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Home My WebLink About05-5932 KENNETH F. LEWIS, ESQUIRE 1.0. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ()~- ~9Jd..... e~;(-r0<..."1 CIVIL ACTION - LAW LOUISE WAGGONER, Plaintiff DAWN MICHELLE GARCIA and NATHAN DAVID JOPPY, SR. Defendants CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you, and a Decree may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 OR (800) 990-9108 KENNETH F. LEWIS, ESQUIRE 1.D. #69383 1101 North Front street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff LOUISE WAGGONER, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, P~NNSY~~NIA NO. O~- [;"9?,~ Clc..>~L ~, CIVIL ACTION - LAW DAWN MICHELLE GARCIA and NATHAN DAVID JOPPY, SR. Defendants CUSTODY COlYlfUlIIJi PEW~mleU FOR CUSTODY 1. The Plaintiff is Louise Waggoner, an adult individual residing at 316 3rd street, New Cumberland, Cumberland County, PA 17070. 2. Defendant Dawn Michelle Garcia is an adult individual currently residing at 21 W. Green st., Mechanicsburg, Pennsylvania 17055. She is the subject child's natural mother. 3. Defendant Nathan David Joppy, Sr. is an adult individual currently residing at 141 S. Queen st., Lancaster, PA 17603. He is the subject child's natural father. 4. Plaintiff seeks custody of CAPRI LORRAINNE DuBOIS, born March 26, 1989 (age 16). 5. For the last five years, the child has resided with the following persons at the following addresses for the following approximate periods of time: NAME Plaintiff & her husband and son ADDRESS see par. #1 above DATE 11/05- present Grandparents: Roy & Sharon Hillman 18 Sherwood Drive Carlisle, PA 17013 2/05- 11/05 Mother/stepdad see par #2 2001-2/05 6. Plaintiff has no information of a custody proceeding concerning the child pending in any Court of this Commonwealth. 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 children. 7. The best interest and permanent welfare of the child will be served by granting primary physical custody to Plaintiff as all parties, including the grandparents with whom the child had previously been living, have agreed that Plaintiff is in the best position to meet the child's needs and have signed a stipulation consenting to the transfer of custody to Plaintiff. The child also wishes to reside with Plaintiff. 8. Each parent whose parental rights to the child has not been terminated and the persons who have physical custody of the children has been named as parties to this action. WHEREFORE, Plaintiff requests the Court to grant her physical and legal custody of the subject child. Respectfully submitted, DATE: Ilp5/05 hi KE NET F. LEWIS, ESQUIRE Attorney for Plaintiff VERIFICATION I hereby verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subj ect to the penal ties of 18 Pa. C. S. section 4904, relating to unsworn falsification to authorities. Dated: / /1/5)05 ~~ (l)~~ LOUISE WAGGONE . 'b<l. co> - (2J C. ;v i ~ t ~ & f; ~ nu r-- 1::> -f- ----< r-' () ~;~ '~~~:N .:~ i \,',:-':l"l:: .-T-; ~:~? -j '-:? 1:>'- C,,) ~~ v:o NOV 1 1 LUUJ Y: '??6,- KENNETH F. LEWIS, ESQUIRE 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.o5-5CfSz Gv1lTe(/Yl LOUISE WAGGONER, Plaintiff DAWN MICHELLE GARCIA and NATHAN DAVID JOPPY, SR. Defendants CIVIL ACTION - LAW CUSTODY ORDER AND NOW, this 18~ day of ~ , 2005, upon stipulation attached hereto, it is Ordered and Decreed as follows: 1. LOUISE WAGGONER shall have legal and physical custody of CAPRI LORRAINNE DuBOIS, born March 26, 1989 (age 16). 2. The subject child's grandparents, SHARON K. HILLMAN and ROY DAVID HILLMAN, and the child's parents DAWN MICHELLE GARCIA and NATHAN DAVID JOPPY, SR. shall have periods of visitation at mutually agreed upon times. BY THE COURT: d J. DIjlTRIBUTION: ~nneth F. Lewis, Esq., 1101 N. Front st., Hbg., PA 17102 ~ise Waggoner, 316 3rd Street, New Cumberland, PA 17070 ~awn Michelle Garcia, 21 W. Green st., Mechanicsburg, PA 17055 ~an David.Jo py, Sr., 141 S. Queen st., Lancaster, PA 17603 ~~. Q.r} \\.\11 " , LOUISE WAGGONER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.OS - 5cuz G'VJ'/JeilVj v. DAWN MICHELLE H~~ll and NATHAN DAVID JOPPY, .$R. Defendants CIVIL ACTION - LAW CUSTODY CUSTODY STIPULATION lil:~ AND NOW, this ~ day of November, 2005, the undersigned stipulate to the following provisions being made an Order of Court: QI\fl-GI A 1. LOUISE WAGGONER, DAWN MICHELLE " and NATHAN DAVID JOPPY, JR. shall share legal custody of CAPRI LORRAINNE DuBOIS, born March 26, 1989 (age 16). 2. LOUISE WAGGONER shall have physical custody of the subject child. 3. The child's grandparents, SHARON K. HILLMAN and ROY DAVID HILLMAN, and the child's parents DAWN MICHELLE HILLMAN and ~N. Ail NATHAN DAVID JOPPY, J:!l. shall have periods of visitation at mutually agreed upon times. NATHAN Y, "~I!P S1/.. 'odt,~ dJ.4=O. DAWN MICHEL E __ _ I QdRc.7.;) c-,~f:!JiP~~ OUISE WAG 0 ER Ij)fdlhdh J~PPPI5r. din 5; .~A tho'S w. fh fhr uhJef 51dh~hd 111M ;H scl~ pt/rpose ;r~r 0Ipt: iJdgas ffJ 6~ (j6/~ 10 ctH~bJ ,n~6/)1 NJ,ef~ ~Ot1:>e PladfOhn pfn:des, ,-, c~~.., ,,;) Cf"' ~~ U ~\::.: c. o .'-r) -\ ::C.4'1 1<1= ,~- -~~O '2::''', -. i(> - J' ";~r~) -_')rC \,0 ~..': S:> .-<: (....) cD