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Home My WebLink About04-5631PENNY J. GEEDY, Plaintiff Vo THOMAS BAUGHMAN, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, :PENNSYLVANIA : : CIVIL ACTION - LAW :CUSTODY : NO. g'Pg/.. ~"g~_3 / CIVIL TERM NOTICE TO DEFEND Legal proceedings .have been brought against you concerning custody. If you wish to defend against the claim set forth in the following pages, you may but are not required to file in writing with the court your defenses or objections. If the court finds that you have willfully failed to comply with its order for custody, you may be found to be in contempt of court and committed to jail, fined or both. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE LAWYER, GO TO OR TELE PHONE 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 St. Carlisle, PA 17013 (717)- 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible 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 hearing. PENNY J. GEEDY, Plaintiff Vo THOMAS BAUGHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY NO. 04- 3'65 / CIVIL TERM COMPLAINT FOR CUSTODY 1. The Plaintiff is Penny J. Geedy, residing at 4420 Gettysburg Road, Apt. 2, Camp Hill, Cumberland County, PA, 17011. 2. The Defendant is Thomas Baughman, residing at 503 Pisgah Road, Shermans Dale, Perry County, PA, 17090. 3. Plaintiff seeks custody of the following child: Name Present Residence Lacy May Jean Grumbianin 4420 Gettysburg Road Apt. 2 Camp Hill, PA 17011 The child was bom out of wedlock The child is presently in the custody of Penny J. Geedy, who resides at 4420 Gettysburg Road, Apt. 2, Camp Hill, Pennsylvania. During the past five years, the child has resided with the following persons and at the following addresses: Individuals Penny J. Geedy Nancy Jean Goodling Address 4420 Gettysburg Road Apt. 2 Camp Hill, PA 17011 Age 4 (DOB 4/29/00) The mother of the child is Penny J. Geedy, currently residing at 4420 Date 4/29/00-present Gettysburg Road, Apt. 2, Camp Hill, PA, 17011. She is a widow. The father of the child is Thomas Baughman, currently residing at 503 Pisgah Road, Shermans Dale, PA, 17030. He is single. 4. The relationship of Plaintiff to the child is that of mother. The Plaintiff currently resides with the following persons: Name Nancy Jean Goodling Relationship Plaintiff's Mother 5. The relationship of Defendant to the child is that of father. The Defendant currently resides with the following persons: Name Tammy Baughman Relationship Defendant' s Sister 6. 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. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: a. Plaintiff is best able to provide the care and nurturing which the child needs for healthy development; b. Plaintiff provides the child with a home with adequate moral, emotional and physical surroundings as required to meet the child's needs; c. Plaintiff is willing to accept custody of the child; d. Plaintiff exercises parental duties and enjoys the love and affection of the child; e. Plaintiff will encourage child to develop and maintain relationship with child's father. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff requests the court to grant her sole legal custody and primary physical custody of the child, granting father periods of partial custody. CHARLENE Y. AQBIILINA Certified Legal Intern ROBERT~E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX Supervising Staff Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 Counsel for Plaintiff VERIFICATION I verify that the statements made in this Complaint 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. Penny J. Geedy . ~ PENNY J. GEEDY, Plaintiff THOMAS BAUGHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN CUSTODY NO. dv~'.-,_q'&31 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Penny J. Geedy, Plaintiff, to proceed in forma pauperis. I, Charlene J. Aquilina, of the Family Law Clinic, Certified Legal Intem, for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal service to the party. Date: Certified Legal Intern THOMAS M. PLACE ROBERT E. RAINS ANNE MACDONALD-FOX Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Attorneys for Plaintiff PENNY J. GEEDY, Plaintiff Vo THOMAS BAUGHMAN, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 1N CUSTODY NO. 04- CIVIL TERM CUSTODY AGREEMENT THE FOLLOWING AGREEMENT, made this <~4~x day of November, 2004, between Plaintiff, Penny J. Geedy (Mother), and Defendant, Thomas Baughman (Father), concerns the custody of their child, Lacy May Jean Grumbianin (Child), bom April 29, 2000. Mother and Father agree to the following: 1. Mother shall have sole legal custody of the Child. 2. Mother shall have primary physical custody of the Child. 3. Father shall have periods of partial physical custody of the Child as determined by the mutual agreement of the parties. 4. In the event of an emergency, both parties shall allow reasonable telephone communication with the child during the other parent's custodial visits. Such phone calls shall not be excessive and shall only be out of necessity. 5. Mother shall keep Father informed of the Child's dietary and medical needs. 6. 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 parent, or which may hamper the free and natural development of the child's love and respect for the other parent. 7. Mother and Father desire to make this agreement a Court Order. 8. The Father understands that the Family Law Clinic represems only the Mother's interest in this matter and he may seek the advice of legal counsel if he so desires. Thomas Baughma~ Date Date Certified Legal Imem ~~~JO~STON-WALS ROBERT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX Supervising Staff Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 Counsel for Plaintiff NOV ~ 0 ZO0~/ PENNY J. GEEDY, Plaintiff THOMAS BAUGHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY NO. 04- 5b.~! CIVIL TERM ORDER AND NOW, this 12~/~day of November, 2004, the attached Custody Agreement is approved and entered as an Order of Court. BY THE COURT, .0