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Home My WebLink About98-02301 'N ,\l i ",I ~. ~. ~ \l ~ ~ ~ ~ () ~ ~ " I , / j / / // I I I I I I ri 'l~: i' I ;----1 ~ I .~ I (jl .....: 01 "01 \'i I I \ ! ~i ~I I ~1 ,i . IN THE COURT OF COMMON PLEAS OF . CHRISTEEN RHOTEN , Plaintitt . CUMBERLAND COUNTY, PENNSYLVANIA . v. . . . NO. 9'g-~301 CIVIL TERM . . . MICHAEL BEAr.IILEY , Detendant : CUSTODY ORD~ AND NOW, this the attached Custody Order ot Court. S~ ~ day ot ~ - (J , 19~, Stipulation and Agreement are the terms ot hereby made an E. CUIDO , J. Sendtol Plaintif.t, ~ .. CHRISTEEN RHOTEN _......~'''~ Nallle 109 11th STREET Address NEtv CUMBERLAND PA 10070 Address Defendant NICHAEL BEArillLEY Nallle 403 B SUHHIT STREET Address NEtv CU~1BERLAND PA 17070 Add.rllss '-""--"- 9 C1-YI:) t eC'f1 Q Rho ten IN THE COURT OF COMMON PLEAS OF , Plaintiff v. CUMBERLAND COUNTY, PENNSYINANIA NO. 98- .)-3>0 I CIVIL TERM .. D. nl -, I ffiIO"Ge\ \...u O(:(.t~' 6e1~hdant CUSTODY CUSTODY STIPULATION AND AGREEMEN~ Made by and between I .Lhr I ",\,-ppn (::'I ph\ l \en hereinafter "Mother," currently residing at I oq I (t.h ,ell- rvP\.lrUrY\OP1\(\N;.1 (Jf-\ 110'lC) and 1f'\\C'r\C\P\ I.).) ~t:)y...,\e~ hereinafter "Father," currently residing at L(()'373 ()IiNII'Il,I RL NllAl (!,}ll1l'C~/'''I'~ PI) /71' ''/0 WHEREAS the parents have a child/children, namely: I::iAME llATILo F BI RTH \<'en \ ,LX' tpc Bb~~ R. \ (3 . C{ ~() hereinafter "child/..' . - Uli" and WHEREAS, the parents wish to enter into an agreement relative to custody, partial custody and visitation of the child/. ' . -. Iii NOW THEREFORE the parents agree as follows: 1. Mother and Father shall have shared legal custody ot the child/all1lJ.uln, meaning that they shall share the legal right to make major decisions affecting the best interest of the child/cAilJ__" and all of the major matters related to the child/c) . n J. _", including, but not limited to, medical, religious and. educational decisions. 2. Hother/r . 111:. shall have primary physical custody of the 10 child/"l ... ., meaning that this person shall have actual physical possession and control of the child/~~'lJ_ PI for a ., majority of the time. 3. The other parent shall have partt1l1=j,ihysical 0101 I <\y/visita'l:ion "Partial physical custody" means the person uti \ ~J shall have the right to take possession of the child/chHJLen C'h--e_I\..'-1 c,J C) r,c~"C\ I;. away from the other parent for a certain period of time; '-'-,j C'trCf O::,r It C' "Visitation" means the person shall have the right to visit the child/cAdl - _n, but does not have the right to remove the child/€La~'rTPl from the custodial person's control" ) as follows: a. AS AGREED as agreed to by the parents. (If you think that you do not need a set schedule, you may stop here and sign the agreement at the end.) b. WEEKENDS (Initial choice 1 or 2 or leave blank) 1. ALTERNATING On alternating ds beginning on ., at _.m. (Day of Week) through at and every (Day of Week) (Time) other weekend (alternating weekends at the 2. SPLIT from (Day at of Week) at (Time) (Day of Week) .m. Week) (Time)._ _~ c. DAY(S) DURI~E WEEK / / at / (Time) ~t _ - .m. and // (Time)- " (Initial if agreed) From (Day of _____.m. through (Day of Week) each week thereatter at tho 11 .f"~:' ...' chil~/children tor the same number of weeks during the Sllm~ vacation provided the same number of weeks n~tice is ~ to the -- other p~rent. ~/ i. MISCELLANEOUS ~nt9 also agreE (Initial if agr~ // to the following: ..--",'/-' //r / / / / / ./ /' j. )3r.H'tional periods of visitation and primary physical ~~Sh~ll be provided as agreed to by the parties. , 4. Transportation of the child/children shall be provided as follows: (Fill in the blank) 5. Neither parent shall do anything which may estrange tn. 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 tor the other parent. 6. Neither parent shall consume alcoholic beverages to the point of intoxication or consume any unprescribed controlled substances (drugs) while the child/!l ".. ,- is in their care. 7. Each parent agrees to provide the other par~nt with an address and telephone number through which the parent may be contacted during periods of custody of the child/ ," 11 _/ . Each parent further agrees to inform the other parent ot any medical emergencies that arise while the child/. . J.l~are in that parent's care. 15 "'I"_"'..c"r .. .i.'i=-"",=,,,",_,.':..', """"''''''"''-~''1!I'''''''_.'''''_1Ie. ( t')1\~)\-ecf) A Rr'DK'J(\ , Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 91'- ;)20/ CIVIL TERM CUSTODY " ( f., ~'..\L-\:."'f Defendant C'Y'I\( 'r-.c:i. e "-' l....c.'t.-' I , - I ' ORDER AND NON, this f\~r\\ day of Q:l"\'r) , 1997 , upon cOflsidez'ation of the plaintiff's Petition and Affidavit in Support of Petition for Leave to Proceed In Forrn~ Eauperis, it is hereby ORDERED and DECREED that Plaintiff, A may file the attached custody action in !Qrm pauperis and proceed to the termination of the proceedings without payment of filing tees or costs. J. 26 ~ ~, ~10, '<;":,', ":"J) 4,\;,,; ,;V< ;L,'t (,1-/"-- < /1' t-; , I-~. ,- ) Y/j'"l./, "'1"h, 'I-- cf(' (:1P^ .' :<'J) <.\'....0 ' 1.-;,.- ,,;}.., .-....~... /,'')l"..h "/ " ~f.'q~" .9,. "r). .02(9 \. .".."f\f'iT~"~"".' , "'1'''''_ ..~ '\ ~-' ,Co. ,_. "~\l',;-'Pro'''l'~'lt<Ri';Tf..i~f.ifl.''!.:V i\';'_I,,''-<:~~'~''. (\'VL~' E'er-. A Q Ill:.)" C'." , Plaintiff IN THE COURT OF COMMON PLEAS OF v. CUMBERLAND COUNTY, PENNSYLVANIA NO. 98- ;)30/ CIVIL TERM : CUSTODY ('f\l c I'\oe,\ w' ee:t)\-''IIC~'I' Defendant PETITION FQB LEAVE TO PROCEED AS AN INDIGENT 1. C:~ri~~(~~f1~f() Plaintiff in the above-titled action, on this ~ day of d LIth , 1997, respectfully requests this Honorable Court to grant her leave t.o proceed as an indigent to the extent that she be relieved from paying the fees and costs in this procedure. 2. Plaintiff has been screened for income eligibility at Legal Services, Inc., has been detel-mined eligible, and has attended a custody class at Legal Services taught. by a private attorney who was providing services free of charge as part of the Cumberland County Bar Association's ~Q QQnQ plan. Verification is attached. 3. Plaintiff has attached an affidavit in support of this petition. By the Plaintiff V-\eJ\ C. dh)~ . I verify that the Plaintiff has been determined by Legal Services, Inc. to meet their financial eligibility guidelines and that the Plaintiff has attended a custody class. r~~ 27 .. '.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 9S- ,1301 CIVIL TERM Nl\'(hc~e..\ \JJ f1J3;l:1'tet Defendant CUSTOD'l AFFIDAVIT IN SUPPORT OF PETITION FOR I,.EAVE TO PROCEED IN FORMA PAUPERIS (\.~< ')\eef") (.\ (,th-J\erl , plaintiff v. 1. I am the plaintiff in the above matter and because of my tinancial condition am unable to pay the fees and cos.ts 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 infonnation below relating to my ability to pay the fees and costs is true and correct. (a) Name: Cry\')~() (<\1(,\\-en Address: \('\C\ \ hI'> <:,\- '" lPl.) CII......re\\cHy..~ eG\ \ III ,0 Social security Number: ;::)\"\ ,'ld Odl 3 (b) It you are presently employed, state Employer: ~. Y\ PC1~ Address: ('('r;(\(pt "')\- Len'..,::>..tY"\8 pf4 \1(':>42> Salary or wages per month:llt3,9(O. W u.ve. "'''OP Type of work: We;: \\-Ce~D If you are presently unemployed, state Date of last employment: Salary or wages per month: Type of work: 28 tr. <0.. ,... 1),.,9.,. <..)-(. ccl.) LL~)?_. E' iL'~ ""\"'.'. u_ ",. F- tJ.., o C'J Q 9 ;r;. """ (: 2: :'r:). t '.-<':;C'. I.,..' ~:i~ C) ~.:J .. ~,~ :~:\s.] 4-~ ..;~'" }Y"Ii:'1J <-~~.J ~,L ~ ~ [) '"'" "'1 C'.-'. c...' .,. ro O~