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Home My WebLink About10-2575 LEIGHTON P. STIFFLER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. /Q , r7Y CIVIL TERM NATOSHA L. STIFFLER, CIVIL ACTION LAW Defendant IN CUSTODY N cV COMPLAINT FOR CUSTODY` - z v t r' -rn rA . 'Virgw*ia an adult individual currently residing at 6 Stiffler hton P Plaintiff is Lei 1 . , . g . Avenue, Carlisle, Cumberland County, Pennsylvania. ; ? J r` v? 2. Defendant is Natosha L. Stiffler, an adult individual believed to be residing at 147 Porter Avenue, Carlisle, Cumberland County, Pennsylvania. 3. The parties are the natural parents of two (2) children, namely, Ethen Elijah Stiffler, born April 3, 2006, and Aaron Powers Stiffler, born September 23, 2004. The children were born in wedlock. 4. For the past five (5) years, or since the children's birth, the children have resided with the following persons at the following addresses for the following periods of time: NAME Leighton P. Stiffler ADDRESS 106 Virginia Avenue Carlisle, PA 17013 DATES December 1, 2009 to Present Natosha L. Stiffler Leighton P. Stiffler and Natosha L. Stiffler 147 Porter Avenue Carlisle, PA 17013 147 Porter Avenue Carlisle, PA 17013 December 1, 2009 to Present Birth to December 1, 2009 1 44 The natural mother of the children is Natosha L. Stiffler, who resides as aforesaid. She is married but separated. The natural father of the children is Leighton P. Stiffler, who resides as aforesaid. He is married but separated. 5. The relationship of the Plaintiff to the children is that of natural father. The Plaintiff currently resides with the children during his periods of custody. 6. The relationship of the Defendant to the children is that of natural mother. Defendant currently resides with the children during her periods of custody. 7. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning custody of the children. 8. Plaintiff has no information of any custody proceedings concerning the children pending in any Court of this Commonwealth. 9. It is in the best interest and permanent welfare of the children to grant the relief requested because: a) Both parties have cared for the children since they were born; b) Both parties can provide a stable home for the children; and c) Both parties can care for the day to day needs of the children. 10. Plaintiff does not know any person not a party to these proceedings who claims to have custody or visitation rights with respect to the children. a 11. Plaintiff is filing a Custody Stipulation and Agreement contemporaneously with the filing of this Complaint. WHEREFORE, Plaintiff requests your Honorable Court enter an Order whereby the parties' Custody Stipulation and Agreement, being filed contemporaneously, with the Custody Complaint, is made an Order. Respectfully submitted, Hannah Herman-Snyder, Esquird Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: L p GH N P. STIFFLER, P aintiff LEIGHTON P. STIFFLER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNS)IE?VAL?!JIA K VS. ? NO. /6-a.5 7 CIVIL TERM rn. rhm NATOSHA L. STIFFLER, CIVIL ACTION LAW s - o Defendant IN CUSTODY '<? "{7: CUSTODY STIPULATION AND AGREEMENT v> THIS STIPULATION AND AGREEMENT entered into this day of January, 2010, by and between Leighton P. Stiffler, (hereinafter referred to as "Father") and Natosha L. Stiffler, (hereinafter referred to as "Mother"); The parties are the natural parents of two children, Ethen Elijah Stiffler, born April 13, 2006 and Aaron Powers Stiffler, born September 23, 2004, (hereinafter referred to as the "children"); WHEREAS, the natural parents are separated and living in different residences; and WHEREAS, the parties wish to enter into this Agreement relative to the custody of the children. NOW THEREFORE, in consideration of the mutual covenants, promises, and agreements as hereinafter set forth, the parties agree as follows: 1. The parties shall share legal custody of the children, Ethen Elijah Stiffler and Aaron Powers Stiffler. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa. C.S. §5309, each parent shall be entitled to all records and information pertaining to the children, including, but not limited to medical, dental, religious or school records, and the residential address of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regards to the minor children. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports, given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 2. The parties shall share equally in the physical custody of the children such that in a two (2) week period, each party has an equal number of overnights. The parties shall schedule their periods of custody in accordance with Mother's work schedule, a 2-2-3 rotation, and they shall schedule their periods of custody such that Father shall exercise custody of the children while Mother is working. 3. The parties shall share equally in the transportation for custody exchanges. 4. The following holidays shall be rotated, with Mother exercising custody of the children for Easter in 2010, and the times for the custody exchanges shall be agreed upon by the parties: Easter, Fourth of July, Halloween, Thanksgiving, and Christmas. 5. Mother shall exercise custody of the children every Mother's Day, and Father shall exercise custody of the children every Father's Day, with the times to be agreed upon by the parties. 6. The parties shall not do anything which may estrange the children from the other party, or injure the opinion of the children as to the other party or which may hamper the free and natural development of the children's love and affection for the other party. 7. It is affirmed that the Court of Common Pleas of Pennsylvania, Cumberland County Branch, had jurisdiction over the issue of custody of the children in this case at the time the proceedings were initiated and the Court has retained jurisdiction over these matters so that it is appropriate for the Court to enter an Order of Court. Further, the parties request that the Court of Common Pleas of Pennsylvania, Cumberland County Branch, enter this as an Order of Court. 8. The parties acknowledge that they have read and understand the provisions of this Agreement. 9. Any modification or waiver of any of the provisions of this Agreement on a permanent basis shall be effective only if made in writing and only if executed with the same formality as this Stipulation and Agreement. 10. The parties acknowledge that they have read and understand the provisions of this Agreement. Each party acknowledges that the Agreement is fair and equitable and that it is not the result of any duress or undue influence. 11. The parties stipulate that in making this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of the other party. WITNESS: ? f B«. Yeig n . Sti Date:, 2010 i Date: 2010 atosha L. Stiffler COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this c2 a day of Z21&,-4 , 2010, before me, the undersigned officer, personally appeared NATOSHA L. STIFFLER, known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notarial Seal Cathy E. Fry. Notary Public South Middleton 1Wp., Cumberland County My Commission Expires July 309 2010 Notary Public COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this Q day of , 2010, before me, the undersigned officer, personally appeared LEIGHTON P. STIFFLER, known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purpose therein contained. 1N WITNESS WHEREOF, I hereunto set my hand and official seal. NOTA?n'A . SEAL r-7:0 A. cbt?r s; Nanry Public Q+r' : E rlr4 , Curi??ia?nd My Commssion B*a Nov. -, 201