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HomeMy WebLinkAbout04-3690 SA/DIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA CLAIRE HEALEY, Plaintiff TRAVlS HOCKENBRAUGH Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO.,~,9~t~'- CIVIL TERM .. : ,9 ¥- : CIVIL ACTION-LAW : IN CUSTODY AGREEMENT OF THE PARTIES 1. The parties hereto are Claire Healey of 3506 Stockwood Street, Mechanicsburg, Cumberland County, Pennsylvania 17050, hereinafter Mother and Travis Hockenbraugh of 307 N. North Enola Drive, Eno{a, Cumberland County, Pennsylvania 17025, hereinafter Father. 2. The parties are parents of the child, Hayden Helm Healey, born 3. The parties desire to settle the terms of custody and child support for their child. 4. The Mother shall have physical and legal custody of the child subject to periods of visitation with Father as the parties can agree. 5. Mother and the child are relocating to Marshall, Michigan. Upon relocation, Mother will provide to Father her address and phone number. 6. Father may visit with the child in Marshall at such times as the parties can agree. 7. Father shall provide for the support of the child as he wishes and he is able. His support shall be made voluntarily. Parties desire that the terms of this agreement be made an order of court. CLAIRE HEALEY TRAVIS HOCKENBRAUGH, SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High $1reet Carlisle, PA SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA CLAIRE HEALEY, Plaintiff VS. TRAVIS HOCKENBRAUGH Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N O.,~,90'5~- CIVIL TERM CIVIL ACTION-LAW IN CUSTOr)y AGREEMENT OF THE PARTIES 1. The parties hereto are Claire Healey of 3506 Stockwood Street, Mechanicsburg, Cumberland County, Pennsylvania 17050, hereinafter Mother and Travis Hockenbraugh of 307 N. North Enola Drive, Enola, Cumberland County, Pennsylvania 17025, hereinafter Father. 2. The parties are parents of the child, Hayden Helm Healey, born 3. The parties desire to settle the terms of custody and child support for their child. The Mother shall have physical and legal custody of the child subject to periods of visitation with Father as the parties can agree. Mother and the child are relocating to Marshall, Michigan. Upon relocation, Mother will provide to Father her address and phone number. Father may visit with the child in Marshall at such times as the parties can agree. Father shall provide for the suppor~ of the child as he wishes and he is able. His support shall be made voluntarily. SAIDIS SHUFF, FLOWER & LINDSAY 26 W, High Street Carlisle, PA Padies desire that the terms of this agreement be made an order of court. CLAIRE HEALE-Y - - ,~ TRAVIS HOCKENBRAUGH, AUG 0 3 CLAIRE HEALEY, Plaintiff VS. TRAVIS HOCKENBRAUGH Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003- CIVIL TERM : CIVIL ACTION-LAW : IN CUSTODY AGREEMENT OF THE PARTIES SAIDIS SHUFF, FLOWER & LINDSAY 1. The parties hereto are Claire Healey of 3506 Stockwood Street, Mechanicsburg, Cumberland County, Pennsylvania 17050, hereinafter Mother and Travis Hockenbraugh of 307 N. North Enola Drive, Enola, Cumberland County, Pennsylvania 17025, hereinafter Father. 2. The parties are parents of the child, Hayden Helm Healey, born 3. The parties desire to settle the terms o'I custody and child support for their child. 4. The Mother shall have physical and legal custody of the child subject to periods of visitation with Father as the parties can agree. 5. Mother and the child are relocating to Marshall, Michigan. Upon relocation, Mother will provide to Father her address and phone number. 6. Father may visit with the child in Marshall at such times as the parties can agree. 7. Father shall provide for the support of the child as he wishes and he is able. His support shall be made voluntarily. Parties desire that the terms of this agreement be made an order of court:. TRAVIS HOCKENBRAUGH, SAIDIS SHUFF, FLOWER & LINDSAY ATTORNEYS*AT*LAW 26 W. High Street Carlisle, PA SAIDIS sHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA CLAIRE HEALEY, plaintiff VS. TRAVIS HocKENBRAUGH Defendant AUG 0 3 2004 IN THE cOURT OF COMMON PLEAS CUMBERLAND couNTY, PENNSYLVANIA NO. 200~- CIVIL TERM CIVIL ACTION-LAW IN cUSTODY ORDER OF COURT NOW, thiS ~/-,l~-. day of __j~v~o~_, 2004, upon consideration of the within Agreement of the Par[les, the terms are hereby made an Order of Court. Claire Healey shall have physical and legal custody of Hayden Helm Healey, born ~ol'~[ ~ subject to periods of visitation as the parties can agree and Father shall pay child suppo, r[, as he is able and willing to pay it. By the Cour[, SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA CLAIRE HEALEY, Plaintiff VS, TRAVIS HOCKENBRAUGH Defendant : IN THE COURT OF COMMON PLEAS : CUMBER[J~ND COUNTY, PENNSYLVANIA : : NO. 2004-3690 CIVIL TERM . .. : CIVIL AC'I'ION.LAW : IN CUSTODY COMPLAINT FOR CU~TOI')y 10. 11. 12. The Plaintiff is Claire Healey, residing at 3506 Stockwood Street, Mechanicsburg, Cumberland County, Pennsylvania 17050. The Defendant is Travis Hockenbraugh, residing at 307 N. Enola Drive, Enola, Cumberland County, Pennsylvania. The parties are parents of Hayden Helm Healey, born July 22, 2004. The child is presently in the custody of the mother, Claire Healey, who resides at 3506 Stockwood Street, Mechanicsburg, Pennsylvania and has been in the custody of the mother since birth. The Mother lives with her parents Polly and Richard Healey at 3506 Stockwood Street, Mechanicsburg, Pennsylvania. The father lives with his mother. The child was born out of wedlock. During the past five years, the child has resided with the following persons and at the following addresses: NAMF AD. QELE~ ~ Claire Healey 3506 Stockwood Street 07/22/04-Present Mechanicsburg, PA The mother of the child is Claire Healey, currently residing at 3506 Stockwood Street, Mechanicsburg, Pennsylvania and she is single. The father of the child is Travis Hockenbraugh, currently residing at 307 North Enola Street, Enola, Pennsylvania 17025 and he is single. The relationship of the Plaintiff to the child is that of mother. The Plaintiff currently resides with the following person(s): Polly ~nd Richard Heal~.y, The relationship of the Defendant to the child is that of father. The Defendant currently resides with the following person(s): Defendant's Mother SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Stree! Carlisle, PA 13. Plaintiff has not participated as a par[y or witness, or in any other capacity in other litigation concerning the custody of the child in this or another jurisdiction. 14. The Plaintiff has no information of a custody proceeding concerning the child pending in a court of the Commonwealth. 15. The 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. 16. The best interest and permanent welfare of the child will be served by granting the relief requested because:: a) The Plaintiff can best provide for the physical and emotional needs of child. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, the Plaintiff requests this Court to grant primary physical custody of the child to the Plaintiff. Respectfully submitted, Carol J. Lindsgy,~Esquire ID #44693 ~,.../ 26 West High Street Carlisle, PA 17013 (717) 243-6222 I, Claire Healey, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Claire He-;ly,' Plaintiff / Date:_r~///-7//'/,~_ . _ SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA CERTIFICATE OF SERVICE I, Carol J. Lindsay, Esquire, of the law firm of SAIDIS, SHUFF, FLOWER & LINDSAY, Attorneys hereby certify that on this ~¢~, day of t~/ , 2004, served the within Complaint for Custody this day by ~'t same deposi ing in the United States Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to: Travis Hockenbraugh 307 North Enola Dr., Enola, PA 17025 SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff "~'6~ rpl'/I. (i n d s ~y, ~-~'q u i~e i~/4/4693 _62_2_2_~...e6 est High Street Carhsle, PA 17013 (717) 2!43-6222