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Home My WebLink About97-01221 ~ o '1 \. " ""( < Cl: ~ 3 ~ ~ " ( \" .~ , ..... . ~ I '" .... ... .":) - 31 . l:'- "" ' ~ ,. ;-, .,...., ""i,~., , \ j " $.... ,/' . LILLIE A. BROWN, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . v. I CIVIL ACTION - LAW . . TAREKA L. ANDERSON, I Defendant I NO. 97-1221 CIVIL TERM AND NOW, this ORDER OF COURT I "(f!,day of March, 1997, upon consideration of the attached custody stipulation with respect to the minor child, DaVone u. Anderson, born May 6, 1995, the terms of the stipulation are entered as an order of court. IT APPEARING that the father of the child, Phillip E. Jackson, Jr., was not made a party to this proceeding, this order shall not be binding upon him and shall have no effect with respect to his parental rights. BY THB COURT, . Lindsay Dare Baird, Esq. 37 South Hanover street Carlisle, PA 17013 Attorney for Petitioner "d" ,07L,~<(-"L .3/17 /9'7, \.-("- .......t.-.J.. ) ,..5';)' , Tareka L. Anderson 1885 Aeronca street Carlisle, PA 17013 Respondent :rc \ :' , '! \"'" . .' ~ '--, I .. ~,....... I,'; , '._ . Ii ,'_ ;) , i' .~) J ..... -.' . .. J r ~ LILLIE A. BROWN, Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v TAREKA L. ANDERSON, Respondent ; 97 - /)..1 ( CIVIL TERM : IN CUSTODY ORDER OF COURT ... . AND NOW, this _ .. _ day of , 1997, upon consideration of the attached custody stipulation with respect to the minor child, DaVone U, Anderson, born May 6, 1995, the terms of the stipulation are entered as an order of court, BY THE COURT, io; ;... i._ "', [ J. Lindsay Dare Baird, Esq, 37 South Hanover Street Carlisle, PA 17013 Attorney for Petitioner Tareka L. Anderson 1885 Aeronca Street Carlisle, PA 17013 Respondent - LILLIE A, BROWN, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 97 - p.J / CIVIL TERM : IN CUSTODY Petitioner v TAREKA L. ANDERSON, Respondent STIPULATION FOR CUSTODY I~+ ,- STIPULATION made this 2 . day oiJCl..r\l..\Q(l.,l' 1997, between Lillie A. Brown, hereinafter referred to as Grandmother, and Tarcka ,Anderson, hereinafter referred 10 as Mother, WHEREAS, the whereabouts of the falher, Phillip E, Jackson, Jr. are unknown, AND WHEREAS, the above-named Mother, a single minor, and the Father had born to them the following child on the following date: NAME DaVone U, Anderson BIRTH DATE May6,1995 AND WHEREAS, the parties desire to enter into a Stipulation as to ths custody of the above- said child, NOW, THEREFORE, In order to effectuate the above purpose, the parties hereby stipulate that: 1. The Mother and Grandmother shall have shared legal custody oi the child. 2. The Grandmother shall have primary physical custody of the child. 3. The parties agree to make mutually agreeable arrangements for visitation, TO THIS PURPOSE, The parties hereto Inlend to be legally bound by the terms of this Stipulation and desire to have the Stipulation entered as an Order of Court, Witness: ~1f~rg~~~~her ~~j;!f~ \it&.& . i ()IIQ~ Tareka L. A~ Mother I "" WITH THE UNITED STATES ARMED FORCES) AT With, th,D United Statos Armod Foroos J At Kllzlngcn, Federal Republic of Germany) I, the undersigned, certify that I am a duly commissioned, qualified, and authorized notary public, Before me personally, within the territorial limits of authority, appeared Lillie A, Brown, who Is known by me to be the person who Is described herein, whose name Is subscribed to , and who signed this Stipulation for Custody as Petitioner, and who, having been duly sworn, acknowledged that this Instrument was executed after its contents were read and duly explained, and that such execution was a free and voluntary act and deed for the uses and purposes herein set forth, Subscribed, sworn to and acknowledged before me by Lillie A, Brown, the Petitioner, who Is known 10 me to be eligible for Legal Assistance under the provisions of 10 USC 91044b or regulations of the Department of Defense, on 2.1 :S:,'IL\C\.r q Iqq-:r. This acknowledgment Is executed In my official capacity under the authority granted by Title 10, United States Code, Section 1 044b, which also states that no seal Is required on this acknowledgment. With the United States Armed Forces J At Kitzingen, Federal Republic of Germany) With the Federal Authority of a Notary Public, Article 136, UCMJ (10 U. S. C. 936) No seal required by law ~. -I ..9~ LESL IE s. nEUTscll CPT, U.S. Army Legal Assistance Attorney Authorized to perform notarial acts lAW AR 27-55 LILLIE A, BROWN, Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v TAREKA L. ANDERSON, Respondent : 97-/J Jj CIVIL TERM : IN CUSTODY PETITION FOR CUSTODY 1, The Petitioner is Lillie A. Brown, a member of the Armed Services of the United States, residing In 38 PSBDET Unit 26525, Box #6, Kltzingen, Germany APOAE 09225 pursuant to Military Orders. 2, The Respondent is Tareka L. Anderson residing at 1885 Aeronca Street, Carlisle, Cumberland County, Pennsylvania 17013, 3, Petitioner seeks shared legal and primary physical custody of the following child: NAME PRESENT RESIDENCE AGE DaVone U, Anderson 1885 Aeronca Street, Carlisle, Pennsylvania 8 months The child was born to Respondent, a single minor, The child is presentiy in the custody of Respondent. During the past eight (8) months child has resided with Respondent at 1885 Aeronca Street, Carlisle, Pennsylvania, The father of the child is Phillip E, Jackson, Jr., whose address is unknown. He is presumed single, 4, The relationship of Petitioner to Ihe child is that of maternal grandmother, The Petitioner is a member of the Armed Forces stationed in the Federal Republic of Germany. She is a single woman, 5, The relationship of Respondent to the child is that of Mother, The Respondent currently resides with the following: Mary E, Brown - Grandmother DaVone U, Anderson - Son 6. Petitioner 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. Petitioner has no information of a custody proceeding concerning the child pending in a court of this Commonwealth, Petitioner 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 respecl to Ihe child. 7, The best Interest and permanent welfare of the child will be served by granting the relief requested because the Petitioner Is best able to provide for the welfare of 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 have 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 RELATIONSHIP ADDRESS Phillip E, Jackson, Jr, Father Unknown WHEREFORE, the Petitioner respectfully requests the court to grant custody of the child, 10 ,,'o.~~ ~rf- A torney for Petitioner I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C,S, ~904 relating to unsworn falsification to authorities, J JlJ~O~ f)luY\ '(tIlTe A, Brow~,\kt~ner WITH THE UNITED STATES ARMED FORCES) AT With the United States Armed Forces i At Kitzingen, Federal Republic of Germany) I, the undersigned, certify that I am a duly commissioned, qualified, and authorized notary public, Before me personally, within the territorlallimils of authority, appeared Lillie A, Brown, who Is known by me to be the person who Is described herein, whose name is subscribed to , and who signed this Stipulation for Custody as Petitioner, and who, having been duly sworn, acknowledged that this Instrument was executed after Its contents were read and duly explained, and that such execution was a free and voluntary act and deed for the uses and purposes herein set forth, Subscribed, sworn to and acknowledged before me by Lillie A, Brown, the Petitioner, who is known to me to be eligible for Legal Assistance under the provisions of 10 USC ~1044b or regulations of the Department of Defense, on 2/ Jeu'] ~\ctllll Ct{ i. This acknowledgment Is executed in my official capacity under the authority granted by Title 10. United States Code, Section 1044b, which also states that no seal is required on this acknowledgment. With the United States Armed Forces I At Kitzingen, Federal Republic of Germany) With. the Federal Authority of a Notary Public, Article 136, UCMJ (10 U, S. C, 936) No seal required by law ~'./ J~ ~i LESLIE S. DEUTSCH CPT, U.S. Army Legal Assistance Attorney , , J" -.---; ,', ~R n ..n ...') 'i'\::. FU [' -I " "",:,,1 ; ':': I ',. (, ~ I , . .'J ,"1 " r '- ~ " j;~ ~ (" I:';' ~ ""- ~ ""' ;~. '\ ...t'l ~ . ~t_ "' ,,, "f' rj ,0 /" , "" .." ;l. oJ\., ,- - , ,/1 '.1 ~ ,<; ~ v.. ~ c...) ~ ~ ~