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Home My WebLink About06-4110 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GIGI LAUGHLIN, Plaintiff NO. 6~ - <{ {/O CIVIL TERM v. CIVIL ACTION - LAW SHANNON LAUGHLIN and BERNARD CONNER, IN CUSTODY Defendants CUSTODY COMPLAINT 1. The Plaintiff, Gigi Laughlin, is an adult individual residing at 58 Drexel Place, New Cumberland, Cumberland County, Pennsylvania. 2. The Defendant, Shannon Laughlin, is an adult individual whose legal and primary residence is 58 Drexel Place, New Cumberland, Cumberland County, Pennsylvania, although she stays with her sister in the Philadelphia area during the week in order to attend attends classes and study programs at CHI Institute in Broomhall, PA. 3. The Defendant, Bernard Conner, is an adult individual who is incarcerated under a sentence of 18 to 36 years and is therefore living at the Huntingdon State Correction Facility located at 1100 Pike Street, Huntingdon, PA. 4. Plaintiff seeks custody of the following children: NAME PLACE OF RESIDENCE AGE O.O.B. Bernard M. Conner 58 Drexel Place 11 10/14/94 New Cumberland, PA 17070 Chelsea Conner 58 Drexel Place 9 3/12/96 New Cumberland, PA 17070 Bishop Conner 58 Drexel Place 4 8/22101 New Cumberland, PA 17070 5. The children were not born out of wedlock. 1 6. The children are presently in the custody of the Plaintiff, GiGi Laughlin, who resides at 58 Drexel Place, New Cumberland, Pennsylvania. The Children are also in the custody of the Defendant, Shannon Laughlin, who resides at 58 Drexel Place, New Cumberland, Pennsylvania on a part time basis due to her school, and work requirements in the Philadelphia area. 7. During the past five years, the children have resided with the following persons and at the following addresses: PERSONS ADli)RESSES DATES Gigi Laughlin 58 Drexel Place 2000 to present Shannon Laughlin New Cumberland, PA 17070 Nikki Laughlin 8. The mother of the children is Shannon Laughlin, currently residing at 58 Drexel Place, New Cumberland, Pennsylvania 17070. The mother is not married. 9. The father of the children is Bernard Conner, currently incarcerated at Huntingdon State Correctional Institution, 1100 Pike Street, Huntingdon, Pennsylvania. The father is not married. 10. The father has no involvement with the Children and has never lived with them in their household. 11. The relationship of Plaintiff to the children is that of Grandmother. The Plaintiff currently resides with the following persons: NAMES RELATIONSHIP Chelsea Conner Granddaughter Bernard M. Conner Grandson Bishop Conner Grandson Shannon Laughlin Daughter Nikki Laughlin Son 2 12. The relationship of Defendant, Shannon Laughlin to the children is that of mother. Defendant Shannon Laughlin currently resides with the following persons: NAMES RELATIONSHIP GiGi Laughlin Mother Chelsea Conner Daughter Bernard M. Conner Son Bishop Conner Son Nikki Laughlin Brother 13. The relationship of Defendant, Bernard Conner to the children is that of father. Defendant Bernard Conner currently resides with the following persons: None except fellow prisoners. 14. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another Court. 15. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 16. Plaintiff knows/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. 17. The best interest and permanent welfare of the children will be served by granting the relief requested because: A. The Children have been with Plaintiff/Grandmother all of their lives and keeping them in their only known home and schools would promote continuity and stability for the children. B The parties want the Plaintiff/Grandmother to have legal and physical custody for the children and have executed a Stipulated Custody Agreement dated March 16,2006, which by its terms is to be entered as an order of court. A true and correct copy of the parties Stipulated Custody Agreement is attached hereto, marked Exhibit "An and made a part hereof. 3 18. 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. WHEREFORE, Plaintiff requests the Court to enter and Order adopting and incorporating the terms of the parties' March 16, 2006 Stipulated Custody Agreement attached hereto as Exhibit "A" Respectfully submitted, IFF, ESQUIRE Trindle ad C ., A17011 Phone: (717) 737-0100 Fax: (717) 975-0697 ID No. 32112 4 VERIFICATION I verify that the statements made in this Custody Complaint are true and correct. I understand that false statements herein are made su ject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date: (Jfo hJ 6 / EXHIBIT "A" STIPULATED CUSTODY AGREEMENT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GIGI LAUGHLIN, Plaintiff NO. CIVIL TERM v. CIVIL ACTION - LAW SHANNON LAUGHLIN and BERNARD CONNER, IN CUSTODY Defendants STIPULATED CUSTODY AGREEMENT AND NOW, this ti ~ of :P }).CJJ.-- , 2006, Gigi Laughlin ("Grandmother"), Shannon Laughlin ("Mother") and Bernard Conner ("Father") and enter into this Stipulated Custody Agreement and stipulate and agree as follows regarding Mother and Father's minor children, to wit: Bernard M. Conner, age 11, born 10/14/94; Chelsea Conner, age 9, born 3/12/96; and Bishop Conner, age 4 born 8/22/01, ("the Children"): 1. Grandmother and Mother shall have joint legal custody of the Children. Both Grandmother and Mother shall have an equal right, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education, religion and financial care. Pursuant to the terms of PA. C.S. !i5309, each party shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other party. 2. Grandmother and Mother shall share physical custody of the Children. Grandmother shall have primary physical custody of the Children. Mother shall have partial physical custody of the Children when she is in the Grandmother's home or at such other times and places as the parties may mutually agree. - 2 - 3. This Stipulated Custody Agreement shall not be deemed to determine Father's custody rights. Rather, such rights shall be determined at a later date, if relevant and appropriate. 4. The parties authorize the Court to enter an Order incorporating the terms of this Stipulated Custody Agreement. IN WITNESS WHEREOF the parties, intending to be legally bound hereby, have set their hands and seals the day and year below written. WITNESS: {SEAL} ,(U-tu-t M ~ d{k, it)/ dlluL~ } / L)~t GHLlN Date: 13/ It) /06 I I ,Oj~~~. ~NNON LAUGHLIN Date: ~JIDID~ f {SEAL} ~~fo~ ~X6C/ Date: 34 (c,Ct? {SEAL} .3- ..-\ ~ -'(" " ,\ ~ - ,;'-.J C) ~ '" .- .- C> C> _.- -., C~'i ~ ~ ~ . .. ," IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GIGI LAUGHLIN, Plaintiff NO.C:{,- '+ liD CIVIL TERM v. CIVIL ACTION - LAW SHANNON LAUGHLIN and BERNARD CONNER, IN CUSTODY Defendants STIPULATED CUSTODY AGREEMENI AND NOW, this if ~ of ~ /'l.c12- ,2006, Gigi Laughlin ("Grandmother"), Shannon Laughlin ("Mother") and Bernard Conner ("Father") and enter into this Stipulated Custody Agreement and stipulate and agree as follows regarding Mother and Father's minor children, to wit: Bernard M. Conner, age 11, born 10/14/94; Chelsea Conner, age 9, born 3/12/96; and Bishop Conner, age 4 born 8/22/01, ("the Children"): 1. Grandmother and Mother shall have joint legal custody of the Children. Both Grandmother and Mother shall have an equal right, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education, religion and financial care. Pursuant to the terms of PA. C.S. 55309, each party shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other party. 2. Grandmother and Mother shall share physical custody of the Children. Grandmother shall have primary physical custody of the Children. Mother shall have partial physical custody of the Children when she is in the Grandmother's home or at such other times and places as the parties may mutually agree. - 2 - ,. . ~ " 3. This Stipulated. Custody Agreement shall not be deemed to determine Father's custodyrights. Rather, such rights shall be determined at a later date, if relevant and appropriate. 4. The parties authorize the Court to enter an Order incorporating the terms of this Stipulated Custody Agreement. IN WITNESS WHEREOF the parties, intending to be legally bound hereby, have set their hands and seals the day and year below written. WITNESS: ;{12-~)t: ~ 1>>)/ {SEAL} Date: 8/ IP /06 I I ~)/~ ~~ 1f(a/!2 S ANNON LAUGHLIN Date: 0JII)/O!f I {SEAL} ~t~~~ ~C/ Date: 34 ~((? {SEAL} - 3 - b--' . '- ( ~.~ i'-c) C) C,' ~-~~r~- ~-".i~" =;~;;,,-i ",--. .k~.....,(\"----./-'-'- ." ()tJ I I IN THE COURT OF.COMMON PLEAS OF CUMBERLAND COUNTY, .' .~', ; .'. '., j GIGI LAUGHLIN, Plaintiff NO.tG;41/0 CIVIL TERM v. CIVIL ACTION - LAW SHANNON LAUGHLIN and BERNARD CONNER, IN CUSTODY Defendants ORDER OF COURT parties' Stipulated Custody Agreement date March 16, 2006, attached to the within , 2006, upon consideration of the AND NOW, this~ day of Complaint as Exhibit "A" IT IS HEREBY ORDERED AND DECREED that the terms of the parties' Stipulated Custody Agreement dated March 16, 2006 are incorporated into this Order and entered as an Order of this Court the same of if fully set forth herein. '.:1-. Distribution to: Attorney for Plaintiff: Diane G. Radcliff, Esquire, 3448 Trindle Road, Camp Hill, PA 17011 ~ 7 -).-o-(j~ Plaintiff: GiGi Laughlin, 58 Drexel Place, New Cumberland PA 17070 -. _ I Defendant: Shannon Laughlin, 58 Drexel Place, New Cumberland PA 17070 't~~ ft"A.ll~ Defendant: 8ernard Conner, Huntingdon State Correctional Institution, 1100 Pike Street, Hunti gdon, P~4-0001 ):is , :-.,1, (:',', \ ,) \'~? ,,'-I :' 0'"":J"7 .~ " ~" 'J