HomeMy WebLinkAbout06-4949
o
/
'"
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 0& - l./9i./q CJVI\
SUE BARTHOL,
Plaintiff
RACHEL THIESSEN,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
COMPJ.,AINT FOR. CY~TODY
AND NOW, comes the Plaintiff, Sue Barthol, through her attorney, Mindy
S. Goodman, and avers the following:
1. Plaintiff is an adult individual residing at 107 Valencia Avenue,
Aptos, California.
2. Defendant is an adult individual residing at 216 Rosemont Avenue,
New Cumberland, Cumberland County, Pennsylvania.
3. Plaintiff is the mother of and Defendant stand in loco parentis to
MARTINA M. BARTHOL, born on December 14, 1993.
4. When Plaintiff adopted the minor child, she did so as a single-
parent adoption and there is no other legal parent than the Plaintiff.
5. As a result of Plaintiff's health and a desire to do what is best for
her daughter, she and Defendant have come to an agreement with regard to the
issues of child custody and have entered into a stipulation, which is filed
simultaneously with this Complaint.
/"
'"
WHEREFORE, Plaintiff requests this Court enter an Order adopting the
stipulation that is filed simultaneously herewith.
Respectfully submitted,
~6....:5 G.:o.D
Mindy S. Goodman
Attorney at Law
10 No. 78407
2215 Forest Hills Drive - Suite 35
Harrisburg, PA 17112
(717) 540-8742
Attorney for Plaintiff
I'~
"
VI;RIEICA TION
I verify that the statements made in the foregoing document are true and
correct. I understand that false statements made herein are subject to the
penalties of 18 Pa.C.S. ~ 4904, relating to unsworn falsification to authorities.
~l}oncdL
Sue BartHo
(<::I
~
C'"
'l'"
~
~~
v..t:.
<:;::rY
tJ'.\ r*
V\
"
"
'4'r Q $ Q.
c
::;: 0'
- ""oi:';' """ ~..,.,
- r,' I I c;:: rne
"t-> z~ G'>
,,< " ~ -art"
(:) .;;- :(JY
C> ,,::: I~~:\~
:-_. 4J
C :C' -,~
-.:,,' -
~;:~~~ w '25'....
..... ~
~ 3- ~ ?Q
u'
~
~
~
"
\
I
,
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. Mr 'IqLIQ
SUE BARTHOL,
Plaintiff
RACHEL THIESSEN,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
$TIPJJLA TIQti.FOR A-H ~G~EI2.QBg~'~ QF CUST.QQY
AGREEMENT, made this ;2;;;t day of ltu. (;.U ";,'/ , 2006,
by and between SUE BARTHOL, hereinafter referred to as "Mother," and
RACHEL THIESSEN, hereinafter referred to as "Rachel."
~
WHEREAS, Plaintiff is the adoptive mother of Martina M. Barthol, whose
date of birth is December 14,1993; and
WHEREAS, Defendant stands in loco parentis to the minor chilcl as a
result of the chilclliving with Defendant for a period in excess of one year and
Defendant having cared for the minor chilcl since the child came into her care and
custody; and
WHEREAS, the parties have come to an agreement concerning the
issues of chilcl custody; and
I
"
WHEREAS, the parties desire that this Stipulation be entered as an Order
by the Court of Common Pleas of Cumberland County, Pennsylvania;
NOW THEREFORE, intending to be legally bound, the parties hereby
stipulate and agree as follows:
L~~AL ClJ$TQID:
1. Rachel shall have primary legal custody of the minor child,
MARTINA M. BARTHOL, legal custody being defined as the legal right to make
major decisions affecting the upbringing of the child, including but not limited to
medical, religious, and educational decisions.
2. Mother has a right to be kept informed ofthe child's educational
and medical development, and shall have a right of access to the child's
educational and mediCal records. Mother shall be entitled to complete and full
information concerning the child from Rachel and from any doctor, dentist,
teacher or similar authority, and to have copies of any reports, notices or other
communications given to Rachel as the individual having primary physical
custody of the minor child.
3. Rachel shall notify Mother of any matter relating to the child, which
could reasonably be expected to be of significant concern to Mother.
?
"
I
eUYSICAL CV'lQQX
4. Rachel shall have primary physical custody of the minor chilcl,
primary physical custody being defined as actual physical possession and control
of the child. Mother shall have partial custody rights with the child as determined
by rnutual agreement between the parties
5. The parties shall share holidays as mutually agreed between the
parties.
6. It is understood and stipulated by the parties that upon mutual
agreement and expanded or altered schedule may be agreed upon between the
parties and that such mutual agreement woulcl be in the best interests of the
chilcl.
7. The parties shall refrain from making derogatory comments about
the other party in the presence of the child and to the extent possible shall
prevent third parties from making such comments in the presence of the child.
WHEREFORE, the parties request that this Stipulation be entered as an
Order of the Court.
~ q ~.Q-------
Wi v"'-n-1<\Jo..\'~v
~d
~ :.~. ~ 6~.Q
ness
--{{A ~
Rachel Thiessen, Defendant
~
;~!
'Iii ~.~"'l'. ;il;t\
. 'll'l~ '\. ~
,l . .1' " ~,'
(,- ;,\ ,", "
"
~--
'';'
'(.-f ~,t\:
. .. ~."",:~
-;
,\,.
;y
n
c
<:.
-t."~:::
P'l f'
"-I'
,,,-:""'
:Z:
~~J.
~':
>',
:::;(-_.
"<:-"..,,_.-
, ~."-
?~
-<:
\
.tfJ;>.~
<:/1_' \
~
"'"
a"
yo
c::
en
~
.;;-
-0
::It
<.?
..
"
Q.
~
r"~
-a.....
-,:)9
(~~I (\)
"\": :1i
(~o'
.{~.. \'1i
-g
?Ii
'"""
I'J
U'
e.l
,..: .>
RECEIVED
AUG ~. 4 2006
BY:
,
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
~ NO. () &, - J.fq 'ICI
SUE BARTHOL,
Plaintiff
RACHEL THIESSEN,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this
ZS- day of
4v'WI"" ,2006, it is hereby
,
ORDERED AND DECREED that the attached Stipulation for an Agreed Order of
Custody is made an Order of Court and said Stipulation is adopted in its entirety
and incorporated herein as an Order of Court.
BY THE COURT:
Dated:
--;(LAtL
Judge
./
,
.
g
<":
-o~i'
cpr_~
7,:(
~2:_
~C
2-:(
~~C~:
~c
Z
:;!
..
,
....,
"'"
=
cr-
o
-n
:I!-n
m-
-oFn
:DC?
OC'
"~j-Ti
:~'5='J
z~~
8
~
"'"
c:
<n
N
co
;po
3:
W
N