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HomeMy WebLinkAbout04-2270AMIE M. McCLINTIC, : Plaintiffs : JAMIE L. COOK, : Defendant : IN THE COURT OF COI~4ON PLEAS CUMBERLAND COUNTY PENNSYLVANIA NO. <p~. ~.0_no CIVIL ACTION - LAW IN CUSTODY CUSTODY COMPLAINT TO THE HONORABLE JUDGES OF SAID COURT: 1. The Plaintiff is Amie M. McClintic whose last residence was 26 Stephen Road, Camp Hill, Cumberland County, PA 17011. 2. The Defendant Browning Road, Rockmart, 3. Plaintiff seeks of the following child: Cameron Jacob Bartlett is Jamie L. Cook, who resides GA. at 1807 shared legal and partial physical custody PRESENT RESIDENCE 1807 Browning Road Rockmart, GA DQB 09/29/00 The child was born in wedlock. The Cameron is presently in the physical custody of Jamie L. Cook who resides at 1807 Browning Road, Rockmart, GA. Cameron has resided with the following persons and at the following addresses: Person A~dress Father & Stepmother 1807 Browning Road Rockmart, GA Mother 26 Stephen Road Camp Hill, PA Mother 30 W. Main Street Shiremanstown, PA Azores, Portugal Mother & Stepfather The mother of the child is Amie M. McClintic who at 26 Stephen Road, Camp Hill, PA. She is not married. Date 04/04 - present 04/03 - 03/04 12/02 - 04/03 08/01 - 12/02 last resided The father of the child is Jamie L. Cook who lives at 1807 Browning Road, Rockmart, GA. He is married. The relationship of Plaintiff to the The Plaintiff currently resides with no J mother. 5. father. persons: 6. The relationship of Defendant to the The Plaintiff currently resides Wife, Stepson & Cameron child is that of other persons: child is that of with the following 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 approving the Custody Stipulation between the parties. Completed on May 19, 2004. 8. Each parent whose parental been terminated and the person who child have been named as parties to this action. her rights to the child have not has physical custody of the WHEREFORE, Plaintiff requests this Honorable Court to grant shared legal and partial physical custody as set forth in the Custody Stipulation completed on May 19, 2004. Respectfully submitted, Thomas D. Gould, Esquire ID %36508 2 E. Main Street Shiremanstown, PA 17011 (717) 731-1461 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 are made subject to the penalties relating to unsworn falsification to of 18 Pa. C.S. Section 4904 authorities. · McClintic Plaintiff 3 JAMi~ L.~ CO(~, t NO. CIVIL ACTZO~ - LAW RTTPUT. TTON IS4IS STZ~JLATI~i~, made ~hisl~'" day af ~ , 2004, by and between ~E M. ~IC, (h~reinafter referred ~o as Mother), and J~K L. ~, ~h~ralnafter referred to as Fa~har). ~, M~th~r and Father ara the biological p~r~nts ~ ~B ~TT, born Septe~er 29, 2000, hereinafter referred' to as ~ild. ~, due to Mother's impending entry into activ~ military service, Mother and Father, for the best interest of the Child, wish to amicably resolv~ the custody o~ ~ J~ ~TT. ~ N~, the parties intending to be legall~ bound hereby agree that a court order be i~sued stating that: 1. Mother and Fathe~ shall share legal custody of the Child, whereby each ~arty agree~ t~ consult with the other conce~in~ all major declslon~ affecting the ~ild, including but not limited to, health, education and religion. I'd O~LS-~89-O~L sso~ a~pp3 dO~:SO ~0 S~ 2, Mother and Father are to have equal access to medical, educational and o%her r~cords of the Child. 3. Father shall have physical custody of the Child subject to Mother's periods of partial custody or visite~ion ss are in, the best interest of the Ghild as agreed by the par~ies, 4. Each parent shall inform the other of $~gnificant events that occur in the Child's life. 5. Zach party is to inform the other of~n~anges in th~£r employment, health, residence or telephone number. AMIE M. M~CLINTIC - Date/ ~' JAMI~ L. COOK AMIE M. McCLINTIC, Plaintiffs JAMIE L. COOK, Defendant IN THE COURT OF C0~940N PLEAS CUMBERLAND COUNTY PENNSYLVANIA NO. CIVIL ACTION - LAW IN CUSTODY AFFIDAVIT OF SIGNATURE I, Thomas D. Gould, am the attorney for Plaintiff, in the above captioned action for custody. Plaintiff was to be inducted into the U.S. Army May 19, 2004, but the induction was suspended until Friday, May 21, 2004, because Plaintiff had not relinquished custody, to obtain induction. defendant who Stipulation. by court order, of her son. There was insufficient time Defendant's original signature prior to Plaintiff's I hereby certify that I personally talked with the advised me that he read and understood the Custody He stated that he signed the Custody Stipulation in front of a witness and faxed a copy to me. Defendant stated that he was aware that I would be submitting the Custody Stipulation with his faxed signature to the court to obtain an Order of Court granting him joint legal custody and physical custody of Cameron Jacob Bartlett. Defendant's faxed signature is on the Custody Stipulation. Thomas D. Gould, Esquire ID % 36508 Attorney At Law 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 AMIE M. McCLINTIC, Plaintiffs JAMIE L. COOK, Defendant IN THE COURT OF COI~4ON PLEAS CUMBERLAND COUNTY PENNSYLVANIA NO. ~ ~- ~ ;-7 ~ CIVIL ACTION - LAW IN CUSTODY PRAECIPE TO PROCEED IN FORMAPAUPERIS TO THE PROTHONOTARY: Please allow Amie M. McClintic to proceed in forma mauperis. I, Thomas D. Gould, attorney for Amie M. McClintic, certify that Amie M. McClintic is not employed, owns no real estate and has no assets available to pay the costs of this custody matter. I am proving my legal services pro bono. Date: /~ ~ O~ ~;~ V Thomas D. Gould Attorney for Plaintiff I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 AMIE M. McCLINTIC, : Plaintiffs : : JAMIE L. COOK, : Defendant : IN THE COURT OF CO~ON PLEAS CUMBERI~%ND COUNTY PENNSYLVANIA NO. O'~- ~7o CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT __ day of May, 2004, upon review of the Custody Complaint and Custody Stipulation it is hereby ordered that: 1. AMIE M. McCLINTIC (Mother) and JAMIE L. COOK (Father) shall share legal custody of CAMERON JACOB BARTLETT (Child) whereby each party agrees to consult with the other concerning all major decisions affecting the Child, including but not limited to, health, education and religion. 2. Mother and Father are to have equal access to medical, educational and other records of the Child. 3. Father shall have physical custo~!y of the Child subject to Mother's periods of partial custody or visitation as are in the best interest of the Child as agreed by the parties. 4. Each parent shall inform the other of significant events that occur in the Child's life. 5. Each party is to inform the other of any changes employment, health, residence or telephone ]number. in their Jo