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HomeMy WebLinkAbout04-1576NANCY BULLOCK, Plaintiff WILLIAM C. BULLOCK, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION- LAW NO. : 1N CUSTODY COMPLAINT FOR CUSTODY The plaintiff is Nancy Bullock, residing at 105 2nd Street, Boiling Springs, Pennsylvania 17007. The defendant is William Bullock, residing at 26 Upland Road, Newville, Pennsylvania 17241. Plaintiff seeks custody of the following children: Name Present Residence DOB Age William C. Bullock, Jr. 105 2nd Street 10/6/89 14 years Boiling Springs, PA David S. Bullock 105 2nd Street 7/1/92 11 years The child William C. Bullock, Jr. was bom out of wedlock. The child David S. Bullock was not bom out of wedlock. The children are presently in the custody of Plaintiff, who resides at 105 2"d Street, Boiling Springs, Cumberland County, Pennsylvania. During the past five years, the children have resided with the following persons and at the following addresses: List All Addresses 105 2nd Street Boiling Springs, PA List All Persons Dates William and Nancy Bullock 1989 -present The mother of the children is Nancy Bullock, currently residing at 105 2nd Street, Boiling Springs, Pennsylvania. She is not married. The father of the children is William Bullock, currently residing at 26 Upland Road, Newville, Pennsylvania. He is not married. 4. The relationship of plaintiff to the children is that of mother. The plaintiff currently resides with the following persons. Name Relationship William Bullock, Jr. Son David Bullock Son Ryan N. Eby Son Christopher A. Eby Son The relationship of defendant to the children is that of father. The defendant currently resides with the following persons. Name Relationship No One Mother was awarded custody of the minor children from a PFA Order dated December 3, 2003 at Cumberland County Docket No. 03-5878. Plaintiff has no information of any other custody proceeding concerning the children 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 children and claims to have custody or visitation rights with respect to the children. The best interest and permanent welfare of the children will be served by granting the relief request because: Plaintiff has undertaken and performed the primary parental responsibilities for the children. Plaintiff is best able to provide the care and nurture which the children need for healthy development. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the children have been named below, who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim N/A WHEREFORE, Plaintiff requests this Court grant Plaintiff primary physical custody in the Mother with visitation in the Father as to be agreed upon by the parties. Respectfully submitted, ROMINGER, BAYLEY & WHARE Date: April 7, 2004 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff VERIFICATION 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. Cons. Stat. § 4904 relating to unswom falsification to authorities. Nancy Bullock, Plaintiff rote: q-o~ ~oq NANCY BULLOCK PLAINTIFF V. WILLIAM C. BULLOCK : DEFENDANT : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA 04-1576 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, April 16, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jae_queline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, May 04, 2004 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an eftbrt will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearinl~. FOR THECOURT, By: /s/ _Iacqueline M. Vern~. Esq Custody Conciliator mhc The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business betbre the court. You must attend the scheduled conference or hearing. YOU SItOULD TAKE TItlS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 NANCY BULLOCK, Plaintiff WILLIAM C. BULLOCK, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION- LAW : NO. 1576-2004 : IN CUSTODY ORDER OF COURT AND NOW, this y of _004, based on the Stipulation of the parties, the Court hereby Orders as follows: Plaintiff Nancy Bullock, hereinafter referenced as "Mother," and Defendant William C. Bullock, hereinafter referenced as "Father," hereby agree to the following terms in an Order defining custody and partial custody rights and responsibilities in relation to William C. Bullock, Jr., born 10/6/89, and David S. Bullock, bom 7/1/92, hereinafter referenced as "Children:" 1. Mother and Father will share legal custody of the children as defined in 23 Pa. C.S.A. {}5302. All decisions affecting the children's growth and including but not limited to medical treatment, education, and religious training, are major decision which Mother and Father shall make jointly after discussion and consultation with each other. 2. As provided in 23 Pa. C.S.A. §5309(a), each parent shall have full and complete access to the children's mental, dental, religious and school records. This includes the names, addresses and telephone numbers of all medical and other providers. 3. Mother shall have primary physical custody of children, and Father shall have periods of partial custody every other weekend from Friday evening at 5::30 PM until Sunday evening at 5:30 PM, beginning the weekend of July 30, 2004. Father shall also have partial custody of the Children during the on his days off from work provided that he gives Mother 48 hours notice. 4. The Mother shall have the Children on Mother's Day and the Father shall have the Children on Father's Day. 5. The parties shall share the following holidays as follows: Even # Years Odd # Years Easter M F Memorial Day F M 4th of July F M Labor Day M F Thanksgiving Schedule A M F Thanksgiving Schedule B F M Christmas Schedule A F M Christmas Schedule B M F New Years Eve F M New Years Day M F Easter runs from Saturday evening at 5:00 PM until Sunday afternoon at 2:00 PM. Memorial Day runs from 5:00 PM the evening before until 4:00 PM Memorial Day July 4th runs from July 3rd at 4:00 PM until July 5th at 9:00 AM. Labor Day runs from 5:00 PM the evening before until 4:00 PM Labor Day Thanksgiving Schedule A runs from Wednesday, Thanksgiving Eve at 6:00 PM until Thursday, Thanksgiving Day at 4:00 PM. Thanksgiving Schedule B runs from Thursday, Thanksgiving Day at 4:00 PM until Friday evening at 4:00 PM. Christmas Schedule A runs from 12:00 PM Christmas ]Eve until 12:00 PM Christmas Day. Christmas Schedule B runs from 12:00 PM Christmas day until 12:00 PM December 26th every year, or as otherwise agreed upon by the parties. New Years Eve Schedule runs from 12:00 PM New Years Eve until 12:00 PM New Years Day New Years Day Schedule runs from 12:00PM New Years Day until 12:00PM January 1, every year, or as otherwise agreed upon by the parties. 6. Holidays take precedence over the other provisions in this Stipulation. 7. Father shall have children for seven (7) consecutive days to go on vacation, after Labor Day, but prior to Memorial Day, for an educational vacation with approval from the children's school. 8. Visitation may be at such other times as the parties mutually agree. 9. The parties shall keep each other advised immediately relative to any emergencies concerning the Children and shall further take any necessary steps to ensure that the health, welfare and well being of the Children are protected. The parties shall do nothing that may estrange the Children from the other party or hinder the natural development of the Children's love or affection for the other party. 10. Neither party shall make any disparaging remarks regarding the other party in the presence of the child. Additionally, neither party shall permit third persons to make disparaging remarks concerning the other party in the presence of the child. 11. Any modification or waiver of any of the provisions of this Agreement of the parties shall be effective only if made in writing and only if executed with the same formality of the Agreement of the parties. 12. The parties hereto acknowledge that they have had the opportunity to consult an attorney prior to executing this Agreement. Mother's attorney is Karl E. Rominger, Esquire. Father's attorney is Nathan C. Wolf, Esquire. 13. The parties hereto agree that this Agreement shall be recorded and incorporated into an Order enfomeable by the Court. Karl E. Rominger, Esquire Nathan C. Wolf, Esquire NANCY BULLOCK, Plaintiff Ve WILLIAM C. BULLOCK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2004-1576 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT AND NOW, this 7th day of December, 2004, the Conciliator having been advised that the parties have reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FORTHECOURT, ey, Esquire, Custo~fi~ttor