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HomeMy WebLinkAbout09-3811 Todd J. Grinaway IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY PENNSYLVANIA VS. CIVIL ACTION - CUSTODY LaRe B. Grinaway, Joshua Parham, Defendants NO. N O T I C E TO D E P E N D 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 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 OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE PA 17013 717-249-3166 Mary A Etter Di singer Attor ey for Plaintiff Todd J. Grinaway IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY PENNSYLVANIA vs. CIVIL ACTION - CUSTODY LaRe B. Grinaway, Joshua Parham, Defendants NO. 0 1- 3,411 et 7T1-1 , COMPLAINT FOR CUSTODY 1. Plaintiff Todd J. Grinaway, maternal grandfather, residing at 1028 Teakwood Lane, Enola, Cumberland County, Pennsylvania. 2. The first Defendant is LaRe B. Grinaway, natural mother, residing at 1028 Teakwood Lane, Enola, Cumberland County, Pennsylvania. 3. The second Defendant is Joshua Parham, natural father, residing at 148 Salem Church Road, Mechanicsburg, Cumberland County, Pennsylvania. 4. Plaintiff seeks custody of the following child: Name Present Residence Age Owen T. Grinaway 1028 Teakwood Lane, Enola DOB- 5/16/09 5. The child was born out of wedlock. 6. The child is presently in the custody of Plaintiff and Defendant Mother, who reside at 1028 Teakwood Lane, Enola, Cumberland County, Pennsylvania. 7. The child is only days old and has resided only with Plaintiff and Defendant Mother at 1028 Teakwood Lane, Enola, Cumberland County, Pennsylvania since date of birth on May 16, 2009. 8. The mother of the child is Defendant, LaRe B. Grinaway, residing at 1028 Teakwood Lane, Enola, Cumberland County, Pennsylvania. 9. She is unmarried. 10. The father of the child is Defendant, Joshua Parham, who currently resides at 148 Salem Church Road, Mechanicsburg, Cumberland County, Pennsylvania. 11. He is unmarried. 12. The relationship of Plaintiff, Todd J. Grinaway, to the child is that of maternal grandfather. 13. The Plaintiff currently Grinaway, the child, Owen T. brother, Levi A. Grinaway. resides with Defendant, LaRe B. Grinaway and the child's infant 14. The relationship of Defendant, LaRe B. Grinaway to the child is that of natural Mother. The Defendant currently resides with Plaintiff, Todd J. Grinaway, the child, Owen T. Grinaway and the child's infnat brother, Levi A. Grinaway. 15. The relationship of Defendant, Joshua Parham, to the child is that of natural Father. The Defendant currently resides with Defendant Stephanie Vokes, his mother. 16. 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. 17. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 18. 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. 19. The best interest and permanent welfare of the child will be served by granting the relief requested because Plaintiff can provide a stable environment within which the child will grow and flourish. 20. 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. 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: NONE. WHEREFORE, Plaintiff requests the Court to grant custody of the child, Owen T. Grinaway, to Plaintiff, Todd J. Grinaway, maternal grandfather. Respectfully Submitted: DISSINGER AND DISSINGER By Mary A. Etter Dissinger Attorney for Plaintiffs Supreme Court I.D. #27736 28 N. 32nd Street Camp Hill, PA 17011 (717) 975-2840 (717) 975-3924 VERIFICATION I, Todd J. Grinaway, verify that the statements made in the Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. odd J. Grinaw , Plain cif, OF THE FROT iC?NOTAPY 2009 JUN -9 PM 2: 4 2 Cum-Elll' 4j ? ? GOLAW Y P'E--NNSYC,,,ANfA e 1o !0338 Todd J. Grinaway : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY : PENNSYLVANIA vs. : CIVIL ACTION - CUSTODY LaRe B. Grinaway, Joshua Parham, Defendants NO. STIPULATION and AGREEMENT AND NOW this 3;k day of ? 2009, the undersigned agree as follows: 1. LaRe B. Grinaway is the mother of the minor child, Owen T. Grinaway, who was born May 16, 2009. 2. Joshua Parham is the father of the minor child, Owen T. Grinaway, who was born May 16, 2009. 3. The parties agree Todd J. Grinaway, LaRe B. Grinaway and Joshua Parham shall have shared legal custody of Owen T. Grinaway. 4. LaRe B. Grinaway agrees that Todd J. Grinaway shall have primary physical custody of Owen T. Grinaway. 5. Joshua Parham, agrees that it is in the best interest of Owen T. Grinaway that Todd J. Grinaway have primary physical custody of the infant. 6. The parties agree that LaRe B. Grinaway and Joshua Parham shall have periods of partial physical custody as the parties may agree and they may agree that the paternal grandparents and other individuals may have periods of partial physical custody. 7. The parties agree this Stipulation and Agreement shall be made an Order of Court. 22 0 Da e Date ^d 1 Date U ta? aRe B. Grinaway ?;Re? Joshua Parham Todd J. Gr' away COMMONWEALTH OF PENNSYLVANIA ss COUNTY OF r\0,-CA On this aQ? day of , ?f)c 2009, before me a Notary Public, personally appear d Todd Grinaway, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. In witness wh eof, I/hereunto set my hand and seal. No axy Pu is COMMONWEALTH OF PENNSYLVANIA Notarial Seal Melissa J. Greenwjod, Notary Public East Permboro Twp„ CurnbedaW County My Commission E)Ores May 16, 2011 Member, Pennsylvania Association of Notaries COMMONWEALTH OF PENNSYLVANIA ss COUNTY OF On this aa day of _ -1 2009, before me a Notary Public, personally appeared LaRe B. Grinaway, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. In witness whereof, I hereunto set my hand and seal. No a y Pub is COMMONWEAL;-i-1 OF PENNSYLVANIA Notarial Seal Me4ssa J. Greenwood, Notary Public East Pennsboro Tvvp., CAimberland County My Commissiad) t _.Oreg vl ay 9 r, 2011 Member, of Notaries COMMONWEALTH OF PENNSYLVANIA . COUNTY OF ss On this day of Mtv , 2009, before me a Notary Public, personally appear d Joshua Parham, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. In witness whereof, I hereunto set my hand and seal. 07;.-JA' r'V-% Notary Public COMMON VEALTH OF R= [+?NSYLVANIA Notarial Seai Melissa J. Greenwood, Notary Public East Pennsboro Twp., Cumberland County My Commission Expires May 16, 2011 Member, Pennsylvania Association of Notaries F T' Y a1Vt. V Yi1? ": ti 20 003 JUN 19 2009 G Todd J. Grinaway Plaintiff VS. LaRe B. Grinaway, Joshua Parham, Defendants : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA : CIVIL ACTION - CUSTODY NO. ORDER And now this ?2-- day ofr-?OV , it is hereby Ordered and Decreed that Todd J. Grinaway, LaRe B. Grinaway, and Joshua Parham shall have shared legal custody, that Todd J. Grinaway shall have primary physical custody of Owen T. Grinaway (DOB 5/16/2009). LaRe B. Grinaway and Joshua Parham, biological parents of Owen T. Grinaway, shall have periods of partial physical custody as the parties may agree. Distribution: Mary A. Etter Dissinger, Esq., 28 N. Thirty-Second Street, Camp Hill, PA 17011 LaRe B. Grinaway, 1028 Teakwood Lane, Enola, PA 17025 Joshua Parham, 148 Salem Church RoaMechanicsburg, PA 17050 .(tip ;2 2 - o ?I 3, 2 C'OQ'.,. ?