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HomeMy WebLinkAbout01-6853BETH A. WOGAN, Plaintiff V. DAVID A. WOGAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. IN CUSTODY STIPULATION REGARDING CUSTODY-VISITATION Plaintiff, Beth A. Wogan, hereinafter referenced as Mother, and Defendant, David A. Wogan, hereinafter referred to as Father, hereby agree to the entry of the following terms in a Court Order defining custody and visitation in relation to the parties' minor child: Josey Leanne Wogan, bom, December 15, 1998, hereinafter referenced as Child: (1) Shared legal custody of Josey Leanne Wogan as contemplated by the Act of November 5, 1984, P.S. §1001, et seq., is awarded to Mother and Father. (2) Physical custody of the Child, Josey Leanne Wogan, is awarded to Mother subject to visitation by Father at Mother's discretion. Beth A. Wogan,"?laintiff - David A. Wogan, De~r~d~tnt, t~ BETH A. WOGAN, : Plaintiff : : V. : : DAVID A. WOGAN, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. IN CUSTODY CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Plaintiff, do hereby certify that I this day served a copy of the Stipulation Regarding Custody/Visitation upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: David Wogan 96 Cold Springs Road Carlisle, PA 17013 Dated: November 6, 2001 Karl E. Rominger, Esquire Attorney for Plaintiff BETH A. WOGAN, : Plaintiff : : : V. : : DAVID A. WOGAN, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 01-(o IN CUSTODY COMPLAINT FOR CUSTODY The plaintiff is Beth A. Wogan, residing at 542A Criswell Drive, Cumberland County, Boiling Springs, Pennsylvania. The defendant is David A. Wogan, residing at 96 Cold Springs Road, Cumberland County, Carlisle, Pennsylvania. 3. Plaintiff seeks custody of the following child: NalTle Josey Leanne Wogan Present Residence Age 542A Criswell Drive, Boiling Springs, PA 2 yrs. 11 mos. The child was not bom out of wedlock The child is presently in the custody of mother who resides at 542A Criswell Drive, Cumberland County, Pennsylvania. During the past five years, the children have resided with the following persons and at the following addresses: List All Persons David and Beth Wogan List All Addresses 26 McBride Ave., Carlisle, PA Dates 12/98 - 11/99 David and Beth Wogan 96 Cold Springs Road, Carlisle, PA 11/99-12/00 Beth Wogan 542A Criswell Drive, Boiling Springs, PA 12/00-present The mother of the child is Beth Wogan, currently residing at 542A Criswell Drive, Boiling Springs, PA. She is married. The father of the child is David Wogan, currently residing at 96 Cold Spring Road, Carlisle, PA. He is married. 4. The relationship of plaintiff to the child is that of mother. The plaintiff currently resides with the following persons. Nanle Josey Leanne Wogan Relationship Daughter 5. The relationship of defendant to the child is that of father. The defendant currently resides with the following persons. Name Relationship No one 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. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 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. The best interest and permanent welfare of the child will be served by granting the relief request because: Plaintiff has undertaken and performed the primary parental responsibilities for the child. Plaintiff is best able to provide the care and nurture which the child needs for healthy development. WHEREFORE, Plaintiff requests that this Honorable Court enter the attached Stipulation in regards to Custody, as the parties have come to a mutually agreeable custody agreement and no further hearing is required in this matter. Respectfully submitted, Date: Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff I verify that the statements made in this complaint are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unsworn falsification to authorities. BETH A. WOGAN, Plaintiff DAVID A. WOGAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. dS/- (,,g53 IN CUSTODY ORDER AND NOW, this /~ ''~ day of ~~ 200 I, in consideration of the attached Stipulation Regarding Custody and Visitation, and signatures therein, it is hereby ordered that: (1) Shared legal custody of Josey Leanne Wogan as contemplated by the Act of November 5, 1984, P.S. §1001, et seq., is awarded to Mother and Father. (2) Physical custody of the Child, Josey Leanne Wogan, is awarded to Mother subject to visitation by Father at Mother's discretion. BY THE COURT: J.