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Home My WebLink About06-3843 '" , SAIDIS, FLOWER & LINDSAY lUl."""".............I~ 26 West High Street Carlisle,PA II TRACEY L. FREELAND, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. (,{,-?f6c.[3 ~ IN CUSTODY v. KEITH W. LAUDERMILCH, Defendant NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the court, your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. 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 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 Car in Attorney Id. 46 26 West Hig reet Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff , .. SAIDIS. FLOWER &. UNDSAY Alu....-.i!ioAT.lAW 26 West High Street Carlisle,PA II " TRACEY L. FREELAND, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ....,- NO. ()t., -3 i '13 c...;,.;t I.L<- v. KEITH W. LAUDERMILCH, Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Tracey L. Freeland, residing at 41 Goldenrod Drive, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is Keith W. Laudermilch, residing at 4507 Winfield Street, Harrisburg, Dauphin County, Pennsylvania. 3. Plaintiff seeks custody of the following children: Name Present Residence Ace 13 Paige Laudermilch 41 Goldenrod, Carlisle, PA 17013 4. The child was born out of wedlock. 5. The child is presently in the custody of Plaintiff who resides at 41 Goldenrod Drive, Carlisle, Cumberland County, Pennsylvania. 6. During the past five years, the child has resided with the following persons and at the following addresses: Name Address Dates Scott A. Freeland, Tracey L. Freeland, Brock Freeland and Elise Freeland 41 Goldenrod Drive, Carlisle, PA May 2001 to present Scott A. Freeland, Tracey L. Freeland, Brock Freeland and Elise Freeland 620 North East St., Carlisle, PA January 1997 to May 2001 Tracey L. Freeland, formerly Tracey L. Baker 114 Second St., W. Fairview, PA December 1996 to January 1997 , -.. SAIDIS, FLOWER & UNDSAY .........",.,.."""'-.lAW 26 West High Street Carlisle, PA II Tracey L. Freeland, formerly Tracey L. Baker Beale Avenue, Enola, PA 17025 March 1996 to November 1996 7. The mother of the child is Tracey L. Freeland, currently residing at 41 Goldenrod Drive, Carlisle, Pennsylvania. 8. She is married. 9. The father of the child is Keith W. Laudermilch, currently residing at 4507 Winfield Street, Harrisburg, Dauphin County, Pennsylvania. 10. He is married. 11. The relationship of Plaintiff to the child is that of Mother. 12. The relationship of Defendant to the child is that of Father. 13. 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. 14. Plaintiff has no infonnation of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 15. 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. 16. The best interest and permanent welfare of the child will be served by granting the relief requested because Plaintiff can best provide for the child's spiritual, physical and emotional welfare. 17. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action, I! , L . ~. SAllIS. FLOWER & LINDSAY A'"r"''''''''''IA'''' 26 West High 5tIttt Carlisle,PA II ."1- WHEREFORE, Plaintiff requests the Court to grant legal and primary physical custody of the child. Respectfully submitted. Carol J. Lindsa}l' E q Ire ID No. 44693 26 West High S reet Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiff I ,.. ...... SAlDIS. FLOWER & UNDSAY ..............I-.:.IAW 26 West High Street Carlisle,PA II 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. 94904, "'''0910 "_0 f",;fl~Uo",to '_.,~~ Trnrey L. " '" ~L Date: 1- 5- 0 L, " , " r-_~ ~ , ~ C--::l (,:) ,:.:., ~ -. ,;...., -n ~\; ,-- ---' ~ , ~. r-~ I" ~ 1 - _..1 <:x:\ - C). D ~ LN - -. ~ J ~ f''<, ::.<. :t . . ' II SAIDIS. FLOWER & LINDSAY IUIUIlI'It!.UtoJU...AW 26 West High Street Carlisle,PA --r- TRACEY L. FREELAND, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW _ NO. of,-3H3 ~ f~ v. KEITH W. LAUDERMILCH, Defendant IN CUSTODY CUSTODY STIPULATION & AGREEMENT THIS STIPULATION AND AGREEMENT entered into the day and year hereinafter set forth, by and between TRACEY L. FREELAND, (hereinafter referred to as "Mother") and KEITH W. LAUDERMILCH, (hereinafter referred to as "Father"). WHEREAS, the parties are the natural parents of one child, Paige Laudermilch, born January 14, 1993 (hereinafter referred to as "Child"); and WHEREAS, the parties live separate and apart, and wish to enter into a comprehensive stipulation and agreement relative to physical and legal custody of their Child. WHEREAS, the parties have heretofor arranged custodial time amicably without a Court Order, but Mother is relocating to Ohio which requires a Court Order to enroll the child in school. NOW THEREFORE, in consideration of mutual covenants, promises and agreements as hereinafter set forth, the parties stipulate and agree as follows: 1. The parties shall share legal custody of the child. 2. The child shall reside primarily with Mother in Marysville, Ohio. 3. Father shall exercise periods of physical custody of the child at times the parties can agree. ~._- II . SAIDIS, FLOWER &. LINDSAY ..'nlll"lI!.I"....]'.lAW" 26 West High Street Carlisle,PA 4. At Father's request, the parties will schedule custodial time for Father for the upcoming year. 5. Both Mother and Father shall keep each other advised in the event of serious illness or medical emergency concerning the child and shall further take any necessary steps to ensure that the health and well-being of the child is protected. During such illness or medical emergency, both parties shall have the right to visit the child as often as he or she desires consistent with the proper medical care of the child. 6. Neither parent shall do or say anything which may estrange the child from the other party, injure the opinion of the child as to the other party, or which may hamper the free and natural development of the child's love and affection for the other party. 7. The parties desire that this Stipulation and Agreement be made an Order of Court. IN WITNESS WHEREOF, The parties hereto intending to be legally bound by the terms hereof, set forth their hands and seals the day and year hereinafter mentioned. WITNESSETH: 1- 5- o~ Date 7 - .1... -Dl.1 Date W KEITH W. LAU MILCH ", -.n -~ \,., \ _1 ---,:-, ......... -- " (.....:) , . II SAIDIS, FLOWER &. LINDSAY ...........-I,..,...lAW 26 West High Street Carlisle,PA TRACEY L. FREELAND, Plaintiff v. KEITH W. LAUDERMILCH, Defendant AND NOW this \"\.'~ RECEIVED JUL 1 V :OC61 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. D(, - 3 f'B ~ IN CUSTODY ORDER OF COURT day of l' v \~ , 2006, the terms of the attached Custody Stipulation and Agreement is hereby made an Order of Court. cc: Carol J. Lindsay, Esquire Attorney for Plaintiff Keith W. Laudermilch, pro se BY THE COURT, ~lU-\ J. ~ ~ 7./:Z'0~ ()-. E '.\ : \\ !, \ ... . v:,:'\') '7\ " u ' ~;i,;l :-JO