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Home My WebLink About05-2081 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SERENA M. CABAN Plaintiff CIVIL ACTION--LAW CUSTODY NO. - 05 - c2o'l/ ~ vs. ANTHONY E. MEADOWS, Defendant COMPLAINT FOR CUSTODY AND NOW, comes Plaintiff, SERENA M. CABAN, by and throu h her attorney, Fiona K. Line, and files the following Complain for Custody, and in support thereof avers as follows: 1. Plaintiff is Serena M. Caban, an adult individual, who currently resides at 207 Plaza Drive, Boiling Springs, Cumber and County, Pennsylvania 17007 since October 27, 2004. 2. Defendant is Anthony E. Meadows, an adult individual, wh currently resides at 12718 Center Parkway, Upper Marlboro, Pr nce Georges County, Maryland since July 2000 . 3. Plaintiff seeks custody of the following child: Kevin Winfield Caban. 4. The relationship of Plaintiff to the child is that of Mother. 5. The relationship of Defendant to the child, is that of Father. 6. The child, Kevin Winfield Caban, was born out of wedlock on February 12, 2004. 7. The child resides at 207 Plaza Drive, Boiling Springs, Cumberland County, Pennsylvania 17007 and is presently in the custody of Plaintiff, Serena M. Caban, and has been since bir h. ~ 8. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody f the child in this or another court. Plaintiff has no informa ion of a custody proceeding concerning the child pending in a cou t of this Commonwealth or any other state. Plaintiff does not now 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. 9. The best interest and permanent welfare of the child wil be served by granting the relief requested. 10. Each parent whose parental rights to the child have not een terminated and the person who has physical custody of the chi d have been named as parties to this action. Dated: Lj-.;l.O- oS ~ /4.L- FIONA KIMBERLY LINE Attorney ID 65283 Attorney for Plaint if 184 Virginia Ave. Carlisle, PA 17013 (717) 991-1382 . . . .... . . 04 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SERENA M. CABAN Plaintiff CIVIL ACTION--LAW CUSTODY/VISITATION vs. NO. ANTHONY E. MEADOWS, Defendant VERIFICATION I verify that the statements made in the foregoing Compl int For Custody are true and correct to the best of my knowledge, information and belief. This Verification is made only as to the factual averments contained herein, and not to legal conclusi ns and averments authorized by counsel in her capacity as attorn y for the party or parties hereto. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. (> ~.> "I c:~) (~ C. .'.::;:) Of' .)'0 4= ---- :!'""'" -..... " ft: ?J 1') C3 v, .., c;:;- \.1-) ~ ~" u-:- C> ~ ~) r:--:) ~") LJ ~ ~ c)..) ~ . .~ o -n .-< .~ -.'--n (n?-,,~ iT ~:J (') .-0 .-<. CHILD CUSTODY AGREEMENT O'~ n ~l .. ) <>(;')5 THIS AGREEMENT, made this .l...3---.- day of February 2005, by and between Serena Marie Caban of Carlisle, Cumberland County, Pennsylvania, a party of the first part, hereinafter referred to as "Mother" and Anthony Eugene Meadows of Upper Marlboro, Prince George's County, Maryland, party of the second part, hereinafter referred to as "Father". WITNESSETH: WHEREAS, Mother and Father are not married, nor were they ever married, bu had a relationship and had a son, Kevin Winfield Caban, born February 12,2004; and WHEREAS, Mother and Father have been living separate and apart from each other since the birth of their son; and WHEREAS, Mother and Father desire to come to an agreement with regard to e custody of their said son, Kevin Winfield Caban; and WHEREAS, it is the intention and purpose of this Agreement to set forth the respective custody arrangements; NOW, THEREFORE, the parties hereto in consideration of the mutually made and to be kept promises set forth herein agree as follows: Mother will have primary physical custody oftheir son, Kevin Winfield Caban, hereinafter referred to as "Son" and Father will have visitation rights with their Son as et forth herein. Mother and Father will have joint legal custody of their Son. Visitation ill be as follows: Father's visitation will be a maximum of one-weekend a month, except as provided herein, provided that Father requests visitation 3 weeks in advance. Upon Father's 3 week advance notice and request to see their Son over a weekend, and Mother's consent, which will not be withheld unreasonably; Father will have custody 0 Son beginning at 5:00 pm on Friday until 5:00 pm on the following Sunday. Transportation is to be provided by Father at all times for visitation of their Son. Moth r and Father agree that their Son will not be taken out of the state of Maryland during visitation with his Father unless Mother gives consent. If the occasion arises where Father would like to take Son out of the state of Maryland, and consent is given by Mother, Father must provide details with regard to the location that their Son will be residing at during the time outside of Maryland. Details to be provided are address of out-of-state location, phone number(s) where Son can be reached, emergency contacts and reason for travel. Mother and Father agree that their son will continue in daycare at Child Care Network. Mother and Father agree that their Son is allowed to be withdrawn from daycare without disciplinary action from Child Care Network for a total of 10 vacation days a year. Mother and Father agree that the 10 vacation days will be split between them evenly,S days in which Father may take Son out of daycare for vacation and 5 da in which Mother may take Son out of daycare for vacation. Father will give Mother 3 weeks advance notice for said vacation days. Mother and Father agree that if during the 5 days in which Father takes Son out f daycare, the vacation extends beyond the 5 days out of daycare, Father will pay for the daycare each day past the allowed five. Mother and Father agree to the following visitation for the Holidays: Christmas - Father will have visitation with Son from noon Christmas Day unti noon the day after Christmas every year. Thanksgiving - Father will have visitation with Son from 6pm the Wednesday before Thanksgiving until noon the Friday after Thanksgiving every odd year (i.e. 2005 . Mother and Father agree that Father's visitation on Son's birthday will be discussed on an annual basis and mutually agreed upon with the day of Son's birthday being the driving factor, (i.e. week day vs. weekend). This agreement is intended to outline the general custody agreement between Mother and Father and can be amended upon mutual agreement of both parties. IN WITNESS WHEREOF, the said parties of this Agreement have hereunto set their hands and seals, intending to be bound legally hereby, the day and year first above written. M/ )yJt ~/P/4/ Witness 3i ffl1ft rrJ Serena Marie Caban / / / )l' . . 4'1[ ~?// I:i'A";-;r&/<f tness c: ~..j'?JL 7,. :0 'hOny E ' ~e~e Meadows. 0 .....' 0 co c; = 11 -eJ'1. ",. ""ct :;V f'-' \"'..) ,-'" CG . . II RtCEIVED APR 222005..1; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SERENA M. CABAN, Plaintiff CIVIL ACTION--LA W CUSTODY NISIT A TION vs. NO. 0:;' "!JoYI 0'~; I ANTHONY E. MEADOWS, Defendant ORDER OF COURT AND NOW, this ~ day of ~ r \ ; l, 2005, upon consideration of the attached Custody Complaint and Custody Agreement between the parties, it is hereby ordered and directed as follows: I. The Mother, Serena M Caban and the Father Anthony E. Meadows shall have shared legal custody of Kevin Winfield Caban, born February 12, 2004. 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 his 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. Each party shall notifY the other of all medical care or treatment which the Child receives while in that party's custody. Each party shall notifY the other promptly of any emergencies concerning the Child which arise during that party's period of custody. 2. Mother shall have primary physical custody oftheir son, Kevin Winfield Caban, hereinafter referred to as "Son" and Father will have partial physical custody in accordance with the following schedule: }JJ<(/''','''l -. -'~':>:,-\:l() 011 :Z fJd 9Z i:!"Pt SnilZ ,,,,.,",,...,. I,'." I "'Hi '0 1\L"i'i(':"'\.)I\\JJ-L~U(J(I':; :I 30lj~-10-o3l1:1 ~ A. Father shall have custody of the Child for a maximum of one-weekend a month. Father shall request visitation 3 weeks in advance of the weekend of Father's custody of the Son. Upon Father's 3 week advance notice and request to see the Son over a weekend, and Mother's consent, which will not be withheld unreasonably; Father will have custody of Son beginning at 5:00 pm on Friday until 5:00 pm on the following Sunday. B. Father shall not take Son outside the state of Maryland dnring his physical custody of son, unless Mother gives consent. If the occasion arises where Father would like to take Son out of the state of Maryland, and consent is given by Mother, Father must provide details with regard to the location that their Son will be residing at dnring the time outside of Maryland. Details to be provided are address of out- of-state location, phone number(s) where Son can be reached, emergency contacts and reason for travel. C. Father shall have physical custody of Son for five vacation days a year, at which time the Son will be withdrawn from daycare without disciplinary action from Child Care Network. Father will give Mother 3 weeks advance notice for said vacation days. D. The parties shall share custody of Son during the holidays as follows: Christmas - Father shall have custody of Son from noon Christmas Day until noon the day after Christmas every year. Thanksgiving - Father shall have custody of Son from 6pm the Wednesday before Thanksgiving until noon the Friday after Thanksgiving every odd year (i.e. 2005). Mother shall have custody of Son from 6 pm the Wednesday before Thanksgiving until noon the Friday after Thanksgiving every even year. 3. Unless otherwise agreed between the parties or provided in this Order, Father is responsible to provide transportation for the exchange. 4. This Order is entered pursuant to an agreement of the parties. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, ,7 / JUDGE