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HomeMy WebLinkAbout02-4066 SA/DIS SHUFF, FLOWER & LINDSAY 26W. High Street Carlisle, PA Darryl Gross and Donna Gross, Petitioners Bruce Brighton, Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Wal - qoOt,. 2002 CIVIL COMPLAINT FOR CUSTODY 1. The Petitioners are Darryl Gross and Donna Gross, adult individuals residing at 1871 Old Main Drive, Box 18, Shippensburg, PA 17257. 2. The Respondent is Bruce Brighton, an adult individual residing at 158 Jacoby Street, Maplewood NJ 07040. 3. The Respondent is the natural Father of two children, Tiffany Brighton, D.O.B. February 22, 1989 and Carla Brighton, D.O.B. April 8, 1992. 4. The Petitioners are the Aunt and Uncle of the children, who are presently in their custody. 5. The children were not bom out of wedlock, and are presently residing with the Petitioners at 1871 Old Main Drive, Box 18, Shippensburg, PA 17257. 6. The Mother of the children is Leslie Brighton who is currently residing at 2750 Morris Avenue in Union, NJ; she is divorced. The Father of the children is the Respondent, Brace Brighton, currently residing at 158 Jacoby Street, Maplewood, NJ; he is divorced. The Petitioners have not participated as a party or witness in any other capacity in any other litigation concerning the custody of these children. Prior to this point in time, custody of these children was voluntarily given to Michael and Nicole SAIDIS SHUFF, FLOWER & LINDSAY 26W. High Street Carlisle, PA Debevec, the brother and sister-in-law of the Petitioners, through an informal agreement. 9. The parties have agreed to a Stipulation for Custody, which is attached hereto and made a part hereof simultaneously filed with this Complaint. WHEREFORE, the parties respectfully request your Honorable Court to enter an Order and adopt the Stipulation for Custody as filed with the Complaint. Dated: o-/~' -d'~_~ By: Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Petitioners VERIFICATION I verify that the statements made in this COMPLAINT FOR CUSTODY 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. Dated: 1 Gross, Petitioner Dated: O,t~z~. c-,qO, 0?002 Donna Gross, Petitioner SAIDIS SHUFF, FLOWER & LINDSAY 26W. High Street Carlisle, PA SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA Darryl Gross and Donna Gross, Petitioners Bruce Brighton, Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.o,k_ 4/0662002 CIVIL STIPULATION FOR CUSTODY AND NOW, comes the parties to stipulate as follows: 1. The Petitioners are Darryl Gross and Donna Gross, adult individuals residing at 1871 Old Main Drive, Box 18, Shippensburg, PA 17257. 2. The Respondent is Bruce Brighton, an adult individual residing at 158 Jacoby Street, Maplewood NJ 07040. 3. The Respondent is the natural Father of two children, Tiffany Brighton, D.O.B. February 22, 1989 and Carla Brighton, D.O.B. April 8, 1992. 4. The subject children are presently in the custody of the Petitioners. 5. The parties agree that they will all share legal custody of the subject children. 6. The parties agree that the Petitioners Darryl and Donna Gross shall have primary physical custody of said children. 7. The parties further agree that with the primary physical custody, the Petitioners shall be able to enroll them in the Shippensburg School District, provide medical care to the children including being covered by the Petitioner's major medical plan, and they will be in a position to make the day-to-day decisions best effecting the welfare of said children. 8. The parties further agree that the Respondent shall have periods of partial physical custody from time to time as the parties may agree. SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA 9. The parties agree that this be entered as an Order of Court, and that Cumberland County Pennsylvania shall have jurisdiction over the children. WHEREVORI:, the parties hereto request your Honorable Court to enter an Order awarding custody as stipulated above. Respectfully submitted, SAIDIS. SHUFF, FLOWER & LINDSAY Dated: J o h n n ~//..,,I/. Ko pe c~, Esqu~f~ AttornEy I.D. # 5'3147 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Petitioners Darryl Gross Date: O¢'''' ~ ~ O.~. Donna- (~ro~s -- Date: ruce Brighton ~ / ' Date: r~-~,,/fi/-' -~'9,..2---~- SAIDIS SHUFF, FLOWER & LINDSAY ATFOP, N~Y~*AT*LAW 26 W. High Street Carlisle, PA Dactyl Gross and Donna Gross, Petitioners Bruce Brighton, Respondent 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. O)'qO/a6 ~CIVIL ORDER AND NOW, this ~day of 2002 in the consideration of the attached COMPLAINT FOR CUSTODY and attached STIPULATION, it is hereby ordered and directed that the parties shall share legal custody of the subject children, Tiffany Brighton, D.O.B. February 22, 1989, and Carla Brighton, D.O.B. April 8, 1992. The Petitioners Darryl Gross and Donna Gross shall have primary physical custody of said children, subject to periods of partial physical custody with the Respondent, as the parties may agree. Dated: By: ~ J.