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Home My WebLink About06-4899 ,~ ' . ROY STEPHEN REINER and, CYNTHIA ANN REINER, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. ; No. Clio - 4P9? (li()i,L~~ JASON BAUCUM and CARISSA BAUCUM, Defendants : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT IN CUSTODY AND NOW comes the Plaintiffs, ROY STEPHEN REINER and CYNTHIA ANN REINER by and through their attorney, Jeanne B. Costopoulos, Esquire, and respectfully aver the following: 1. The Plaintiff, Roy Stephen Reiner, is an adult individual who currently resides at 200 Hearth Road, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. The Plaintiff, Cynthia Ann Reiner, is an adult individual who currently resides at 200 Hearth Road, Camp Hill, Cumberland County, Pennsylvania, 17011. 3. The Defendant, Jason Baucum, is an adult individual who currently resides at a temporary address in Dillsburg, York County, Pennsylvania. 4. The Defendant, Carissa Baucum, is an adult individual who currently resides at a temporary address in Dillsburg, York County, Pennsylvania. 5. There is one (1) dependent child from the marriage of the Defendants, namely Paije Anna Baucum, born August 27, 2004. 6. The Plaintiffs seeks primary physical and legal custody of the following child: Name Present Residence Ae:e Paije Anna Baucum 200 Hearth Road Camp Hill, PA 17011 23 months DOB 8/27/2004 . The child named above is presently in the custody of her natural maternal grandparents, Plaintiffs Roy Stephen Reiner and Cynthia Ann Reiner, at 200 Hearth Road, Camp Hill, Cumberland County, Pennsylvania, 17011. Since birth, the child has resided with the following persons and at the following addresses: Name Address Dates Plaintiffs 200 Hearth Road Camp Hill, PA 170ll 4/8/2006 to present Defendants 110 Wedgewood Circle Harold Baucum (Jason's grandpa) Etters, PA Dorothy Baucum (Jason's grandma) birth to 4/8/2006 The mother of the child is Carissa Baucum, Plaintiff, currently temporarily residing with friends in DilIsburg, York County, Pennsylvania. The father of the child is Jason Baucum, who also temporarily resides with his wife, Carissa Baucum, at the home of their friends in Dillsburg, York County, Pennsylvania. Plaintiff and Defendant are married to each other and the child was not born out of wedlock. 7. The relationship of the Plaintiffs, Roy Stephen Reiner and Cynthia Ann Reiner, to the child is that of natural maternal grandparents. Plaintiffs currently reside together with the subject child at their home at 200 Hearth Road, Camp Hill, Cumberland County, Pennsylvania, 17011. 8. The relationship of the Defendants, Jason Baucum and Carissa Baucum, to the child is that of natural parents. It is unknown by Plaintiffs with all whom the Defendants reside at their temporary location in Dillsburg, York County, Pennsylvania. .. . . 9. Plaintiffs have 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. 10. Plaintiffs do not know of a person not a party to the proceedings who has physical custody of the child or claims to have physical custody or visitation rights with respect to the child. 11. The best interests and permanent welfare of the child will be served by granting the relief requested because: a. Plaintiffs have established a strong bond the child; b. Plaintiffs are able to provide a nurturing stable environment for the child; c. Defendants are not currently in a position to adequately provide for the child's needs; d. Defendants agree that Plaintiffs should have custody of the child at this time. 12. 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. No other persons are known to have or claim a right to custody or visitation of the child to be given notice of the pendency of this action and the right to intervene. WHEREFORE, Plaintiffs respectfully request that they be granted primary physical and legal custody of their granddaughter. DATE: ?/zl/~ RESPECTFULLY SUBMITTED: ~ ...--'.~.' BY: / ------ ..-1eanne B. Costopoulos, Esquire ATTORNEY FOR PLAINTIFFS 3803 Gettysburg Road Camp HilI, PA 17011 Phone: (717) 920-2500 P A Supreme Ct. ID No. 68735 .4 po. t ROY STEPHEN REINER and, CYNTHIA ANN REINER, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. JASON BAUCUM and CARISSA BAUCUM, Defendants : CIVIL ACTION - LAW : IN CUSTODY VERIFICATION I, Roy Stephen Reiner, hereby verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. Date: griLl - 06 Signature: ~ c-/;-; J.. ~: - -.-J ROYSt~ VERIFICATION I, Cynthia Aml"Reiner, hereby verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. Date: ~ ~ Signature: ~ A) 1.. t - 0-> - ~I ~ V ~ ~ - - )..> . () ~ ~ ~ -....L.. 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"" 3 r:-i' U1 (.r. ~ '1-" nlp -ofT'", 'Ot'J ~'") T ~1~J "'1',-'f) ~)(~ :'-:::':rn o S;! ~ ROY STEPHEN REINER and, CYNTHIA ANN REINER, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. ; No. Dl- - 4~q Q."'U ~L'-r~ JASON BAUCUM and CARISSA BAUCUM, Defendants CIVIL ACTION - LAW IN CUSTODY STIPULATION FOR AN AGREED ORDER OF CUSTODY AND NOW, come the parties, Plaintiffs Roy Stephen Reiner and Cynthia Ann Reiner, and Defendants Jason Baucum and Carissa Baucum, and respectfully request the following Stipulation to be entered as an order of court: WHEREAS the parties, Jason Baucum and Carissa Baucum ("parents" hereinafter) have born to them one (1) child, namely Paije Anna Baucum, born August 27, 2004 ("child" hereinafter); and WHEREAS, the child is currently residing with her maternal grandparents, Roy Stephen Reiner and Cynthia Ann Reiner ("grandparents" hereinafter); and WHEREAS, all parties desire to enter into a comprehensive custody stipulation and agreement setting forth the physical and legal custody arrangements for the child; and WHEREAS, all parties have been provided an opportunity to review this Stipulation with the counsel of their choice prior to signing. THEREFORE, in consideration of the mutual covenants, promises, and agreements as hereinafter set forth, and intending to be legally bound, the parties agree as follows: 1. Lel!:al Custodv The parties shall share legal custody of the child. They shall consult with each other relative to all important decisions concerning the child, including such matters as health, education, and religion. Each parent shall consult with the other on all non-routine decisions (to be defined as those decisions with a greater than a day to day effect, including, but not limited to, such matters as surgery, major medical treatment, and selection of schools) with a view to having a harmonious policy calculated to promote the best interest of the child. Each of the parties shall have access to all the child's medical, dental, hospital, and school records, including test results and report cards; each party shall permit and encourage communication by the other parties with doctors, teachers, and school administrators regarding the child's health and education progress. 2. Physical Custody Grandparents shall have primary physical custody of the child. Parents shall have liberal partial physical custody of the child at times mutually agreed upon. Grandparents shall not unreasonably withhold partial physical custody of the child from parents. 3. Address and Phone Numbers of Parties All parties must keep each other informed of any changes of address or change of phone number. Any changes in address or phone number shall be immediately forwarded to all other parties. 4. Notice of Whereabouts /Illness Each party agrees to keep the others reasonably informed of the whereabouts of the child while with the other party. If any party has knowledge of illness or accident or other serious circumstance affecting the welfare of the child, he or she shall promptly notify the other parties of said circumstances. 5. Teleohone Contact with Child All parties shall have the right to reasonable telephone contact with the child during other party's periods of custody/visitation. No party shall interfere with the another party's telephone contacts with the child. Each party shall 2 make all reasonable efforts to promptly return calls or messages left by other parties regarding the child. 6. Alcohol and Drul!s During any period of custody or visitation, the parties shall not possess or use any non-prescribed controlled substance, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise assure that the child is not exposed to any other individuals who cannot comply with this prohibition 7. Disparallinl! Remarks No party shall make any remarks in the presence of the child or otherwise do anything which may estrange the child from or injure the opinion of the child as to another party or those closely associated with that party or which may hamper the free and natural development of the child's love or affection for the other parties or those closely associated with the parties. Under no circumstances shall adult issues involving the parties be discussed in the presence of the child. No party shall argue with other parties in the presence of the child. No party shall permit the child to remain in the company of any third parties who do not follow the provisions of this paragraph. 8. Modification Any of the provisions of this Stipulation may be modified or deleted upon mutual agreement of all parties or by subsequent Order of Court. 9. Supersedeas of Prior Court Orders This Stipulation, once signed, shall supersede all prior Court Orders, Stipulations, or Agreements. WHEREFORE, the parties, intending to be legally bound, and with the desire that this Stipulation be entered as an order of court at the request of either party, hereby set their hands and seals and the date of their acknowledgment. 3 . . ' . Date: 7!-(C{-(J0 Date: ~~ Date: ~ "7,.IIlV Date: 1.flf. t1 f/ Signature: ~hL~ y Stephen Reiner ~ Cyn . a Ann Rei \ c- 6 _):J~ ~ Signature: Signature: . l_~~ SIgnature: ~ ssa Ba 4 (") c: ~ "'Oij: mr-r; Z:-.;- -;;--,.. . ~I\~ ct,., 1', 7', ~() .r c:' ~ "-' = = a' ~ :i:!.." n1r= -Om ,nO ::-) I ~7'l~? ()-.~ '"M -' 6 -I it -< ;po ,- ci'5 N W .,., :x ~ U1 CO . . , ;; .RF;CEIVED AUG .2 4 2006 B; ROY STEPHEN REINER and, CYNTHIA ANN REINER, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. ; No. Df. -4ffl (!.;u~L <-r ~ JASON BAUCUM and CARISSA BAUCUM, Defendants : CIVIL ACTION - LAW : IN CUSTODY AND NOW, this ORDER OF COURT .)t;1y of ~ ,2006, upon consideration of the attached Stipulation for an Agreed Order of Custody which is incorporated herein by reference, IT IS HEREBY ORDERED AND DECREED that said Stipulation is hereby approved and adopted as an Order of Court with full weight and effect as if it had been set forth in full hereinafter. It is binding and enforceable upon the parties hereto. All prior Orders in this matter are hereby vacated. J. ,D\I) o ~/, o W\\fJ'ilASi\!N3d AlNnCC "'ir'J::iV~n8 61 :2 Wd 62 50V 9002 Al:l\I10NOHi08d 3H1:30 381::l30-a311~