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Home My WebLink About09-5830SCOTT A. CALAMAN and : IN THE COURT OF COMMON PLEAS MELANIE E. CALAMAN, : CUMBERLAND COUNTY, PENNSYLVANIA Husband and Wife, Plaintiffs : CIVIL ACTION - LAW vs. : 2009 - Sn6 CIVIL TERM AMBER N. CALAMAN, : CUSTODY Defendant : COMPLAINT FOR CUSTODY 1. The Plaintiffs are Scott A. Calaman and Melanie E. Calaman, husband and wife, residing at 6 Mountain View Lane, Newville, PA 17241, Cumberland County. 2. The Defendant is Amber N. Calaman, also residing at 6 Mountain View Lane, Newville, PA 17241, Cumberland County. 3. The Plaintiffs seek joint legal and physical custody of the following child: Name Present Address Age Kapri Raquel Calaman 6 Mountain View Lane 5 months Newville, PA 17241 Born: 03/18/2009 The child was born out of wedlock. The child is presently in the joint physical and legal custody of Scott A. Calaman, Melanie E. Calaman, and Amber N. Calaman, who reside at 6 Mountain View Lane, Newville, PA 17241. During the past five years, the child has resided with the following persons and at the following addresses: Scott A. Calaman 6 Mountain View Lane, March 2009 - Melanie E. Calaman Newville, PA 17241 August 2009 Amber N. Calaman The mother of the child is Amber N. Calaman, currently residing at 6 Mountain View Lane, Newville, PA 17241. She is single. The father of the child is unknown. 4. The relationship of the plaintiffs to the child are that of maternal Grandparents. The plaintiffs currently reside with the following persons: Amber N. Calaman Kapri Raquel Calaman 5. The relationship of the defendant to the child is that of Mother. 6. Plaintiffs have not participated as a party or witness, or in another capacity, in any litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding 2 concerning the child pending in a court of this Commonwealth or any other state. 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 the child has resided in the primary care and custody of the Mother and the maternal Grandparents, who have jointly cared for the child since her birth. 8. Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiffs request the Court to grant them joint physical and legal custody of the chi . G? Dale F. u art, Jr. Atto ne .9 .1 10 Webi? Ui gh Street Carlisle, PA 17013 (717) 241-4311 Attorney for Plaintiffs 3 I verify that the statements made in this 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 unsworn falsification to authorities. Scott A. Calaman e anie alaman 4 CUSTODY AND GUARDIANSHIP FOR MINOR CHILD THIS AGREEMENT, made this ;?2) `-"'day of May, 2009, by and among SCOTT A. CALAMAN and MELANIE E. CALAMAN, husband and wife, of 6 Mountain View Lane, Newville, Cumberland County, PA 17241, and AMBER NICOLE CALAMAN, of 6 Mountain View Lane, Newville, Cumberland County, PA 17241, WITNESSETH: WHEREAS, AMBER N. CALAMAN, is the natural mother of KAPRI RAQUEL CALAMAN, a minor child, born March 18, 2009, Social Security No. 209-84-0233; and WHEREAS, the Father of the Minor Child is unknown; and WHEREAS, SCOTT A. CALAMAN and MELANIE E. CALAMAN are the Father and Mother of AMBER N. CALAMAN and Grandparents of KAPRI R. CALAMAN; and WHEREAS, AMBER N. CALAMAN, is unable to provide the care necessary for KAPRI R. CALAMAN at the current time and desires that SCOTT A. CALAMAN and MELANIE E. CALAMAN, husband and wife, be legal guardians of her person. NOW, THEREFORE, the parties hereto, intending to be legally bound hereby, do covenant and agree as follows: 1. Effective upon execution and acknowledgement of this Agreement by all parties, SCOTT A. CALAMAN and MELANIE E. CALAMAN, husband and wife, shall be the guardians of KAPRI R. CALAMAN, a minor child, and shall be responsible for her care, control and supervision. KAPRI shall reside at 6 Mountain View Lane, Newville, PA with her guardians and her natural mother, AMBER N. CALAMAN, in the joint legal and physical custody of the Mother and the guardians of her person. 2. The guardians shall have the right to complete, execute and acknowledge any and all documents, writings, insurances, and instruments necessary to obtain or authorize all matters pertaining to the schooling, medical treatment and complete care of the child. The guardianship shall be utilized by any school or school district; by any hospital, clinic, doctor or practitioner of medicine; by any agency of the federal, state or local government; or by any other agency, firm, organization, corporation or association. This guardianship shall be effective for use including, but not limited to, the following: authorization for any act or activity associated with the education of the child; authorization for any emergency treatment, diagnostic examination or surgery or any other medical procedure or admission to any medical facility; authorization for participation in any and all sports, recreational and club activities; and for all other matters affecting the health, education, safety and welfare of the minor child. The guardian shall be authorized to act as guardians of the minor child with this power of attorney for all purposes and to do all lawful acts requisite for effectuating the aforesaid, 2 and AMBER N. CALAMAN hereby ratifies and confirms all that the guardians shall do by virtue of this guardianship. This guardianship shall be sufficient to meet the requirements under HIPPA. 3. A copy of this authorization is and shall be relied upon as the equivalent for all purposes as if it were the original. 4. This Agreement may be entered as an Order of Court in the Court of Common Pleas, for Cumberland County, Pennsylvania, at the sole option and expense of SCOTT A. CALAMAN and MELANIE E. CALAMAN. 5. This Agreement shall remain in full force and effect unless or until superseded by further written Agreement of the parties or Order of Court. IN WITNESS WHEREOF, the parties hereto set their hands and seals the day and year first above written. Witness: SCOTT A. CALAMAN r MELANI Lf- E CALAMAN AMBER N. CALAMAN 3 COMMONWEALTH OF PENNSYLVANIA :SS: COUNTY OF CUMBERLAND On this, the Re day of May, 2009, before me, the undersigned officer, personally appeared Scott A. Calaman and Amber N. Calaman, known to me (or satisfactorily proven) to be the persons whose names are subscribed to the within agreement, and acknowledge that they executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. W AR1AL SEAL BONNIE L COYLE. NOTARY PUBUC BORO OF CARLISLE. CUMBERLAND CO. PA FIRES OCTOBER 17, 2010 MY COMMISSION EX Notary Public COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND :SS: On this, the &??Ott day of May, 2009, before me, the undersigned officer, personally appeared Melanie E. Calaman, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within agreement, and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. F OTARIAL SEAL Notary Public OYL E. NOTARY PUBLIC SLE, CUMBERLAND CO. PA EXPIRES OCTOBER 17, 2010 4 OF THE PHU, ?ONOTAP* 2003 AUG 24 PSI 23 /417/ ?? 1i , AUG 2 4 2009 4 SCOTT A. CALAMAN and : IN THE COURT OF COMMON PLEAS MELANIE E. CALAMAN, : CUMBERLAND COUNTY, :PENNSYLVANIA Husband and Wife, Plaintiffs : CIVIL ACTION - LAW Vs. : 2009 -6g3o CIVIL TERM AMBER N. CALAMAN, : CUSTODY Defendant : ORDER OF COURT THIS Z-(.' day of August, 2009, upon presentation and consideration of the attached Custody and Guardianship Agreement of the parties, it is hereby ordered and decreed that the attached Agreement is made an Order of Court, granting the Maternal Grandparents, Scott A. Calaman and Melanie E. Calaman, husband and wife, and their daughter, Amber N. Calaman, joint physical and legal custody of Kapri Raquel Calaman, a minor child. Distribution: Scott A. Calaman Melanie E. Calaman Amber N. Calaman ,/f/o Dale F. Shughart, eon £s rrLa L Ll By the Court, J. Jr., Esquire FILED-;_ OF THE T,'tFY 2099 AUG 26 Act 10: v 6 4 40 PE, M