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Home My WebLink About00-03131 ,-~-,h__~ -- . .~'- - ~ ,',. ,~ ,;' ,,' ~ --. '. ...-".","'"",",- .- ~;,,"'; - >'~-, '"'~;,! FRANK W. GORSUCH III, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00- 3/3/ CIVIL TERM v. CIVIL ACTION- - LAW LISA M. NIFVES, Defendant : CUSTODY ORDER OF COlJRT AND NOW, this 1. ~('~day of , 2000, upon vlt1 21 consideration of the within Custody Stipulation and Agreement between FRANK W. GORSUCH III, hereinafter "Father," and LISA M. NIEVES, hereinafter "Mother," regarding the child CODY J. GORSUCH, born April 28, 1997, hereinafter "Child," it is hereby ordered as follows: 1. The parties shall have shared legal custody of the child, meaning that they shall share the legal right to make major decisions affecting the best interest of the child and all of the major matters related to the child, including but not limited to, medical, religious and educational decisions. 2. The parties shall share primary physical custody of the child. a) Mother shall have physical custody of the child from Sunday, May 21, 2000 through Sunday May 28, 2000 at times to be determined by the parties, and alternating weeks thereafter, and other times as agreed to by the parties. b) Father shall have physical custody of the child from Sunday, May 28, 2000 through Sunday, June 4, 2000, at times as agreed to by the parties, and v:lwr 'C .! alternating weeks thereafter, and other times as agreed to by the parties. I 'N ! I' j I, ,."_~~:,/'.:('\,, ,:! Ai nc:; ~.,., .. , ~ 3. Child care shall be provided through an agreed upon child care center. I 0 :t; Wd l] Z ,,',, AWlONOI.HO'" ,J :;.\...'i,:;....... ',<,' -~ ' < .- ',~ -;,-,1.. <~,.- ~"' 'C' , ", '_"'~'-'_'"'_;'-;' ',-;c., i>-,?", - '" '-,',,- ,__d ".'0,..,__,'-' '-'_:i--" 4. Neither parent shall do anything which may estrange 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's love and affection for the other parent. 5. The failure to either party to insist on strict performance of the provisions of this stipulation and agreement shall not be construed as a waiver of any subsequent default of the same or similar provision. BY THE COURT, . 1. James K. Jones, Esquire Attorney for Plaintiff 7 Irvine Row Carlisle, PA 17013-3019 ~~ $-.;24-00 Rk.s Lisa M. Nieves 627 Hoot Owl Rd. Boiling Springs, P A 17007 t, ','" , ;, ~ '" ~ , , ~,.' ,'., I" -. ",,~ 0' ,_ _ ,~',,,,- ~ ' -'-"->';-"''' .--" ,"'" - -,"-- ",-,- ,"~-,'''',';,~ ~,'~ '-',; '~ _~~ - -'J-;~I 'I ;1 ~ i' ~ < . FRANK W. GORSUCH III, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ; NO. 00- 3/3} CNIL TERM v. CIVIL ACTION- - LAW LISA M. NIEVES, Defendant CUSTODY Made this CUSTODY STIPULATION AND AGREEMENT {?7t1 day of A/.JY , 2000, by and between FRANK W. GORSUCH III, hereinafter "Father," and LISA M. NIEVES, hereinafter "Mother,ll; WHEREAS the parties have a child, namely CODY J. GORSUCH, born April 28, 1997, hereinafter "Child"; and WHEREAS, the parties wish to enter into an agreement relative to custody, partial custody and visitation of the child; and WHEREAS, Child has resided in Cumberland County, Pennsylvania for at least six (6) months, thus giving this Court jurisdiction. NOW THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth, the parties agree as follows: I. The parties shall have shared legal custody of the child, meaning that they shall share the legal right to make major decisions affecting the best interest of the child and all of the major matters related to the child, including but not limited to, medical, religious and educational decisions. 2. The parties shall share primary physical custody of the child. a) Mother shall have physical custody of the child from Sunday, May 21, 2000 through Sunday May 28, 2000 at times to be determined by the parties, and alternating weeks thereafter, and other times as agreed to by the parties. 1.,,",,- I..:. ".~"jl,';';'>,:,-,:,-,,- ' -~ ~' 'I I , ! . b) Father shall have physical custody of the child from Sunday, May 28, 2000 through Sunday, June 4, 2000, at times as agreed to by the parties, and alternating weeks thereafter, and other times as agreed to by the parties. 3. Child care shall be provided through an agreed upon child care center. 4. Neither parent shall do anything which may estrange 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's love and affection for the other parent. 5. The failure to either party to insist on strict performance of the provisions of this stipulation and agreement shall not be construed as a waiver of any subsequent default of the same or similar provision. 6. The parties agree and desire that this stipulation and agreement be made an Order of Court of Common Pleas of Cumberland County, Pennsylvania. 7. This Stipulation and Agreement shall become an Order of Court with the Court of Common Pleas of Cumberland County, entering said Order and retaining jurisdiction should either party desire or require modification of said order. IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms hereof, set forth their hands and seals the day and year herein set forth. WITNESS: ~JT4-4'~ FRANK W. GOR CH III eft 0 &J{YlJ71,~ /-EO I AM. NIEVES .""."".,., ""'kg" . K~' - ~ ~' (,C,.',"'"", "",.",;c." ".r ~~ ~ l ~ ~. \ 1 ~~ ~ ,- ~,~ ' '~"" ;.;" ~. /",,; .','~ '- CJ 8 ~ :;: '~~~1 ~ -t::, _"-~ \__~C) 3I:c' 52 -7 ::j -< ~l ~ ~ ~ ~ <'1\ CJl '1 ~\j \ ~,~ '~ ~ r ~"' '. "1 . ., :::n ,~ --0 ~,; :TI _,_,l-n 'jO .~~~ C) 'Pi ::0 -< -'",,.. t:: :..:> (,) -~ _.......,;:.,,""';:',, -' FRANK W. GORSUCH III, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF v. CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00-3131 CIVIL TERM LISA M. NIEVES, a.k.a. LISA M. BEVAN : Defendant/Petitioner CUSTODY l CUSTODY ORDER AND NOW, this ~ day of August, 2002, upon consideration of the parties' Consent Agreement and Stipulation to Modify Custody, the following Order is entered with regard to custody of the parties' child, Cody J. Gorsuch, hereinafter referred to as the "child." 1. The plaintiff/respondent, Frank W, Gorsuch III, hereinafter referred to as the "father", and the defendant/petitioner, Lisa M. Nieves, a.k.a. Lisa M. Bevan, hereinafter referred to as the "mother", shall have shared legal custody of the child. 2. The mother shall have primary physical custody of the child. 3. The father shall have partial physical custody of the child, according to the following schedule: Every weekend from Friday night until Sunday night. Mother will drop the child off at the home of Father's mother, except that: One weekend a month, the mother shall have the child upon giving the father two weeks notice. At other times as mutually agreed upon by the parties, including holidays. 4. If father's schedule so allows, father shall have children for a one-week period during summer vacation upon one-month notice. _ ",4>.~~~,,.. - Of ."\ n ,".{lr~\Ct. \- ts8,:;c;'Y'1\\OT t'P,'! ",',] ,,'.."" n" 2' ,;P- 01 I" \ Q '" \ " L .. 02 fU>.o 'i ." ., "'''''J\'\TV ,""""\' :.1,,\; I ". "Ii l AIJ" ,,1",.",--'\ i"\,'.,-", '....1'-' V ",\D_,,"~' \1',N'h PENNSYbA, in ~ ~, ,.- '"""'" 1., ,~~J1llffinl"Kv:;!rJWqT'il1_...~~i!j!QJH~l!!~~_,~."_~_,, ,..'" - 5. The mother and father will notify each other of all medical care the child receives while III that parent's care. Each parent will notify the other immediately of medical emergencies, which arise while the child is in that parent's care. 6. 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, Frank W. Gorsuch, III, Plaintiff/Respondent pro se David Lopez, Esq. Attorney for DefendantlPetitioner 8 Irvine Row Carlisle, PA 17013 ~ ~ I'_Jq-o~ r+ . '^"'-' '-'N~' - e"'f . FRANK W. GORSUCH III, PlaintifflRespondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-3131 CIVIL TERM LISA M. NIEVES, a.k.a. LISA M. BEVAN : DefendantlPetitioner CUSTODY CONSENT AGREEMENT AND STIPULATION TO MODIFY CUSTODY This Agreement is entered on this 9th day of August, 2002, by the plaintiff/respondent, Frank W. Gorsuch III, and the defendant/petitioner, Lisa M. Nieves, a.k.a. Lisa M. Bevan. The plaintiff/respondent represents himself; the defendant/respondent is represented by David Lopez, Esq. of MidPenn Legal Services. The plaintiff/respondent and the defendant/petitioner agree to the entry of an Order providing for the following custody schedule for their child, Cody 1. Gorsuch, hereinafter referred to as the "child." 1. The plaintiff/respondent, Frank W. Gorsuch III, hereinafter referred to as the "father", and the defendant/petitioner, Lisa M. Nieves, a.k.a. Lisa M. Bevan, hereinafter referred to as the "mother", shall have shared legal custody of the child. 2. The mother shall have primary physical custody of the child. 3. The father shall have partial physical custody of the child, according to the following schedule: Every weekend from Friday night until Sunday night. Mother will drop the child off at the home of Father's mother, except that: One weekend a month, the mother shall have the child upon giving the father two weeks notice. At other times as mutually agreed upon by the parties, including holidays. j,' "" '''''''. '~-- '-\' 4. If father's schedule so allows, father shall have children for a one-week period during summer vacation upon one-month notice. 5. The mother and father will notify each other of all medical care the child receives while ill that parent's care. Each parent will notify the other immediately of medical emergencies, which arise while the child is in that parent's care. 6. 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. WHEREFORE, the parties request that an Order of Court be entered to reflect the above terms. ~~~;~ Frank W. Gorsuch, III, Plaintiff pro se ~jp..~.~ IJ('~ A. sa M. Nleves, a.k.a. Lisa M. Bevin, Defendant David Lopez, Esq. Attorney for Defendant 8 Irvine Row Carlisle, PA 17013 .IBm' !Jtj~~"ilI~~!l!lll1r:1~r~~~_.r"~.'" ,," "',"'", ~~ '" --- .,,' ',"' '''d., " ''''''ll . " o c:: ~tr ~;') <'~ [~lC: 5i[? 2: =< "."', o r,..) o -1'l Do <5-3 ,-, ''(,= ,1 ;~fl ;0 '~..), 1 .!'::./ ;JI'1 -,"~ SJ -< m " 0) ""t I if':. ~ r ..' FRANK W. GORSUCH III, Plaintiffi'Respondent : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA v. : No. 00-3131 CNIL TERM :CUSTODY 0 0 C> C r,) -0;;:: -Of J:>o mO,-; c::: n, ~5~! 0.--:> :I.J ,---;-1 -r--;:' , C"o 'y ~t, -.) (:, ':P;c ....'~ ., -1", d_ 23 :z: -' " >~' -:7 '...,J '- m Z .'0 S;; ."j -< , D ::;0 -< LISA M. NIEVES, a.k.a. LISA M. BEVAN,: DefendantlPetitioner PRAECIPE TO PROCEED IN FORMA P AUPERlS To the Prothonotary: Kindly allow, Lisa M. Bevan, DefendantlPetitioner, to proceed in forma pauperis. I, David Lopez, 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. avid Lopez Attorney for DefendantlPetitioner MIDPENN LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 j~~ij~~_t!ll~~R&_g~rnfMJj6iMr'= 0-' ;"'.u,;,~ ".:.u:Yuf .'"-,' -.....' - ,~"",;,;~,,, .. ~~~ <:;:: .. .'<~ '"~ - 1iii.i~Q:;[ " 'M". ,', ,,;,j".:i-idc;<':'i FRANK W. GORSUCH III, Plaintiff LISA M. NIEVES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00--~/,3/ CIVIL TERM : CIVIL ACTION- - LAW : : CUSTODY AND NOW, this ~.~:b¢,~day of 1442 '4 , 2000, upon consideration of the within Custody Stipulation and Agreement between FRANK W. GORSUCH III, hereinafter "Father," and LISA M. NIEVES, hereinafter "Mother," regarding the child CODY J. GORSUCH, bom April 28, 1997, hereinafter "Child," it is hereby ordered as follows: 1. The parties shall have shared legal custody of the child, meaning that they shall share the legal fight to make major decisions affecting the best interest of the child and all of the major matters related to the child, including but not limited to, medical, religious and educational decisions. 2. The parties shall share primary physical custody of the child. a) Mother shall have physical custody of the child from Sunday, May 21, 2000 through Sunday May 28, 2000 at times to be determined by the parties, and alternating weeks thereafter, and other times as agreed to by the parties. b) Father shall have physical custody of the child from Sunday, May 28, 2000 through Sunday, June 4, 2000, at times as agreed to by the parties, and '~ alternating weeks thereafter, and other times as agreed to by the parties. 3. Child care shall be provided through an agreed upon child care center. ~ ,~", ' ~ ~I~020NON[O!' ' :3 4. Neither parent shall do anything which may estrange 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's love and affection for the other parent. 5. The failure to either party to insist on strict performance of the provisions of this stipulation and agreement shall not be construed as a waiver of any subsequent default of the same or similar provision. James K. Jones, Esquire Attorney for Plaintiff 7 Irvine Row Carlisle, PA 17013-3019 Lisa M. Nieves 627 Hoot Owl Rd. Boiling Springs, PA 17007 BY THECOURT, FRANK W. GORSUCH III, Plaintiff LISA M. NIEVES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00- .3/37 CIVIL TERM CIVIL ACTION- - LAW CUSTODY CUSTODY STIPULATION AND AGREEMENT Made this [~'rt~ day of /~/gp' , 2000, by and between FRANK W. GORSUCH III, hereinafter "Father," and LISA M. NIEVES, hereinafter "Mother,"; WHEREAS the parties have a child, namely CODY J. GORSUCH, bom April 28, 1997, hereinafter "Child"; and WHEREAS, the parties wish to enter into an agreement relative to custody, partial custody and visitation of the child; and WHEREAS, Child has resided in Cumberland County, Pennsylvania for at least six (6) months, thus giving this Court jurisdiction. NOW THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth, the parties agree as follows: 1. The parties shall have shared legal custody of the child, meaning that they shall share the legal right to make major decisions affecting the best interest of the child and all of the major matters related to the child, including but not limited to, medical, religious and educational decisions. 2. The parties shall share primary physical custody &the child. a) Mother shall have physical custody of the child from Sunday, May 21, 2000 through Sunday May 28, 2000 at times to be determined by the parties, and alternating weeks thereafter, and other times as agreed to by the parties. b) Father shall have physical custody of the child from Sunday, May 28, 2000 through Sunday, June 4, 2000, at times as agreed to by the parties, and alternating weeks thereafter, and other times as agreed to by the parties. 3. Child care shall be provided through an agreed upon child care center. 4. Neither parent shall do anything which may estrange 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's love and affection for the other parent. 5. The failure to either party to insist on strict performance of the provisions of this stipulation and agreement shall not be construed as a waiver of any subsequent default of the same or similar provision. 6. The parties agree and desire that this stipulation and agreement be made an Order of Court of Common Pleas of Cumberland County, Pennsylvania. 7. This Stipulation and Agreement shall become an Order of Court with the Court of Common Pleas of Cumberland County, entering said Order and retaining jurisdiction should either party desire or require modification of said order. IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms hereof, set forth their hands and seals the day and year herein set forth. WITNESS: A M. NIEVES C~ c~ FRANK W. GORSUCH III, PlaintifffRespondent 1N TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 00-3131 CIVIL TERM LISA M. NIEVES, a.k.a. LISA M. BEVAN: Defendant/Petitioner : CUSTODY CUSTODY ORDER AND NOW, this ..~__~!ay of Au~st, 2002, upon consideration of the p~ies' Consent Agreement and Stipulation to Modify Custody, the following Order is entered with regard to custody of the parties' child, Cody J. Gorsuch, hereinafter referred to as the "child." 1. The plaintiff/respondent, Frank W. Gorsuch III, hereinafter referred to as the "father", and the defendant/petitioner, Lisa M. Nieves, a.k.a. Lisa M. Bevan, hereinafter referred to as the "mother", shall have shared legal custody of the child. 2. The mother shall have primary physical custody of the child. 3. The father shall have partial physical custody of the child, according to the following schedule: Every weekend from Friday night until Sunday night. Mother will drop the child off at the home of Father's mother, except that: One weekend a month, the mother shall have the child upon giving the father two weeks notice. At other times as mutually agreed upon by the parties, including holidays. 4. If father's schedule so allows, father shall have children for a one-week period during summer vacation upon one-month notice. 5. The mother and father will notify each other of all medical care the child receives while in that parent's care. Each parent will notify the other immediately of medical emergencies, which arise while the child is in that parent's care. 6. 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, · /~ ,/× sleyOle ~Jr~. Judge x~' -. Frank W. Gorsuch, III, Plaintiff/Respondentpro se David Lopez, Esq. Attorney for Defendant/Petitioner 8 Irvine Row Carlisle, PA 17013 FRANK W. GORSUCH III, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 00-3131 CIVILTERM : LISA M. NIEVES, a.k.a. LISA M. BEVAN: Defendant/Petitioner : CUSTODY CONSENT AGREEMENT AND STIPULATION TO MODIFY CUSTODY This Agreement is entered on this 9th day of August, 2002, by the plaintiff/respondent, Frank W. Gorsuch III, and the defendant/petitioner, Lisa M. Nieves, a.k.a. Lisa M. Bevan. The plaintiff/respondent represents himself; the defendant/respondent is represented by David Lopez, Esq. of MidPenn Legal Services. The plaintiff/respondent and the defendant/petitioner agree to the entry of an Order providing for the following custody schedule for their child, Cody J. Gorsuch, hereinafter referred to as the "child." 1. The plaintiff/respondent, Frank W. Gorsuch III, hereinafter referred to as the "father", and the defendant/petitioner, Lisa M. Nieves, a.k.a. Lisa M. Bevan, hereinafter referred to as the "mother", shall have shared legal custody of the child. 2. The mother shall have primary physical custody of the child. 3. The father shall have partial physical custody of the child, according to the following schedule: Every weekend from Friday night until Sunday night. Mother will drop the child offat the home of Father's mother, except that: One weekend a month, the mother shall have the child upon giving the father two weeks notice. At other times as mutually agreed upon by the parties, including holidays. 4. If father's schedule so allows, father shall have children for a one-week period during summer vacation upon one-month notice. 5. The mother and father will notify each other of all medical care the child receives while in that parent's care. Each parent will notify the other immediately of medical emergencies, which arise while the child is in that parent's care. 6. 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. WHEREFORE, the parties request that an Order of Court be entered to reflect the above terms. Frank W. Gorsuch, III, Plaintiff pro se ~I~a-l~. Nieves, '~ a.k.a. Lisa M. Bevin, Defendant David Lopez, Esq. Attorney for Defendant 8 lxvine Row Carlisle, PA 17013 FRANK W. GORSUCH III, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA V. ~ :No. 00-3131 CIVIL TERM : LISA M. NIEVES, a.k.a. LISA M. BEVAN,: Defendant/Petitioner : :CUSTODY PRAECIPE TO PROCRF, D IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Lisa M. Bevan, Defendant/Petitioner, to proceed in foima pauperis. I, David Lopez, 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. Attorney for Defendant/Petitioner MIDPENN LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400