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HomeMy WebLinkAbout01-5370Michael S. Travis ID No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 JILL E. BEAM, Plaintiff, VS. RICHARD L. BEAM, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 2O0 - 55?(9 IN CUSTODY COMPLAINT FOR CUSTODY TO THE HONORABLE JUDGES OF SAID COURT: 1. The Plaimiff is Jill E. Beam residing at 72 Tory Circle, Enola, Cumberland County, Pennsylvania 17025. 2. The Defendant is Richard L. Beam residing at 1407 Yorktowne Road, Cumberland County, Mechanicsburg, Pennsylvania 17055. 3. Plaintiff seeks shared legal custody and primary custody subject to the father's liberal periods of visitation of the following children: NAME PRESENT RESIDENCE DOB Sean Mackenzie Beam 72 Tory circle, 1/7/93 Enola, PA 17025 72 Tory Circle Enola, PA 17025 Shaelyn Nicholle Beam 9/21/96 The children were not bom out of wedlock. The children are presently in the custody of Jill E. Beam who resides at 72 Tory Circle, Enola, PA 17025. The children have resided with the following persons and at the following addresses for the last five years: Persons Jill and Richard beam Addresses 1407 Yorktowne Road Mechanicsburg, PA 17055 Dates 6/93 - 7/1/01 Jill Beam 72 Tory Circle 7/1/01 - date Enola, PA 17025 The mother of the children is Jill E. Beam, currently residing at 72 Tory Circle, Enola, PA 17025. She is married to the father. The father of the children is Richard L. Beam, currently residing at 1407 Yorktowne Road, Mechanicsburg, PA 17055. He is married to the mother. 4. The relationship ofpla'mtiffto the children is that of mother. The Plaintiff currently resides with the children only. 5. The relationship of the defendant to the children is that of father. The defendant currently resides alone. 6. Neither party has participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 7. 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. 8. The best interest and permanent welfare of the children will be served by granting the relief requested because: A. Plaintiff has participated in the primary care of the children throughout their lives. B. Plaintiff can provide a stable environment. C. Plaintiff can provide a loving home. 9. Each parent whose parental rights to the children has not been terminated and the person who has physical custody of the child has been named as parties to this action. 10. The parties hereto have reached agreement with respect to custody. A copy of the parties Custody Stipulation and Agreement is attached hereto as Exhibit A. ! 1. The parties request that the Stipulation and Agreement be entered as an Order of Court. WHEREFORE, Plaintiff requests this Honorable Court to grant her shared legal custody and primary physical custody of the children subject to the father's periods of liberal visitation according to the custody stipulation attached hereto. Attorney for Plaintiff Supreme court ID No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 Michael S. Travis ID No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 JILL E. BEAM, Plaintiff, VS. RICHARD L. BEAM, Defendant. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA -_ : : No. : : : IN CUSTODY CUSTODY STIPULATION AND AGREEMENT AND NOW, come the parties hereto, Plaintiff, Jill E. Beam ("Mother") and Defendant, Richard L. Beam, ("Father") as said parties have reached mutual agreement as to the custody of their children Sean M. Beam, bom January 7, 1993, and Shaelyn N. Beam, bom September 21, 1996, and hereby stipulate to the following custody agreement, and hereby request the Court to enter the same as an Order of Court: 1. Mother and Father shall share legal custody of said children, as to all matters regarding the children's health, education, and welfare. 2. Mother shall have primary physical custody of said children. Father's visitation schedule shall be as follows: Father shall have physical custody of the children on alternating weekends beginning and ending times as the parties may agree from Friday through Sunday beginning on Auqust 27 ,2001. The parties shall share transportation of the children. Father shall have additional periods of visitation with the children during the week as the parties may agree. The non-custodial parent shall have liberal telephone contact with the children. 3. Holidays: Mother and Father shall share holidays as they may agree. 4. Father shall have one week of uninterrupted period of visitation during the summer, after having given at least thirty (30) days' notice to Mother. Exhibit A 5. Father shall have visitation on Father's Day each year; Mother shall have visitation on Mother's Day each year. These days shall supersede the parties' regular schedule. 6. If either parent is unable to keep their scheduled times of visitation, they shall provide at least twenty-four (24) hours' notice. 7. The parties shall have the right to modify any provision of the custody schedule hereto upon mutual agreement by both parties. In the event a proposed modification is not agreed to, the schedule as stated shall be complied with by the parties. The parties reserve the right to modify this Stipulation and Agreement through the court pursuant to Pennsylvania Law, as Cumberland County, Pennsylvania, shall retain jurisdiction. Richard L. Beam, Defendant VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Dated: 60Z 3~-~ns '.LggaZ$ Z:a:~aVIN 9/-OU · ~AV'I J.¥ ASNaO.L~.V glA¥~/ 'S 'I:IyFI~II,N JILL E. BEAM, Plaintiff, VS. RICHARD L. BEAM, Defendant : IN T~Hr~ COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA · IN CUSTODY ORDER OF COURT AND NOW, this /~ day of-~~ 2001' it is hereby ORDERED and DECREED that the attached Custody Stipulation is entered as an Order of this Court. BY THE COURT: Jo