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Home My WebLink About06-4756 Elizabeth A. Hoffman, Esquire 106 Walnut Street Harrisburg, PA 17101 (717)236-2956 SUZETTE R. REICH and RYAN DAVID REICH, Plaintiffs v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0'- -~~S''- {!'oL~~ CIVIL ACTION - LAW IN CUSTODY MELISSA A. BAILEY, Defendant COMPLAINT IN CUSTODY 1. Plaintiffs Suzette R. Reich and Ryan David Reich ("Plaintiffs") are adult individuals whose current mailing address is 6211 Blue Ridge Avenue, Harrisburg (Dauphin County), Pennsylvania 17112. 2. Defendant Melissa A. Bailey ("Mother") is an adult individual whose current mailing address is 11 Falcon Court, Mechanicsburg (Cumberland County), Pennsylvania 17055. 3. Mother is the natural parent of the minor child, Andrew M. Erb. whose date of birth is 4/19/91. 4. During the past fIVe years the minor child has lived in the following locations with Mother: Location 11 Falcon Court Mechanicsburg, PA Dates 3/06 - Present 12B Richland Lane Camp Hill, PA 3/05 - 3/06 1001 Ruply Road Camp Hill, PA 3/04 - 3/05 1591 Scagrave Drive Watsontown, PA 5/03 - 3/04 . 8 East Spect Street McClure, PA 7/02 - 5/03 Beaver Springs, PA 1996-2002 5. There is no custody order in this case. 6. Mother has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or any other court. 7. The whereabouts of the father of the minor child is unknown has not been known since the minor child was an infant. 8. There are no other persons known to have or claim to have a right to custody or visitation of the child, and therefore no further notice of the pendency of this action and the right to intervene shall be given, other than to the parties named herein. 9. Plaintiffs and Mother are in agreement that it is in the best interests and welfare of the minor child for Plaintiffs to have primary physical custody. Therefore, the parties are submitting concurrently with this complaint a Stipulated Custody Agreement which they are requesting to be converted into a custody order. WHEREFORE, it is respectfully requested that this Honorable Court enter an order which grants Plaintiffs primary physical custody and Mother partial custody of the minor child. Respectfully submitted, Eliza th A. Hoffman, E 106 Walnut Street Harrisburg, PA 17101 (717) 236-2956 10#71000 VERIFICATION I verify that the information provided in the attached document is true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.SA ~904, relating to unsworn falsification to authorities. Date: 8- \L\-~ ~ Q.CLL 5 R. Reich VERIFICATION I verify that the information provided in the attached document is true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.SA ~4904, relating to unsworn falsification to authorities. Date: e. /'1- 0 6J VERIFICATION I verify that the information provided in the attached document is true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.SA ~4904, relating to unsworn falsification to authorities. ~ CERTIFICATE OF SERVICE I, Elizabeth A. Hoffman, Esquire, do hereby certify that a true and correct copy of the attached complaint was sent by U.S. mail to the following persons: Melissa A. Bailey 11 Falcon Court Mechanicsburg, PA 17055 Suzette and Ryan Reich 6211 Blue Ridge Avenue Harrisburg, PA 17112 Date: 1/ tDf{)ro Eliza A. Hoffman, Esq e 106 Walnut Street Harrisburg, PA 17101 (717) 236-2956 10 #71000 ~ ~ - ~~~ 1:> . g ~ - ~ ~ ~ - ...:l f" 0() ~ -4 ~ -of~' ~}1~'\ (/'; _:~ -,:., 1""0\- l(~ ~ ~ Q. ~ -i .... :J; -n t::: r" r: ~ ~~~~ Q ~ "6~{,f\:::) {5 _=-t ;; ~ &" . , SUZETTE R. REICH and RYAN DAVID REICH, Plaintiffs v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0" - 4'U're (?,"u~L ~~ CIVIL ACTION - LAW IN CUSTODY MELISSA A. BAILEY, Defendant STIPULATED CUSTODY AGREEMENT AND NOW comes Plaintiffs Suzette R. Reich and Ryan David Reich, and Defendant Melissa Bailey, who stipulate to the issuance of a custody order containing the terms set forth below: 1. Plaintiffs shall have primary physical custody of the minor child, Andrew M. Erb (DOB 4/19/91 ). 2. Defendant shall have physical custody of the child at times mutually agreed upon by the parties. 3. Custody during holidays shall be determined by mutual agreement of the parties. 4. The parties shall have joint legal custody of the minor child. Thus, each of them shall have the right to receive information from the child's school, attend parent-teacher conferences, and to participate in all school activities. In addition, each shall have the right to be informed of any major medical problems which the child may have and to participate in making any decisions about the treatment for said problems. At all times, the parties shall keep each other informed of any illnesses of the child which require medical care. Finally, any other major decisions regarding the child shall require joint approval of all the parties. IN WITNESS WHEREOF, the parties place their hands and seals to this Stipulated Custody Agreement on this day of August, 2006. , , Id-~~ __ tf/ Witn~ kL~u ~ wKlfe ~. .Q,~ ~ReiCh k~ '~~,A ~ t7 Wi~ c7 ~ g 2::. -1j:l1': \"1-'1\ \,' -;1",.. 7(:- (n:> .:.<, r:;L ~- '~~ ~~;i >c Z:. :2. ....~ g d' ~ G'l - C1J Q. ~-n ~-- b "J,o 'o,c> ~.::;::J;.; ~il ~~\ S ~ ~ .- q o C1' ~y: ~ \ ) v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 6'- - J.(?rfo (!('"utL~~ CIVIL ACTION - LAW IN CUSTODY SUZETTE R. REICH and RYAN DAVID REICH, Plaintiffs MELISSA A. BAILEY, Defendant AND NOW this ORDER ~t./ ~ day of ~ , 2006, it is hereby ordered that the attached Stipulated Custody Agreement is adopted as a Custody Order. J. Distribution: ~lizabeth A. Hoffman, Esquire, 106 Walnut Street, Harrisburg, PA 17101 ~uzette and Ryan Reich, 6211 Blue Ridge Avenue, Harrisburg, PA 17112 ~elissa Bailey, 11 Falcon Court, Mechanicsburg, PA 17055 ~tl VIN'1^l,l,SNNJd ",\('\(^,,,.,,.,,,,ru:1':1W"t"\ (\.U'<"jy;'r "'{.,,'; <,-'..,..1.'...., s Z,:} Wdo1}Z~fi'onoz );' ~,'t . , ^tN10N'>~Md 3\-U.:lO 3;)\:\;!(Y03i8