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HomeMy WebLinkAbout02-2129JUDITH STAFFORD Plaintiff V. RONNIE D. HICKS Defendant : IN TI-IE COURT OF COMMON PLEAS OF : CUMBERI.AND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : :NUMBER ~.~-,~/-~9 CIVILTERM : IN DIVORCE STIPULATION AND AGREEMENT COME NOW, the Plaintiff, ~[lgiithS~ffo~, by and through her counsel, SALLY J. WINDER, ESQUIRE, and Defendant, ~ali.cJ)~:lif,~, and stipulate and agree as follows: 1. The Plaintiff is the paternal grandmother of a minor child, ~ bom _la:~¢~,l/~, currently residing with Plaintiff ~ at ~ ~ Newburg. Cumberland County, Penn.~ylvania. 2. The parties hereto and each of them agree that the grandmother J~;iillLSlal~fial~ is capable of caring for the minor child and is presently caring for the minor child, and it is in the child's best interest and for her permanent welfare that primary residential and physical custody of the child be awarded to grandmother, ~udilh~.~fnla~. 3. The father, _P~azlie~l~_, shall have certain rights of partial custody and visitation with the minor child as the parties may from time to time mutually agree. 4. Father shall have certain rights of partial custody and visitation with the minor child at such time as he shall have a permanent residence and shall have demonstrated that he is capable of caring for the child. 5. Grandmother, _J~llliIll.$3a~:l~, shall not unreasonably withhold fights of partial custody and visitation as requested by mother/father. 6. The parties agree that this stipulation shall be entered as an order by the Court without the necessity of their presence. IN WITNESS WHE~OF, the parties hereto and each of them have hereunto set their hands and seals intending to be legally bound hereby. WITNESS: JUDITH STAFFORD Plaintiff Vo RONNIE D. HICKS Defendant : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA : : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY COMES NOW, the Plaintiff, JUDITH STAFFORD, by and through/her counsel, Sally J. Winder, Esquire, and does represem as follows: 1. The Plaintiff is JUDITH STAFFORD, residing at 60 East Creek Road, Newburg, Cumberland County, Pennsylvania 17240. 2. The Defendant is RONNIE D. HICKS, residing at the last known address of 125 South Queen Street, Apt. 2, Chambersburg, Franklin County, Pennsylvania. 3. Plaintiff seeks Custody of the following child: Aislinn Renae Hicks, bom June 20, 2000. The child was bom out of wedlock. The child is presently in the custody of Plaintiff, who resides at 60 East Creek Road, Newburg, Pennsylvania. Since birth, the child has resided with the following persons and at the following addresses: with Plaintiff, Judith Stafford at 60 East Creek Road, Newburg, Pennsylvania. The mother of the child is Lila Jackson. currently residing at an unknown address and whose whereabouts is unknown. The father of the child is Ronnie D. Hicks, currently residing at and having a last known address of 125 S. Queen Street, Chambersburg, Pennsylvania. He is single. 4. The parties have entered into a Stipulation and Agreement for the custody of Aislinn R. Hicks as attached to, and filed with this Complaint and Plaintiffrequests the entry of an Order in the foc~n submitted as agreed upon in the stipulation and agreemem. 6. Plaintiff has not participated as a party or wimess, or in another capacity, in other litigation concerning the custody of the child(ren) in this or another Court. Plaintiff has no information ora custody proceeding concerning the child(ren) filed in a Court of this Commonwealth Plaintiff knows/does not know of a person not a party to the proceeding who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interests and pe~tnanent welfare of the child, will be served by granting the relief requested because the child has resided with the Plaintiff since birth and she is the only adult who has provided for the physical and emotional needs of the child. WHEREFORE, Plaintiff requests the Court to grant Custody of the child to Plaintiff as set forth in the attached Stipulation and Agreement. Respectfully submitted, S~ally J. ~inder, Esquire Attorney for Plaintiff VERIFICATION I verify that the statements made in this complaint are true and correct to the best of my personal kn_owledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. JUDITH STAFFORD Plaintiff RONNIE D. HICKS Defendant : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA : : CIVIL ACTION - LAW : : NUMBER 0~- ,,Qt~9 CIVIL TERM : IN DIVORCE ORDER OF COURT AND NOW, this ff.~l~ day of'q~my, 2002, upon consideration of the Stipulation and Agreement and Motion of Sally J. Winder. Esquire, it is hereby ORDERED AND DIRECTED, 1. Primary physical and residential custody of Aislinn Renae Hicks, born June 20.2000, is hereby awarded to, and placed in, thc Plaintiff. Judith Stafford. 2. Father, Ronnie D. Hicks, shall not exercise any fights of partial custody or visitation with the minor child, Aislinn Rcnac Hicks until such ti~ne as he shall have a permanent residence and shall have demonstrated that he is capable of caring for the child.