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HomeMy WebLinkAbout04-3951 YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS CONPLAINT 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 CLAINS SET FORTH AGAINST YOU. 7OU 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 CO~PLAINT OR FOR ANY OTHER CLAIN 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 ~OUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE PA 17013 717 249 3166 CLORISA BLANKENSHIP, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. :No. JEREMY RHOADS, Defendant : CIVIL ACTION - AT LAW IN DIVORCE COMPI_~INT FOR CUSTODY The Plaintiff, Clorisa Blankenship, Pro Se, seeks to obtain custody of her minor child and makes the following avermems in support thereof: 1. Plaintiff is "Mother," an adult individual, who currently resides at 110 North Market Street, Mechanicsburg, Cumberland County, and State of Pennsylvania. 2. Defendant is "Father," an adult individual, who currently resides at 100 West Locust Street, Mechanicsburg, Cumberland County, and State of Pennsylvania. 3. Plaintiff seeks custody of the following minor child: Name: Address: Age: Kendra Rhoads 110 North Market Street 4 years Mechanicsburg, PA 17055 4. The child was bom out of wedlock. 5. The child is presently in the custody of Mother, whose address is 110 North Market Street, Mechanicsburg, Cumberland County, and State of Pennsylvania. 6. During the past five years, the child has resided with the following persons at the following address: Persons: Clorisa Blankenship Suzanne Blankenship Robert Blankenship Melinda Blankenship Address: 110 North Market Street Mechanicsburg, PA 17055 Dates August 2004 - Present Clorisa Blankenship Jeremy Rhoads Alec Rhoads Clorisa Blankenship Suzanne Blankenship Robert Blankenship Melinda Blankenship Jeremy Rhoads Alec Rhoads Clorisa Blankenship Jeremy Rhoads Alec Rhoads Clorisa Blankenship Jeremy Rhoads Alec Rhoads Suzanne Marcus Dennis Marcus Nicholas Marcus Mike Rhoads Clorisa Blankenship Jeremy Rhoads Alee Rhoads Clorisa Blankenship Jeremy Rhoads Alee Rhoads Suzanne Marcus Dennis Marcus Nicholas Marcus M'tke Rhoads 100 West Locust Street Mechanicsburg, PA 17055 110 North Market Street Mechanicsburg, PA 17055 16 B. West Glenwood Drive Enola, PA 17011 240 Stetler Road New Cumberland, PA 17070 Main Street Mechanicsburg, PA 17055 240 Stetler Road New Cumberland, PA 17070 June 2004 - August 2004 November 2003 - June 2004 Februa~ 2003 - November 2003 July 2001 - February 2003 June 2000 - July 2001 February 2000 - June 2000 7. The Mother of the child is Clorisa Blankenship, who currently resides at 110 North Market Street, Mechanicsburg, Cumberland County, and State of Pennsylvania. She is not Married. 8. The Father of the child is Jeremy Rhoads, who currently resides at 100 West Locust Street, Mechanicsburg, Cumberland County, and State of Pennsylvania. He is not Married. 9. The relationship of Plaintiffto the child is that of Mother. Plaintiff currently resides with the following people: Names: Relationship: Kendra Rhoads Suzanne Blankenship Robert Blankenship Melinda Blankenship Daughter Mother Father Sister 10. resides with the following people: Names: Relationship: Alee Rhoads Son The relationship of Defendant to the child is that of Father. Defendant curremly 11. Plaimiff 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. 12. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 13. Plaimiff 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. 14. The best interests and permanent welfare of the child will be served by granting the relief requested because Plaintiff is in a better position to take care of the child as both mother and Primary Caregiver for the child's entire life. 15. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order granting her custody of the child. Respectfully submitted, CLORISA BLANKENSHIP, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. JEREMY RHOADS, Defendant : CIVIL ACTION- AT LAW IN DIVORCE VERIFICATION I, Clorisa Blankenship, verify that the statements made in this Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom falsification to authorities. Clorisa Blankenship ~/ CLORISA BLANKENSHIP, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. JEREMY RI-lOADS, Defendant : CIVIL ACTION- AT LAW IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Complaint for Custody upon the person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by hand delivering a copy of the same to the person, and at the address, as follows: Jeremy Rhoads 100 West Locust SWeet Mechanicsburg, PA 17055 Respectfully submitted, CLORISA BL?dNKENSHIP, Plaintiff VS. JEREMY RI-lOADS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA d:> : : CIVIL ACTION - AT LAW IN DIVORCE ~'1'1 p[N,ATION WHEREAS, the parties, Clorisa Blankenship, the "Mother" hereinat~er, and Jeremy Rhoads, the "Father" hereinat~er, are adult individuals and residents of the Commonwealth of Pennsylvania, and intend to be legally bound by the within terms; and WHEREAS, the parties have bom to them one child, namely Kendra Rhoads, bom February 02, 2000, the "Child" hereinafteg, and WHEREAS, the parties wish to enter into an agreement relative to custody, partial custody, and visitation of the child; and WHEREAS, the child has resided in Cumberland County, Pennsylvania for the past six months, thus giving this Court jurisdiction; THEREFORE, this Il day of I~ 200c]. in consideration of the mutual covenants, promises, and agreements as hereinatter set forth, and intending to be legally bound, the parties agree as follows: 1. The Mother, Clofisa Blankenship, and the Father, Jeremy Rhoads, shall have shared legal custody of the Child, Kendra Rhoads. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well being including but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of this paragraph, each parent shall be entitled to all records and information pertaining to the Child, including, but not limited to, school and medical records and information. 2. The Mother shall have primary physical custody of the Child. 3. The Father shall have partial physical custody of the Child on alternating weekends, beginning August 20, 2004, from Friday at 5:00 p.m. until Sunday at 5:00 p,n~ The parties shall mutually agree upon transportation of the Child, The parties have agreed to a holiday schedule, and shall have custody of the Child, as follows: a. 1'2hriatman: Unless otherwise agreed, custody of the Child on Christmas shall be divided into two separate custodial periods: Period "A" begins at 5:00 p.m. on Chri~h~tas eve until 2:00 p.m. on Christmas day; Period "B" begins at 2:00 p.m. on Christmas day until 8:00 p.m. on Christmas day. These two periods of custody shall alternate between Mother and Father, yearly, begiuning with Mother having custodial Period "A" on Christmas eve, 2004. b. lMother'q Day/Fathw'a Day: Each year, Mothers Day shall be spent with Mother, and Father's Day shall be spent with Father. c. Alt~.matlng lq~liclay~: Unless otherwise agreed, the parties shall alternate having custody of the Child on Labor Day, New Years Day, Thanksgiving, Easter, July 4a', and Memorial Day, each year, as arranged by agreement. 5. Father shall have custody for one full, uninterrupted weeksthrough the summer vacation. Notice of when Father intends to exercise his summer custody schedule shall be provided to Mother no later than thirty (30)days ahead ofthe scheduled vacation.( 0~0/¢_ c~uff~ rga Oc~,/~ct + ~3~edo~/~ 'i 6. Holiday schedules shall supersede the regular custodial scti~u/e. Vacattons sOh~l supersede the regular custodial schedule and holiday schedules upon notice as provided above. 7. Each parent shall be entitled to reasonable telephone comact with the Child during the other parent's custodial periods. 8. Each parent shall refrain from making derogatory, or disparaging remarks around the Child during his/her custodial period. 9. Mother and Father must supervise the child at all times during their custodial period. 10. During each part3~s custodial periods, they shall consume no alcohol to the point of intoxication, or drugs, except prescription drugs properly taken pursuant to a medical prescription. 11. This stipulation may only be altered by the mutual consent of Mothar and Father. 12. If Mother's or Father's address or telephone number should change, each must notify the other of the change before a regularly scheduled, holiday, or vacation custodial period. Failure to notify will be grounds for forfeiting the next scheduled custodial visit. 13. This Stipulation shall supersede any prior order of court with specific respect to the custody, partial custody, and/or visitation of the Child. 14. It is the intention and desire of each of the undersigned parties that this Stipulation be confirmed as an order of court, without requiring their presence before the court, pursuant to Rule 1915.7. WITNESS Clorisa Blankenship / ' WITNESS CLOKISA BLANKENSHIP, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. :No. oq- %q'51 JEREMY RI-lOADS, : CIVIL ACTION - AT LAW IN DIVORCE Defendant : ~ ~ow, t~i~ ~y o~ ~ ~ ~00~ , ~o~ ~o~i~o. o~ ~ Sti~a~on of ~e p~es ~ ~e abov~ca~oned ~R~, co~i~g of ~ p~es ~d b~g thc ~a~ ~nt of~e p~es, ~ upon ~on of t~s corn ~t ~e p~es n~ not be prat before ~e ~m ~ order m ~co~orate ~ Sfip~ation ~to a ~nt ord., ~ IS O~D ~t ~d SfipOafion is ~orat~ h~ffm by ~ as · ~ foah ~ ~ ~d approv~ as a Count ~dg pur~t to P~ylv~a R~e of Ci~ ~o~e, ~e 1915.7. B,Y THE COURT: