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HomeMy WebLinkAbout01-4783Robert Hirsch 8.8.01. Custody Complaint IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT R. HIRSCH, : Plaintiff : V. : LYNN A. THOMAS, : NO.0f-~7g~ClVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY COMPLAINT The Plaintiff is Robert R. Hirsch, residing at 1002 Robert Street, Mechanicsburg, PA 17055. The child was born out of wedlock. The child is presently in the custody of the Robert R. Hirsch who resides at 1002 Robert Street, Mechanicsburg, PA 17055. During the past five years, the child has resided with the following persons and at the following addresses: NAME PLACE OF RESIDENCE AGE D.O.B. Nathaniel Robert Hirsch 1002 Robert Street 2 5/21/99 Mechanicsburg, PA 17055. The Defendant is Lynn A. Thomas, residing at Apt. 7, Creston Apartments, Camp Hill, PA 17011. Plaintiff seeks custody of the following child: Robert Hirsch 8.8.01. Custody Complaint PERSONS ADDRESSES DATES Robert R. Hirsch 1002 Robert Street, June 2001 IMechanicsburg, PA 17055. to present Robert R. Hirsch 1002 Robert Street, June 1999 Lynn Ann Thomas Mechanicsburg, PA 17055. to June 2001 Robert R. Hirsch 1441 Apple Circle, Apt 181 Birth to Lynn Ann Thomas Mechanicsburg, PA 017055 June 1999 currently residing at Apt. 7, 10. 11. 12. The mother of the child is Lynn Ann Thomas Creston Apartments, Camp Hill, PA 17011. The mother is single. The father of the child is Robert R. Hirsch currently residing at 1002 Robert Street, Mechanicsburg, PA 17055.. The father is single. The relationship of Plaintiff to the child is that of Father. The Plaintiff currently resides with the following persons: NAMES RELATIONSHIP Nathaniel Robert Hirsch son David Hirsch brother Leah Hirsch niece Courtney Hirsch niece 13. The relationship of Defendant to the child is that of Mother. 14. The Defendant currently resides with the following persons: - 2 - Robert Hirsch 8.8.01. Custody Complaint NAMES RELATIONSHIP Deborah McGee friend Joseph Thomas son 15. 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. 16. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 17. 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. 18. The best interest and permanent welfare of the child will be served by granting the relief requested because the parties have agreed to this custodial arrangement pursuant to the marked Exhibit A and made a part hereof. Each parent whose parental rights to the and the person who has physical custody of parties to this action. Stipulation attached hereto, child have not been terminated the child have been named as - 3 Robert Hirsch 8.8.01. Custody Complaint WHEREFORE, Plaintiff requests the Court to enter the foregoing custody order pursuant to the Stipulation of the parties attached thereto. Respectfully submitted, ~ Trindle~oad Camp-Hill, -PA 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 ID No. 32112 - 4 Robert Hirsch 8.8.01. Custody Complaint correct. I understand that false penalties of 18 Pa.C.S. 4904 authorities. VERIFICATION I verify that the statements made in this Custody Complaint are true and statements herein are made subject to the relating to unsworn falsification to Date: OF -c3~'- ~2/ Robert Hirsch 6.18.01. Agreement STIPULATION AND AGREEMENT FOR CUSTODY (hereafter referred to as "Father") and Lynn Ann Thomas referred to as "Mother") (collectively "Parents") hereby stipulate and agree custody of their son, Nathaniel Robert Hirsch born May 21, R. Hirsch (hereafter hereafter referred to as as follows pertaining to 1999: 2 o Legal Custody: The Parents shall have joint legal custody of the Child and shall have the right to participate in all major decisions affecting the Child, including but not limited to matters governing religion, heath, physical well being. Pursuant thereto, the right of access to all information, education and general each parent shall have documents and persons pertaining to the general well being of the Child. Primary Physical Custody: Father shall have primary physical custody of the Child subject to Mother's rights of partial custody hereafter set forth. Partial Physical Custody: Mother shall have rights of partial physical custody of the Child at such times and places as the Robert Hirsch 6.18.01. Agreement parties shall hereafter mutually agree. Telephone Contact: Both Parents shall be afforded reasonable telephone contact with the Child while in the other Parent's custody and for said purposes each Parent shall provide the other parent with his or her home phone number where the Child can be reached when in the that Parent's custody. Temporary Absence from Commonwealth: If either Parent intends on removing the Child from the Commonwealth of Pennsylvania for a period in excess of forty-eight (48) hours that Parent shall provide the other Parent with the address and phone number where the Child can be reached durinG the period of absence. Relocation: Neither Parent shall remove the Child from the jurisdiction of the Court of Common Pleas of Cumberland County, Pennsylvania on a permanent basis without providing the other Parent with at least ninety (90) days advance notice thereof. Said ninety (90) day time period is designed to allow the Parents to negotiate a modification of this Stipulated Agreement and in absence thereof to be able to petition the Court for a modification if the same is appropriate under the circumstances. Robert Hirsch 6.18.01. Agreement 7. Activities: The party having custody at any given time shall see that the Child is taken to their regularly scheduled activities so that their participation in said activities is not interrupted. 8. Transportation: The transportation necessary for the custodial exchanges herein set forth shall be provided by Mother. 9. Order: The parties agree that upon request of either party this terms of this Agreement shall be entered as an order of Court. IN WITNESS WHEREOF the Parents, intending to be legally bound hereby, have set their hands and seals the day and year below written. WITNESS: R~B~RT R. ~I~S~H - Date: LYN~ ANN THO~S Date: - 3 - Robert Hirsch 6.18.01. Agreement IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT R. HIRSCH, Plaintiff V. LYNN A. THOMAS, Defendant N0z2t- ~IVIL TERM CIVIL ACTION - LAW IN CUSTODY CONSENT CUSTODY ORDER AND NOW, the within Stipulated Custody Hirsch ("Father") and Lynn individually ~Parent" and collectively their minor child, Nathan Robert Hirsch, this [-~ day of !~.~~, 2001, upon consideration of Agreement executed by Robert R. A. Thomas (~Mother")(sometimes "Parents") pertaining to born May 21, 1999 (~the Child), IT IS HEREBY ORDERED AND DECREED as follows: 1. ~: The Parents shall have joint legal custody of the Child and shall have the right to participate in all major decisions affecting the Child, including but not limited to matters governing physical well being. the right of access to all information, pertaining to the general well being of religion, heath, education and general Pursuant thereto, each parent shall have documents and persons the Child. - 1 Robert Hirsch 6.18.01. Agreement 2. Primary Phvsical Custody: Father shall have primary physical custody of the Child subject to Mother's rights of partial custody hereafter set forth. 3. Partial Physical Custody: Mother shall have rights of partial physical custody of the Child at such times and places as the parties shall hereafter mutually agree. 4. Telephone Contact: Both Parents shall be afforded reasonable telephone contact with the Child while in the other Parent's custody and for said purposes each Parent shall provide the other parent with his or her home phone number where the Child can be reached when in the that Parent's custody. 5 o Temnorarv Absence from Commonwealtl~: If either Parent intends on removing the Child from the Commonwealth of Pennsylvania for a period in excess of forty-eight (48) hours that Parent shall provide the other Parent with the address and phone number where the Child can be reached during the period of absence. Relocation: Neither Parent jurisdiction of the County, Pennsylvania the other Parent with at least ninety shall remove the Child from the Court of Common Pleas of Cumberland on a permanent basis without providing (90) days advance notice Robert Hirsch 6.18.01. Agreement 7 o 8 o thereof, Said ninety (90) day time period is designed to allow the Parents to negotiate a modification of this Stipulated Agreement and in absence thereof to be able to petition the Court for a modification if the same is appropriate under the circumstances. Activities: The party having custody at any given time shall see that the Child are taken to their regularly scheduled activities so that their participation in said activities is not interrupted. Trans ortation: The transportation necessary for the custodial exchanges herein set forth shall be provided by Mother. Order: The parties agree that upon request of either party this terms of this Agreement shall be entered as an order of Court. BY THE ~~ Jo - 3 -