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HomeMy WebLinkAbout09-5839 TANNER LAW OFFICES, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 Telephone: (717) 731-8114 Facsimile: (717) 731-8115 SHERIFAT I. ENGLE, § Plaintiff § V. § PATRICK T. ENGLE, § Defendant § IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CUSTODY NO. CR - -%3q a-"i I -I-axrn COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, Sherifat I. Engle, by and through her attorney, Tanner Law Offices, LLC, and represents as follows: 1. Plaintiff is Sherifat I. Engle, an adult individual currently residing at 509 Thomas Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Patrick T. Engle, an adult individual currently residing at 306 South Hanover Street, Apartment 4, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks sole legal and physical custody of the following child: Name Present Address Age Patrice O. Engle 509 Thomas Road 4 Camp Hill, PA 17011 (D.O.B.9/17/2004) 4. The child was born out of wedlock. 5. The child is presently in the custody of the Plaintiff, Sherifat I. Engle, who resides at 509 Thomas Road, Cumberland County, Pennsylvania 17011, with her fiancee. I . 4 6. During the last five years, the child has resided with the following persons at the following addresses: Persons : Address: Dates: Plaintiff 509 Thomas Road 9/08-present Chad Forcey (Plaintiff's fiancee) Camp Hill, PA 17011 Plaintiff 415S.32 nd St. 9/07 - 9/08 Defendant Camp Hill, PA 17011 Plaintiff 8 Marshall Drive 9/07 - 9/07 Camp Hill, PA 17011 Plaintiff 415 S.32 nd St. 9/06 - 9/07 Defendant Camp Hill, PA 17011 Plaintiff 909 W. Maple St. 6/06 - 9/06 Valley View, PA 17983 Plaintiff 415S.32 nd St. 1/06 - 6/06 Defendant Camp Hill, PA 17011 Plaintiff 216 Locust St. 12/05 - 1/06 Defendant Columbia, PA Plaintiff Nigeria 9/04 - 12/05 7. The mother of the child is Plaintiff, Sherifat I. Engle, currently residing at 509 Thomas Road, Camp Hill, Cumberland County, Pennsylvania 17011. 8. The father of the child is Defendant, Patrick T. Engle, currently residing at 306 South Hanover Street, Apartment 4, Carlisle, Cumberland County, Pennsylvania 17013. 9. The relationship of the Plaintiff to the child is that of mother. 10. The relationship of the Defendant to the child is that of father. 11. Plaintiff has not participated as a party in other litigation concerning the custody of the child in a court of this Commonwealth or any other state. 12. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. 13. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. 14. The best interests and permanent welfare of the child will be served by granting the relief requested. The quality of the child's physical, intellectual, moral and spiritual environment would be improved by Plaintiff's sole legal and physical custody. WHEREFORE, Plaintiff requests the Court to grant Sole Legal and Primary Physical Custody of the Child. Respectfully submitted, By: ln,)-? // Tabetha A. Tanner, Esquire Supreme Court I.D. No.: 91979 Attorney for Plaintiff TANNER LAW OFFICES, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 (717) 731-8114 VERIFICATION I verify that the statements made in this Complaint for Custody are true and correct. I understand that false statements made herein may subject me to penalties of Pa.C.S. §4904 relating to unsworn falsification to authorities. Date Sheri fa le, Plaintiff r rL( ,,alt C'rY 2009 AUG 25 AN I I : - r? $1(o S. 56 Po A'n'd C Y a544 wt u9,la4 - G•; SHERIFAT I. ENGLE, Plaintiff V. PATRICK T. ENGLE, Defendant § IN THE COURT OF COMMON PLEAS OF § CUMBERLAND COUNTY, PENNSYLVANIA § CIVIL ACTION - LAW § CUSTODY § NO. STIPULATED CUSTODY AGREEMENT AND NOW, this j 15 day of A 0G cj 5 , 2009, Sherifat I. Engle, residing at 509 Thomas Road, Camp Hill, Cumberland County, Pennsylvania 17011 (hereinafter referred to as "Mother"), and Patrick T. Engle, residing at 306 South Hanover Street, Apartment 4, Carlisle, Cumberland County, Pennsylvania 17013 (hereinafter referred to as "Father") (Mother and Father are individually "Parent" and collectively "Parents") hereby stipulate and agree to the following regarding custody of their minor child, Patrice O. Engle, born September 17, 2004. A. Legal Custody Mother shall have sole legal custody of the Child. B. Physical Custody Mother shall have sole physical custody of the Child. C. Travel/Passport: Mother shall have the sole right to authorize the issuance of the Child's U.S. passport. D. Entry of Court Order• The parties authorize the Court of Common Pleas of Cumberland County, Pennsylvania to enter an order incorporating the terms of this Stipulated Custody Agreement. Page 1 of 2 IN WITNESS WHEREOF, the Parents, intending to be legally bound hereby, have set their hands and seals the day and year written below. Witness: - i - Joh err, Attorney for Father Tabetha A. Tanner, Attorney for Mother Patrick T. En , Fat r Date: , `b Page 2 of 2 Sherifat I. Engle, Mother OF TP; CfTARY 2009 AUG 25 AH it' - 36 T I. 11 j SHERIFAT I. ENGLE, Plaintiff V. PATRICK T. ENGLE, Defendant § IN THE COURT OF COMMON PLEAS OF § CUMBERLAND COUNTY, PENNSYLVANIA § CIVIL ACTION - LAW § CUSTODY § NO. 0R - 5859 0-Wit 7irpt STIPULATED ORDER FOR CUSTODY AND NOW, this z? day of .?- , 2009, this Order is being entered as a result of an Agreement between the parties as evidenced by the attached Stipulated Custody Agreement, dated e?L,,,., /8_ , 2009. This matter is before the Court on Plaintiff's Complaint. This matter involves the custody of. Patrice O. Engle Date of Birth: September 17, 2004 A. Legal Custody: The mother shall have sole legal custody of the Child. B. Physical Custody: The mother shall have primary physical custody of the Child. Visitation shall be mutually-agreed upon by the parties. C. Travel/Passport: Mother shall have the sole right to authorize the issuance of the Child, Patrice O. Engle's U.S. passport. Page 1 of 1 AL ISJ L. OF THE 2009 AUG 27 AM I0= 09