The URL can be used to link to this page

Home My WebLink About04-1202Barbara Surnple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland. PA 17070 (717) 774-1445 DEBRA I. PERTSCHI, Plaintiff BRYAN L. WOODSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 0V"12(02, CIVIL ACTION - LAW 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 prompt action. You are warned that if you fail to do so the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody and visitation of your children. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 DEBRA I. PERTSCHI, Plaimiff BRYAN L. WOODSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: CIVIL ACTION - LAW CUSTODY CUSTODY COMPLAINT 1. The Plaintiff is Debm I. Pertschi (hereinafter referred to as "Paternal Grandmother"), who currently resides at 1700 Anna Street, New Cumberland, Cumberland County, PA 17070. 2. The Defendant is Bryan L. Woodson (hereinafter referred to as "Father"), who currently resides at 1700 Anna Street, New Cumberland, Cumberland County, Pennsylvania 17070. following children: NAME Keith R. Woodson Plaintiffseeks to establish a formal order of shared legal and physical custody of the Kasandra D. Woodson PRESENT RESIDENCE 1700 Anna Street New Cumberland, PA 17070 1700 Anna Street New Cumberland, PA 17070 DATE OF BIRTH July 8, 1993 July 8, 1993 4. The children are presently in the custody of Plaintiffand the children's father, Bryan L. Woodson, who have principally resided at 1700 Anna Street, New Cumberland, Cumberland County, Pennsylvania 17070. following addresses: DATES During the last five years, the children have resided with the following persons at the ADDRESSES NAMES OFPERSONS IN HOUSEHOLD 1999- Present 1700 Anna Street New Cumberland, PA 17070 Debra I. Pe~schi Frank Pe~schi Bryan L. Woodson 6. The Father of the children is Bryan L. Woodson, currently residing at 1700 Anna Street, New Cumberland, Cumberland County, Pennsylvania 17070. He will be relocating from that address on or about March l, 2004 and will be residing at 1500 Bridge Street, Basement Apartment, New Cumberland, Cumberland County, Pennsylvania 17070. He is currently single. 7. The Mother of the children is Lorelei Darr. Her current address is unknown and she has had no contact with the children for the last 2 years. Her marital status is unknown. 8. The relationship of the Plaintiffs to that of the children is that of Maternal Grandmother. The Plaimiff currently resides with the following persons: NAME RELATIONSHIP Frank Pertschi Plaintiff's husband Bryan L. Woodson Keith R. Woodson Kasandm D. Woodson Son Grandson Granddaughter 9. The relationship of the Defendant to the children is Father. The Defendant currently resides with the above referenced persons but, as of March l, 2004, will be living alone: NAME RELATIONSHIP SELF 10. Plaintiff has not participated as a party or witness, or in maother capacity, in other litigation concerning the custody of the children in this or another court. 11. The Plaintiff has no information of a custody proceeding concerning the children pending in any court of this Commonwealth. 12. Plaintiff does not know of a person not a party to the proceedings that has physical custody of the children or claims to have custody or visitation rights with respect to the children. l 3. The best interest and permanent welfare of the children will be served by granting the relief requested in the Stipulation Regarding Custody, which stipulation is being filed simultaneously with this Complaint. The parties have jointly co-parented the children for many years and desire to continue with such a plan despite the present relocation of the Defendant from Plaintiff's home. The 3 parties also desire to confirm the Plaintiff's rights of legal custody concerning the children and to allow her formal participation in major decision making for the children, including but not limited to educational, medical and other major decisions. Therefore, the parties have amicably resolved all matters concerning custody by agreement and created a custodial plan for the children. 14. Except for the natural mother whose whereabouts are uncertain, each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, the Plaintiffs request the Court to grant shared legal and joint physical custody of the children pursuant to a Stipulation Regarding Cusi~.y~,5~ c~/) ,2004. DATE: 2004 / [ ,/ Barbara Sumple-Sullivan, Esquire ~ 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 4 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774- I445 DEBRA I. PERTSCHI Plaintiff, BRYAN L WOODSON, Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: CIVIL ACTION - LAW CUSTODY VERIFICATION I, Debra 1. Pertschi, hereby certify that the facts set forth in the foregoing CUSTODY COMPLAINT are true and correct to the best of her 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 unsworn falsification to authorities. Dated: ~)/~.~, J:v ,2004 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 DEBRA I. PERTSCHI, Plaintiff BRYAN L. WOODSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :NO: 0k~--.!~' :CIVIL ACTION - LAW : CUSTODY STIPULATION REGARDING CUSTODY THIS AGREEMENT is made this 1st day of March, 2004, by and between Debra I. Pertschi, (hereinafter referred to as "Paternal Grandmother"), an adult individuals residing at 1700 Anna Street, New Cumberland, Cumberland County, Pennsylvania, and Bryan L. Woodson, (hereinafter referred to as "Father") an adult individual residing at 1500 Bridge Street, New Cumberland, Cumberland County, Pennsylvania 17070. WITNESSETH WHEREAS, Plaintiffis paternal grandmother of two (2) children, Keith R. Woodson, (bom July 8, 1993), and Kasandra D. Woodson (born July 8, 1993); WHEREAS, Defendant is the natural Father of said children. WHEREAS, the children have resided primarily in the home of Plaintiff and her husband for approximately 6 years and have actively co-parented the children in that environment with their Father, Bryan L. Woodson; WHEREAS, the children have had no contact with their natural mother since October of 2001; WHEREAS, the Defendant, Bryan L. Woodson, is relocating from the home of the Plaintiff effective March 1, 2004 and the parties desire to amicably resolve all matters concerning custody of the children by agreement; WHEREAS, the parties desire that this agreement be submitted to the court for entry of an order of custody. NOW A. THEREFORE, the parties intending to be legally bound, do agree as follows: SHARED LEGAL CUSTODY. It is agreed between Plaintiff and the Defendant that it is in the best interest of the minor children to allow the Plaintiff and Defendant to share legal custody of the minor children, Keith R. Woodson and Kasandra D. Woodson. The parties agree that major decisions concerning the children's health, welfare, education, religious training and upbringing shall be made by the Plaintiff and Defendant jointly, after discussion and consultation with each other, with a view towards obtaining and following a harmonious policy to arrive at decisions that are in the children's best interest. Each party agrees to keep the other informed of the progress of the children's education and social adjustments. Each party shall notify the other of any activity that could reasonably be expected to be of significant concern to the other. SHARED PHYSICAL CUSTODY. The parties agree that the children shall be m the primary physical custody of the Plaintiff and continue to reside with her. The Defendant shall have periods of partial physical custody as the parties shall arrange by mutual agreement between them. 1N WITNESS WHEREOF, the parties hereto acknowledge that they are entering m to this Agreement with the full knowledge that this Agreement shall be entered as a court order with the same force and effect as ifa full heating on this matter has been held. SIGNED, SEALED AND DELIVERED IN THE PRESENCE OF: 'Barbara Sumple-Sullivan, Esquire e' Debra I. Pertschi n L. Woodson 3 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 DEBRA I. PERTSCHI, Plaintiff BRYAN L WOODSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW ' CUSTODY .ORDER ADOPTING ,STIPULATION OF PARTIE,,; AND NOW, to wit, this,~day of ~~ ,2004, upon consideration of the foregoing Stipulation for Custody and on motion of Barbara Sumple-Sullivan, Esquire, counsel for Plaintiff, it is hereby ordered, adjudged and decreed that the terms, conditions and provisions of the foregoing Stipulation for Custody dated March 1, 2004 are adopted as an Order of Court. B~C'O~T,