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Home My WebLink About08-6809 ¦ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA //?? 08 - load V U Tp . STEPHANIE KELLEY DOCKET No. CV CU PLAINTIFF vs. QAADIR WOOD CIVIL ACTION DEFENDANT IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Stephanie Kelley, residing at 701 Stanwix Avenue, Apartment 4, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Qaadir Wood, residing at 701 Stanwix Avenue, Apartment 4, Carlisle, Cumberland County, Pennsylvania 17013. 3(a). Plaintiff seeks custody of the following child: Name Present Residence Date of Birth Cincere K. Wood 701 Stanwix Ave. Carlisle. Cumberland County. PA 17013 10/25/2007 3(b). The child was born out of wedlock. The child is presently in the custody of Stephanie Kelley, who resides at 701 Stanwix Avenue, Apt. 4, Cumberland County, PA, 17013. Her relationship to the child is Mother. During the past five (5) years, the child has resided with the following persons and at the following addresses: 1 List All Persons List All Addresses Dates Stephanie Kelley 701 Stanwix Avenue, Apt 4, Carlisle. PA 17013 2/12/08 - Present Qaadir Wood 701 Stanwix Avenue, Apt 4 Carlisle, PA 17013 2/12/08 - 5/30/08 Gloria Lytle 3242 Enola Road Carlisle, PA 17015 10/27/07 - 2/11/08 Roger Morrison 3242 Enola Road, Carlisle. PA 17015 10/27/07 - 2/11/08 Qaadir Wood 3242 Enola Road, Carlisle, PA 17015 10/27/07 - 2111/08 3(c). The mother of the child is Stephanie Kelley, currently residing at 701 Stanwix Avenue Apt 4, Carlisle, Cumberland County, PA 17013. She is unmarried. The father of the child is Qaadir Wood, currently residing at 701 Stanwix Avenue, Apt. 4, Carlisle, Cumberland Counter PA 17013. His marital status is unmarried. 4. The relationship of the Plaintiff to the child is that Mother to the child. The Plaintiff currently resides with the following persons: Name Relationship Stephanie Kelley 701 Stanwix Avenue, Apt. 4 Carlisle, PA 17013 Mother 5. The relationship of the Defendant to the child is that of father. 6. The Defendant currently resides with the following persons: Name Relationship N/A N/A 2 7(a). 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. 7(b). Plaintiff' HAS NO information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 7(c). 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. 8. The best interest and permanent welfare of the child will be served by granting the relief requested because (set forth facts showing that the granting of the relief requested will be in the best interest and permanent welfare of the child): Please See Attached Custody Agreement and Stipulation. 9. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim No known individuals 3 WHEREFORE, Plaintiff requests this honorable Court to grant custody of the child, Cincere Wood, to the Plaintiff, Stephanie Kelley. requested, I Ala6elbv& Asociates, P.C. Attorney Weguaification No. 66856 Dated: 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 unworn falsification to authorities. -)J?ILVXXA\ A, dD ? AA- Steph ie Kelley, Plaintiff 4 R t ? i> F n N C, _TJ CD -TI 00 (? b -.._ r t rt C-o Ic i7 --< CUMBERLAND COUNTY, IN THE COURT OF COMMON PLEAS PENNSYLVANIA No. Stephanie Kelley Plaintiff CIVIL ACTION - LA W V. Qaadir Wood CUSTODY r ?v ? p Defendant C= .C ?7-0 d r: USTODY AGREEMENT AND STIPUI-ATION j _ y =`r 9 C Y AGREEMENT AND STIPULATION, made this -' Cj / ay 1 C n-e THIS CUSTOD 2008, by and between Stephanie Kelley, resident of Carlisle, Pennsylvania, hereinafter referred to as "Mother" and Qaadir Wood, resident of Chambersburg, Pennsylvania hereinafter referred to as "Father", relative to the minor child, Cincere Wood, born to October 25, 2007, hereinafter referred to as "Child"; WHEREAS, the parties hereto wish to enter into a formal Agreement and Stipulation about to be made a Court Order, reflecting the Agreement they have entered into; NOW, THEREFORE, in consideration of the mutual covenants contained herein, and intending to be legally bound hereby, the parties hereby agree as follows to wit: Legal Custody: Mother will have legal custody of the child, Cincere Wood. Legal custody means the right of the party to make decisions of importance in the life of the child, including educational, medical, and religious decisions 2. Physical Customs: Plaintiff, Mother will have primary physical custody of the child with the right and responsibility to make decisions involving the child's day-to-day living 3. Visitation: Father will be permitted to have partial physical custody of the child at mutually agreed upon times and places. 4. Modification of Order: The parties are free to modify the terms of this Order but in order to do so the Court makes it clear that both parties must be in complete agreement to any new terms. That means both parties must consent on what the new terms of the custody arrangement or visitation schedule shall be. NOW, THEREFORE, the parties hereby request, Agree and Stipulate that this Agreement shall be made into a Court Order of the Court of Common Pleas of Cumberland County, Pennsylvania as a Custody Order, with the same full weight, force, and effect as if it had been entered at a conclusion of a trial on the matter including the powers of the Court to enforce same by all the powers of the Court, including but not limited to Contempt of Court. This AGREEMENT AND STIPULATION shall be made into a Court Order, by parties presenting same to the Court but without further appearance by either party or his/her attorney and by mere reference to this paragraph. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, set their hands and seals the date and year first above-written. 2 SIGNATURE: DATE: Stephanie Kelley - Mother Qaadir Wood - Father COMMONWEALTH OF PENNSYLVANIA COUNTY OF C v ? e o` ZR?l ( before me, a Notary Public, On this L14,4ay of iruu-vl known to me (or the undersigned officer, persona ly appeared Stephanie Kelley, satisfactorily proven) to be the person whose name is subscribed contain instrument, and acknowledged that she executed the same for the purpose therein IN WITNESS WHEREOF, I hereunto set my hand and official seal. lIMII! d loom Notary Public *411 ft r1? ,gIIMiM iri1'l?M 0010. ni t da of before me, a Notary Public, On this D y - known to me (or and acknowledged that he executed the same for th purpose COMMONWEALTH OF PENNSYLVANIA the undersigned officer, personall appeared Qaadir Wood, satisfactorily proven) to be the person whose name e subscribed therein witind instrument, COUNTY OF G N^ IO` IN WITNESS WHEREOF, I hereunto set my hand and official seal. IM?I1? !iK MMI? 0 f?#ION! t000C1 vim Oct 4.2011 my COMSWO IW4 _S Notary Public 3 uNnw 4m 2,19wm? t [as .6 too $so" polo - 103 Vu l?t O Milt ?owA WOW „11 r rot ,r too "Pow o Mw t ., 1 NOV 1 8 200 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA STEPHANIE KELLEY DOCKET No. PLAINTIFF vs. QAADIR WOOD CIVIL ACTION DEFENDANT IN CUSTODY &809 0';V;1 -r-- At CV CU ORDER AND NOW, TO WIT, this 1+6'ti day of t?o 0-'O "r 2008, in consideration of the attached Stipulation and Agreement of the a ove captioned parties, with the advice of their counsel of choice, and upon motion of R bin J. Marzella, Esquire, attorney for Stephanie Kelley, is hereby i ORDERED that said Stipulation and Agreement for Custody shall be adopted and made an Order of Court. BY THE COURT: By: - '\?x -V' J. Cc: ? R bin J. Marzella, Esquire, 3513 North Front Street, Harrisburg, PA 17110 ,/Stephanie Kelley, 701 Stanwix Avenue, Apartment 4, Carl sle, Cumberland ,?Ounty, Pennsylvania 17013. ? Qaadir Wood, 701 Stanwix Avenue, Apartment 4, Carlisl , Cumberland County, Pennsylvania 17013. C IO Ft es /rn' aA ????los 1 C? "till'sVA IASINKOd C Z :8 WV 0Z AOH 00OZ X31?H