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HomeMy WebLinkAbout02-3815TEKA M. SLOAN, RYAN BARRICK, Plaintiff VS. Defendant IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 02- 3 f/fi' CIVIL TERM :CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiffis Teka Sloan, residing at 617 West Pine Street, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 2. The defendant is Ryan Barrick, residing at 12 Kerrs Avenue, Carlisle, Cumberland County, Pennsylvania 17013. 3. The plaintiff seeks custody of the following child: Name Present Residence Age Trevor Sloan-Barrick 617 West Pine Street 10 months Mt. Holly Springs, PA 17065 The child was born out of wedlock. The child is presently in the custody of the mother, who resides at 617 West Pine Street, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. During the child's lifetime, he has resided with the following persons and at the following addresses: Name Teka Sloan Ryan Barrick Jodi Giant Frank Shoop Codi Fry Address 156B W. Penn St. Carlisle, PA 17013 Date Oct. 2001-Dec. 2001 Teka Sloan Ryan Barrick Jodi Glant Frank Shoop Codi Fry Teka Sloan Ryan Barrick Cody Sloan Teka Sloan Nancy Sloan Cody Sloan 12 Kerfs Avenue Carlisle, PA 17013 Dec. 2001-April 2002 27 Chesmut St. April 2002-June 2002 Apt. 5 Mt. Holly Springs, PA 17065 617 West Pine St. June 2002-present Mt. Holly Springs, PA 17065 The mother of the child is Teka Sloan, currently residing at 617 West Pine Street, Mt. Holly Springs, Pennsylvania 17065. She is single. The father of the child is Ryan Barrick, currently residing at 12 Kerr Avenue, Carlisle, Pennsylvania 17013. He is single. 4. The relationship of plaintiff to the child is that of mother. The plaintiff currently resides with the following persons: Name Relationship Trevor Sloan-Barrick son Cody Sloan son Nancy Sloan grandmother 5. The relationship of defendant to the child is that of father. The defendant currently resides with the following persons: Name Relationship Codi Fry brother Jodi Glant mother 6. The 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. 7. The plaintiff has no infoi-iixation of a custody proceeding concerning the child pending in a court of this Commonwealth. 8. The plaintiff does 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. 9. The best interest and permanent welfare of the child will be served by granting the relief requested for reasons including, but not limited to the following: i.) The mother has been the primary caregiver since the child's birth and she has established a stable residence for the child and his half-sibling. ii.) The father has not acted in the best interest of the child in ways including but not limited to the following: a. The father has anger management problems when it comes to dealing with the routine care of the child. b. The father has repeatedly threatened to remove the child from the mother's custody and a custody order will stabilize the situation. 10. 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. WHEREFORE, the plaintiff requests this Court to grant primary physical custody of the child to the plaintiff with partial custody in the defendant every other weekend from 10:00 a.m. to 7:00 p.m. on Saturday and 10:00 a.m. to 7:00 p.m. on Sunday and at times mutually agreed upon by the parties. Plaintiff further requests any other relief that is just and proper. Respectfully submitted, Attorney for Plaintiff Mid Penn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 VERIFICATION I verify that I am the Plaintiff as designated in the present action and that the facts and statements contained in the above Custody Complaint are tree and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. {}4904, relating to unswom falsification to authorities. Dated:~-7-F)0 ,0'~_,~ ~ ~ - - Teka Sloan, Plaintiff TEKA M. SLOAN, RYAN BARRICK, Plaintiff VS. Defendant : In The Court of Common Pleas of : : CUMBERLAND County, Pennsylvania No. 02-~/~Civil Te~ci : Custody CUSTODY ORDER AND NOW, this ~ ' day of August, 2002, the following Order is entered by consent of the parties with regard to custody of the parties' child, Trevor Sloan-Barrick, born October 10, 2001. 1. Plaintiff, Teka M. Sloan, hereinafter referred to as the mother shall have primary physical and legal custody of the child. 2. Defendant, Ryan Barrick shall have visitation according the following schedule: a. Every other weekend from 10:00 a.m. to 7:00 p.m. on Saturday and from 10:00 a.m. to 7:00 p.m. on Sunday, and b. At other times mutually agreed upon by the parties. 3. The father's visitation shall take place in the presence of Jodi Glant, Frank Shoop, Sharon Barrick and/or Teka Sloan. 4. The father shall not consume alcohol for a period of twelve hours prior to and during the visitation periods and shall insure that there is no consumption of alcohol by anyone during his visitation periods. 5. The father shall enter and complete anger management and parenting skills courses and provide verification of his enrollment to the mother before his visitation commences; he shall further provide the mother and/or her attorney with notification of attendance and completion of the program. he shall further provide the mother and/or her attorney with notification of attendance and completion of the program. 6. The mother shall be responsible for all transportation. 7. The mother and father agree that each shall notify the other immediately of medical emergencies that arise while the child is in that parent's care. 8. Neither party shall do anything which may estrange the child from the other parent, or injure the opinion of the child as to the other parent or which may hamper the free and natural development of the child's love or respect for the other parent. 9. The mother and father may vary from this schedule by mutual agreement, by this Order shall remain in effect pending further order of court. By the Co~~ , Judge This Order is entered pursuant to the consent of Plain~~~ Teka M. Slo~ ;~f~c~l~, Defenda~ ~ ~Carey, Attorney f~./Plaintiff ...,~f. _ ~ v~/j.~_~..~__~.,~.~__ B~ck, Defendant Pro Se /Mi~e~ Legal Se~ic~ 12 Ke~s Avenue 8 I~ine Row C~lisle, PA 17013 Carlisle, PA 17013