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HomeMy WebLinkAbout09-1012Tanya M Honicker Plaintiff v. Maria 8 Godoy-Rodriguez Defendant : IN THE COURT OF COMMON PLEAS : CUMERLAND COUNTY, PENNSYLVANIA / ?/-- . No. CV Cu 64 - 1012- : CIVIL ACTION - LAW : CUSTODY ACTION 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 COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY AN 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 COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. 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. THE TELEPHONE OR THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 _ Name: lama Honick-or (ftwNww) Address: J? A , Sr1' Rear City: A p,J n eC61 •? , PA Zip: ) "70 90 Telephone: O19) 0& 64.33 (Your 1'ekph m Number) Email: :ton, ti ten; ?-rQ ?s-/', ref G 9 J b I G ht =L -tt'01, (Your EmaN Address) COMMON Plaintiff?an o,,rNW„e) ?onrckcr ; 0-u aTHE RCAONO eco ? PmN PLEA A V. : NO. CV CU Qrsc-_ ONC _ R4 Woe_z : CIVIL ACTION -LAW Defendant (Nmne of m o#4r Poople have : CUSTODY ACTION Custody tZiptds) •.? 1 • i • 1. The Plaintiff(s) islare r") f"% va M - l-?on k r residing at (YOU Name / nn_ IQ6 Ag -1kn d , .Lymlrkld County, PA (SVW Address) (CRY) (COU*) 1700 The Plaintiff's telephone number is (gyp code) (re*phone Number of Fwnum 2. The Defendant(s) is/are Xaria " - )Wr `ovc Z_ , residing at (Name of AM Other o* Ww K&W Custody tom) j yi i?r? 36 i yr a ?? County, PA /17/oy (Sge•t Address (City (Zip code) The Defendants telephone number is f 9??) /pQ5- a! a 9 (Telephone mftw of Defendant) 3(a). Plaintiff seeks (CIRCLE ONE) (p mn ary cum (partial custody) (shared custody) (visitation) of the following child(ren): Name(s) of Child(ren) presen Residence Date- of Birth 0- b3 - J)e j evl4erLd I)ea`1?v 7 L'Vla- C?? 106 4 S+1 Qarrr 3(b). The child(ren) ere) (was not/were not) born out of wedlock. The child(ren) are presently in the custody of -rnnja M, LLai c6r, , who resides at (Name of Person), 106 146 S+? Lar Aloe riAi_l4n4 , PA. His or her relationship to ( ) the child(ren) is in o a??n t,'s (Relationship to hild(ren) During the past five years, the child(ren) have resided with the following persons and at the following addresses: List All Persons -T to ya M, ?. Hm icke I ILtf ?a _ t o o (Lam) Dates - r25eir?" T-v6- y-(YI n3- p-OS" List All Addresses ..4, JeAL.4 Aa.rr v t 3(c). The mother of the child(ren) is /nan'o 13. (o' cdov- U14c?e z- , (Name of Mother) currently residing at IYy! &rrv 64 ,3 F 14-a ri'sw?? , PA. She is Address of Mother) (CIRCLE ONE) (married) divorced (single). The father of the child(ren) is erg lic-6cfc 's • currently residing at San J;r ;,Trw QiAc m uaAX? O . he PA. He is (Address of Fatter) (CIRCLE ONE) (married) divorce (single). 4. The relationship of Plaintiff to the child(ren) is that of (CIRCLE ONE) (Mother) (Father) Other If Other, explain: M I-Oro no.rp/1 '-,5 The Plaintiff currently resides with the following persons: Name Relationship 6"1 a- - C22 o5/ 5. The relationship of Defendant to the child(ren) is that of (CIRCLE ONE) (Father) (Other): If Other, explain: The Defendant currently resides with the following persons: Name Relationship &a` fa- //via ?odo? ?Q cr lWil4ga ke/lel' 02- 6(a). Plaintiff (CIRCLE ONE) (has) has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child(ren) in this or another court. The court, term, number, and its relationship to this action is: 6(b). Plaintiff (CIRCLE ONE) (has) as no information of a custody proceeding concerning the child(ren) pending in a court of this Commonwealth or any other state. The court, term, number, and its relationship to this action is: 6(c). Plaintiff (CIRCLE ONE) (knows) does not know of a person not a party to the proceedings who has physical custody of the child(ren) or claims to have custody or visitation rights with respect to the child(ren). The name and address of such person is: 7. The best interest and permanent welfare of the child(ren) 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(ren): Revised 1-09 8. Each parent whose parental rights to the child(ren) have not been terminated and the person who has physical custody of the child(ren) 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(ren) will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim Wherefore, plaintiff requests the court to grant (CIRCLE ONE) primary custody (partial custody) (shared custody) (visitation) of the child. I verify that the statements made in the 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 unswom falsification to authorities. Date Sign "e o Plaintiff (Your signature) be 017) !ns OR I Telephone Number of Plaintiff (Your Telephone Number) 7v h R' O N v ??. f,7 ? .ly '? "'4'tc C?'t j,:?T . f ?^"' ' . [ , ? C?. "? {? ? ?,? ?. _?. ?; _ a .?.. ..? Tanya M Honicker IN THE COURT OF COMMON PLEAS Plaintiff CUMERLAND COUNTY, PENNSYLVANIA V. No. CV CU 9 .-16I ?- >YY T 6& Maria B Godoy-Rodriguez CIVIL ACTION -LAW Defendant CUSTODY ACTION AGREEMENT AS TO CUSTODY OF THE MINOR CHILD THIS AGREEMENT is made the 18th day of February 2009, by and between: TANYA M HONICKER, hereinafter referred to as the " In Loco Parentis, Mother", and MARIA B GODOY-RODRIGUEZ, hereinafter referred to as the "Mother" WHEREAS, the defendant is the parent and natural guardian of the minor child, BEATRYZ LARA-GODOY, born June 30, 2003, and WHEREAS, the parties have given serious consideration to the future welfare of the minor child, and hereby agree as follows: 1. Legal Custody. Legal custody of the minor child is given solely to Tanya M Honicker. Ms. Honicker will have sole responsibility in making decisions of importance in the life of the child, including educational and medical decisions. Ms. Godoy-Rodriguez will be granted access to the child's school, medical and dental records, if requested. If Ms. Godoy-Rodriguez wishes copies of school papers, including report cards, Ms. Honicker will provide them to her in a timely manner. 2. Physical Custody. Primary physical custody of the child, as that term is defined in the Custody Act, shall be with " In Loco Parentis, Mother". 3. Telephone Calls. All parties are urged to use common sense in scheduling telephone calls to talk to the child. All parties are hereby directed to refrain from preventing the parry who may be calling from talking to the child, or preventing the child from calling the other party, provided that the phone calls are not excessively frequent not too long in duration that they disrupt the child's schedule. 4. Visitation. Visitation will be scheduled around the child's schedule and around the Parties schedule's. Arrangements will be made on a as needed basis, S. Mutual Consultation. Each party is directed to keep the other informed of her residence and telephone number to facilitate communication concerning the welfare of the child and the custody situation. 6. Emergency Situation. If an emergency arises that affects the child's health or welfare, "in Loco Parentis, Mother" will notify the Mother as soon as possible to inform her of the situation. 7. Welfare of Child To Be Considered. The welfare and convenience of the child shall be the prime consideration of the parties in any application of the provisions of this Agreement. The parties are directed to listen carefully and consider the wishes of the child in addressing the custodial schedule, any changes to the schedule, and any other parenting issues. 8. Modification of Agreement. The parties are free to modify the terms of this Agreement if the parties are in complete agreement to any new terms. That means the parties must consent on what the new terms of the custody arrangement or schedule shall be. 9. order of Court. This Agreement shall be made a part of the Order of Court. IN WITNESS WHEREOF, the parties hereto set their hands to this Agreement on the date above- mentioned. Witness: Tanya M Honicker Maria B Godoy-Rodriguez C= CD tom ri . rr! :Tz'T7 ' ?" - Cass ; -i. ? fs`t r o :3.7 Tanya M Honicker : IN THE COURT OF COMMON PLEAS Plaintiff : CUMERLAND COUNTY, PENNSYLVANIA V. . No. CV CU QQ, /01 -Z 61, Maria B Godoy-Rodriguez : CIVIL ACTION -LAW Defendant : CUSTODY ACTION ORDER OF COURT A 1 AND NOW, TO WIT, this U day of Fe,1f%)O -y , 2009, the Within Agreement as to Custody of the Minor Child having been signed and acknowledged by the respective parties thereto, the terms and conditions of the aforesaid Agreement are here by adopted as the Order of this Court. BY THE COURT, Judge Z rg WV LZ 93A 6001 aH.L' .'U