HomeMy WebLinkAbout02-2880AMBER NORMAN, :
Plaintiff :
..
V.
.,
JOSEPH CARR, :
Defendant :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. CIVIL ACTION - LAW
IN CUSTODY
COMPLAINT FOR CUSTODY
The plaimiff is Amber Norman, residing at 102 Big Spring Terrace, Newville,
Pennsylvania.
The defendant is Joseph Carr, residing at 331 Fairview Street, Carlisle, Pennsylvania.
Plaintiff seeks custody of the following child:
Name Present Residence DOB: 3/15/200 Age
Logan Norman 102 Big Spring Terrace, Newville, PA 2
The child was bom out of wedlock
The child is presently in the custody of Plaintiff, Amber Norman, who resides at 102 Big
Spring Terrace, Cumberland County, Newville, Pennsylvania.
During the past five years, the child has resided with the following persons and at the
following addresses:
List All Persons
Amber Norman
Courtney Lehman
Susan Gordon
List All Addresses
102 Big Spring Terrace, Newville, PA
102 Big Spring Terrace, Newville, PA
102 Big Spring Terrace, Newville, PA
Dates
3/15/2000 to present
3/15/2000 to present
3/15/2000 to present
The mother of the child is Amber Norman, currently residing at 102 Big Spring Terrace,
Newville, Pennsylvania.
She is not married.
The father of the child is Joseph Carr, currently residing at 331 Fairview Street, Carlisle,
Pennsylvania.
He is not married.
4. The relationship of plaintiff to the child is that of mother.
The plaimiff currently resides with the following persons.
maine
Sue Gordon
Courtney Lehman
Logan Norman
Relationship
Mother
Daughter
Son
5. The relationship of defendant to the child is that of father.
The defendant currently resides with the following persons.
Name Relationship
Anna Cart Grandmother
Plaintiffhas 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 children pending in a
court of this Commonwealth.
Plaintiff does not know of a person not a party to the proceedings who has physical
custody of the child and 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
request because:
Plaintiff has undertaken and performed the primary parental responsibilities for the child.
Plaintiff is best able to provide the care and nurture which the children need for healthy
development.
WHEREFORE, Plaintiffrequests that this Honorable Court enter the attached Stipulation
in regards to Custody, as the parties have come to a mutually agreeable custody agreement and no
further hearing is required in this matter.
Respectfully submitted,
Date:
Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Plaintiff
I verify that the statements made in this complaint are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to
unswom falsification to authorities.
Amber Norman, Plaintiff
AMBER NORMAN,
Plaintiff
JOSEPH CARR,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. CIVIL ACTION - LAW
IN CUSTODY
STIPULATION REGARDING CUSTODY-VISITATION
Plaintiff, Amber Norman, hereinafter referenced as Mother, and Defendant, Joseph Carr,
hereinafter referred to as Father, hereby agree to the entry of the following terms in a Court Order
defining custody and partial custody rights and responsibilities in relation to the parties' minor child:
Logan Norman, hereinafter referenced as Child:
(1) Shared legal custody of Logan Norman as contemplated by the Act of November 5, 1984,
P.S. §1001, et seq., is awarded to Mother and Father.
(2) Primary physical custody of the Child, Logan Norman is awarded to Mother subject to
partial custody to Father as follows, which he is directed to exercise:
(a) Visitation shall be mutually agreed upon by the parties.
(b) It is contemplated that Father will attend a Hemophilia Clinic with the child at
Hershey Medical Center, which takes place every six months, to become aware of how to treat
Hemophilia, and how to proceed if the child has a bleed, as the parties agree failure to treat
Hemophilia in a correct and immediate manner, may place the child in grave danger.
(c) It is further contemplated that as Father and son become familiar with one another, and
after paragraph (b) is satisfied, Mother will agree to, and encourage more frequent visitation, and at
discretion of Mother alone, allow overnight visitation and prolonged stays outside of the
Mother's home.
(d) It is further agreed that any and all medical providers are directed to provide either
parent upon request with complete access to medical records of the child.
(e) Father is not allowed to pick up/remove child from any daycare/private child care provider
at any time without the approval of the Mother.
(3) The parties mutually agree that this Agreement shall be submitted to the Court of
Common Pleas of Cumberland County, Pennsylvania for approval and entry of an Order awarding
custody as set forth herein; and the parents hereby request that this Honorable Court enter such an
Order.
Witness
Witness
a~,, ~Defendant '~
Date:
AMBER NORMAN, :
Plaintiff :
._
V.
JOSEPH CARR, :
Defendant :
IN THE COURT OF C(
CUMBERLAND COUN
No. CIVIL ACTIO
IN CUSTODY
AND NOW, this
ORDER
2002, in consideration of the attached Stipulation Regarding Custody aa
ordered that:
(1) Shared legal custody of Logan Norman as contemplated by
P.S. §1001, et seq., is awarded to Mother and Father.
(2) Primary physical custody of the child, Logan Norman is awe
partial custody to Father as follows, which he is directed to exercise:
(a) Visitation will be mutually agreed upon by the parties.
(b) It is contemplated that Father will attend a Hemophilia C
Hershey' Medical Center, which takes place every six months, to becon
Hemophilia, and how to proceed if the child has a bleed, as the parties a
Hemophilia in a correct and immediate manner, may place the child in
(c) It is further contemplated that as Father and son become fA
after paragraph (b) is satisfied, Mother will agree to, and encourage mor,
discretion of Mother alone, allow overnight visitation and prolonged sta
Mother's home.
~MMON PLEAS OF
TY, PENNSYLVANIA
N - LAW
td Visitation, it is hereby
he Act of November 5, 1984,
:ded to Mother subject to
[nic with the child at
aware of how to treat
tee failure to treat
ave danger.
Jliar with one another, and
frequent visitation, and at
s outside of the
(d)
upon request with complete access to medical records of the child.
(e) Father is not allowed to pick up/remove child from an dayca
at any time without the approval of the Mother.
(3) The parties mutually agree that this Agreement shall be subr
Common Pleas of Cumberland County, Pennsylvania for approval and,
custody as set forth herein; and the parents hereby request that this Hon
Order.
It is further agreed that any and all medical providers are directed to provide either parent
:e/private child care provider
fitted to the Court of
retry of an Order awarding
)rable Court enter such an