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Home My WebLink About04-5025SHANE GEEDY Plaintiff CHRISTY A. GEEDY Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004- ,.N"O,,~.~ CIVIL TERM CIVIL ACTION - LAW IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Shane Geedy, an adult individual, currently residing at 108% 3r~ Street, Boiling Springs, Pennsylvania 17007. 2. Defendant is Christy A. Geedy, an adult individual, currently residing at 509 3rd Street, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff seeks custody of the following children: Ashlyn E. Geedy, age 12, born April 22, 1992, and Leah M. Geedy, age 9, born May 31, 1995. The children were not born out of wedlock. The children are presently in the custody of Plaintiff, who resides at 108% 3~ Street, Boiling Springs, Cumberland County, Pennsylvania. During the past five years, or since the children's birth, they have resided with the following persons at the following addresses: (a) from 1998 to April 3, 2004 with Shane Geedy and Christy A. Geedy at 1876 Spring Road, Carlisle, Pennsylvania. (b) from April 3, 2004 to May 15, 2004 with Shane Geedy at 1876 Spring Road, Carlisle, Pennsylvania. (c) from to May 15, 2004 to Present with Shane Geedy at 108% 3r~ Street, Boiling Springs, Pennsylvania. The natural mother of the children is Christy A. Geedy, currently residing 509 3r~ Street, Carlisle, Pennsylvania. She is not married. The natural father of the children is Shane Geedy, currently residing at 108~ 3r~ Street, Boiling Springs, Pennsylvania. He is not married. 4. The relationship of the Plaintiff to the children is that of natural father. The plaintiff currently resides with the following persons: (a) Ashlyn E. Geedy (b) Leah M. Geedy 5. The relationship of the Defendant to the children is that of natural mother. 6. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning the custody of the children in this or in any other Court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: (a) Father is best able to care for the children at this point in time. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action and the right to intervene. NAME ADDRESS BASIS OF CLAIM None. VERIFICATION I verify that the statements made in the foregoing Complaint for primary physical 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 unsworn falsification to authorities. DATE: September ~"~, 2004 Shane Geedy WHEREFORE, Plaintiff requests your Honorable Court to grant primary physical custody of the children. Respectfully submitted, O'BRIEN, BARIC & SCHERER Michael A. Scherer, Esquire I.D. 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 mas.dirldomesticlgeedylcustody.comp SHANE GEEDY PLAINTIFF V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-5025 CIVIL ACTION LAW CHRISTY A. GEEDY : IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, October 14, 2004 , upon considezation of the attached Complaint, it is hereby directed that parties and their respective counsel appear beibre Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, October 29, 2004 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an eftbrt will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children are five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearin!~. FORTHECOURT. By: /s/ Hubert X. Gilroy, Esq. Custody Conciliator mhc The Court of Conunon Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information abont accessihle facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or heating. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FOR'IH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 SHANE GEEDY Plaintiff CHRISTY A. GEEDY Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-5025 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY STIPULATION AND AGREEMENT THIS AGREEMENT AND STIPULATION entered into the day and year hereinafter set forth, by and between Shane Geedy (hereinafter referred to as "father") and Christy A. Geedy (hereinafter referred to as "mother"). WHEREAS, Shane Geedy is the natural father of the children; and WHEREAS, Christy A. Geedy is the natural mother of the children, Ashlyn E. Geedy, born April 22, 1992, and Leah M. Geedy, born May 31, 1995 (hereinafter referred to as "children"); and, WHEREAS, the natural parents are divorced and living in separate residences; and, WHEREAS, the parties believe it to be in the best interest of the children that Father be primary custodian in the children's life; and, WHEREAS, the parties wish to enter into an 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: NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth, the parties agree as follows: 1. The parties shall exercise physical custody of the children as follows: a. Father shall have primary physical custody of the children from the date of this Order. b. Mother shall have partial physical custody of the children on Tuesday evenings and alternating weekends, at such times as they may agree upon. 2. The parties are free to deviate from this Order at any time provided both parities agree on the deviation. 3. The parties will keep each other advised immediately relative to any emergencies concerning the children and shall further take any necessary steps to insure that the health and well being of the children is protected. 4. The parties shall not do anything which may estrange the children from the other parties, or injure the opinion of the children as to the other parties or which may hamper the free and natural development of the children's love or affection for the other parties. 5. The parties desire that this Stipulation and Agreement be made an Order of Court to the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberla~nd County does, in fact, have jurisdiction over the issue of custody and the minor children and shall retain jurisdiction should circumstances change and any party desires or requires modification of said Order. 6. The parties acknowledge that they have read and understand the )rovisions of this Agreement. IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms hereof set their hands and seal the day and year written below. WITNESS: Date: ShaneGeedy / Date: Ch{'is~,. G~edy u mas.dirldomesticlgeedylcustody.stp OCT 2 2 200,4 SHANE GEEDY Plaintiff Vo CHRISTY A. GEEDY Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-5025 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this ~' day of o~.~ ,2004, the Court adopts the following Stipulation and Agreement as an Order of Court, with respect to the following children: Ashlyn E. Geedy, born April 22, 1992, and Leah M. Geedy, born May 31, 1995 (hereinafter referred to as "children"). 1. Shane Geedy (hereinafter "father") and Chris~ A. Geedy (hereinafter "mother") shall have joint legal custody of the children. 2. The parties shall exercise physical custody of the children according to the following schedule: a. Father shall have primary physical custody of the children from the date of this Order. b. Mother shall have partial physical custody of the children on Tuesday evenings and alternating weekends, at such times as they may agree upon. 3. The parties are free to deviate from this Order at any time provided both parties agree on the deviation. 4. The parties will keep each other advised immediately relative to any emergencies concerning the children and shall further take any necessary steps to insure that the health and well being of the children is protected. WNV,¥~kSN~ 5. The parties shall not do anything which may estrange the children from the other parties, or injure the opinion of the children as to the other parties or which may hamper the free and natural development of the children's love or affection for the other parties. BY THE COURT, /0-2q -0 SHANE GEEDY, : Plaintiff : V : CHRISTY A. GEEDY, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04 - 5025 IN CUSTODY COURT ORDER AND NOW, this I ~ day of November, 2004, the Conciliator having been advised that the parties have reached an agreement, the Conciliator relinquishes jurisdiction. BY THE COURT, Custody Con~l~tor · ~. ~d 2- AON ~OOZ Ab¥.LONG-~O~ ?FU. ::I0