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HomeMy WebLinkAbout05-4762 v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005- ,/'TC,.:u CIVIL TERM CIVIL ACTION-LAW IN CUSTODY TODD A. SOULLlARD, Plaintiff CYNTHIA L. THIBODEAU, Defendant COMPLAINT FOR CUSTODY 1. Plaintiff is Todd A. Soulliard, an adult individual, residing at 315 East Old York Road, Carlisle, Cumberland County, Pennsylvania 17013. 2, Defendant is Cynthia L. Thibodeau, an adult individual. residing at 95 Tiffany Street, Unit 11, Attleboro, Massachusetts 02703. 3. The parties are the parents of two minor children: Joshua Allen Soulliard, born July 26, 1989 and Daniel Allen Soulliard, born February 15, 1991. The children were born in wedlock. The children are presently in the custody of Defendant at 95 Tiffany Street, Unit 11, Attleboro, Massachusetts. During the past five years, the children have resided with the following persons at the following addresseS: Persons Residences Dates Francis Thibodeau Cynthia L. Thibodeau Francis Thibodeau Cynthia L. Thibodeau 95 Tiffany Street. Unit 11 Attleboro, Masachusetts 5 Dane Street Mansfield, Massachusetts August, 2001 to present January, 2000 to August, 2001 The natural father of the children is Todd A. Soulliard, residing at 315 East Old York Road, Carlisle. Cumberland County, Pennsylvania. He is married to Wendy Soulliard. The natural mother of the children Cynthia L. Thibodeau, residing at 95 Tiffany Street, Unit 11, Attleboro, Massachusetts. She is married to Francis Thibodeau. 4. The relationship of the Plaintiff to the children is that of natural father. The plaintiff currently resides with the following persons: Names Relationship Wendy Soulliard Wife 5. The relationship of the Defendant to the child is that of natural mother. The defendant currently resides with the following persons: Names Relationship Francis Thibodeau Husband Joshua Allen Soulliard Son Daniel Allen Soulliard Son 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 children 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. 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. NONE. WHEREFORE, Plaintiff requests your Honorable Court to grant him shared legal and shared physical custody of the children. Respectfully submitted, O'BRIEN. BARIC & SCHERER 11t ' ~ MiC~ Scherer, Esquire 1.0.61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 mas.dir/domestic/soulliard/custodycomplaint.pld VERIFICATION , verify that the statements made in the foregoing Complaint for Custody are true and correct. \ understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. DATE: 75 '5~o5 41;;rLJ- Todd A. Soulliard \ II ~re~ ~~ U'-\ ~ C5\~~ V\ ~, ~, ,.--:-:) ,----, L)l "..; TODD A. SOULLIARD PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA V. 05-4762 CIVIL ACTION LAW CYNTHIA L. THIBODEAU IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, September 2], 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, October II, 2005 at 8:30 AM for a Pre-Hearing Custody Conference, At such conference, an effort 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 age 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 hearing. FOR THE COURT, By: Isl Tacqueline M. Verney. Esq. .J-' Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For infonnation about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our oftice, 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. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE, IF YOU DO NOT HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH 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 - ~~~ - ~ 4" Jo i"('~ . ~ ;> ~'" ~k; .5" ec"-~ ~?" ~ ;2 /">r~~ ~ ',Pp Si7- ee6 ,~- j (>',I,.I,~LI \iif\JVr\ t\,_,;,-, ':-:-;>~::iN('l3 }JNn:)'.' -. .",,! ....s r007 6 I :8 l~d Z2 d:J JU v -"i '\'U ::JHl:lO ^t!\iIONi.mlG;)~ 7, - 3:)1:J:I.o-0310 TODD A. SOULLJARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2005-4762 CIVIL TERM CYNTHIA L. THIBODEAU, Defendant CIVIL ACTION-LAW IN CUSTODY CUSTODY STIPULATION AND AGREEMENT i I' II 11,1 Ii by and between Todd A. Soulliard (hereinafter referred to as "Father") and Cynthia L. II I! II Ii Ii born July 26, 1989 and Daniel Allen Soulliard, born February 15. 1991 (hereinafter referred to THIS AGREEMENT AND STIPULATION is entered into the 4th day of October. 2005, Thibodeau (hereinafter referred to as "Mother"). WHEREAS, the parties are the natural parents of thl9 children, Joshua Allen Soulliard, as "Children"); and, WHEREAS, the parties are divorced; and, WHEREAS, the parties wish to enter into an agreement relative to the custody of Children. NOW, THEREFORE, in consideration of the mutual covenants. promises and agreements as hereinafter set forth, the parties agree as follows: 1. Mother and Father shall have shared legal cLlstody of the children. 2. Until July, 2006, Father shall have primary physical of Joshua Allen Soulliard and Mother shall have primary physical custody of Daniel Allen Soulliard. In July, 2006, Father shall have primary physical custody of both children and Mother shall have periods of partial physical custody of the children at such times as the parties shall, from time to time, agree and at all such times as the children desire to be in the custody of their Mother. 3. The parties shall share in the transportation of the children and shall meet at a location which is half way between their respective residenGes. 4. The parent who has the child or children in their primary custody shall maintain health insurance for the child or children. 5. The parents shall keep each other advised as to all health, and school issues related to the children and the parent exercising primary custody of the child or children shall furnish copies of all report cards for the child or children to the other parent. 6. Neither parent will pay the other parent child support either before or after July, 2006. 7. The parties will not be under any obligation to assist with post-secondary educational expenses of the children. 8. The parties shall not do anything which may estrange Children from the other party, or injure the opinion of the children as to the other party or which may hamper the free and natural development of the children's love or affection for the other party. 9. 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 Cumberland 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. II ~ Ii 10. The parties acknowledge that they have read and understand the provisions 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 Wrlltten below. WITNESS: ~1fL- ~i:fC/{I.J.. Todd A. Soulliard ~~~:hfi~/~ Cynthia L. Thibodeau mas.dir/domestic/sou Iliard/custodystipu lation .pld Q 'c._. i'- c" "', c" = ~~." c::> ~ o -n -' ::t:"'T"! rnp -()m :.'129 ":!CJ ',~ :~.~ .'")__n ..~ C) ~;;{n :",,) ....1 ?iJ Co< o ~) -.,' r~y 'J1 .;;~ - RECEIVED OCT 0 7 ZO~ TODD A. SOULLIARD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-4762 CIVIL TERM CYNTHIA L. THIBODEAU, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 7th day of October, 2005, the Conciliator being notified that the parties have reached an agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, ;ir. tit line M. Verney, Esquire, Custody onciliator "', ..-;:-':::) 0 C~;:l en -n 0 ..... ('"'') R1:I1 -<l c: j" c, y C' -n ) :':'f.( ~ l ") )" :__J rn N :::--1 0 1) 1'-' -< --- II -1,..- "-C'~I\/;:r; ~^, ~ . :Ge~ ,;:iJI R_ ._1 ,_J ~J '~ TODD A. SOULLlARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V_ NO. 2005-4762 CIVIL TERM CYNTHIA L. THIBODEAU, Defendant CIVIL ACTION-LAW IN CUSTODY ORDER OF COURT AND NOW, this ~ day of 0 c.-i . , 2005, the Court adopts the following Stipulation and Agreement as an Order of Court, with respect to the following children: Joshua Allen Soulliard, born July 26, 1989 and Daniel Allen Soulliard, born February 15. 1991 (hereinafter referred to as "Children"). 1. Mother and Father shall have shared legal custody of the children. 2. Until July, 2006, Father shall have primary physical of Joshua Allen Soulliard and Mother shall have primary physical custody of Daniel Allen Soulliard. In July, 2006. Father shall have primary physical custody of both children and Mother shall have periods of partial physical custody of the children at such times as the parties shall, from time to time, agree and at all such times as the children desire to be in the custody of their Mother. 3. The parties shall share in the transportation of the children and shall meet at a location which is half way between their respective residences. 4. The parent who has the child or children in their primary custody shall maintain health insurance for the child or children. n ('., .' - .- ';..;- -- -~ - LU :C ..- u.... o c) c::> I;'::, S N I .),~ -') Z) .,,-------- Ii 5. The parents shall keep each other advised as to all health and school issues related to the children and the parent exercising primary custody of the child or children shall furnish copies of all report cards for the child or children to the other parent. 6. Neither parent will pay the other parent child support either before or after July, 2006. 7. The parties will not be under any obligation to assist with post-secondary educational expenses of the children. 8. The parties shall not do anything which may estrange Children from the other party, or injure the opinion of the children as to the other party or which may hamper the free and natural development of the children's love or affection for the other party. 9. 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 Cumberland 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. 10. The parties acknowledge that they have read and understand the provisions of this Agreement. BY THE COURT, ~cP \tJ\