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HomeMy WebLinkAbout00-01883 II . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA ROBERT VIDAL, Plaintiff, CIVIL ACTION - LAW vs. NO. D-6. J? f3 e.u,U I kV- CHERYL WATTS, Defendant. IN CUSTODY ORDER OF COURT AND NOW, this ~ day of March, 2000, upon consideration of the attached complaint, it is hereby directed that the parties and their respective coun~t;! appear before \\.h(:\\, Y.. ,C"')~ \ f'O-.-\ ,e:;"q ~ ' the conciliator, at ~1:... L\,'i"" ~C~m6.(SJ.. (o..x~S-c....dn the i day of 0:...... 11 ,2000, at _IQ; 30 A. M., for a Pre-Hearing Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to defme and narrow the issues to be heard by the court, and to enter in to a temporary order. All children five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. BY THE COURT, ~~~\)r~\ "X.AJdnOCJ% Custody Conciliator (~:) The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the schedule conference hearing. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A Telephone Number 717-249-3166 MARK, WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET _ SHIPPENSBURG, PA 17257-1397 t-~,~ ,. -~ '! .' _""0.. : " '- '-' .. w ,~- iJ't:!~':"-~illiw~ !lilU!tW" ;"".~~"Uillil '" !lJj_~!llll\lil'Jj;~!lA;dlllDIiil\-"~OL4>~~~I:Wlll~.!iilMh...rwtii';,"W1i~i:ti,~~iOiilii~~i!!ll1$,@ll' 'ri.....~ l J J/.(p .t)O I/.{p.{) tI J.(.(, -00 - _, t I:,!U:D .{FFiCE OF 'T: !::- :.::"';,"':',.'t',:+JT/\RY OO~P;(-.6 P!i 3:fl9 CUMBE!~:Lj\NJ COUNTY PEN~.ISYLVN~iA w~~~4~ ~~~~~ ~~~ #'~'P' , 1 II ii IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT VIDAL, Plaintiff, CIVIL ACTION - LAW vs. NO. f>-o. Ifr3 ~ 'Lv- CHERYL WATTS, Defendant. IN CUSTODY COMPLAINT FOR CUSTODY I. The Plaintiff is Robert Vidal, presently residing at 2413 Letterkenny Road, Chambersburg, Franklin County, Pennsylvania 17201. 2. The Defendant is Cheryl Watts, presently residing at Safe Harbour, 102 West High Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks custody of the following child: NAME Taylor Soule PRESENT RESIDENCE Safe Harbour, 102 West High Street Carlisle, Cumberland County, P A 17013 AGE 4 months The child was born out of wedlock. The child is presently in the custody of Cheryl Watts, who resides at Safe Harbour, 1 02 West High Street, Carlisle, Cumberland County, Pennsylvania 17013. During the past five years, the child has resided with the following persons and at the following addresses: NAME Cheryl Watts, Mother Michael Soule Jordan Soule ADDRESS Safe Harbour, 102 West High Street Carlisle, Cumberland County, PA 17013 DATE 12/99- present The mother of the child is Cheryl Watts, currently residing at Safe Harbour, 102 West High Street, Carlisle, Cumberland County, Pennsylvania 17013. She is single. The father of the child is Robert Vidal, currently residing at 2413 Letterkenny Road, Apartment lB, Chambersburg, Franklin County, Pennsylvania 17201, since February 2000, He is single. MARK, WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET _ SHIPPENSBURG. PA 17257-1397 ':;1 ,--,-~" y '" - ~ -" . f1ll!l!l!!l!lllP !I 4. The relationship of Plaintiff to the child is that off ather. The Plaintiff currently resides with the following persons: NAME Pauline McMullen Aaron Novak RELATIONSHIP girlfriend Pauline McMullen's son 5. The relationship of Defendant to the child is that of mother. The Defendant currently resides with the following persons: NAME Michael Soule Jordan Soule RELATIONSHIP son son 6. 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. 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because Defendant is an unfit mother and based upon her actions With regard to her other children Plaintiff avers that: a. Defendant does not maintain a clean and sanitary environment for the child. b, Defendant does not provide proper meals. c. Defendant does not properly supervise the children. d. Two of Defendant's children were removed from the home by Children and Youth Services. One child is in the care and custody of the Defendant's sister. Plaintiff is better able to provide a suitable and stable home for the child. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: NAME None ADDRESS BASIS OF CLAIM MARK, WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET _ SHIPPENSBURG, PA 17257-1397 !'." '0_ ,-,=,~ ,.' " , - II "' WHEREFORE, Plaintiff requests the Court to grant both legal and primary residential custody of the minor child, Taylor Soule, to the Plaintiff, Robert Vidal. WEIGLE, PERKINS AND ASSOCIATES By: g~ (YO~ David P. Perkins, Esquire Attorney for Plaintiff LD.# 34342 126 East King Street Shippensburg, PA 17257 717-532-7388 MARK, WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET _ SHIPPENSBURG, PA 17257.1397 ~, -'. ~ " ,- !I " 1~ I verify that the statements made in the foregoing Complaint for Custody are true and correct. I understand that fulse statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. ~4 Robert Vidal Dated: fP VERIFICATION 1,110 , --," , ~ MARK, WEIGLE AND PERKINS - ATTORNEYS AT LAW _ 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 " '. " 'I I , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA ROBERT VIDAL, CIVIL ACTION - LAW Plaintiff, vs. NO. 0-0 - / S' f3 ~0. -r:b- CHERYL WATTS, Defendant. IN CUSTODY PRAECIPE TO PROCEED IN FORMA P AUPERlS To the Prothonotary: Kindly allow, Plaintiff, Robert Vidal, to proceed in forma pauperis. I, David P. Perkins, attorney for the party proceeding in forma paueris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs oflitigation is attached hereto. Q~~ David P. Perkins, Esquire Attorney for Plaintiff Attorney LD. #34342 126 East King Street Shippensburg, P A 17257 717-532-7388 MARK, WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 ~--- _ l - _0 I ~ ". ,"'-.' _ _ 1 ,. "'- - ~ :l ,~ 1~'l'/l''lU~'''!'''''I'' ~. ,,-- ~, ~, , . 0.r-.sv;.~~j\'0C) ,j,~i' ,,"'. ,. ~, ,,'. (\ tv .\\ \','-' ~\f)v '/., '(Ii. \ \\ '.!c, ~ ,(' rv- \y\ ::.'..J . \~ ,\' ,.:" ,,,,,I. ~";I ,'" ,'\:o) i ~\ \\>' ""\:'>, [-~\.,j )(j\'~" \\~\))J...,\r-\l'(Y f'P -;;- ~.d..~~ J.,U~~Ifi._~~m" .4~~!'m!<If1~.lf"'~!:1I'i,-.m~!",~I:a1~~~Ojj~lIlfIi!li\lllllllllfl~IlWl'INt~: II I , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA ROBERT VIDAL, CIVIL ACTION - LAW Plaintiff, vs. NO. 0-0 . / Y U ~ 7;-<-0 CHERYL WATTS, Defendant. IN CUSTODY AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA P AUPERlS 1. 1 am the Plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs oflitigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: Robert Vidal Address: 2413 Letterkenny Road, Apartment IB, Chambersburg, Pennsylvania 17201 (b) Social Security Number: 170-56-6588 If you are presently employed, state Employer: Manpower Address: 106 Western Parkway, Hagerstown, Maryland 21740 Salary: approximately $8/hour starting in April Type of work: Laborer (c) Other income within the past twelve months Employer: McDonald's Address: 3347 Black Gap Road, Chambersburg, Pennsylvania 17201 MARK, WEIGLE AN~ PERKINS - ATTORNEYS AT LAW _ 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 Ii, , _.c. - II 'I " Salary or wages per month: approximately $600/month Type of Work: fast food crew person Other self-employment: none Interest: none Dividends: none Pension and annuities: none Social Security Benefits: none Support Payments: none Disability Payments: none Unemployment Compensation and Supplemental Benefits: none Workman's Compensation: none Public Assistance: none Other: none (d) Other Contributions Wife Name: none Girlfriend: Pauline McMullen Employer: Ross Distribution Address: Carlisle, Pennsylvania Salary or wages per month: $500 every two weeks Type of work: laborer Contributions from children: nI a MARK, WEIGi-E AND PERKINS - ATTORNEYS AT LAW _ 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 I.',~,~ ,~ -,-' I~I~' ~-"_,,,,-- "j , II :1 Ii l' I (e) Property owned Cash: $20.00 Checking Account: approximately $50.00 (for medical only) Savings Account: none Certificates of Deposit: none Real Estate (including home): none Motor vehicle: Make none Year Cost Amount owed Stocks; bonds: none Other: (f) Debts and Obligations 1,1 " " Mortgage: n/a Rent: $275.00/month Loans: none Monthly Expenses: approximately $235.00 (g) Persons dependent upon you for support Wife Name: Children, if any Name Taylor Soule Age 3 months 4. 1 understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. MARK, WEIGLE AND PERKINS - ATTORNEY$ AT LAW - 126 EAST KING STREET _ SHIPPENSBURG, PA 17257-1397 '"". ~ ' c' ". _ ." ~ . "r_._." '-,- I! [' 5. 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 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Date: 7>/27/00 / I ~ - Robert Vidal MARK, WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET _ SHIPPENSBURG, PA 17257-1397 '! . "' -<"" -,' ~ l ;.~ ~J Ii ! p ,J l~J I;: ~; " r i' J;! j "! ~; t 'i c " [; "i i;-: ;; ''''~ " . ,.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COlUNTY, PENNSYLVANIA ROBERT VIDAL, Plaintiff, CIVIL ACTION - LAW vs. NO. 00-1883 Civil CHERYL WATTS, Defendant. IN CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ~ COUNTY OF CUMBERLAND Rhonda Wolford, being duly sworn according to law, deposes and says that on April 10, 2000, she served true and attested copies of Complaint for Custody together with Order of Court upon the Defendant, Cheryl Watts, by mailing the same postage paid, certified mai~ addressee only, and return receipt requested, at Shippensburg, Pennsylvania, addressed as follows: Rhonda Wolford Sworn to and subscribed before me this 14th day of April, 2000. /~ /( /C~ Notary Public l ~ Seal .1 Unda K. KIeIrl. NoIaJy PublIc ~flA CIIIIllerIlInd ColIIIy My c:onunIssIan ExpIres August 15, l!GIlO MARK, WEIGLE AND PERKINS - ATTORNEYS AT LAW ~ 126 EAST KING STREET _ SHIPPENSBURG, PA 17257-1397 ,.1", ",0 ,'- " '>- ' =n '~ fl ~ I 'it (UOmeSffc IV/all un/yo /\/0 Insurance Goverage ~/ovlOeaJ Ltl ru ru D l:.her '\15 :l- ~ Po,''''. $ oE'~- vJ..o.. \ Certified Fee f'"' Retum A~lielpt Fee CJ (Endorsement equJred) D D =r .-'I !J'" D Wa.H.:> -:;3.5> ( {) (2S "2' $ s;: 9s Restricted Delivery Fee (Endorsement Required) Total Posta'g& & Fees D ru n.J Name (Please Print Clearly) (To be !jmPleted by mailer) rn _~_bg_Cj.l___W__01:1:_~_____.~LCL~~...Ho...r.::QQ_,:\.c.._..__ StrtHlt. Ap'l No.; or PO Box No. +- l{?3...lN..(.:!:L...t\!~l:I......~tr._~_L......_....______...._......... elf Slate, ZIP.+ 4 I IT' IT' D I'- o. SENDER: -@ . Complete items 1 and/or 2 for additional services. "w . Complete items 3, 4a, and 4b. CD . Print your name and address on the reverse of this form so that we can return this t! card to you. --. CD . Attach this fo'rm to "'front of the mailpiece, or on the back if space does not ~ permit. . Write "Return Receipt Requested" on the mailpiece below the article number. CD . The Return Receipt will show to whom the article was delivered and the date :5 delivered. ' I also wish to receive the following services (for an extra fee)~,;.. 1. 0 Addressee's Address 2. ~estricted Delivery Consult postmaster for fee. 6 3. Article Addressed to: " * is. E o u C-her'l J Wee+! 5 C/o 'So.+e t\o.V-P.Ol.lI 10 do Wes+ 1-\ ISn ~tV-l"eT CCt....hs\e P1'\ 111013 ..LsrCertified o Insured o COD 5. Received By: (Print Name) Domestic Return Receipt - .. " .. s: I- 11 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT VIDAL, CIVIL ACTION - LAW Plaintiff, vs. NO. 2000-1883 CIVIL CHERYL WATTS, Defendant. IN CUSTODY ORDER OF COURT ~ NOW, Alc~ I , 2000, upon consideration of the within Stipulation and Agreement, it is hereby ordered as follows: I. Robert Vidal and Cheryl Watts shall have shared legal custody of the child, Taylor Soule, born December 23, 1999. 2. Physical custody shall be handled as follows: A. Father shall have physical custody of the minor child every other week from Sunday at 7:00 p.m. until the following Sunday at 7:00 p.m., commencing on Sunday, October 8, 2000. B. Mother shall have physical custody of the minor child every other week from Sunday at 7:00 p.m. until the following Sunday at 7:00 p.m., commencing on Sunday, October 15, 2000. C. Father shall handle transportation for exchange of custody. Father shall ensure that he has appropriate child restraints in his vehicle for transportation. 3. The parties shall alternate physical custody of the child on the following holidays with the times of pick up and return to be mutually agreed upon by the parties: A. In the even numbered years, father shall have physical custody of the minor child on the following holidays: New Year's Day, Memorial Day, Labor Day, Thanksgiving Day, and Christmas Day. B. In the even numbered years, mother shall have physical custody of the minor child on the following holidays: Easter, 4th of July, Trick or Treat, the child's birthday and New Year's Eve. WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, 'PA 17257~1397 !" c: " ~ ~ 0:' .~, .' - "" 8i" .$ lHQ ..;:r O~ ;ll:;. H=~ a... 00" 9~': -7;>::. - i1j'W C!l...,-- I 'Z uJO- iXm , ="" -'I. iJ: ,-,., 0 i:t5o.. I t-;".~ ..2: 2 LL d :J 0 0 <.) <, - ~jiJij~;&l!!!!!lR1>~_~~~"""""IMI~!U[!ll.,.,,,~~~"~ J:l1Wllf. ~~ _"!!""' ~...MI~IM' ... C. In odd numbered years, father shall have physical custody of the minor child on the following holidays: Easter, 4th of July, Trick or Treat, the child's birthday, and New Year's Eve. D. In odd numbered years, mother shall have physical custody of the minor child on the following holidays: New Year's Day, Memorial Day, Labor Day, Thanksgiving Day, and Christmas Day. 4. The parties shall share time with the minor child on the child's birthday, at such times as the parties mutually agree. 5. The father shall have physical custody of the minor child on Father's Day and mother shall have physical custody of the minor child on Mother's Day. 6. The parties shall not smoke in the presence of the child. The parties shall not permit other individuals to smoke while in the presence of the minor child. 7. Both parties shall share all medical information conceming the child and shall keep the non-custodial parent advised with respect to any medical emergencies. The mother is directed to provide father with any details of the child's dietary needs or restrictions. 8. Father shall transport the child to and from mother's residence in Carlisle. In the event mother is working, Father shall pick up and deliver the child to the child caregiver in accordance with any instructions given by the mother. The present child caregiver "is Tressler Lutheran located at 21 South Bedford Street, Carlisle, Pennsylvania. By the Court, ~tL J. WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257~1397 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT VIDAL, CIVIL ACTION - LAW Plaintiff, VS. NO. 2000-1883 CIVIL CHERYL WATTS, Defendant. IN CUSTODY STIPULATION AND AGREEMENT This Stipulation and Agreement is made this 4"""' day of ad\) 'o~.- , 2000, by and between Robert Vidal of 2413 Letterkenny Road, Apartment 1B, Chambersburg, Franklin County, Pennsylvania, (hereinafter referred to as "Father") and Cheryl Watts of Carlisle, Cumberland County, Pennsylvania, (hereinafter referred to as "Mother"). 1. Robert Vidal and Cheryl Watts are the natural parents of Taylor Soule, born December 23, 1999, hereinafter referred to as "the child." 2. Robert Vidal and Cheryl Watts were not married at the time of the birth of the child. 3. Robert Vidal has initiated a custody action with the Cumberland County Court and the parties are currently subject to a temporary Order of Court and Directive for Conciliation dated June 8, 2000. 4. The parties desire to continue generally the custody conciliation scheduled for Friday, September 8, 2000, at 8:30 a.m. 5. The parties have reached an agreement with regard to the custody of the child, Taylor Soule, and desire to reduce their agreement to an Order of Court. NOW THEREFORE, the parties intending to be legally bound and waiving their right to be present when this Agreement and Order are presented and executed hereby stipulate and agree that the Court may enter the following Order of Court in the above-captioned case: ORDER OF COURT NOW, , 2000, upon consideration of the within Stipulation and Agreement, it is hereby ordered as follows: 1. Robert Vidal and Cheryl Watts shall have shared legal custody of the child, Taylor Soule, born December 23,1999. WEIGL-E, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257~1397 R__, < '!" ~ , ' ,,__,r_ ,.,_, :"." .', ,__<~,," __ . -,..' ---, -,-. 2. Physical custody shall be handled as follows: A. Father shall have physical custody of the minor child every other week from Sunday at 7:00 p.m. until the following Sunday at 7:00 p.m., commencing on Sunday, October 8, 2000. B. Mother shall have physical custody of the minor child every other week from Sunday at 7:00 p.m. until the following Sunday at 7:00 p.m., commencing on Sunday, October 15,2000. C. Father shall handle transportation for exchange of custody. Father shall ensure that he has appropriate child restraints in his vehicle for transportation. 3. The parties shall alternate physical custody of the child on the following holidays with the times of pick up and return to be mutually agreed upon by the parties: A. In the even numbered years, father shall have physical custody of the minor child on the following holidays: New Year's Day, Memorial Day, Labor Day, Thanksgiving Day, and Christmas Day. B. In the even numbered years, mother shall have physical custody of the minor child on the following holidays: Easter, 4th of July, Trick or Treat, the child's birthday and New Year's Eve. C. In odd numbered years, father shall have ghysical custody of the minor child on the following holidays: Easter, 4 of July, Trick or Treat, the child's birthday, and New Year's Eve. D. In odd numbered years, mother shall have physical custody of the minor child on the following holidays: New Year's Day, Memorial Day, Labor Day, Thanksgiving Day, and Christmas Day. 4. The parties shall share time with the minor child on the child's birthday, at such times as the parties mutually agree. 5. The father shall have physical custody of the minor child on Father's Day and mother shall have physical custody of the minor child on Mother's Day. 6. The parties shall not smoke in the presence of the child. The parties shall not permit other individuals to smoke while in the presence of the minor child. WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 7. Both parties shall share all medical information concerning the child and shall keep the non-custodial parent advised with respect to any medical emergencies. The mother is directed to provide father with any details of the child's dietary needs or restrictions. 8. Father shall transport the child to and from mother's residence in Carlisle. In the event mother is working, Father shall pick up and deliver the child to the child caregiver in accordance with any instructions given by the mother, The present child caregiver is Tressler Lutheran located at 21 South Bedford Street, Carlisle, Pennsylvania. By the Court, J. The parties further agree that, in procuring this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of the other. IN WITNESS WHEREOF, the parties, intending to be bound by the terms and conditions of this agreement, execute this Agreement by signing below. ~ ROBERT VIDAL 0)A 0: ~ Witness L, la~J~ CJu4# 1{)~~ CHER ATTS WI ess ~~\\7 Ltw Ctll';,L. WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 C<." __I I verify that the statements made in this Stipulation and Agreement 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 unsworn falsification to authorities. Dated: /, 1j# / !iffl!/~ ROBERT IDAL I verify that the statements made in this Stipulation and Agreement 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 falsification to authorities. Dated: /() -:J y -00 ~ WC{:I/;;~ CHER ATTS WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257~1397 I NOV 2 0 2000roo ROBERT VIDAL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW CHERYL WATTS, Defendant NO. 2000 - 1883 CIVIL IN CUSTODY COURT ORDER ;t AND NOW, this jfJ day of November, 2000, the Conciliator being advised that the parties have reached an agreement, the Conciliator relinquishes jurisdiction. BY THE COURT, J. Kevin A. Hess "'", ",;, "1"_'0 _,"'Y_ _ "__, <_._ k ", ~ -- I . r:' ~(Y,'l',n\1 "!1r'!( (J[j Ml'")u ."'i:') .1.... ;':1__" _,,_ '/ . ~ ~r Ii: / I CUlV6L/~ii /,,\f.. " i"i--' PENr"S;Y'L~"'i/'u(jU/\!7Y ~... \if' vIA w -;r:.-