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Home My WebLink About06-0641 .. . \ Vl, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Docket No.: f)(...(..,'-II (J;;.j ~ FRANCES J. CARTER, Plaintiff JA Y 1. GOODLING, Defendant CIVIL ACTION - CUSTODY COMPLAINT FOR CUSTODY I. The Plaintiff is Frances J. Carter, residing at 107 Pennsylvania Avenue, Carlisle, Pennsylvania 17013. 2. The Defendant is Jay L. Goodling, residing at 107 Pennsylvania Avenue, Carlisle, Pennsylvania 17013. 3. Plaintiff seeks custody of the following children: NAME RESIDENCE QOB Connor J. Goodling 107 pennsylvania Avenue, Carli;le, P A 17013 10/7/05 4. The child was born out of wedlock. 5. The child is presently in the custody of Frances J. Carter. 6. During his life, the child has resided with the following persons and at the following addresses: NAME ADDRESS DATES Frances J. Carter & Jay L. Goodling 107 Pennsylvania Avenue, Carlisle 10/07 lOS-Present 7. The mother of the child is Frances J. Carter, currently residing at 107 Pennsylvania Avenue, Carlisle, Pennsylvania 17013. She is unmarried. 8. The father of the child is Jay L. Goodling, currently residing at 107 Pennsylvania Avenue, Carlisle, Pennsylvania 17013. He is unmarried. 9. The relationship of the Plaintiff to the child is that of mother . The Plaintiff currently resides with the following persons: Zachary D. Austin and Emily T. Austin. . \ O. The relationship of the Defendant to the children is that offather. The Defendant currently resides with the following persons: Frances J. Carter, Zachary D. Austin and Emily T. Austin. ] I. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 12. Plaintiff has no information ofa custody proceeding concerning the children pending in a court of this Commonwealth. 13. 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 child. ]4. The best interest and permanent welfare of the children will be served by granting the relief requested for the following reasons: A. Plaintiff has undertaken and performed the primary parental responsibilities for the child; and B. Plaintiff is best able to provide the care and nurture which the chid needs for healthy development; and C. A Court Order of custody and structured visitation is desired so that the Plaintiff and the child may plan their schedules accordingly, and so that misunderstandings and unmet exceptions regarding custody and visintion can be avoided, and also so that the child is not used in a manipulative fashion D. Plaintiff desires to maintain the family household which has been established, and the continued stability of the household is in the best interest ofthe child. ] 5. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the chi Id have been named as parties to this action. . . " WHEREFORE, Plaintiff requests the Court to grant custody of the children to Plantiff subject to structured partial custody by the Defendant pending t Paul radfor r, :squire Attorney for Plaintiff 50 East High Street Carlisle, PA 17013 Telephone: (7\7) 258-8558 Supreme Court ID No. 71786 . , " COMMONWEALTH OF PENNSYLVANIA ) : SS. 166-62-5512 COUNTY OF CUMBERLAND ) I verifY that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made sthject to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. DATE: / (3(,( ell ~ I /( .' (ItI./L( I(~{:ll Frances Y. Carter ~ \) ~ --- 7l. ~ () ~~ s ('") ~ C) C'-_:' 11 ~ ~:..1'.j~' :b "':>, ~- ~ '" :'Jr. >:h'1 .. ~J '2 '~J .r.:- :~ tD FRANCES J. CARTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . v. Docket No.: OC; - 0. 'II JAY L. GOODLING, Defendant CIVIL ACTION - CUSTODY STIPULA TED CUSTODY AGREEMENT WHEREAS, JAY L. GOODLING, hereinafter matter referred to as "FATHER" and FRANCES J. CARTER, hereinafter referred to as "MOTHER" are the natutal parents of CONNO.R JA YMES GOODLING (DOB: lO-7-05); and WHEREAS, FATHER and MOTHER desire to make arrangements for the custody and visitation of the said child; and, WHEREAS, both parties have been advised by counselor have had the opportunity to be advised by counsel; and, WHEREAS, the parties intend to submit this Stipulated Custody Agreement to the Court of appropriate jurisdiction for incorporation and merger into a Comt Order approving said Agreement; NOW, THEREFORE, it is hereby stipulated and agreed as follows: 1. The parties shall have joint legal custody of the child and shall confer with respect to major decisions with respect to the upbringing of the child incltding, but not limited to, their education, health, medical care and religious upbringing. 2. Mother shall have Primary Physical Custody of said child with Fatherhaving every other weekend visit. Father's periods of Custody shall begin on Friday at 6:00 pm and shall end on Sunday at 6:00 pm, on the mother's working weekend, to become effective after father obtains suitable housing. 3. Both parties shall have shared holidays as mutually agreeable by the Parties. Parties will also agree on shared birthdays with the child. 4. Both parties agree to cooperate with one another in the implementation ofthe aforesaid Agreement and understand and agree that other changes or modfications in the aforesaid schedule and/or times specified may be necessary to enable both parents to continue to foster and develop a good and healthy relationship with the child. To that end, the parties agree to cooperate with one another to encourage the relationship of the child with the other parent and agree to refrain from any and all conduct, activity, or communication which would adversely affect the child's relationship with either parent. 5. Upon the knowledge of pending relocation, temporary or permanent, of either parent, each parent must immediately inform the other of his/her new address and telephone number. 6. Both parties agree that neither shall move out of the jurisdiction of Pennsylvania with the children without consent ofthe other parent or court order. Both parties agree that neither shall take the child out of the jurisdiction of Pennsylvania without seven (7) days prior Written Notice to the other party. 7. This Agreement shall be effective immediately upon signature by both parties and its validity is not contingent upon Court approval. WHEREFORE, the parties pray that the Court enter the Order attached hereto. We verify that the statements made in this Petition are true and correct. We understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 9 4904 relating to unsworn falsifications to authorities. Date:~ (bL}CG, arter, Mother Date: I 130)06 Ci C'. r--> C? ~~ --r'l r'1 OJ \ ~ ..J".~ ~ :;:J~I rl1F'"" ';"1r:D !}~[~ . '.....~.j ~< i'Ti , :.::~\ ~~ 9 U1 ... ~ VI. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Docket No.: 0(..- L4! GcJ~L~~ FRANCES 1. CARTER, Plaintiff JAY L. GOODLING, Defendant CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, this ":J . . I day of r'cAr>/i , 2006, upon review and consideration of the Stipulated Custody Agreement of the parties, a copy of which is attached hereto, said Agreement is hereby APPROVED, ADOPTED, MERGED and INCORPORATED herein as the Order of this Court. BY THE COURT: J. fi r l (' ~ p f~, ~ ~ 1 r i'l .0 i,:'[1 00, - ~n.:J SOOl '- "l},.~' ...._ ,. '. -,. .'; -.j' ~"J ^t1vll...;i\\./.. ;,_:'!.":,.,~ _:,.- 1. ....\ :::j~J1,:i,~:C>-{j:,11IJ