The URL can be used to link to this page

Home My WebLink About10-2596 V I'-,- ?llz?4 ?lvU?kvlo,Ad &UAy, oSvwwC? U' 1?c1(?? Rio . Ib ?s9,(, &"P4 r }? C' YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DE rSDZ AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO THE TELEPHONE OR THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 q /w od 'eod - 4 CHRISTINA SWEENEY, Plaintiff The defendant is Jason Sweeney, residing at 134 Rellim Street, Carlisle, Cumberland County, Pennsylvania 17013. V. CIVIL ACTION - LAW NO. JASON SWEENEY, Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Christina Sweeney, residing at 1814 Sterretts Gap Avenue, Carlisle, Cumberland County, Pennsylvania 17013. 2. 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff seeks custody of the following child: Name Emma Grace Anne Sweeney Present Residence 1814 Sterretts Gap Ave. Carlisle, PA 17013 DOB Age 09/06/09 7 mo. The child was not born out of wedlock The child is presently in the custody of Plaintiff, residing at 1814 Sterretts Gap Avenue, Carlisle, Cumberland County, Pennsylvania 17013. During the past five years, the child has resided with the following persons and at the following addresses: List All Persons List All Addresses Christina & Jason Sweeney 134 Rellim St. Carlisle, PA 17013 Christina Sweeney 1814 Sterretts Gap Ave. Carlisle, PA 17013 Dates 09/09 - 2010 2010 present 4. The Mother of the child is Christina Sweeney, residing at 1814 Sterretts Gap Avenue, Carlisle, Cumberland County, Pennsylvania 17013. She is married. The Father of the child is Jason Sweeney, residing at 134 Rellim Street, Carlisle, Cumberland County, Pennsylvania 17013. He is married. The relationship of Plaintiff to the child is that of Mother. The plaintiff currently resides with the following persons. Name None. Relationship 6. The relationship of Defendant to the child is that of Father. The defendant currently resides with the following persons. Name Relationship None. 7. 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 child 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. 8. The best interest and permanent welfare of the child will be served by granting the relief request because: A Court Order of custody and structured visitation is desired so that the Plaintiff and the child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion. A Court Ordered determination of custody is required to avoid continuing conflict between the parties regarding responsibility for custody and support. WHEREFORE, Plaintiff requests this Court grant Plaintiff primary physical custody subject to visitation with Defendant as agreed upon by the parties. Respectfully submitted, Date: 1 C90Iv Romin er & Associates c Kar . Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court I.D. # 81924 Attorney for Christina Sweeney CHRISTINA SWEENEY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. JASON SWEENEY, Defendant IN CUSTODY VERIFICATION 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. Cons. Stat. § 4904 relating to unsworn falsification to authorities. Christina Sweeney, Plaintiff CHRISTINA SWEENEY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. JASON SWEENEY, Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Christina Sweeney, certify that I this day served a copy of the within Complaint for Custody upon the following by depositing the same in the United States Mail, first class, postage pre-paid, addressed as follows: Jason Sweeney, pro se 134 Rellim Street Carlisle, Pennsylvania 17013 Date: 4 /CX// v Respectfully submitted, Rominger & Associates e_? 1% KafrE. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court I.D. # 81924 Attorney for Christina Sweeney I The parties hereto agree that the best interest and continuing welfare of the Child would be best served with the custody arrangement as follows: a. Plaintiffs and Defendants will share legal custody of Child as defined in 23 Pa. C.S.A. §5302. All decisions affecting the Child's growth and development, including but not limited to medical treatment, education, and religious training, are major decisions which Plaintiffs and Defendants shall make jointly after discussion and consultation with each other. b. As provided 23 Pa. C.S.A. §5309(a), each party shall have full and complete access to the Child's mental, dental, religious and school records. This includes the names, addresses and telephone numbers of all medical and other providers. c. Plaintiff shall have primary physical custody with Defendant having visitation as agreed upon by the parties. CHRISTINA SWEENEY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSY-?VA IA a V. CIVIL ACTION - LAW : r NO- /0 JASON SWEENEY, Defendant IN CUSTODY 5- C- w STIPULATION AGREEMENT AS TO CUSTODY Plaintiff Christina Sweeney, hereinafter referenced as "Mother," and Defendant Jason Sweeney, hereinafter referenced as "Father" hereby agree to the following terms in an Order defining custody and partial custody rights and responsibilities in relation to Emma Grace Anne Sweeney, born September 6, 2009, hereinafter referenced as "Child:" 2. 3 Each party shall have reasonable telephone and e-mail access to the Child while the Child is in the custody of the other party. The parties shall keep each other advised immediately relative to any emergencies concerning the Child and shall further take any necessary steps to ensure that the health, welfare and well being of the Child are protected. The parties shall do nothing that may estrange the Child from the other party or hinder the natural development of the Child's love or affection for the other party. 4 5 6 8 Each party shall not make any disparaging remarks or allow others to make any disparaging remarks concerning the Child's parents in front of the Child. Any modification or waiver of any of the provisions of the agreement of the parties shall be effective only if made in writing and only if executed with the same formality of the agreement of the parties. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. Both parties agree that the terms of this agreement have been fully explained to them by their respective counsel or that both parties have had the opportunity to have legal counsel review and fully explain the terms of this agreement. Plaintiff is represented by Karl E. Rominger, Esquire of Rominger & Associates. The parties hereto agree that this agreement shall be recorded and incorporated into an Order enforceable by the Court. 9. Consented to: 4119110 Date '//q // 1) Date ITIA Date `I't3-1U Date C? weeny, Plaintiff , Esquire S Witness for Jason Sweeney COIN/PvIONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF ?11)A?GjRC& ) On this, the day of 2010, before me a notary public, the undersigned officer, personally appeared Christina Sweeney, known to me (or satisfactorily proven) to be the persons whose names are subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. In witness whereof, I hereunto set my hand and official seal. COMMQNWEALTH OF PENNsyLVANIA Noloilel gao Tomb L l ubic CA" DNotoi PCouray L*0Wft%WME*h*S@PL%2011 Idanbor, F.nn.yhranle AeeocfMbn of ftwies otary Public COMMONWEALTH OF PENNSYLVANIA COUNTY OF M &&"j- SS: On this, the 1?- day of kjo i , 2010, before me a notary public, the undersigned officer, personally appeared Jason Sweeney, known to me (or satisfactorily proven) to be the persons whose name are subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. In witness whereof, I hereunto set my hand and official seal. Notary Public TH OF EENNSYLV NOTARIAL SEAL DARCIE A. NEIL, Notuy Pubic Boro of Cor06, cwftft fd CWdy My CarM*Won SxpWft Nov. 94, 90113