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v.
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUN1Y, PENNSYLVANIA
CML ACTION LAW
~ NO. Dj }..JS(
: IN CUSTODY
CIVIL TERM
Stephanie Jill Brinser,
Plaintiff
Michael Eugene Sheaffer,
Defendant
COMPLAINT FOR CUSTODY
I. The plaintiff is Stephanie Jill Brinser, an adult individual that resides at 621 High Street,
Enola, P A 17025.
2. The defendant is Michael Eugene Sheaffer, an adult individual that resides at 312 Valle
Street, Marysville, P A 17053
3. Both the Plaintiff and the Defendant are the natural parents of the child Jacob Wesley
Sheaffer, born December 24, 2003.
Per the Stipulation and Agreement signed by both parties:
4. Plaintiff seeks full custody of the following child:
Name Present Residence
Jacob Wesley Sheaffer 621 High Street, Enola, PA
Alle
16 months
a. The child was born out of wedlock.
b. The child is presently in the custody of Stephanie Jill Brinser who resides at 62
High Street, Enola, P A 17025.
c. During the past 16 months, Jacob has resided at the following address:
621 High Street
Enola, PA 17025
d. During the past 16 months Jacob has lived with the following people:
Stephanie Jill Brinser Mother
Renee Simpson Grandmother
David Simpson Grandfather
5. The Plaintiff has no information of a custody proceeding concerning the child pending . n
any Court of this Commonwealth.
6. The best interest and permanent welfare of the child will be best served by granting th
relief, requested by both the Plaintiff and the Defendant, as the Plaintiff is better suite to
provide a stable environment to foster the child's well being.
Respectfully submitted,
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Stephanie Jill Brinser
621 High Street
West Fairview, PA 17025
(717) 732-2280
I
Verificaiton
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.
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Step anie Jill Brinser
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V.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CML ACTION LAW
Stephanie Jill Brinser,
Plaintiff
Michael Eugene Sheaffer,
Defendant
NO. rJ5 .J'). rgg
IN CUSTODY
CML TERM
CUSTODY STIPULATION & AGREEMENT BE1WEEN
STEPHANIE JILL BRINSER AND MICHAEL EUGENE SHEAFFER
3,d
This Stipulation and Custody Agreement, made this day of
2005, by and between Stephanie Jill Brinser and Michael Eugene Sheaffer.
The parties are the natural parents of one child, namely Jacob Wesley Sheaffer, b m
December 24, 200,3 (hereinafter referred to as "Child"); and
51!>
The partie~ve separate and apart, and wish to enter into a comprehensive stipula . on
and agreement relative to custody of their child.
The welfare and best interest of the child is the primary consideration of the partie m
making this agreement.
In consideration of mutual covenants, promises and agreements as hereinafter set t: rth,
the parties stipulate and agree as follows:
1. Mother shall have full custody of the child.
2. Father shall have periods of visitation at times which the parties mutually agree.
Any modification or waiver of any of the provisions of this Agreement on a p ent
basis shall be effective only if made in writing, and only if executed with the same fo lity
as this Stipulation and Agreement.
The party's desire that this Stipulation and Agreement be made an Order of Court 0 the
Court of Common Pleas of Cumberland County does, in fact, have jurisdiction over the . sue
of custody of the parties' minor child.
The parties stipulate that in making this Agreement, there has been no aud,
concealment, overreaching, coercion, or other unfair dealing on the part of the other p
The parties acknowledge that they have read and understand the provisions 0 this
Agreement. Each party acknowledges that the Agreement is fair and that it is not the res It of
any duress or undue influence.
The parties agree that this Agreement may be adopted as an Order of Court witho t the
necessity of a hearing.
-
This Agreement and all of its terms and conditions shall extend to be binding on th
parties. This agreement shall be governed and controlled by the laws of Pennsylvania.
The parties hereto intending to be legally bound by the terms hereof, set forth their ban
and seals the day and year hereinafter mentioned.
S:-2-oS
Date
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Witness:
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Stepha:nie Jill Brinser, Mother
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Witness
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Stephanie Jill Brinser,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
:: No. OS - J..J..t:t 1
Civil Term
Michael Eugene Sheaffer,
Defendant
: CUSTODY
: CIVIL ACTION LAW
ORDER OF COURT
AND NOW, 'I ~ day of /?? ~ ' 2005, up n
consideration ofthe attached Custody Agreement it is order and directed as follows:
1. The mother, Stephanie Jill Brinser, shall have primary physical and legal cust y
ofJacob Wesley Sheaffer, born December 24,2003.
2. The Father, Michael Eugene Sheaffer, may have periods of visitation es
which the parties mutually agree upon.
BY THE COURT,
J.
cc~ephanie Jill Brinser
/Michael Eugene Sheaffer \I
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