aF-7,717 C> c' :'J f .? c.ra -tl . ITI, t!J t ,--" .I APR 1 4 2008 p? TIM WAGNER AND IN THE COURT OF COMMON PLEAS PATRICIA BROWN-WAGNER CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. JESSICA L. KANE AND JOSUE R. VALENTIN Defendant NO. DB - aa39 C tv? ? Tef`M CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this day of , 2008, it is hereby ORDERED that the attached Custody Stipulation is hereby adopted as an Order of Court as if set forth in full. BY THE COURT: MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 e-W?' C U? C':'rY7 AA ' f 7 33.ad0 A6 V- -?m Z TIM WAGNER AND PATRICIA BROWN-WAGNER Plaintiffs \'S. JESSICA L. KANE AND JOSUE R. VALENCIN Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-2239-Civil Term CIVIL ACTION - LAW IN CUSTODY PROOF OF SERVICE COMPLAINT FOR CUSTODY ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Jessica L. Kane 67 Sussex Road Shiremanstown, PA 17011 A. S gnature o X ? Agent N A U/"- -, K?f ? Addressee B. R eived by (Printed Name) C. Date of D2E.Xery Y-/,) D. Is delivery address different from item 1? ? Yes If YES, enter delivery address below: ? No 3. Service Type Certified Mail ? Express Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number 7006 0100 0005 1038 2025 (rransfer from service labeo PS Form 3811, August 2001 Domestic Return Receipt 102595-02-M-1540 MEYERS, DESFOR, SALTZGIVER & BOYLE 41( NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 { Jessica L. Kane 67 Sussex Road Shiremanstown, PA 17011 Josue Valentin 875 Columbus Avenue Apartment 14-F New York, New York 10025 Respectfully submitted, Catherine A. Boyle, Esquire MEYERS, DESFOR, SAL ZGIVER & BOYLE Attorney I.D. #76328 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717) 236-9428 Attorney for Plaintiffs TIM WAGNER AND PATRICIA BROWN-WAGNER Plaintiffs VS. JESSICA L. KANE AND JOSUE R. VALENTIN Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-2239-Civil Term CIVIL ACTION - LAW IN CUSTODY CERTIFICATE OF SERVICE I hereby certify on this day of April, 2008, a copy of Proof of Service of Complaint for Custody was sent VIA U.S. Mail to: MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 TIM WAG R AND PATRICIA ROWN-WAGNER Plain iffs vs. JESSICA L?KANE AND JOSUE R. ALENTIN IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-2239-Civil Term CIVIL ACTION - LAW IN CUSTODY PROOF OF SERVICE COMPLAINT FOR CUSTODY s f t,Zww&pro - 4 IN PAWOWO Odwety Is doebecL I a your nom wW >wcdow on to mown to "M MwM ftaMd * you. by 06 owd So theiba*, or n tHNroat ff apace lsdaiwryad f. Aft is Addressed to: offyMo1w jr-11 a vaIentin t 0 AgMk ----a Dor t1lMtp" 875 Columbus Avenue' J ? Apa tment 14-F ?99a New York, NY 10025 s. ?+. a" 0 OPM*MN C) W E7 psM1m )i a*! for 0 kWAVd MY C1 CAA. 4. RAC4ed Dsiwwy? Aft FOO lM Number 7006 0100 0005 1038 2032 Ma0aw fiom swv+le? la6sQ ra 9A1 i,,c 2oa? e.MMo ?r+wMw ? ? MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (7171 236-9428 • FAX (717) 236-2817 TIM WAG ER AND PATRICIA ROWN-WAGNER Plai tiffs vs. JESSICA L?KANE AND JOSUE R. ALENTIN IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-2239-Civil Term CIVIL ACTION - LAW IN CUSTODY CERTIFICATE OF SERVICE I hei Complaint i y certify on this day of April, 2008, a copy of Proof of Service of Custody was sent VIA U.S. Mail to: Jessica L. Kane 67 Sussex Road Shiremanstown, PA 17011 Josue Valentin 875 Columbus Avenue Apartment 14-F New York, New York 10025 Respectfully submitted, Catherine A. Boyle, Es ire MEYERS, DESFOR, SALTZGIVER & BOYLE Attorney I.D. #76328 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717) 236-9428 Attorney for Plaintiffs MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 J i. w. ?' _.? +-? P ? f^ J ?? _... YY??i -J ?. "'C