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HomeMy WebLinkAbout09-5232 SHANNON L. YOST, Plaintiff VS. LESTER D. TRIMBLE, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ?'`7 " CIVIL TERM CIVIL ACTION LAW IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Shannon L. Yost, an adult individual currently residing at 348-B McCulloch Road, Shippensburg, Cumberland County, Pennsylvania. 2. Defendant is Lester D. Trimble, Jr., an adult individual believed to be residing at 24 North Baltimore Avenue, Apt. 1, Mount Holly Springs, Cumberland County, Pennsylvania. 3. The parties are the natural parents of one (1) child, namely, Jordan Donovan Yost, born October 8, 2008. The child was born out of wedlock. 4. For the past five (5) years, or since the child's birth, the child has resided with the following persons at the following addresses for the following periods of time: NAME ADDRESS DATES Shannon Yost 348-B McCulloch Road Birth to Shippensburg, PA 17257 Present 4 0. The natural mother of the child is Shannon L. Yost, who resides as aforesaid. She is single. The natural father of the child is Lester D. Trimble, Jr., who resides as aforesaid. He is single. 5. The relationship of the Plaintiff to the child is that of natural mother. The Plaintiff currently resides with the child. 6. The relationship of the Defendant to the child is that of natural father. Defendant is believed to be currently residing with his significant other ,`Bunny" Robinson, and their child, Ridge Trimble. 7. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning custody of the child. 8. Plaintiff has no information of any custody proceedings concerning the child pending in any Court of this Commonwealth. 9. It is in the best interest and permanent welfare of the child to grant the relief requested because: a) Plaintiff has been the primary caretaker since the child was born; b) Plaintiff can provide a stable home for the child; and c) Plaintiff can care for the day to day needs of the child. 10, Plaintiff does not know any person not a party to these proceedings who claims to have custody or visitation rights with respect to the child. 11. Plaintiff is filing a Custody Stipulation and Agreement contemporaneously with the filing of this Complaint. WHEREFORE, Plaintiff requests your Honorable Court enter an Order whereby the parties Custody Stipulation and Agreement, being filed contemporaneously, with the Custody Complaint, is made an Order. Respectfully submitted, Hannah Herman-Snyder, Esquire0 Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 46 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: jb--4? a'?? SHANNON L. YOST, P intiff r FLED", U - - QA ?II?SSG C?? dU?vu SHANNON L. YOST, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. LESTER D. TRIMBLE, JR., Defendant : NO. C y- X131 CIVIL TERM CIVIL ACTION LAW IN CUSTODY CUSTODY STIPULATION AND AGREEMENT THIS STIPULATION AND AGREEMENT entered into this day of June, 2009, by and between Shannon L. Yost, (hereinafter referred to as "Mother") and Lester D. Trimble, Jr., (hereinafter referred to as "Father"); The parties are the natural parents of one child, Jordan Donovan Yost, born October 8, 2008, (hereinafter referred to as the "child"); WHEREAS, the natural parents are separated and living in different residences; and WHEREAS, the parties wish to enter into this Agreement relative to the custody of the child. NOW THEREFORE, in consideration of the mutual covenants, promises, and agreements as hereinafter set forth, the parties agree as follows: 1. The parties shall share legal custody of the child, Jordan Donovan Yost. 2. Mother shall exercise primary physical custody of the child. 3. Father shall exercise partial physical custody of the child every other weekend from Friday at 12:00 p.m. to Sunday at 12:00 p.m., and at other times as agreed upon by the parties. 4. The parties shall share equally in the transportation of custody exchanges such that the party receiving custody of the child shall provide the transportation. 5. The parties shall share equally in any unreimbursed medical expenses incurred on behalf of the child, outside of the routine co-pays, which shall be paid by Mother. In regards to medical expenses outside of the routine co-pays, Mother shall satisfy the expense and Father shall reimburse Mother for fifty percent (50%) of any said expense, within thirty (30) days of Mother's request for the same. 6. The parties shall not do anything which may estrange the child from the other party, or injure the opinion of the child as to the other party or which may hamper the free and natural development of the child's love and affection for the other party. 7. It is affirmed that the Court of Common Pleas of Pennsylvania, Cumberland County Branch, had jurisdiction over the issue of custody of the child in this case at the time the proceedings were initiated and the Court has retained jurisdiction over these matters so that it is appropriate for the Court to enter an Order of Court. Further, the parties request that the Court of Common Pleas of Pennsylvania, Cumberland County Branch, enter this as an Order of Court. 8. The parties acknowledge that they have read and understand the provisions of this Agreement. 9. Any modification or waiver of any of the provisions of this Agreement on a permanent basis shall be effective only if made in writing and only if executed with the same formality as this Stipulation and Agreement. 10. The parties acknowledge that they have read and understand the provisions of this Agreement. Each party acknowledges that the Agreement is fair and equitable and that it is not the result of any duress or undue influence. 11. The parties stipulate that in making this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of the other party. WITNESS: utd- - Shannon L. Yost ester D. Trimble, Jr. Date: , 2009 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this aq4klay of ?u Iy , 2009, before me, the undersigned officer, personally appeared SHANNON L. YOST, known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Not Pu 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this Ulkay of S"I , 2009, before me, the undersigned officer, personally appeared LESTER D. TRIMBLE, JR., known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. &Ujo'-? `n Notary Public NOTARIAL SEAL CAMELA J MANSES Notary Public HAMILTON TWP. FRANKLIN COUNTY My Commiulon Expims Jun 21, 2010 "T 7 t JUL 3 0 2009 el SHANNON L. YOST, Plaintiff VS. LESTER D. TRIMBLE, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :NO. CIVIL TERM CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW this 3o day of 2009, the attached Custody Stipulation and Agreement is hereby made an Order of Court. cc: Hannah Herman-Snyder, Esquire Attorney for Plaintiff Lester D. Trimble, Jr. Pro Se ?'es m? t ?o? 7 t"'a