HomeMy WebLinkAbout02-3431 SAIDIS
SHUFF, FLOWER
& LINDSAY
26 W. High Street
Carlisle, PA
Richard A. Crawford and,
Debra L. Crawford,
Plaintiffs
Eve Clair Crawford,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. CIVIL 2002
STIPULATION FOR CUSTODY
AND NOW, these parties by and through the respective Counsel, to stipulate as
follows:
1. The Plaintiffs are Richard A. Crawford and Debra L. Crawford, adult individuals
residing 301 Meadows Road, Newville, Cumberland County, Pennsylvania.
2. The Defendant is Eve Clair Crawford is an adult individual residing at Box 252,
Shermansdale, Perry County, Pennsylvania;
3. The Plaintiffs are the grandparents of a child, Brayden Allen Crawford, date of
birth 03-14-2000.
4. The Defendant is the natural mother of Brayden Allen Crawford, date of birth 03-
14-2000.
5. The parties agree that the Plaintiffs shall have primary legal and physical custody
of said child.
6. The parties further agree that the Defendant, Eve Clair Crawford, may have
periods of partial physical custody of the child, as the parties may agree.
7. The parties desire this Agreement be evidenced by Order of Court.
8. The parties desire that this Court retain jurisdiction in this matter.
SAIDIS
SHUFF, FLOWER
& LINDSAY
26 W. High Street
Carlisle, PA
WHEREFORE, the parties respectfully request your Honorable Court to enter an
Order based on this Stipulation.
Respectfully submitted,
SAIDIS, SHUFF, FLOWER & LINDSAY
Dated:
Attorney I.D. # 53147
26 West High Street
Carlisle, PA 17013
(717) 243-6222
Attorney for Plaintiffs
Debra L. Crawford
Date:~ ~ ¢~¢~)~) ~
Richard M. Crawfo~f" ~
Date:~T)/v' ~_~. -C~-~ __
Eve lair ~ord~
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATrOI~YS*AT*LAW
26 W. High Street
Carlisle, PA
Richard A. Crawford and,
Debra L. Crawford,
Plaintiffs
Eve Clair Crawford,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. CIVIL 2002
COMPLAINT FOR CUSTODY
AND NOW comes the Plaintiffs, Richard A. Crawford and Debra L. Crawford, by and
through their attorney, Saidis, Shuff, Flower and Lindsay, and respectfully avers the following:
1. The Plaintiffs are Richard A. Crawford and Debra L. Crawford, adult individuals
residing at 301 Meadows Road, Newville, Cumberland County, Pennsylvania.
2. The Defendant is Eve Clair Crawford, an adult individual, residing at Box 252,
Shermansdale, Perry County, Pennsylvania;
3. The Plaintiffs are the grandparents of one child, Brayden Allen Crawford, date of
birth 03-14-2000;
4. The child was born out of wedlock. The child is presently in the custody of the
Plaintiffs. Since 2001, the child has lived with the Plaintiffs at their address, 301
Meadows Road, Newville, Cumberland County, Pennsylvania;
5. The mother of the child is Eve Clair Crawford, currently residing at Box 252,
Shermansdale, Perry County, Pennsylvania. She is not married;
6. The father of the child is Wade Leaky. His address, at the present time, is
unknown;
7. Plaintiffs have not participated as a part or witness, or in another capacity, on other
litigation concerning the custody of the child in this or another court. The court, term
and number, and its relationship to this action is: Not applicable.
SAIDIS
SHUFF, FLOWER
& LINDSAY
26 W. High Slreet
Carlisle, PA
Plaintiffs have no information of a custody proceeding concerning the child pending
in a court of this Commonwealth. The court, term and number, and its relationship
to this action is: Not applicable.
Plaintiffs do not know of a 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 the
child. The name and address of such person is: Not applicable.
8. The best interest and permanent welfare of the child will be served by granting
them custody at the present time, and which is agreed to by the Defendant,
pursuant to the attached Stipulation.
WHEREFORE, the Plaintiffs respectfully request your Honorable Court to grant them
legal and physical custody of said child, pursuant to the attached Stipulation.
Dated:
Respectfully submitted,
SAIDIS, SHUFF, FLOWER & LINDSA¥
Attorney I.D. # 53~47
26 West High Street
Carlisle, PA 17013
(717) 243-6222
Attorney for Plaintiffs
VERIFICATION
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. C.S. Section 4904,
relating to unswom falsification to authorities.
JDIS
~;DSAy
Street
PA
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATrORI~Y~*ATaLAW
26 W. High Street
Carlisle, PA
Richard A. Crawford and,
Debra L. Crawford,
Plaintiffs
Eve Clair Crawford,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. CIVIL 2002
ORDER
AND NOW this Z ~ d day July, 2002 a consideration of the attached Stipulation it
is hereby ordered and decreed that legal and primary physical custody of the child, Brayden
Allen Crawford, date of birth 03-14-2000, shall be with the Plaintiffs, subject to periods of
partial physical custody as the parties may mutually agree with the Defendant.
BY THE COURT:
Jo