HomeMy WebLinkAbout05-4753
HOLLY BIERBOWER,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. C>!; - 4"15..3
(}LL)~tT~
VS.
STEVEN CUPP,
DEFENDANT
CIVIL ACTION - LAW (CUSTODY)
COMPLAINT FOR CUSTODY
1. Holly Bierbower (hereinafter "Mother") is an adult individual with an address
of 3 Bentley Court, Midland, Texas 79701. Prior to her move to Texas she
had been a resident of the Commonwealth of Pennsylvania with a residence in
Cumberland County. Pennsylvania.
2. Steven Cupp (hereinafter "Father") is an adult individual with an address of
354 Dorwart Court, Etters, York County, Pennsylvania 17319. The home
Father resides in at the present time is owned by Mother.
3. The parties are the natural parents of Jaxson Cupp (DOB 8/12/04; Age 1).
4. Mother shall have primary physical custody of Jaxson Cupp. Mother and
Father shall share legal custody of Jaxson Cupp.
5. The parties have entered into a Stipulation which may be entered as an Order
of Court. The original is attached hereto as Exhibit "A".
6. Mother is represented by Steven Howell, Esquire. Father is unrepresented by
counsel but has enjoyed the opportunity to review this Stipulation with
counsel prior to executing the document.
7. The parties waive the right to be present in court at the time this Stipulation is
entered as an Order of Court.
8. The parties agree that this Stipulation is a free and voluntary act in the best
interests of Jaxson Cupp.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter the
proposed Stipulation as a final order in this case.
Respectfully submitted,
BY:
ven we I, Esquire
owell Law Firm
619 Bridge Street
New Cumberland, P A 17070
(717) 770-1277
Supreme Court ID 62063
Date: August 22, 2005
Verification
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A.
Section 490 . g to sworn Isification to authorities.
BY~
HOLL Y BIERBOWER,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. O~- 47.53
VS.
STEVEN CUPP,
DEFENDANT
CIVIL ACTION - LAW (CUSTODY)
STIPULATION OF THE PARTIES
FOR ENTRY OF A CUSTODY ORDER
I. Holly Bierbower (hereinafter "Mother") is an adult individual with an address
of 3 Bentley Court, Midland, Texas 79701. Prior to her move to Texas she
had been a resident of the Commonwealth of Pennsylvania with a residence in
Cumberland County. Pennsylvania.
2. Steven Cupp (hereinafter "Father") is an adult individual with an address of
354 Dorwart Court, Etters, York County, Pennsylvania 17319. The home
Father resides in at the present time is owned by Mother.
3. The parties are the natural parents of Jaxson Cupp (DOB 8112/04; Age I).
4. Mother shall have primary physical custody of Jaxson Cupp. Mother and
Father shall share legal custody of Jaxson Cupp.
5. Father shall have periods of partial custody and visitation rights with Jaxson
as the parties may agree. It is the intention of the parties that Father play an
important role in Jaxson's life and he shall be entitled to reasonable visitation
and partial custody so long as he is able to provide a safe, stable and child
friendly environment for his development.
6. The parties agree that Mother's relocation to Texas with Jaxson is in the
child's best interest and Father agrees to this relocation.
7. The parties agree that Father is in no way giving up his parental rights to
Jaxson by agreeing to this relocation.
8. This Stipulation may be entered as an Order of Court in the Commonwealth of
Pennsylvania or the State of Texas. Personal and subject matter jurisdiction
for any future custody disputes shall rest with Texas once the child has resided
in the state for at least six (6) months.
9. The parties shall keep each other notified of any changes in telephone
numbers or addresses within seven (7) days of the change.
10. The parties shall keep each other notified of any serious medical conditions
involving the child within seven (7) days of the incident.
II. The parties agree that each is entitled to reasonable telephone contact with the
child while the child is in the custody of the other parent.
12. Mother is represented by Steven Howell, Esquire. Father is unrepresented by
counsel but has enjoyed the opportunity to review this Stipulation with
counsel prior to executing the document.
13. The parties waive the right to be present in court at the time this Stipulation is
entered as an Order of Court.
14. The parties agree that this Stipulation is a free and voluntary act in the best
interests of Jaxson Cupp.
BY:
BY s~0q ~
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ~f'/(Iklcl
7ft
On this, the /2 day of AUGUST 2005 before me, the undersigned officer,
personally appeared HOLLY BIERBOWER known to me (or satisfactorily proven)
to be the person whose name is subscribed to the within document and acknowledged
that he/she executed the same for the purposes therein contained. IN WITNESS
WHEREOF, I hereunto set my hand and official seal.
SS
BY:
[~.~ffi~
Notary Public
My Commission Expires
COMMONWEALTH OF PENNSYLVANIA
NotarlaJ Seal
_T. Howell, Notary Public
New CUrnbeIIand Boro, CUrnbeIIand County
My CllI",11stiIoo , ElcpIreeMay 10,2009
Member, Pennsylvania Association of Notaries
COMMONWEALTH OF PENNSYLVANIA
COUNTYOF Cumber-lancL
SS
On this, the II day of AUGUST 2005 before me, the undersigned officer,
personally appeared STEVEN CUPP known to me (or satisfactorily proven) to be
the person whose name is subscribed to the within document and acknowledged that
he/she executed the same for the purposes therein contained. IN WITNESS
WHEREOF, I hereunto set my hand and official seal.
BY ~1~lV,;~
otary Pubh
My Commission xpires I -- -- IllOTARIAL SEAL
I SUIlAN J MILLeR, Notary p,*
Camp HIli Bora, Cumbe~and CounIr
~y Con:mlsolon Expir.. Sept. 19, 2005
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HOLL Y BIERBOWER,
PLAINTIFF
/'y
IN THE COURT OF COMMON ~LEAS
OF CUMBERLAND COUNTy,~ECEIVED SEP 152005
PENNSYLVANIA
NO. 0$ - 4'iS3 (Jl~~l'ttl2-.Y'VI..-
VS.
STEVEN CUPP,
DEFENDANT
CIVIL ACTION - LAW (CUSTODY)
ORDER OF COURT
AND NOW, this z..o~day of
~('~f
,
, 2005 it is hereby Ordered
that the terms of the Stipulation attached hereto as Exhibit "A" are incorporated as the
Order of Court in this case regarding legal and physical custody of Jaxson Cupp (DOB
8/12/04; Age 1).
BY THE COURT:
w~
J.
Certified Copies To:
~ven Howell, Esquire (Attorney for Plaintiff)
619 Bridge Street
New Cumberland, P A 17070
~ven Cupp, Pro Se Defendant
354 Dorwart Court
Etters, PA 17319
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