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Home My WebLink About06-6852 SAlOIS, FLOWER & LINDSAY .(ffi)1INE\'So,u.\AW 26 West High Street Carlisle, PA 11 OUGLAS W. KARPER, Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ~ No. O(p -- {p ~5 ol- C,w-i.. , OBBIE SUE KARPER , Defendant : Civil Action - Law : In Custody COMPLAINT FOR CUSTODY 1. The Plaintiff is Douglas W. Karper, an adult individual currently residing at 5 Snyder Heights, Richfield, Pennsylvania. 2. The Defendant is Bobbie Sue Karper, an adult individual with a current mailing address of P.O. Box 292, Boiling Springs, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant are the parents of four children namely: Richard Ward Levi Karper, born November 13, 1989, Douglas Ward Karper, II, born March 19, 1993, Quentin Seregei Karper, born March 3, 1996, and Samuel Raymond Karper, born August 30, 1999. 4. The parties presently share custody of the children, pursuant to a Custody Stipulation and Agreement executed November 18, 2006. 5. During the past five years, the children have resided with the following persons and at the following addresses: NAME ADDRESS FRONUTO Douglas Karper (all four) 33 Hamilton Rd. 08/2002 Boiling Springs, P A 17007 Douglas Karper (all four) 13 Park St. Mt. Holly Springs, P A 17065 08/2004 Fire at home children living with various families of church for 1 month OS/2005 SAIDIS, FLOWER & LINDSAY ATI{)IlNMoAT.\AW 26 West High Street Carlisle, PA II Douglas Karper (all four) 185 Kutz Road Carlisle, PA 17013 06/2005 Douglas Karper (Samuel & Quentin) RRl Box 1002 Richfield, P A 17086 08/2006 Bobbie Karper (Douglas & Richard) P.O. Box 292 Boiling Springs 17007 08/2006 Douglas Karper 5 Snyder Heights (Samuel, Quentin & Douglas)Richfield, PA 17086 11/05/2006 6. The mother of the children is Bobbie Sue Karper, with a current mailing address as aforesaid. She is single. 7. The father of the children is Douglas W. Karper, currently residing as aforesaid. He is married. 8. The relationship of the Plaintiff to the children is that of natural father. The Plaintiff currently resides with his wife and two (2) of the children namely, Quentin Seregei Karper and Samuel Raymond Karper, pursuant to the terms of the Agreement dated November 18,2006. 9. The relationship of the Defendant to the children is that of natural mother. The Defendant currently resides with two (2) of the children namely, Richard Ward Levi Karper and Douglas Ward Karper, II, pursuant to the terms of the Agreement dated November 18,2006. 10. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation concerning the custody of the children in this or another jurisdiction. 11. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. SAlOIS, ROWER & LINDSAY ~~folAW 26 West High Street Carlisle, PA 12. The Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 13. The parties desire that the terms of the Custody Stipulation and Agreement executed by them on November 18, 2006 be incorporated into an Order of Court. WHEREFORE, the Plaintiff requests this Court to grant him shared physical custody ofthe children. Respectfully submitted, SAlDIS, FLOWER & LINDSAY ated: ll/l<b(00 > '7b/ l:C N) Matas, Esquire Attorne Id.84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff . SAlOIS, FlOWER & LINDSAY AT!ORNnSo/J.\AW 26 West High Street Carlisle, PA II VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and orrect on behalf of DOUGLAS W. KARPER who is outside the jurisdiction of this court d upon information provided to me by him. I understand that false statements herein e made subject to the penalties of 18 Pa. C.S. ~ 4904, relating tp unsworn falsification authori ti es. 00 -<..... ~~ ~v -- ~J ~ 0- - ~~ I..N -. ~ ......... ~ ~ () C ~?"' 8f.0, ~:6~;', gc) ~:g ?c ~ ~ ~ = a"' % o ..c N \D -0 3 r C> (..) ~ :r i11~ :Bt? (~O ~'"t., i5-d ZO om ~ ~ SAIDIS, FLOWER & LINDSAY ~AT.IAW 26 West High Street Carlisle, PA ~ " I ~ DOUGLAS W. KARPER, : COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : NOt, ~ ~ fS;;.. W ~ . o. BOBBIE SUE KARPER , : Civil Action - Law Defendant : In Custody STIPULATION AND AGREEMENT FOR CUSTODY THIS STIPULATION AND AGREEMENT entered into the day and year hereinafter set forth, by and between DOUGLAS W. KARPER (hereinafter referred to as "Father") and BOBBIE SUE GORDON (hereinafter referred to as "Mother"). WHEREAS, the parties are the natural parents of the following four (4) children: Richard Ward Levi Karper (born 11/13/89); Douglas Ward Karper, " (born 03/19/93); Quentin Seregei Karper (born 03/03/96); and Samuel Raymond Karper (born 08/30/99); WHEREAS, the parties live separate and apart, and wish to enter into a comprehensive stipulation and agreement relative to physical and legal custody of their children; NOW THEREFORE, in consideration of the mutual covenants, promises and agreements as herein set forth, the parties stipulate and agree as follows: 1. Mother and Father shall exercise shared legal custody of the children. 2. Father shall exercise primary physical custody of the children, Quentin and Samuel. 3. Mother shall exercise primary physical custody of the children, Richard and Douglas. SAIDIS, ROWER & LINDSAY MrullNEYiMfoIAW 26 West High Street Carlisle, PA " I ... 4. Each parent shall exercise periods of partial physical custody of the children not in their primary physical custody at times as can be agreed. 5. The parties shall keep each other advised in the event of serious illness or medical emergency concerning the children and shall further take any necessary steps to ensure that the health and well-being of the children is protected. During such illness or medical emergency which might require hospital care, both parties shall have the right to visit the children at the hospital as often as he or she desires consistent with the proper medical care of the children. 6. Neither parent shall do anything which may estrange the children from the other party, injure the opinion of the children as to the other party, or which may hamper the free and natural development of the children's love and affection for the other party. 7. Any modification or waiver of any of the provisions of this Agreement on a permanent basis shall be effective only if made in writing, and only if executed with the same formality as this Stipulation and Agreement. 8. The parties desire that this Stipulation and Agreement be made an Order of Court of the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County does, in fact, have jurisdiction over the issue of custody of the parties' minor children. 9. The parties stipulate that in making this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of the other party. SAlOIS, FlOWER & LINDSAY ATIOIINIMloAT.lAW 26 West High Street Carlisle. PA II i 10. r- The parties desire that this Stipulation and Agreement be made an Order of Court of Common Pleas of Cumberland County. IN WITNESS WHEREOF, The parties hereto intending to be legally bound by the terms hereof, set forth their hands and seals the day and year hereinafter mentioned. ~~ ,~~.O~ \,/ Il/rr/~ II / ~/O,b ~ ..t- ,r//. Ou~S W. Karper Cy5.JLs:~ Bobbie Sue Kar er .. SAIDIS, FLOWER & LINDSAY ATRJRNEYSoAT.IAW 26 West High Street Carlisle, PA 'I COMMONWEALTH OF PENNSYLVANIA: . : SS COUNTY OF ~ On this rl-lh day of ~ ' 2006, before me, the undersigned officer, personally appeared DOUGLAS W. KARPER, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. JlMLC.~ Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Susan E. Truitt, Notary Public COMMONWEALTH OF PENNSYLVANIA: FayelteTwp.,JuniataComty S S My Qommission Expires June 5, 2008 r.._ . : COUNTY OF ~~{} ~ : Member, PennsylvBOIa AssocialionOf Notaries On this 7 ~ day of )(\~D J... ,2006, before me, the undersigned officer, personally a~red BOBBIE SUE GORDON, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal L _....IEAL MERLENE J. IMRHMA. .JMlVMUC CARLISLE. CUMBEfUlI) UVVI'I_I" PI\ MY COMMISSION EXPIREI.uEiI01. NOV 2 0 2()(J) (") "1:}~ ~Pi -;I "Y-. ~-_. ..... 8; :~:~~. ~c :2:,,-) ~.o :':;;"C z ~ JA38 JMlATOIt :JJ8t,q "'AtOM ,AWRHR'lM t ~vn ! --{Iii A't .)1~.;(I:) OMAJR~';"I!'l l' , OtlN ,r. ii,f If, 2,~~I~,'(j .' ~.\' ----....-..~ ,.....,. N> = = t;;F' % o -< N \.0 -U ~ ~ =2:n ~fTl t36 :~~ 11 (~B 'c--m ~ ~ ~ .r:- Cl I.D " SAlOIS, HOWER & LINDSAY ATfOIlNn"SoAT.\AW 26 West High Street Carlisle, PA 's J DEe Q IlUUr : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ~ No. tJ'--c'fP- ~ DOUGLAS W. KARPER Plaintiff BOBBIE SUE KARPER, : Civil Action - Law Defendant : In Custody ORDER OF COURT ;\h AND NOVV, this 5- day of Q e...t..l.~~~(, ,2006, the attached Stipulation and A!~reement for Custody is hereby made an Order of Court. Cc: Marylou Matas, Esquire Attorney for Plaintiff Bobbie Sue Gordon, pro se 200 South Ridge Road Boiling Springs, PA 17007 BY THE COURT: J. ~.~ /J-~ ,t:J(, 4-. S S :8 H\f 9- J30 9DOl .. '''1'''\ '" . i", '::1 -Hl :JO Ak" f f'\!, ;,., ':, >", .. U't....~JI ,..,"'1....:......11,.'"'1 -' 3;)U::iO--031!:1