The URL can be used to link to this page

Home My WebLink About09-1422t r J THOMAS D. GOULD, ESQUIRE 2 EAST MAIN (STREET SHIREMANSTOWN, PA 17011 (717) 731-14161 AMIE M. MCCLINTIC, Plaintiff V. TEDDY GERALD VANCE, JR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. U 9 / 5(a 2- CIVIL TERM CIVIL ACTION - LAW CUSTODY ACTION CUSTODY COMPLAINT TO THE HONORABLE JUDGES OF SAID COURT: 1. The Plaintiff is Amie M. McClintic currently stationed at Ft. Steward, Georgia, with a home of record and residence at 30 W. Main Street, Shiremanstown, Cumberland County, Pennsylvania 17011. 2. The Defendant is Teddy Gerald Vance, Jr. who is currently stationed at Ft. Lewis, Washington with a residence of 2836B Monfore Drive, Ft. Lewis, Washington 98433. 3. Plaintiff seeks legal and physical custody of the following child: NAB PRESENT RESIDENCE DOB Faith Marie McClintic 30 West Main Street 12/31/08 Shiremanstown, PA The child was not born in wedlock. The child is presently in the physical custody of Amie M. McClintic who resides at 30 West Main Street, Shiremanstown, Pennsylvania 17011. The child has resided with the following persons and at the following addresses: Person Add 30 West Main Street 01/09 - present Mother Shiremanstown, PA The mother of the child is Amie M. McClintic who resides at 30 West Main Street, Shiremanstown, Pennsylvania 17011. She is not married. The father of the child is Teddy Gerald Vance, Jr. who lives at 2836 B Monfore Drive, Ft. Lewis, Washington. He is married. 4. The relationship of Plaintiff to the child is that of Mother. The Plaintiff currently resides with the following persons: Nate Rsl L " ip Faith Marie McClintic Daughter Leola M. Gould Mother Thomas D. Gould Stepfather Zoe A. McClintic Niece 5. The relationship of Defendant to the child is that of Father. The Defendant currently resides with the following persons: Name Linda Vance Wife Brittani Vance Daughter Brianna (Summer) Vance Daughter Dakota Vance Son 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. 2 ? 4 ? 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: A. Plaintiff has been the only caretaker for the child. B. Defendant is scheduled to deploy overseas in the near future. 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. wHEgEFORE, Plaintiff requests this Honorable Court to approve the parties' Custody Agreement which provides that Plaintiff is to have legal and physical custody of the child, subject to periods of visitation for the defendant as the parents my agree. Respectfully submitted, Thomas D. Gould, Esquire ID #36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 3 . - , VERIFICATION I, Amie M. McClintic, 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 made subject to the penalties of 18 Pa. C.S. Section 4904 are relating to unsworn falsification to authorities. L'M' Amie M. McClint' c DATED: Plaintiff 4 \ Q T(? ? N V?rr 0. p v AMIE M. MCCLINTIC, IN THE COURT OF COM M PLEAS Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. D9- /y-?Z CIVIL TERN TEDDY GERALD VANCE, JR., CIVIL ACTION - LAW Defendant IN CUSTODY CUSTODY AGREEM PNT THIS AGREEMENT, made this y)1' day of IW4ee4 , 2009, by and between AMIg M. mcCLINTiC, (hereinafter referred to as Mother), and TEDDY GERALD VANCE, JR., (hereinafter referred to as Father). WITNESSETH : WHEREAS, Mother and Father are the biological parents of FAITH MARIE MCCLISTIC, born December 31, 2008, hereinafter referred to as Faith. WHEREAS, Mother and Father are on active duty with the United States Army stationed at military posts a great distance apart and Father=s unit is scheduled to deploy to Iraq, Mother and Father, for the best interest of the Faith, Wish to amicably resolve the custody of MTH MARIE McCLINTIC. AND NOW, the parties intending to be legally bound hereby agree that: 1. Mother shall have legal custody of the Faith, and Mother shall inform Father of all significant events in Faith=s life. 2. Mother and Father shall have equal access to medical, educational and other records of the Faith. 3. Mother shall have physical custody of Faith subject to Father=s periods of visitation as are in the best interest of Faith as agreed by the parties. 4. Father and Mother shall encourage open communication between themselves and Faith through telephone, email or other forms of communication. 5. Each parent shall inform the other of significant events that occur in their life that effect Faith=s life. 6. Each parent is to inform the other of any changes in their employment, health, residence or telephone number. 7. This Agreement may be modified in the best interest of Faith by mutual agreement of the parties. 8. This Agreement shall supersede any and all other Orders, Agreements or Stipulations concerning the custody of Faith and is to be entered as an Order of Court. Date Witness AMIE M. McCLINTIC iNitness,; ti S. 11cei Date TEDDY LD ANCE, JR. 2. Mother and Father shall have equal access to medical, educational and other records of Faith. 3. Mother shall have physical custody of Faith subject to Father's periods of visitation as are in the best interest of Faith as agreed by the parties. 4. Father and Mother shall encourage open communication between themselves and Faith through telephone, email or other forms of communication. 5. Each parent shall inform the other of significant events that occur in the their life that effect Faith's life. 6. Each parent is to inform the other of any changes in their employment, health, residence or telephone number. 7. This Agreement may be modified in the best interest of Faith by mutual agreement of the parties. 8. This Agreement shall supersede any and all other Orders, Agreements or Stipulations concerning the custody of Faith and is to be entered as an Order of Court. Witness ate AMIE M. 12- NTIC Witness Date TEDDY GERALD VANCE, JR. ? j Commonwealth of Pennsylvania: ss County of Cumberland PERSONALLY APPEARED BEFORE ME, this S+ 2009, a notary 1 day of J, public, in and for the Commonwealth of Pennsylvania, AMIE M. McCLINTIC, known to me (or satisfactorily proven to be) the person whose name is subscribed to the within custody agreement and acknowledged that she executed the same for the purposes herein contained. i Notary Public COMMONWEALTH OF PENNSYLVANIA NOWN Seal Leda M. GOUId, Notary Public LOYrarAgsn Tv*, Cwnberhnd County COMMIS n 20, 2012 Member, Psnns*onia A"oman of otWdes State of Washington county of ss PERSONALLY APPEARED BEFORE ME, this day of 2009, a notary public, in and for the Commonwealth of Pennsylvania, TEDDY GERALD VANCE, JR., known to me (or satisfactorily proven to be) the person whose name is subscribed to the within custody agreement and acknowledged that he executed the same for the purposes herein contained. Notary Public Commonwealth of Pennsylvania: ss County of Cumberland PERSONALLY APPEARED BEFORE ME, this day of 2009, a notary public, in and for the Commonwealth of Pennsylvania, AMIE M. MctLINTIC, known to me (or satisfactorily proven to be) the person whose name is subscribed to the within custody agreement and acknowledged that she executed the same for the purposes herein contained. Notary Public State of Washington '? s s County of PERSONALLY APPEARED BEFORE ME, this `-i _ P% y of Ct rN?_ 2009, a notary public, in and for the Commonwealth of Pennsylvania, TEDDY GERALD VANCE, JR., known to me (or satisfactorily proven to be) the person whose name,...?P%*,%u ribed to the within custody agreement and acknowledc % ,h1a* "y hexecuted the same for the purposes herein contaijaeGg""••.??,;? r. a 0 50 cn ai ,°l t W AMIE M. MCCLINTIC, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009 - /Yd -7- CIVIL TERM TEDDY GERALD VANCE, JR., CIVIL ACTION - LAW Defendant CUSTODY ACTION ORDER OF COURT AND NOW this 1k day of , 2009, the terms and conditions of the attached CUSTODY AGREEMENT dated March 4, 2009, is hereby incorporated and made an order of this Honorable Court. v dZI c AMIE M. MCCLINTIC, Plaintiff V. TEDDY GERALD VANCE, JR., Defendant IN THE COURT OF COMM10K PLEAS CUMBERLAND COUNTY PENNSYLVANIA NO. v9 - / 9.2 Z- CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY AGREEMENT THIS AGREEI?NT, made this y day of M4e6 4 2009, by and between AMIE M. MCCLINTIC, (hereinafter referred to as Mother), and TEDDY GERALD VANCE, JR., (hereinafter referred to as Father). WITNESSETH: WHEREAS, Mother and Father are the biological parents of FAITH MARIE MCCLINTIC, born December 31, 2008, hereinafter referred to as Faith. WHEREAS, Mother and Father are on active duty with the United States Army stationed at military posts a great distance apart and Father=s unit is scheduled to deploy to Iraq, Mother and Father, for the best interest of the Faith, Wish to amicably resolve the custody of FAITH MARIE MCCLINTIC. AND NOW, the parties intending to be legally bound hereby agree that: 1. Mother shall have legal custody of the Faith, and Mother shall inform Father of all significant events in Faith=s life. 2. Mother and Father shall have equal access to medical, educational and other records of the Faith. 3. Mother shall have physical custody of Faith subject to Father=s periods of visitation as are in the best interest of Faith as agreed by the parties. 4. Father and Mother shall encourage open communication between themselves and Faith through telephone, email or other forms of communication. 5. Each parent shall inform the other of significant events that occur in their life that effect Faith=s life. 6. Each parent is to inform the other of any changes in their employment, health, residence or telephone number. 7. This Agreement may be modified in the best interest of Faith by mutual agreement of the parties. 8. This Agreement shall supersede any and all other Orders, Agreements or Stipulations concerning the custody of Faith and is to be entered as an Order of Court. Witness Date AMIE M. McCLINTIC Witness; h S. ?LLI Date TEDDY LD ANCE, JR. 2. Mother and Father shall have equal access to medical, educational and other records of Faith. 3. Mother shall have physical custody of Faith subject to Father's periods of visitation as are in the best interest of Faith as agreed by the parties. 4. Father and Mother shall encourage open communication between themselves and Faith through telephone, email or other forms of communication. 5. Each parent shall inform the other of significant events that occur in the their life that effect Faith's life. 6. Each parent is to inform the other of any changes in their employment, health, residence or telephone number. 7. This Agreement may be modified in the best interest of Faith by mutual agreement of the parties. 8. This Agreement shall supersede any and all other Orders, Agreements or Stipulations concerning the custody of Faith and is to be entered as an Order of Court. r/GGf'• Witness Date AMIE M. MIL INTIC Witness Date TEDDY GERALD VANCE, JR. Commonwealth of Pennsylvania: County of Cumberland contained. i 7 Notary Public ss PERSONALLY APPEARED BEFORE ME, this I day of ?" , 2009, a notary public, in and for the Commonwealth of Pennsylvania, AMIE M. McCLINTIC, known to me (or satisfactorily proven to be) the person whose name is subscribed to the within custody agreement and acknowledged that she executed the same for the purposes herein COMMONWEALTH OF PENNSYLVANIA Notarial Seal Leola M. 6pdd, Notary Public Lower Allen I1Ap., Curnimiand County 2 29,201 Mamber, PenneyNanis ASSOMM of Notaries State of Washington County of ss PERSONALLY APPEARED BEFORE ME, this day of , 2009, a notary public, in and for the Commonwealth of Pennsylvania, TEDDY GERALD VANCE, JR., known to me (or satisfactorily proven to be) the person whose name is subscribed to the within custody agreement and acknowledged that he executed the same for the purposes herein contained. Notary Public e Commonwealth of Pennsylvania: ss County of Cumberland PERSONALLY APPEARED BEFORE ME, this day of , 2009, a notary public, in and for the Commonwealth of Pennsylvania, AMIE M. McCLINTIC, known to me (or satisfactorily proven to be) the person whose name is subscribed to the within custody agreement and acknowledged that she executed the same for the purposes herein contained. Notary Public State of Washington ss County of PI to a "0' PERSONALLY APPEARED BEFORE ME, this y day of Ct 2009, a notary public, in and for the Commonwealth of Pennsylvania, TEDDY GERALD VANCE, JR., known to me (or satisfactorily proven to be) the person whose nam??..,w..scribed to the within custody agreement and acknowledha*, executed the same for the .....,.c, .Y44 purposes herein contaijaeb.,••,0 '• .,. ,? ' ,? 4Y C.) 4 C n 50 r ` j': . .. T°r