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HomeMy WebLinkAbout02-2621 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NICOLE R. RANCK Plaintiff, VS. STUART L. NORTHCRAFT Defendant· : CIVIL ACTION - LAW : IN CUSTODY ~COMPLAINT FOR CUSTODY The Plaintiff is Nicole R. Ranck, presently residing at 403 Hilltop Road, Newburg, Cumberland County, Pennsylvania 17240. The Defendant is Stuart L. Northcraff, presently residing at 2107 Orens Road, Middle River, Baltimore County, Maryland 21220, with a mailing address of PO Box 53, Pleasant Hall, Pennsylvania 17246. Plaintiff seeks custody of the following child: NAME Kailee Nichele Ranck The child was bom out of wedlock. PRESENT RESIDENCE 403 Hilltop Road Newburg, PA 17240 AGE 3 years DOB: 2/9/99 The child is presently in the custody of mother who resides at 403 Hilltop Road, Newburg, Pennsylvania 17240. During the past five years, the child has resided with the following persons and at the following addresses: NAME Robert Ranck, grandfather Doris Ranck, grandmother Stacey Ranck, aunt Nicole Ranck, mother ADDRESS 403 Hilltop Road Newburg, PA 17240 DATE February 9, 1999 (birth) to October 29, 2000 Nicole Ranck, mother 10 West Main Street Newburg, PA 17240 October 30, 2000 to October 29, 2001 Robert Ranck, grandfather Doris Ranck, grandmother Stacey Ranck, aunt Nicole Ranck, mother 403 Hilltop Road Newburg, PA 17240 October 30, 2001 to Present The mother of the child is Nicole Ranck, currently residing at 403 Hilltop Road, Newburg, PA 17240. She is single. The father of the child is Stuart L. Northcraft, presently residing at 2107 Orens Road, Middle River, Baltimore County, Maryland 21220, with a mailing address of PO Box 53, Pleasant Hail, Pennsylvania 17246. He is single. The relationship of Plaintiff to the child is that of mother. The Plaintiff currently resides with the following persons: NAME RELATIONSHIP Robert Ranck Father Doris Ranck Mother Stacey Ranck Sister Kailee Nichele Ranck Child The relationship of Defendant to the child is that of father. resides with the following persons: NAME Unknown RELATIONSHIP The Defendant currently Plaintiff has 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. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonweaith. Plaintiff does not know of a person, not a party to the proceedings, who has physicai custody of the child or claims to have custody or visitation rights with respect to the child. The best interest and permanent welfare of the child will be served by granting the relief requested because the Plaintiff has been the sole legai and physical custodian of the child since the child's birth. WEIGLE & ASSOCIATES, RC. -- ATTORNEYS AT [-AW -- 126 EAST KING STREET -- SRIPPENSBURG, PA 17257-1397 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. Ail other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: NAME None ADDRESS BASIS OF CLAIM WHEREFORE, Plaintiff requests the Court to grant both legal and primary physical custody of the minor child to the Plaintiff. By: WEIGLE & ASSOCIATES, P.C. I.D.#71755 126 East King Street Shippensburg, PA 17257 Telephone 717-532-7388 WEIGLE & ASSOCIATES, P.C. -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG. PA 17257-1397 VERIFICATION I verify that the statements made in the foregoing Complaint for Custody 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. Dated: ~. ~t~ .(.~,~ NICOLE-RTRANcK - . _ WEIGLE & ASSOCIATES, IRC. -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257o~397 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NICOLE IL RANCK Plaintiff, VS. STUART L. NORTHCRAFT Defendant. CIVIL ACTION - LAW IN CUSTODY STIPULATION AND AGREEMENT This Stipulation and Agreemem is made this /[ ~' day of ~'~/45~t ~-y , 2002, by and between Nicole R. Ranck of 403 Hilltop Road, Newburg, Cumberland County, Pennsylvania 17240, hereinafter referred to as "Mother") and Smart L. Northcraft of 2107 Orens Road, Middle River, Baltimore County, Maryland 21220, with a mailing address of PO Box 53, Pleasant Hall, Pennsylvania 17246, (hereinafter referred to as "Father"). 1. Nicole R. Ranck and Stuart L. Northcraft are the natural parents of Kailee Nichele Ranck, bom February 9, 1999,.hereinafter referred to as "the child". 2. Nicole R. Ranck and Stuart L. Northcraft were not married at the time of the birth of the child. 3. No prior custody action has been filed with the court. 4. The child, Kallee Nichele Ranck, is presently in the care and custody of Mother. 5. During the last five years, the child has resided with the following persons and at the following addresses: NAME Robert Ranck, grandfather Doris Ranck, grandmother Stacey Ranck, aunt Nicole Ranck, mother Nicole Ranck, mother ADDRESS 403 Hilltop Road Newburg, PA 17240 10 West Main Street Newburg, PA 17240 DATE February 9, 1999 (birth) to October 29, 2000 October 30, 2000 to October 29, 2001 Robert Ranck, grandfather 403 Hilltop Road October 30, 2001 to Doris Ranck, grandmother Newburg, PA 17240 Present Stacey Ranck, aunt Nicole Ranck, mother The parties have not participated as a party or wimess, or in another capacity, in other litigation concerning the custody of the child in this or another court. The parties have no information of a custody proceeding concerning the child pending in a court of this Commonwealth. WEIGLE, PERKINS ~{ ASSOCIATES -- ATTORNEYS AT LAW -- 126 EAST KING STF1EET -- SHIIPPENSIBURG, IDA ~7257-1397 7. Each parent whose parental rights to the child have not been tcmfinated and the person who has physical custody of the child have been named as parties to this action. 8. Neither of the parties know of any person not a party to the proceedings who has physical custody of the child, or claims to have custody or visitation rights with respect to ~e child. 9. Mother and Father understand that the words "legal custody," "physical custody," and "visitation" as they are used in this agreement are defined under Pennsylvania statutory law at 23 Pa CSA § 5302 as follows: a. "Legal Custody." The legal right to make major decisions affecting the best interest of a minor child, including, but not limited to, medical, religious and educational decisions. b. "Physical Custody." The actual physical possession and control of a child. c. "Visitation." The right to visit a child. The term does not include the right to remove a child from the custodial parent's control. 8. The parties have reached an agreement with regard to the custody of the child and desire to reduce their agreement to an Order of Court. NOW THEREFORE, the parties intending to be legally bound and waiving their right to be present when this Agreement and Order are presented and executed hereby stipulate and agree that the Court may enter the following Order of Court in the above-captioned case: ORDER OF COURT NOW, ,2002, upon consideration of the within Stipulation and Agreement, it is hereby ordered as follows: 1. Nicole R. Ranck ("Mother") shall have sole legal custody of the minor child, Kailee Nichele Ranck, bom February 9, 1999 ("the child"). 2. Mother shall have sole physical custody of Kallee Nichele Ranck. 3. Stuart L. Northcraft ("Father") may exercise limited supervised visitation with the child. Father shall provide Mother with at least two (2) weeks prior notice of his visitation request to Mother. Visitation shall take place at a mutually agreed upon date and time. Visitation shall take place under Mother's supervision at the Mother's residence or such other place as the parties may mutually agree. 4. Under no circumstances shall Father remove or attempt to remove the child from the physical care and control of Mother. 5. Under no circumstances shall Father remove or attempt to remove the child from the Commonwealth of Pennsylvania. 6. The costs of this proceeding have been paid by Mother. By the Court, WEIGLE, pEFtKINS & ASSOCIATES -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397 The parties further agree that, in procuring this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of the other. IN WITNESS WHEREOF, the parties, intending to be bound by the terms and conditions of this agreement, execute this Agreement by signing below. Witness NICOLE R. RANCK COMMONWEALTH OF PENNSYLVANIA : : SS COUNTY OF CUMBERLAND : On this, the !_~ day of ~'j'~r79n~, , 2002, before me a Notary Public in and for said County and State, the undersigned officer, perso~aally appeared Smart L. Northcrafi, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official s~al. COMMONWEALTH OF PENNSYLVANIA : : COUNTY OF CUMBERLAND : SS (SEAL) ii NOTARIAL SEAl_ P~MELAA SWITALSKI Notary Public Shippensburq~ Cumbeda~nd County On this, the I I day of ~--xo~b ,2002, before me a Notary Public in and for said County and State, the undersigned officer, personally appeared Nicole R. Ranck, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. (SEAL) I NOTARIAL SEAL [ DEBORAH WARREN, Notmy Public I , Shippensburg, Cumberland County ~ Mv Commission Expires Nov. 8, 2005' WEIGLE, PERKINS E~ ASSOCIATES -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG. PA 17257-1397 I verify that the statements made in this Stipulation and Agreement are tree and correct. 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. Dated: ~b. ~!, gt/~> NICOLE R. RANCK I verify that the statements made in this Stipulation and Agreement are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to falsification to authorities. Dated: )t"ef~t /1! Z~OY. STUA.~TL. NOR~HCRAFT-~ ,/~.~ WEI(~LE, PERKINS ~ ASSOCIATES -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NICOLE IL RANCK Plaintiff, VS. STUART L. NORTHCRAFT Defendant. CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT NOW, ~' ~ ~ ., 2002, upon consideration of thc within Stipulation an Agreement, it is hereby ordered as follows: 1. Nicolc R. Ranck ("Mother") shall have sole legal custody of the minor child, Kailec Niche] Ranck, born February 9, 1999 ("the child"). 2. Mother shall have sole physical custody of Kailce Nichele Ranck. Stuart L. Northcraft ("Father") may exercise limited supervised visitation with the child. Fath~ shall provide Mother with at least two (2) days prior notice of his visitation request to Mothe Visitation shall take place at a mutually agreed upon date and time. Visitation shall ta~ place under Mother's supervision at the Mother's residence or such other place as the patti{ may mutually agree. Under no circumstances shall Father remove or attempt to remove the child from the physic~ care and control of Mother. Under no circumstances shall Father remove or attempt to remove the child from ti Commonwealth of Pennsylvania. 6. The costs of this proceeding have been paid by Mother. WEIGLE, PERKINS ~ ASSOCIATES -- ATTORNEYS AT 1AW -- 126 EAST KING STREET -- SHIPPENSBURG, Pa 17257~1397 :