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HomeMy WebLinkAbout08-3079Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 LAUREN E. BREED, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -CUSTODY RYAN S. McKEE, ; Defendant :NO. 08 - 30 '9 Oiv;t l em 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 Petition 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 claims 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 Petition or for any other claim or relief requested by the Plaintiffs. 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 Two Liberty Avenue Carlisle, Pa 17013 (717) 249-3166 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 LAUREN E. BREED, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO: O P- 367? C4;ia 7Z,- RYAN S. McKEE, CIVIL ACTION -LAW Defendant CUSTODY CUSTODY COMPLAINT 1. The Plaintiff is Lauren E. Breed (hereinafter referred to as "Mother"), who currently resides at 3818 Claverton Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Defendant is Ryan S. McKee (hereinafter referred to as "Father"), who currently resides at 2379 Huckleberry Highway, Berlin, Somerset County, Pennsylvania 15530. 3. Plaintiff seeks an order of sole legal custody and to establish an order confirming the physical custody agreement of the parties for the following child: NAME PRESENT RESIDENCE DATE OF BIRTH Logan R. McKee 3818 Claverton Road 12/13/05 Mechanicsburg, PA 4. The child is presently in the custody of Mother, Lauren E. Breed who resides at 3818 Claverton Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. 5. During the past five years the child has resided with the following persons at the following addresses: DATES Birth until 1/13/2006 ADDRESSES Brambles Apartments 1405 Louisa Lane Mechanicsburg, PA 17050 NAINESOFPERSONS IN HOUSEHOLD Father, Mother Child. 1/13/2006 - Present 3818 Claverton Road Mother, Maternal Mechanicsburg, PA 17050 Grandparents and Child 6. The Father of the child is Ryan S. McKee currently residing at 2379 Huckleberry Highway, Berlin, Somerset County, Pennsylvania 15530. 7. The Mother of the child is Lauren E. Breed currently residing at 3818 Claverton Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. The parties were never married and each is currently single. 8. The relationship of the Plaintiff to that of the child is that of Mother. The Plaintiff currently resides with the following persons: NAME Logan R. McKee Marilyn Breed Roger Breed RELATIONSHIP Child Mother of Plaintiff Father of Plaintiff 2 9. The relationship of the Defendant to the child is that of Father. The Defendant currently resides with the following persons: NAME Chantelle Lewis Noah McKee RELATIONSHIP Defendant's girlfriend Defendant's son 10. 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. 11. The Plaintiffhas no information of a custody proceeding concerning the child pending in any court of this Commonwealth. 12. 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. 13. The best interest and permanent welfare of the child will be served by granting the relief requested because Plaintiff and Defendant have reached a mutually agreed upon arrangement for custody of the minor child. The child is severely handicapped and is in need of significant physical care, supervision, and oversight of his affairs. The parties desire to enter a formal custody order confirming their arrangement and agreement. The purpose of this filing is to allow for the agreement to be placed of record and confirmed by court order. 3 14. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as a party to this action. WHEREFORE, the Plaintiff requests the Court grant the relief requested. DATE: May 13, 2008 (717) 774-1445 Supreme Court I.D. 32317 4 Daiuaia aumpic-auuulvan, r,squire 549 Bridge Street New Cumberland, PA 17070-1931 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 LAUREN E. BREED, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO: RYAN S. McKEE, CIVIL ACTION -LAW Defendant CUSTODY VERIFICATION I, Lauren E. Breed, hereby certify that the facts set forth in the foregoing CUSTODY COMPLAINT are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unworn falsification to authorities. Dated: /2 l/ V . auren E. Breed ??? c) f-3 C=20 C7 W N "< Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 LAUREN E. BREED, Plaintiff V. RYAN S. McKEE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: ??' 3474 Ct?-! CIVIL ACTION -LAW CUSTODY q STIPULATION REGARDING CUSTODY o v?:- Cj S THISA GREEMENTis made this 12th day of may , 2008, by ancjb`etweee _ ' 0 Lauren E. Breed, (hereinafter referred to as "Mother") an adult individual residing 3 8 Claverton Road, Mechanicsburg, Cumberland County, Pennsylvania, and Ryan S. McKee, (hereinafter referred to as "Father") an adult individual residing at 2379 Huckleberry Highway, Berlin, Somerset County, Pennsylvania 15530. WITNESSETH WHEREAS, Mother and Father are the natural parents of Logan R. McKee, born December 13, 2005; WHEREAS, the parties desire to formalize their agreed upon custodial plan for their child; 1 WHEREAS, the parties desire to have this mutually agreed upon custodial plan incorporated into a court order. NOW THEREFORE, the parties intending to be legally bound, do agree as follows: A. Mother, Lauren E. Breed, shall have sole legal custody of the parties' minor child, Logan R. McKee. B. The child shall remain residing with Mother, Lauren E. Breed. C. Father, Ryan S. McKee, shall have visitation with the minor child, Logan R. McKee. This visitation shall occur on two (2) weekends (four weekend days) each month as the parties can arrange. Father's visitation shall consist of five (5) hours per each visitation day. Mother shall have the right to be present during Father's visitations. D. Until such time as Father, Ryan S. McKee, completes adequate training to meet the complex needs of the parties' minor child, Logan R. McKee, Father shall not take the child on excursions outside the current primary residence. Upon Father's completion of adequate training and he is able to demonstrate competency and full understanding of emergency procedures and basic care needs for the child, Logan R. McKee, excursions outside the primary residence may be granted. Mother shall have the right to be present on these outings until further agreement of the parties. E. The above visitation agreement may be changed in the future with both Mother and Father in agreement. Father's time with the child will be no less than what is currently established. 2 IN WITNESS WHEREOF, the parties hereto acknowledge that they are entering in to this Stipulation with the full knowledge that this stipulation shall be entered as a court order with the same force and effect as if a full custody hearing on this matter has been held. SIGNED, SEALED AND DELIVERED IN THE P OF: WI Barbara Sumple-Sullivan, Esquire ?7< auren E. Breed -??Jzw6e R n S. McKee 3 COMMONWEALTH OF PENNSYLVANIA ) COMbtMVO ) SS. COUNTY OF ) Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County, personally appeared Lauren E. Breed, who being duly affirmed according to law, deposes and says that the facts and matter set forth in the within and foregoing Stipulation Regarding Custody are true and correct to the best of her knowledge, information and belief. Affirmed and subscribed to before me this 1 day of _ffia? 2008. 4AVyPWLk1CL0-1 My commission expires: Ol?la COMMONWEALTH OF PENNSYLVANIA COUNTY OF CM'U--06Wd (SEAL) COMMONWEALTH OF PENNSYLVANIA Notarial Seal Jennifer N. Grove, Notary Public Silver Spring Twp., Cumberland County My Commission E)Ores Jan. 28, 2012 Member, Pennsylvania Association of Notaries ) SS. Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County, personally appeared Ryan S. McKee, who being duly affirmed according to law, deposes and says that the facts and matter set forth in the within and foregoing Stipulation Regarding Custody are true and correct to the best of his knowledge, information and belief. Affirmed and subscribed to before me this VI day of_, 2008. AN UTA R! P LIC My commission expires:M&.D1-?- (SEAL) COMMONWEALTH OF PENNSYLVANIA Notarial Seal Jennifer N. Grove, Notary Public Silver Spring TWP., Cumberland County My Commission E)Ores Jan. 28, 2012 Member, Pennsylvania Association of Notaries 4 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 LAUREN E. BREED, Plaintiff V. RYAN S. McKEE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: d8 -30`19 CtVI? lPa'Y?, CIVIL ACTION -LAW CUSTODY ORDER ADOPTING STIPULATION OF PARTIES AND NOW, to wit, this 7(day of ' 4, a , 2008, upon consideration of the attached Stipulation for Custody and on motion of Barbara Sumple-Sullivan, Esquire, counsel for Plaintiff, Lauren E. Breed, it is hereby ordered, adjudged and decreed that the terms, conditions and provisions of the attached Stipulation for Custody dated 1jay 12 , 2008 are adopted as an Order of Court.