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HomeMy WebLinkAbout04-4103NATASHA STRINE, Plaintiff COREY A. STRINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004- ~//o ~ CIVIL TERM CIVIL ACTION-LAW IN CUSTODY NOTICE 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 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 OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 NATASHA M. STRINE, Plaintiff COREY A STRINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 200~t-~' q/~.~ CIVIL TERM CIVIL ACTION-LAW IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, Natasha M. Strine, by her attorney, David A. Baric, Esquire and files this Complaint and Agreement For Custody representing as follows: 1. Petitioner/Plaintiff, Natasha M. Strine (hereinafter referred to as "Mother"), is an adult individual residing at 1158 Centerville, Newville, Cumberland County, Pennsylvania. 2. Respondent/Defendant, Corey A. Strine (hereinafter referred to as "Father"), is an adult individual residing at 3576 Ritner Highway, Newville, Cumberland County, Pennsylvania. 3. Petitioner/Plaintiff and Respondent/Defendant are the natural parents of a minor child, Hennessy Jordan Strine, born November 6, 2003. 4. Petitioner and Respondent have not participated as a party, witness, or in any other capacity in other litigation concerning the child in this or another court. 5. Petitioner and Respondent have no information regarding any other custody proceeding concerning the child pending in a court of this Commonwealth. 6. Petitioner and Respondent do not know of a person not a party to the proceeding who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. Petitioner and Respondent believe and therefore aver that the best interest and permanent welfare of the child require that the parties have shared legal and that the Petitioner have periods of physical custody of the child in accordance with their mutual agreement. 8. Both parties, as evidenced by theirjoint execution of this Complaint, have mutually agreed upon an amicable arrangement for legal and physical custody of the child and request that the Court enter an Order as provided below without the necessity of a hearing: A. The parties will have joint legal custody of the child. B. Mother shall have primary physical custody of the child. Father shall have physical custody of the child on Wednesday evenings from 5 p.m. to 8 p.m. and every other weekend from 5 p.m. Friday evening until 1 p.m. Sunday afternoon. The parties shall share the following Holidays Thanksgiving, Christmas and Easter. In the event that Father has physical custody on a Saturday Holiday, Mother shall have visitation commencing at 10 a.m. until 3 p.m., when Father shall resume normal visitation after 3 p.m. In the event that Father has physical custody on a Sunday Holiday, Father shall have visitation continuing to 1 p.m., when mother shall resume normal visitation. In the event that Mother has physical custody on the Holiday Father will have visitation commencing at 2 p.m. until 6 p.m. when mother shall resume normal custody. The Holiday schedule would supemede the other provisions regarding custody. The parties shall share time on the child' birthday as follows: If father has physical custody of the child on his birthday, mother shall be entitled to have the child on her birthday from 5:00p.m. until 8:00 p.m. If mother has physical custody of the child on her birthday, father shall be entitled to have the child on her birthday from 5:00 p.m. until 8:00 p.m. The father shall have the child every Father's day from 9 am until 4:30 p.m. regardless of any other provision herein, and mother shall have the child every Mother's Day regardless of any other provision herein. 9. The parties will keep each other advised immediately in the event of serious illness or emergency concerning the child and shall further take any necessary steps to insure that the health and well being of the child is protected. During such illness or medical emergency, both parties shall have the right to visit the child as often as he or she desires consistent with the proper medical care of the child. 10. Neither parent shall do anything which may estrange the child from the other party, or injure the opinion of the child as to the other party, or which may hamper the free and natural development of the child's love and affection for the other party. 11. Any modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and only if executed with the same formality as this Agreement. 12. The parties desire that their Agreement be made an Order of Court through the Court of Common Pleas of Cumberland County, Pennsylvania without the necessity of a hearing or other proceeding thereon and further acknowledge that the Court of Common Pleas of Cumberland County has jurisdiction over these issues and shall retain such jurisdiction for purposes of enforcement or should circumstances change and either party request modification of this Order in the future. WHEREFORE, Your Petitioner and Respondent respectfully request your Honorable Court to enter and Order, in the form attached hereto, providing for the legal and physical custody of the child as aforesaid. Respectfully submitted, David A. Baric, Esquire I.D. 44853 17 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 dab.dir/domesticInstrine/custodycomplaint.pld NATASHA M. STRINE, Plaintiff COREY A. STRINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004 CIVIL TERM CIVIL ACTION-LAW IN CUSTODY VERIFICATION AND CONFIRMATION OF AGREEMENT We do hereby verify that the facts set forth in this Complaint are true and correct. We understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unswom falsifications to authorities. Further, by the execution of this Confirmation, we do each unequivocally express our mutual and voluntary agreement to the amicable custody arrangement provided above and request that the terms herein be entered as an Order of Court ~hout the necessity of a cz~conciliation, Date: hearing, or other proceeding. Natasha M.Strine Date: NATASHA M. STRINE COREY A. STRINE Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW · NO. 2004- CIVIL · IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that on this the ~ day of August, 2004, I, Robert L. O'Brien, Esquire of O'Brien, Baric & scherer, did serve a copy of the Complaint for Custody document, by first class U.S. mail, postage prepaid, to the party listed below, as follows: John H. Broujos 4 North Hanover Street Carlisle, Pennsylvania 17013 Robert L. O'Brien, Esquire NATASHA M. STRINE Plaintiff VS. COREY A. STRINE Defendant · iN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2004 CIVIL : IN CUSTODY ORDER OF COURT AND NOW, this ~ day of August, 2004, upon review of the attached Complaint for Custody, the custody provisions set forth therein are hereby made an Order of the Court and all prior orders on this matter are hereby vacated. NATASHA M. STRINE Plaintiff COREY A. STRINE Defendant · IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW · NO. 2004- dr C,V,L : IN CUSTODY CERTIFICATE OF SERVICE. I hereby certify that on this the I1 day of August, 2004, I, Robert L. O'Brien, Esquire of O'Brien, Baric & Scherer, did serve a copy of the Complaint for Custody document, by first class U.S. mail, postage prepaid, to the party listed below, as follows: John H. Broujos 4 North Hanover Street Carlisle, Pennsylvania 1701 ~ Rot)eR L. O'Brien, Esquire