HomeMy WebLinkAbout00-02581
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ANDRE K. SANDERS,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
VS.
ELIZABETH STOTLER,
Defendant
: NO. 2000- dlSf I CIVIL TERM
: CUSTODY
pRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow Andre K. Sanders, Plaintiff in the above captioned case, to proceed in forma pauDeris.
I, Joan Carey, attorney for the party proceeding in forma DauDeris, 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 of litigation is attached hereto.
~ry
Attorney for Plaintiff
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ANDRE K. SANDERS,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
vs.
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2000- 25ft CIVIL TERM
ELIZABETH STOTLER,
Defendant
: CUSTODY
AFFIDAVIT IN SUPPORT OF PETITION
FOR LEAVE TO PROCEED IN FORMA PAUPERIS
1. I 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 of litigation.
3. I represent that the information below relating to my ability to pay the fees and costs is true
and correct.
(a) Name: Andre K. Sanders
Address: 200 B Lincoln St.
(b) Social Security Number: 577-90-0388
If you are presently employed, state
Employer: N/A
Address:
Salary or wages per month:
Type of work:
If you are presently unemployed, state
Date of last employment: Carlisle Tire and Wheel
4/20/00
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Salary or wages per month: $8.00 an hour
Type of work: Order Processor
(c) Other income within the past twelve months
Business or profession: N/A
Other self-employment: N/A
Interest: N/A
Dividends: N/A
Pension and annuities: N/A
Social Security benefits: N/A
Support payments: N/A
Disability payments: N/A
Unemployment compensation and
supplemental benefits: N/A
Workman's compensation: N/A
Public Assistance: N/A
Other: N/A
(d) Other contributions to household support
Name:
Elizabeth Stotler
If your (husband) (wife) is employed, state
Employer: Misc.
Salary or wages per month:
$200 / Month
Type of work: Babysitter
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Contributions from children: N/A
(e) Property owned
Cash: None
Checking Account: N/A
Savings Account: N/A
Certificates of Deposit: N 1 A
Real Estate (including home): N/A
Motor vehicle: Make
N/A
Year
Cost Amount owed
Stocks; bonds:
Other:
N/A
N/A
(t) Debts and obligations
Mortgage: N/A
Rent: $361 Month
Loans: $1100
Monthly Expenses: $90 - food: $61.75 Utility Bills: $30 - Personal Items:
$275 Fines
(g) Persons dependent upon you for support
(Wife) (Husband) Name: N/A
Children, if any:
Name: Chelsea Ann Stotler
Age:
1 year
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4. I 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.
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: 4 -'JL- 6 V
Andre K. Sanders,
Plaintiff
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ANDRE K. SANDERS,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
vs.
: NO. 2000- ~'61 CIVIL TERM
ELIZABETH STOTLER,
Defendant
: CUSTODY
TEMPORARY CUSTODY ORDER
AND NOW, this 25TH day of April, 2000, upon consideration of the parties' Consent
Agreement, the following Order is entered with regard to custody of the parties' child, Che1sie
Ann Stotler, D.O.B. February 25, 1999.
1. Plaintiff, hereinafter referred to as the ~, and Defendant, hereinafter referred ~or'
to as the father, shall share legal custody of the child. ~'u
f\'"otlut,
2. The mother and father shall share physical custody of the child according to the
following schedule:
a. The father shall have custody three days (including overnights) each week
at times to be agreed upon by the father and mother.
b. The father shall have custody from 8:30 p.m. unti12:30 a.m. on days when
the mother is working; these periods of custody shall be at the mother's
residence.
c. The mother shall have custody those periods when the father is not
scheduled to have custody in paragraphs 2a and 2b above.
3. The father and mother shall share custody on holidays and the child's birthday at
mutually agreed upon times.
4. The mother and father shall each have the right to take the child on a vacation of
three days (including to places outside Cumberland County or the state of Pennsylvania);
each shall give the other the address and phone number where the child can be reached in
case of an emergency.
5. The mother and father, by mutual agreement, may vary from this schedule at any
time, but the Order shall remain in effect until further order of court.
6. The mother shall not take the child to the home of her Aunt Fran on Pitt Street
during evenings when the mother is working.
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7. There shall be reasonable notice given to the other party if a scheduled period of
partial custody needs to be cancelled or modified and a make-up period shall be offered
within a reasonable time frame.
8. The mother and father agree that each shall notify the other immediately of
medical emergencies which arise while the child is in that parent's care. .
9. 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 love or respect for the other parent.
, Judge
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If entered pursuant to the consent of Plaintiff and Defendant:
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E zabeth Stotler, Defendant
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Attorney for Defendant C~ ~I :h;1e
FAMILY LAW CLINIC )j i
Joan Carey
Attorney for P1ainti f
LEGAL SERVICES, INC.
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ANDRE K. SANDERS,
Plaintiff
VS.
ELIZABETH STOTLER,
Defendant
:IN THE COURT OF COMMON PLEAS OF
:
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2000- ,~_q'~'/ CIVIL TERM
: CUSTODY
TEMPORARY CUSTODY ORDER
AND NOW, this 25TM day of April, 2000, upon consideration of the parties' Consent
Agreement, the following Order is entered with regard to custody of the parties' child, Chelsie
Ann Stotler, D.O.B. February 25, 1999.
1. Plaintiff, hereinafter referred to as the ~r, and Defendant, hereinafter referred
to as the fat,5~, shall share legal custody of the child.
2. The mother and father shall share physical custody of the child according to the
following schedule:
The father shall have custody three days (including ovemights) each week
at times to be agreed upon by the father mad mother.
The father shall have custody from 8:30 p..m. until 2:30 a.m. on days when
the mother is working; these periods of custody shall be at the mother's
residence.
The mother shall have custody those periods when the father is not
scheduled to have custody in paragraphs ,.a and 2b above.
The father and mother shall share custody on holi[days and the child's birthday at
mutually agreed upon times.
4. The mother and father shall each have the right to take the child on a vacation of
three days (including to places outside Cumberland County or the state of Pennsylvania);
each shall give the other the address and phone number where the child can be reached in
case of an emergency.
5. The mother and father, by mutual agreement, may vary from this schedule at any
time, but the Order shall remain in effect until further order of court.
6. The mother shall not take the child to the home of her Aunt Fran on Pitt Street
during evenings when the mother is working.
7. There shall be reasonable notice given to the other party if a scheduled period of
partial custody needs to be cancelled or modified and a make-up period shall be offered
within a reasonable time frame.
8. The mother and father agree that each shall notifi,~ the other immediately of
medical emergencies which arise while the child is in that parent's care.
9. 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 love or respect for the other parent.
By the Court,
If entered pursuant to the consent of Plaintiff and Defendant:
,Judge
J~ Carey~Andre Kelvin Sanders~
Attomey for Plaintiff
LEGAL SERVICES, 1NC.
El{zabeth ~iotler, Defgr~da~t
Attorney for Defendant
FAMILY LAW CLINIC
ANDRE K. SANDERS,
Plaintiff
VS.
ELIZABETH STOTLER,
Defendant
:IN THE COURT OF 'COMMON PLEAS OF
:
: CUMBERLAND COUNTY, PENNSYLVANIA
_.
: NO. 2000- ,~ff-$r / CIVIL TERM
..
: CUSTODY
To the Prothonotary:
pRAECIPE TO PROCEED IN FORMA PAUPERIg
Kindly allow Andre K. Sanders, Plaintiff in the above captioned case, to proceed in forma pauperis.
I, Joan Carey, attorney for the party proceeding in forma pauperis, 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 of litigation is attached hereto.
~oan ~are~//
ANDRE K. SANDERS,
Plaintiff
VS.
ELIZABETH STOTLER,
Defendant
:IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 2000- J~'~'! CIVIL TERM
:
: CUSTODY
AFFIDAVIT IN SUPPORT OF PETITION
FOR LEAVE TO PROCEED IN FORMA PAUPERIS
1. I 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 of litigation.
3. I represent that the information below relating to my ability to pay the fees and costs is tree
and correct.
(a) Name: Andre K. Sanders
Address:_200 B Lincoln St.
(b) Social Security Number:_577-90-0388
If you are presently employed, state
Employer: N/A
Address:
Salary or wages per month:
Type of work:
If you are presently unemployed, state
Date of last employment: Carlisle Tire and Wheel
4/20/00
Salary or wages per month:..$8.00 an hour
Type of work: Order Processor
(c) Other income within the past twelve months
Business or profession: N/A
Other self-employment: N/A
Interest:
Dividends:
N/A
N/A
Pension and annuities: N/A
Social Security benefits: N/A
Support payments: N/A
Disability payments: N/A
Unemployment compensation and
supplemental benefits: N/A
Workman's compensation: N/A
Public Assistance: N/A
Other:
N/A
(d) Other contributions to household support
Name: Elizabeth Stotler
If your (husband) (wife) is employed, state
Employer: Misc.
Salary or wages per month:
Type of work:_Babysitter
$200/Month
Contributions from children: N/A
(e) Property owned
Cash: None
Checking Account: N/A
Savings Account: N/A
Certificates of Deposit: N/A
Real Estate (including home): N/A
Motor vehicle: Make N/A Year
Cost Amount owed
Stocks; bonds: N/A
Other: N/A
(f) Debts and obligations
Mortgage: N/A
Rent: $36/Month
Loans: $1100
Monthly Expenses:_$90 - food; $61.75 Utility Bills; $30 - Personal Items;
$275 Fines
(g) Persons dependent upon you for support
(Wife) (Husband) Name: N/A
Children, if any:
Name:. Chelsea An~ Stotler
Age:. 1 year
4. I 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.
5. I verify that the statements made in this affidavit are tree 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.
Andre K. Sanders,
Plaintiff