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HomeMy WebLinkAbout09-0596r THOMAS D. GOULD, ESQUIRE 2 EAST MAIN STREET SHIREMANSTOWN, PA 17011 (717) 731-1461 ADAM J. TRUMP, Plaintiff V. TRISHA M. EDELMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009 - ?(y CIVIL TERM CIVIL ACTION - LAW CUSTODY ACTION CUSTODY COMPLAINT TO THE HONORABLE JUDGES OF SAID COURT: 1. The Plaintiff is Adam J. Trump residing at 1780 S. Meadow Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is Trisha M. Edelman who resides at 362 E. Derry Road, Hershey, Dauphin County, Pennsylvania 17033. 3. Plaintiff seeks shared legal physical custody of the following child: NAME PRESENT RESIDENCE DOB Ryleigh A. Trump 1780 S. Meadow Drive 10/03/08 Mechanicsburg, PA The child was not born in wedlock. The child is presently in the physical custody of Adam J. Trump who resides at 1780 S. Meadow Drive, Mechanicsburg, Pennsylvania. The child has resided with the following persons and at the following addresses: Person Address Date Father 1780 S. Meadow Drive 01/30/09 Mechanicsburg, PA Mother & 362 E. Derry Street 10/08 -01/09 Father Hershey, PA The mother of the child is Trisha M. Edelman who currently resides at 362 E. Derry Street, Hershey, Pennsylvania 17033. She is not married. The father of the child is Adam J. Trump who lives at 1780 S. Meadow Drive, Mechanicsburg, Pennsylvania 17055. He is not married. 4. The relationship of Plaintiff to the child is that of Father. The Plaintiff currently resides with the following persons: His parents 5. The relationship of Defendant to the child is that of mother. The Defendant currently resides with the following persons: Her parents 6. Neither party has 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 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. 2 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: A. Plaintiff can properly care for his child. B. Plaintiff can provide a loving home. C. Plaintiff wants to be a significant part of his daughter's life. 8. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff requests this Honorable Court to grant him joint legal custody and shared physical custody of his child, as set forth in the attached Agreement. Respectfully submitted, Thomas D. Gould, Esquire ID #36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 ?X 3 VERIFICATION I, Adam J. Trump, hereby certify that the foregoing CUSTODY COMPLAINT is true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: 2/3 ?D9 am J. mp Plaint' 4 c -„ . t ? V' tit L c J't . ADAM J. TRUMP, Plaintiff V. TRISHA M. EDELMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008 - 0,5 96 CIVIL TERM CIVIL ACTION - LAW CUSTODY ACTION AGREEMENT FOR AN ORDER OF CUSTODY ?< THIS AGREEMENT, made this 2 day of 2 etAa e , 2009, by and between Adam J. Trump, hereinafter referred to as Father, and Trisha M. Edelman, hereinafter referred to as Mother, is to settle and resolve the issue of the custody of their daughter. WITNESSETH: WHEREAS, Mother and Father are the parents of Ryleigh A. Trump, born October 3, 2008; and WHEREAS, Mother and Father agree that this custody arrangement is in their child's best interest; and WHEREAS, Mother and Father wish to enter into this Custody Agreement to replace all previous custody orders or agreements; NOW THEREFORE, it is agreed by the parties that: 1. Mother and Father shall share legal custody of their child, which means that each parent is to have equal access to their child's personal, school and medical records and each parent is to inform the other of significant events that occur in their child's lives. Each parent is to insure that the other parent receives timely information regarding medical, school and extra curricular activities of the child while in their care. C 2. Mother and Father are to share physical custody of their child with the following schedule: A. During each 14-day period Mother will be responsible for Ryleigh on Monday-Tuesday-Friday-Saturday-Sunday-Wednesday- Thursday and Father will be responsible for Ryleigh on Wednesday- Thursday-Monday-Tuesday-Friday-Saturday-Sunday. The receiving parent is responsible for providing transportation for the exchange of custody. Unless otherwise agreed, any adult with a valid driver's license and an appropriate vehicle with an approved car seat may provide transportation for Ryleigh. 3. Holidays: A. The Holidays of Easter, Thanksgiving and Christmas are to be shared with the exchange occurring at 2:00 p.m. In odd years, Mother is to have the early part of the holidays of Easter and Christmas and the late segment of Thanksgiving and Father shall have Ryleigh in the late segments of Easter and Christmas and the early segment of Thanksgiving. In even years Mother is to have the late part of the holidays of Easter and Christmas and the early segment of Thanksgiving and Father shall have Ryleigh in the early segments of Easter and Christmas and the late segment of Thanksgiving. B. Mother is to have Ryleigh on Mother's Day and Father is to have her on Father's Day. C. The parents agree to share or alternate any other holidays, including birthdays, as are in Ryleigh's best interest. 2 4., Vacations: Each parent, with 30 days notice, is annually entitled to two weeks of uninterrupted time with Ryleigh, that must include their regularly scheduled weekend and not a shared holiday. 5. This Agreement may be modified by mutual agreement of the parents. If the parents are not able to agree, the terms of this agreement shall control. 6. The parents agree to provide a safe, drug fee, loving and stable environment for their child. 7. Mother and Father agree to place any personal differences aside and work for the best interests of their child. 8. The parents agree that they shall not make derogatory comments about the other in the presence or hearing of their child. Each parent will use their best efforts to insure that other persons do not make derogatory comments about the other parent in the presence or hearing of their child. 9. Each parent is to inform the other of any change in employment, living arrangements and/or telephone number. 10. This Agreement shall supersede any and all other Orders, Agreements or Stipulations concerning the custody of the child. 11. It is the intent of the parents that the terms of this Agreement be made an Order of Court. 213k? W TNESS DATE dam Tr r? (1 WITNESS DATE risha M. Edelman 3 Commonwealth of Pennsylvania . . ss County of Cumberland PERSONALLY APPEARED BEFORE ME, this 13 day of r--A1orOrkllrl? , 2009, a notary public, in and for the Commonwealth of Pennsylvania, ADAM J. TRUMP, known to me (or satisfactorily proven to be) the person whose name is subscribed to the within custody stipulation and acknowledged that he executed the same for the purposes herein contained. MMONWEALTROEPENN NOTARIAL SEAL MEGAN ANN TYSON, Notary Public Susquehanna Twp., Dauphin County My Commission Expires November 19, 2012 14'eAa'- P blic Commonwealth of Pennsylvania . County of Cumberland ss cuo.M-,? , PERSONALLY APPEARED BEFORE ME, this 3 day of 2009, a notary public, in and for the Commonwealth of Pennsylvania, TRISHA M. EDELMAN, known to me (or satisfactorily proven to be) the person whose name is subscribed to the within custody stipulation and acknowledged that she executed the same for the purposes herein contained. -,.ru nF PENN$YJ? NOTARIAL SEAL Public MEGAN ANN TYSON, Nom minty Susquehanna M?N?ber19,2012 My Cornmisat0 Expi ----------- Notary blic 4 C o ?O ? 7 r © 6 ADAM J. TRUMP, Plaintiff V. TRISHA M. EDELMAN, Defendant IN THE COURT OF CO] CUMBERLAND COUNTY, NO. 2009 - OS96 CIVIL ACTION - LAW CUSTODY ACTION ORDER OF COURT ON PLEAS PENNSYLVANIA CIVIL TERM AND NOW this V day of 2009, the terms and conditions of the attached Agreement For A Agreed Order of Custody dated February 3, 2009, is hereby incorporated and made and Order of this Honorable Court. .p BY T14E COURT:,, J. /j 0 4 "1 EJ?1 3Q1 ray 833 ?r?oz Advj( )iv,