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Home My WebLink About96-04598 ~\ ...... ..... ~ I ~ ~ 0 ~ ! . I ~ ? ...... ~ ~ ~ o \ Z " , , / / r ~ I ~ I ~ I \':: l;: ~~; ;:; T -r., r- ~fi: 17:11) t!.; 1.1. o -'" c" M ,: u.. ,.., ~ 3-:1" ..")", ~:jo ~l ~j :.i3 ;.",;uJ _,<.1.. ::;J o Cl :., "" '" en ~ Ul .0: r.:! 1-1 'ID p.,.o:", Z'" ZZ.... Or.:! ~p., o - U>< E-r r...z 00 o E-rU 0:: 00 OZ u.o: 1-1 r.:!0:: :I:r.:! E-rlll lE: ZOO HUZ . 0::1-1 UlI-1 r.:! -0:: 1-10:: 1-10 r.:!Z 0:: 0:: 0:<: Z .0: '0 ..,Z .0: ><~ 0:: 0::'0 .0: c: III <1l = N "" -...J l(., ~ 1.:1 -::) -..J ~ ~ - 1-1 1-1 r.:! 0:: 0:: o Z .0: Z Z .0: , Ul :> 0 ..., Z .0: :r:: U E-r (<I 0:: '-' "" ..... Iv: -..:::;- t&--J v-, \l-- N'I ~...... ~' .......N ~.. ..... ~ c)~(0 >< o o E-r Ul o u Z H E-< Z H .0: H Po< lE: o U , , 00'" :-"J v:/ -'~y..z.-- r , ",.\", I" "i) _,0' < U ::l ~ ~ E w ..J ~ ~ o ~ ::t ~ I ~ i z ~ UJ 0: ~ o ~ ~ w... . U~5~ z ~ 0: < <( a: u I.J... .' ~ ~~ ~ ~ "'" .1 f' 1 t"<. ~ z ~ :.J ,. U) z z '" w 0 c. ~ GRETCHAN JOSANNA NORRELL .. IN CUSTODY BARRY J. NORRELL, SR. and WANDA K. NORRELL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PE~mSYLVANIA NO. CIVIL 1996 v. COMPLAINT FOR CUSTODY 1. Barry J. Norrell, Sr. and Wanda K. Norrell reside at 534 North Hanover street, Carlisle, Cumberland County, Pennsylvania, 17013, 2. Gretchan Josanna Norrell resides with her parents, Barry J. Norrell, Sr., and Wanda K. Norrell at 534 North Hanover Street, Carlisle, PA, 17013. 3. Gretchan Josanna Norrell, age 17, is a student at Carlisle High School and the natural mother of Kaitlyn Sierra Stitt born December 22, 1995. 4. The natural father, Robert Samuel Stitt is presently serving a sentence in the Perry County Prison. 5. The natural parents are not married. 6. The natural mother Gretchan Josanna Norrell has lived with her parents at 534 North Hanover Street for the past 13 years and her daughter Kaitlyn has resided there since her birth. 7. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody for the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child 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 or claims to have custody or visitation rights with respect to the child. 8. The best interest and permanent welfare of the child will be served by granting the relief requested because the plaintiffs have been the primary caretakers of the child since birth. 9. Each parent whose parental rights to the child have not terminated and the persons who have physical custody of the child have been named as parties to this action. WHEREFORE, plaintiffs, the maternal grandparents request the court to grant custody of Kaitlyn Sierra Stitt to them. J ) )" . /,tlle ".. ,'-, >/ )( d'h~' Frances H. Del Dllca '" Attorney for Plaintiffs I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made sUbject to the penalties of 10 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. Dated: PI/<///6 W~K~ FRANCES H. DEI. DUCA ATTORNEY AT LAW TEN We:ST HIGH flTREET CARL1SL~""'NN5YLVANIA 17013 02.p<-<~ - # tl/ X~____ t.t'.~}1'7J /(/ '~_-Si',/. ''J'1?rl'~ EAL ) Norrell , and WANDA K. NORRELL v. CUMBERLAND COUNTY, PENNSYLVANIA NO.1(,. It,j 1J CIVIL 1996 GRETCHAN JOSANNA NORRELL .. IN CUSTODY STIPULATION 1. Barry J. Norrell, Sr. and Wanda K. Norrell are the maternal grandparents of Kaitlyn Sierra Stitt born December 22, 1995 at Carlisle. 2. Gretchan Josanna Norrell, the natural mother of Kaitlyn Sierra Stitt, was born May 27, 1979 and is a student at Carlisle High School. 3. The natural father, Robert Samuel Stitt, of Kaitlyn Sierra Stitt is not married and is presently serving a sentence in the Perry County Prison. 4. Gretchan Josanna Norrell has always resided with her parents and Kaitlyn has also resided with the grandparents since birth. 5. The parties agree that Barry J. Norrell, Sr. and Wanda K. Norrell have legal and physical custody of Kaitlyn. \ WITNESS: W 6vJ.-v-}( y!<''''l..At.t2-Z, (SEAL) Wanda K. Norrell ~~; - - c:: c-,: ~ 1-' ~ wf'., ~ o- J u:L' " ~~~ ~F, ,- ; ::-:. If) ,- r' '~3 u.,..J ~ ~l" t.~ ltJJ u.. .~ i-'-- .,..:.; , , , '"'- Lt. ......, :3 u C) (,) _....._----_._------_.-."._.~--_._-~ ~~ ....."',.....,,.,.m~'~~~~~~'F.~~.,...;~.~,?l..'~,:'['f0'i,l~:.~~,:,:t.li}a.., _ ^ , , FRANCES H. DEL DUCA ATTORNEY AT LAW TEN WEST HIGH STREET CARLISLE. PENNSYLVANIA 17013 ~241~9~ ,.i . BARRY J. NORRELL, SR. and WANDA K. NORRELL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-4598 CIVIL 1996 v. GRETCHAN JOSANNA NORRWELL ,. and ROBERT SAMUEL STITT IN CUSTODY AND NOW, ORDER this 2. (. tI... day of March, 1998, upon agreement of the parties, legal and physical custody of Taylor Nicole Stitt, born March 18, 1998, as well as Kaitlyn Sierra Stitt, born December 22, 1995, is granted to the maternal grandparents, Barry J. Norrell, Sr. and Wanda K. Norrell with visitation by the natural parents as the parties may agree. BY THE COURT, r) ," ;;,) 0 :-":' " ,", -) . _.:1 on , 1 r" ,-~1 ~ ;. .J .." . ) " ,J :..J ) " ,-, i , ::6 - ';:) -< ~ BARRY J. NORRELL, SR. and WANDA K. NORRELL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-4598 CIVIL 1996 v. GRETCHAN JOSANNA NORRWELL .. and ROBERT SAMUEL STITT IN CUSTODY COMPLAINT FOR CUSTODY 1. Barry J. Norrell, Sr. and Wanda K. Norrell reside at 534 North Hanover Street, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Gretchan Josanna Norrell resides with her parents, Barry J. Norrell, Sr., and Wanda K. Norrell at 534 North Hanover Street, Carlisle, PA, 17013. 3. Gretchan Josanna Norrell, age 18, will be a student at Nursing School in August, 1998, and is the natural mother of Taylor Nicole Stitt born March 18, 1998. 4. The natural father, Robert Samuel stitt resides at 31 Winchester Gardens, Carlisle, PA, 17013. 5. The natural ~drents are not married. 6. The natural mother Gretchan Josanna Norrell has lived with her parents at 534 North Hanover Street for the past 13 years and her daughter Kaitlyn, born December 22, 1995 has resided there since her birth, as well as Taylor Nicole Stitt since her recent birth. The Court granted custody of Kaitlyn Sierra Tritt to Barry and Wanda Norrell by agreement of the parties by order dated August 14, 1996. 7. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody for the child in this or another court, Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Conunonwealth. 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. 8. The best interest and permanent welfare of the child will be served by granting the relief requested because the plaintiffs have been the primary caretakers of the child since birth. 9. Each parent whose parental rights to the child have not terminated and the persons who have physical custody of the child have been named as parties to this action. WHEREFORE, plaintiffs, the maternal grandparents request the court to grant custody of Taylor Nicole Stitt to them. --- I ) ~ ~I . 7 / " If"f-u' - , :4~ -- Frances H. Del Duca Attorney for Plaintiffs Dated: March.l.~ 1998 I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 10 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. Dated: ~lflo/I L\) 0-....1- '.- ~''Y\--{l-~v,~ ~ . 0"; Ii<> . '>-'1 - -.!> rj .......... f'r) ":I ,";} ~ .J ~ 'F >- c-, ~'i: ," u: ,-- ~, ../ U.J(:"'! ...::-; t.)/. G:~-' 'r , 11._" 2: , C)I- 0".' .-. " 11 ':::h <'1 ,'/: eft!. (,. o ' ~,- -';;;' ~; ...-;.; dj~'2 L' ::c .'= 0 CD :::J en U