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Home My WebLink About00-03085 .- DORTHIA L. EVANS, Plaintiff, v. ADRIAN MCBRIDE, Defendant. AND NOW, this , ' '.~ lli_ JUN 2 6 2~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 00-3085 Civil Action - Law In Custody ORDER OF COURT a ~y of June, 2000 the Conciliator, being advised by Plaintiff s counsel that all custody issues have been resolved by Stipulation of the Parties, hereby relinquishes jurisdiction in this case, FOR THE COURT, Mol" . Pool G"'''''''~ 1II.~..,'J - - - --.;..;"'-"-~~ '~,,~- :nD ~fIJ~ , .' ..........0' '''~,j,\!' FfLFD--'Or:p!CE (,r- -. '0 'co'''._. 1,-, ','>-rADV .,1' ! ';_ i,c ~'-'!nU'!\iUjr1iIl 00 JUN 29 Pi1 2: I 7 CUMBEhUWD COUNTY PENNSYLVANIA ~"~,, ~, ' , ,~ ",. "" ~_. . . L >" I"" ~" , --"-~;" I , IN THE COURT OF COMMON PLEAS OF CUMBERLkND COUNTY, PENNSYLVANIA CIVIL ACTION - L1 w I DORTHIA L. EVANS, Plaintiff No. OO-~085 ! Civil Term v. ADRIAN McBRIDE, Defendant I , IN CUSTrDY I , , i ORDER OF COU AND NOW, this Ict day of ) ,2000, upon consideration of the attached Stipulation for Entry of a Custody Order, IT IS H REBY ORDERED AND DECREED that custody of the minor child, ALAYSIA EVANS, bol June 14, 1999, is awarded as follows: I 1, MOTHER shall have primary physical and legal custody of the minor child, 2. FATHER shall have partial physical custody 10fthe minor child. At the current time, FATHER works out of State for three (3) weeks and is ho e in Philadelphia for one (I) week each month. FATHER shall have the child one (1) weekend pe month when he is home in Philadelphia from Friday until Sunday, when he will retum her to MOT ER by 7:00 p,m, FATHER shall advise MOTHER which weekend he will have the child each mo ,th as soon as he has his schedule, By the Wednesday before FATHER's weekend, he shall give MdTHER notice of the approximate time he , will pick the child up on Friday, , f\\e~ \(\ ~'\1\~O\l!l~ O+Flcsc ~ .j I,,\\Y :u , JOOO . . , _ ,_" , _ "_'c~""',_ _,~,,,,,, ''''~_""' _ ,'~"'^"" _l,..J!wq ",= "~T!";'-~ -,<,,-""^_'!'C>,,'_",,_"y, '" _,_"_.J~71~.Il'~i!I~!l"~"'i!\ii"~! "-,,"',,*~I,-~ . ,,_.~,...rIM! ' ,.tlDIlf.1 > - , ~1iilIII ""~. , "'" " i ~_E,1 FATHER's first weekend with the minor child shall be from June 23'd until June 25, 2000, Additional times for F ATHER to have partial custody of the minor child shall be by mutual agreement of the parents. 3, Beginning in 200 1, FATHER shall have one (1 ) week of summer custody with the minor child, He shall give MOTHER at least thirty (30) days written notice of his chosen week, 4. The parents shall share the Thanksgiving holiday with the minor child each year. MOTHER shall have the child on Thanksgiving Day, FATHER shall have the child from the Friday after Thanksgiving until the Sunday after Thanksgiving, when he shall return her to MOTHER by 7:00 p,m, 5, The parents shall share the Christmas holiday with the minor child each year. MOTHER shall have the child every Christmas Day, FATHER shall have from December 220d until December 24'\ or from December 26'h until December 28'\ whichever he chooses each year, He shall retum the child to MOTHER by 9:00 p,m, By December I" of each year, FATHER shall give MOTHER written notice of the days he wishes to have the minor child for the Christmas holiday, 6, Beginning in 200 I, MOTHER shall have the child on Mother's Day and FATHER shall have the child on Father's Day, The hours shall be from the Friday before the holiday until 7:00 p,m, the day of the holiday when FATHER shall return the child to MOTHER., 7, FATHER shall provide all transportation for the custody transfers, 8, The schedules for all holidays and vacations shall take priority over the regular weekly schedule, 9, There shall be reasonable telephone access between the child and both parents, J , . t.' .' ~ ,;,.. L ~=~"-',_ I 0, By mutual consent of the parents, a revised schedule may be agreed upon between them for and in the best interests of their minor child, 11, This Order shall replace and supercede any and all prior Custody Orders, and shall remain in full force and effect until further Order of Court.. BY THE COURT: to}UtOJ 1-flO- R){~ J, , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW DORTHIA L. EVANS, Plaintiff No. 00-3085 Civil Term v. ADRIAN McBRIDE, Defendant IN CUSTODY STIPULATION FOR ENTRY OF CUSTODY ORDER DORTHIA L. EVANS (hereinafter referred to as "MOTHER"), and ADRIAN McBRIDE (hereinafter referred to as "FATHER"), desiring to amicably settle and resolve all outstanding issues concerning custody with respect to ALAYSIA EVANS, born June 14, 1999, the minor child involved in this action, hereby stipulate and agree to the entry of an Order of Court awarding custody of ALA YSIA as follows: 1. The parents agree that MOTHER shall have primary physical and legal custody of the minor child, 2. The parents agree that F ATHER shall have partial physical custody of the minor child. At the current time, F ATHER works out of State for three (3) weeks and is home in Philadelphia for one (1) week each month. FATHER shall have the child one (1) weekend per month when he is home in Philadelphia from Friday until Sunday, when he will return her to MOTHER by 7:00 p,m, F ~ THER shall advise MOTHER which weekend he will have the child each month as soon as he has his schedule. By the Wednesday before F ATHER's weekend, he shall give MOTHER notice of the approximate time he will pick the child up on Friday. FATHER's fIrst weekend with the minor child shall be from June 23'd until June 25, 2000. ~I"'" . - :'i :) ',j , " :i 'i il 'I II , i ,I ,I Ii Ii II I' ,I il 'I II Ii 'I 'I Ii :1 ii' '. t>. ~- ~ , ~ "~ MlL,C . ; Additional times for FATHER to have partial custody of the minor child shall be by mutual agreement of the parents, 3. Beginning in 2001, FATHER shall have one (I) week ofsUffimer custody with the minor child. He shall give MOTHER at least thirty (30) days written notice of his chosen week. 4. The parents agree that they shall share the Thanksgiving holiday with the minor child !.' I: I', each year, MOTHER shall have the child on Thanksgiving Day. FATHER shall have the child from the Friday after Thanksgiving until the Sunday after Thanksgiving, when he shall return her to MOTHER by 7:00 p.m. i !'~; S. The parents agree that they shall share the Christmas holiday with the minor child each year, MOTHER shall have the child every Christmas Day. FATHER shall have from December 22nd until December 24'h, or from December 26th until December 28'h, whichever he chooses each year, He shall return the child to MOTHER by 9:00 p.m. By December 1st of each year, FATHER shall give MOTHER written notice of the days he wishes to have the minor child for the Christmas holiday. 6, Beginning in 2001, the parents agree that MOTHER shall have the child on Mother's r I, [ , i I ~ Day and FATHER shall have the child on Father's Day, The hours shall be from the Friday before the holiday until 7 :00 p.m. the day of the holiday when FATHER shall return the child to MOTHER.. 7. F ATHER agrees to provide all transportation for the custody transfers, 8. The schedules for all holidays and vacations shall take priority over the regular weekly schedule. 9. The parents agree that there shall be reasonable telephone access between the child and both parents. 10, Both parents agree that, by their mutual consent, a revised schedule may be agreed upon " ,--, , . ; between them for and in the best interests of their minor child. II, The parents agree that this Agreement shall be submitted to the Court of Common Pleas of Cumberland County for approval and for entry of an Order awarding custody as set forth herein, and the parents hereby request that this Honorable Court enter such an Order. IN WITNESS WHEREOF, the parties have executed this Stipulation for Entry of a Custody Order on the date indicated below. 1t/.1r1~ tJO Date ~ l 'Y_~ \); Witness IlL;;) 21))0 ~ 'lwL~uL Witness Jli" .~_~<o..jj i ;'j ;-1 ('I :'1 / '<I . .' .i " ~ Ii 11 II .. n " Ii lj tl .1 i ii .< '.I ~! " I, d ., ~~~Jl.;tll;.b j-,~~Ml'liII:tll~lliIliifl!llll.';Ull~'_~~I!Ojj~E~"~~:""";- " ".,,~ """^'"'~-"JiiLll "'~ -~,~u, . . , ""C _"""__,",,>_' '.,'_ _~^~ ,- ~', , ,~" (") C s: ;:PCD "I J'." /--;..: ?r.-' (J.5:-;-. -<' .-:." r%C'-r: ~:::'~~:) )>~~ --'1 -:. '.,' ."'-,..".... .. " C:) o 5= q r- -, ,..., - 1:='':; .Y S~ ~~~; i;~~ ':5:J -<: .-j '.' .~,.) 0') ~ .- , "'~i~. " ~ DORTIllA L. EVANS PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. ADRIAN MCBRIDE DEFENDANT 00-3085 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 23rd day of May ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear befor<Melissa P. Greevy, Esq. , the conciliator, at 214 Stnate Avenue, Suite 105, Camp Hill, PA 17011 on the ~ day of June ,2000, at11:15AM for a Pre-Hearing Custody 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 into a temporary order. All children age 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. FOR THE COURT, By: Isl The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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 scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE, IF YOU DO NOT HAVE AN ATTORNEY 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, Pennsylvania 17013 Telephone (717) 249-3166 Ii " ~"-. . .~.,.. -lidJi: FiLED-OFFICE C.I: "-' r., GR:iTHnNOTAAY ..II J;b,] ".-'_1 -,< 00 HAY 30 PH 2: 3lt CUMBEPJ.AND COUNlY t>ENNSVlVANlA 5,~.CJC M, C'~ /Jf~ ~ X 5'. .5-:30-(/0 'r7~ ~ -z, ~ .s:~.Ocj ~ h!~ ~ 4- ~UI}PfY .~ &J ~ .' -, - ~-, - ""' ~~ .~-" ~~~~"""~~"'1~,<"~.~,r~!IiI_WJll~I~ _"~~....,~,.,?"",,~ . llIJ~r~:u:m~ -II!III!I~! ~ ~,~ ,-. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DORTHIA L. EVANS, Plaintiff v. --- NO. 05-~ Civil Term ADRIAN McBRIDE, Defendant : : IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , the Conciliator, at on the day of , 2000, at ___.m., for a Pre-Hearing Custody Conference. At such Conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court and to enter into a temporary Order. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent Order. BY THE COURT: Custody Conciliator 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, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 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 the office set forth above. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled Conference or Hearing. ,- ']X'l. it' ;:, n I," " LI i'j ~l If! ~j I: I!~ I: !: ],'j I, ii Ii II I' Ii ,. ,I Ii II i 1 '1 ~ < "-" " "----- . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW < , , u . ,;! DORTHIA L. EVANS, Plaintiff '! ii v. NO. IHJ -J6,fj/ Civil Term ADRIAN McBRIDE, Defendant (: . . : IN CUSTODY COMPLAINT FOR CUSTODY I ~i 1;1 i" I_I 1" Ii !:I n i:J AND NOW comes the Plaintiff, DORTHIA L. EVANS, by and through her attorney, Maryann Murphy, Esquire, of Legal Services, Inc., and respectfully files this Complaint for Custody, and in support I,! i pi I' " ;j thereof avers as follows: 1. The Plaintiff is DORTHIA L. EVANS who currently resides at 161 West North Street, Apartment B, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is ADRIAN McBRIDE who currently resides at 308 Memorial Drive, Apartment #49, Hinesville, Georgia. 3. The Plaintiff seeks primary physical and legal custody of the following child: ALAYSIA EVANS, born June 14, 1999 4. The child was born out of wedlock. She currently resides with the Plaintiff. w ~ " , . . ,'""-'>' -~- 'j j -~ -'1 j 5. During the lifetime of the child, she has resided at the :,1 .1 i i'i following addresses with the following persons: 'j ] , :j Time Address wi th Whom birth-l0/99 1871 Douglas Drive Carlisle, PA Plaintiff/Plaintiff's daughter/Plaintiff's parents :.'1 10/99-present 161 West North St. Carlisle, PA Plaintiff/Plaintiff's daughter ! 'j , :J Ii (': " r:j "i i1 F i1 '1 ! 'j 6. The father of the child is ADRIAN McBRIDE. He is single. 7. The mother of the child is DORTBIA L. EVANS. She is single. :1 12. Each parent whose parental rights to the child have not " !i i 'I H " II !;I " .1 :j ,I ~i ., j ~ , ~ 11 , ~ I I I I I I I I I I I 8. The child currently resides with Plaintiff. 9. The Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the child in this or any other Court, except as set forth above. 10. The Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. 11. 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. been terminated, and the persons who have physical custody of the ,,~ ~ . .~ "" child, have been named as parties to this action. There are no other persons known to have or claim a right to custody or visitation of the child and therefore, no further notice of the pendency of this action and the right to intervene shall be given, other than to the parties named herein. 13. The best interest and permanent welfare of the minor child will be served by granting Plaintiff primary physical and legal custody. WHEREFORE, Plaintiff requests this Honorable Court to grant her primary physical and legal custody of ALAYSIA. Respectfully submitted, Maryann Murphy, Legal Services, 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 LD. # 61900 Attorney for Plaintiff r ',,>--,.,: ~, .',~-..:...."" ;,:c,._, 1'; VERIFICATION I, DORTHIA L. EVANS, verify that the statements made in the foregoing Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of I', 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. r:, I'~ ( C k I C' I:" 1 I 1 ,~ r:i i ,J ,:: r'i H :,1 , I> ! I':; ~j , :j I: II p ;1 !J 'j 11 I~ 11 !I f1 Ii I; !J 11 oj -., ,'..........- .1 J~~" . ~ . "l'''iof, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DORTHIA L. EVANS, Plaintiff . . . . VB. : NO. Civil Term . . ADRIAN McBRIDE, Defendant . . : IN CUSTODY CERTIFICATE OF SERVICE I, Maryann Murphy, Esquire, do hereby certify that on the " ;,j , 2000 I served a true and correct copy i'j i:i day of hi I: i:, (i i~ of the foregoing Custody Complaint on the Defendant, ADRIAN McBRIDE at the address set forth below, by placing a copy of same in the !,~ i ,,' " United States Mail, postage prepaid, certified/restricted delivery. I , Adrian McBride 308 Memorial Drive, Apartment #49 Hinesville, GA 31313 Respectfully submitted, M ryann rphy, Legal Services, 8 Irvine Row Carlisle, PA 17013 (717) 540-8600 I.D. # 61900 ~!ii~' ,:.~--" 2!L:tJ~il1! '~_Ii1!K! ~""1Al!jli~i!iill!l.~la~)II~~' ""'!IJ'!l', ~,JI\:JW''}II!l.,,",~. w>"~~.',-, .",^~""_ Q,-, '-' , ....", "" ..' _....drl....'...... 111'-""""''--''':1' i H (") C:;l Ci ~ ~~~ C) -r; , :;1l'; --'t n -o('f' ::J':"~ ifl! r~ ~''"'.. ;-->1p ~ Z~T t , 1 ~~'::~ ..r,.--n ~ C'~ :bb -<---;': (:)~ \.::(.~; :;:;:;,~ ~~~ ~ i;:Cj =\~~ (;00 S;~ om ~ =-' :....1 55 ,:", -~ .-1 -< -- ~ '" 0 <L ,,= ,- , 'e', ~ _ >-,- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DORTHIA L. EVANS, Plaintiff : NO. tf)tJ-30?S v, : IN CUSTODY ADRIAN McBRIDE, Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Civil Term Kindly allow, DORTIDA L. EVANS, Plaintiff, to proceed in forma pauperis. I, Maryann Murphy, Esquire, of Legal Services, Inc., 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. ~ Ma~, Esquire Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 J.D. # 61900 Attorney for Plaintiff ~~.....;;..; , -~",;.o~'g,~ " " r r; l' " t " i , I,' i, l" ,Ji ~J t; ~j , I ~; 11 .l" _'m"':".',"""".._" ">'0'"-'_'-' -w-, _,,,co, 1__ -- ,,--~-.;:,~ '-,+~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DORTIDA L. EVANS, Plaintiff ; NO. P1J. 36 ilS" Civil Term v. : IN CUSTODY ADRIAN McBRIDE, Defendant AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS I. I am DORTHIA L. EVANS, 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: DORTIDA L. EVANS Address: 161 West North St.. Apt. B. Carlisle. PA 17013 (b) Social Security Number: 182-54-4264 If you are presently employed, state Employer: EXEL Address: 350 Salem Church Rd.. Mechanicsburl!. PA 17055 Salary or wages per month: $1.692.00 Type of work: Clerk - - , ,-;; "',,-"'4',_"'_ '"i"- _. ~>"-" If you are presently unemployed, state NfA Date oflast employment: NfA Salary or wages per month: NfA Type of work: NfA (c) Other income within the past twelve months Business or profession: -0- Other self-employment: -0- Interest: -0- Dividends: -0- Pension and annuities: -0- Social Security benefits: -0- Support payments: $324.00 Disability payments: -0- Iii I' t: , ", Ii'! j!'! I I " j:! I: I' ,i I' I 11 Ii " I: I. I' Ii 11 I; 11 Unemployment compensation and supplemental benefits: -0- Workman's compensation: -0- Public Assistance: -0- Other: -0- (d) Other contributions to household support (Wife)(Husband) Name: N/A If your (husband) (wife) is employed, state Employer: NfA n, > , ,", "'" _n'", -;f_ ;;-_', ; .~. ,__" -, -~-f""'-i~' Salary or wages per month: N/A Type of work: N/ A Contributions from children: -0- I , i I I I i I' I f, I' i l; i' it I' ~ . (e) Property owned Cash: $-0- Checking Account: -0- Savings Account: -0- Certificates of Deposit: -0- f:, j, Real Estate (including home): N/A Motor vehicle: Make N/A Year N/A Cost N/A Amount owed N/A , i= I Stocks; bonds: -0- Other: -0- ~ (t) Debts and obligations Mortgage: -0- Rent: $530.00 Loans: -0- Monthly Expenses: $1.400.00 (g) Persons dependent upon you for support N/A (Wife) (Husband) Name: N/A , Children, if any: Name: Alaysia 10 months Age: Name: Alyshia 11 Age: ., , ~- -"''''';~''' 4. I understand that I have a continuing obligation to inform the court of improvement in V ij "' my fmancial circumstances which would permit me to pay the costs incurred herein. S. I veritY that the statements made in this affidavit are true and correct. I understand that I I ,. " false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Date:Sd.i.ill..- ~J j I I ~;: to:'; ii' , , I:: :;! ~~_iW' '"' __~i/It~ij;j~;I1iJ!,M~q,,;iN'i~BM~-"";.o. ,-" "_d._CC"'_"-.(_~~ ~.,", . ~'~ 1iijI~'1Il fliOi:::i(" ~ ~f~ 6)~;~ ~o -S,...C,l Y~8 :3 -..... - ., .-- C) ,- - C-'J o () ~'n --; -r ;~lp T1rTI L~9 -.~6 p,::3j ?io om ?5 -< - -,.-.,. :X:;:!ll -'C co .J:1-'" ::..: :'.> ...J