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HomeMy WebLinkAbout01-4242 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACTION CIVIL ORDER OF COURT AND NOW, this~.day of ~,,~-/ 2001, upon consideration of the attached Custody Stipulation, it is hereby ordered that Ann Kerchoff shall have full, legal and physical custody of the Micheal A. Reed and Arthur J. Lincoln V. BY THE COURT,/ Teresa M. Reed 1950 Simpson Ferry Road Mechanicsburg, PA 17055 PLAINTIFF Ann Kerchoff PO Box 428 North Main Street .co/ay Herndon, PA 17830 DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACTION Micheal A. Reed and Arthur J. Lincoln V CIVIL NO: CUSTODY STIPULATION It is hereby stipulated that: Teresa M. Reed, natural mother of herein named minor, is an adult individual who currently resides at 1950 Simpson Ferry Road Mechanicsburg, PA 17055. Arthur Lincoln III, natural father of herein named minor, is an adult individual whose whereabouts currently are unknown. Arthur's last known address was 1950 Simpson Ferry Road Mechanicsburg, PA 17055. Daniel Reed, natural father of herein named minor, is an adult individual whose whereabouts currently unknown. Daniel's last known address was 177 Wallace Blvd. Clarksville, TN 37042. Arthur J. Lincoln V, minor and natural child of Teresa M. Reed and Arthur Lincoln III, currently resides at PO Box 428 North Main Street Herndon, PA 17830. Micheal A. Reed, minor and natural child of Teresa M. Reed and Daniel Reed, currently resides at PO Box 428 North Main Street Herndon, PA 17830. Ann Kerchoff, the step mother of Teresa M. Reed, is an adult who currently resides at PO Box 428 North Main Street Herndon, PA 17830. Teresa M. Reed has full, legal, and physical custody of Micheal A. Reed and Arthur J. Lincoln V. Teresa M. Reed wishes to give custody of Micheal A. Reed and Arthur J. Lincoln V to Ann Kerchoff. Ann Kerchoff will have full, legal and physical custody of Micheal A. Reed and Arthur J. Lincoln V, including the right and responsibility to make decisions regarding Micheal and Arthur's education, health, financial and any other decision that may be required to properly care for said minor. Ann Kerchoff wishes to accept full, legal and physical custody of Micheal A. Reed and Arthur J. Lincoln V. There is no requirement for Teresa M. Reed to pay child support in any manner or form. Respectfully Submitted: 1 Name Teresa M. Reed Date d)O / Name Ahn Ker~off - uo NOTARIAL SEAL ROBERT J. GOLD, Notary Public Hampden Twp. Cumberlsnd County My Commission F_xpi;es July !0, 2003 IN RE: TERESA M. REED vs ANN M. KERCHOFF : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : : NO: 01-4242 CIVIL : : CUSTODY ORDER OF COURT AND NOW, this '4,! day of March, 2003, upon consideration of the attached petition and by agreement of the parties, the following Order is entered regarding custody of Michael A. Reed and Arthur J. Lincoln, V: Plaintiff, Teresa M. Reed, shall have sole physical and legal custody of the children. This Court relinquishes jurisdiction of the custody case; any further custody matters should be filed where the children reside. BY THE 7~ i. Hess, Judge This Order is entered pursuant to the consent of the Plaintiff and Defendant: Teresa Reed, Plaintiff J~At~ff X'nn Kerchoff, ~o se Defendant Distribution: Joan Carey, Attorney for Plaintiff MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle PA 17013 Ann Kerchoff, pro se Defendant P.O. Box 428 North Main Street Hemdon, PA 17830 IN RE: TERESA M. REED vs ANN M. KERCHOFF : IN THE COURT OF COMMON PLEAS · OF CUMBERLAND COUNTY : : NO: 01-4242 CIVIL : : CUSTODY p~_mr~vTr,x~ ~vr~ ~ aa'~r~Tlci'V CUSTODY ORDER Plaintiff, Teresa M. Reed, by and through her attorney, Joan Carey of MidPenn Legal Services states the following: Plaintiff, Teresa M. Reed, hereinafter referred to as the mother, currently resides at 316 Apartment J, Boulder Drive, Newport News, Virginia, 23608. o Defendant, Ann M. Kerchoff, who is the stepmother of the plaintiff/mother, Teresa Reed, currently resides at P.O. Box 428, North Main Street, Herndon, Pennsylvania, 17830. Arthur Lincoln, III, is the natural father of the minor child, Arthur J. Lincoln; the natural father's whereabouts are unknown to the mother and his last known address was 1950 Simpson Ferry Road Mechanicsburg, PennsylXmnia 17055. Daniel Reed, is the natural father of the minor child, Michael A. Reed; to the best of the mother's knowledge he last resided in Georgia at an address unknown to her, and he is currently in the military in Kuwait. An Order of Court was entered on July 13, 2001, in the above captioned case granting Defendant legal and physical custody of the mother's minor children, Michael A. Reed and Arthur J. Lincoln, V. Defendant returned the children to the custody of their mother on or about February 23, 2002, and they have resided with their mother since that time. o The mother requests that the Order of July 13,2001, be modified to confirm the status quo of custody in the mother. o The mother further requests that the court relinquish jurisdiction of the case, and order that any further matters regarding custody be brought where the children reside. The parties are in agreement and wish to have an Order entered consistent with the above terms and pursuant to their signed consent. WHEREFORE, the Plaintiff/mother requests that the court enter an Order granting her sole physical and legal custody of her children. Respectfully submitted, ~~~ey, A~iaintiff MidPenn Legal Services 8 Irvine Row Carlisle PA 17013 VERIFICATION The above-named Plaintiff, Teresa M. Reed, verifies that the statements made in the above Petition are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification, to authorities. Date: Teresa M. Reed, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACTION NO. ORDER OF COURT AND NOW, this~daY of <~,~ 2001, upon consideration of the attached Custody Stipulation, it is hereby ordered that Ann Kerchoff shall have full, legal and physical custody of the Micheal A. Reed and Arthur J. Lincoln V. BY THE COURT,/ Teresa M. Reed 1950 Simpson Ferry Road Mechanicsburg, PA 17055 PLAINTIFF Ann Kerchoff PO Box 428 North Main Street ,.c~/, Herndon, PA 17830 DEFENDANT IN THE COURT OF COMMo CUMBERLAND _~N PLEAS OF COUNTY, PENNSYLVANIA ACTION Micheal A. Reed and Arthur j. Lincoln V CIVIL NO: CUSTODY STIPULATION It is hereby stipulated that: 1. Teresa M. Reed, natural mother of herein named minor, is an adult individual who currently resides at 1950 Simpson Ferry Road Mechanicsburg, PA 17055. 2. Arthur Lincoln ill, natural father of herein named minor, Js an adult individual whose whereabouts currently are unknown. Arthur's last known address was 1950 Simpson Ferry Road Mechanicsburg, PA 17055. Daniel Reed, natural father of herein named minor, is an adult individual whose whereabouts c address was 1 7 %^l~,f~ ...... urrentJy unknown Da ' ' 7_. ,=,,,~ u~vd. ClarksviJle, TN 3~042 nlei s last known 3. Arthur J. Lincoln V, minor and natural child of Teresa M. Reed and Arthur Lincoln III, currently resides at PO Box 428 North Main Street Herndon, PA 17830. Micheal A. Reed, minor and natural chi/d of Teresa M. Reed and Daniel Reed, currently resides at PO Box 428 North Main Street Herndon, PA 17830. 4. Ann Kerchoff, the step mother of Teresa M. Reed, is an adult who currently resides at PO Box 428 North Main Street Hemdon=, PA 17830. 5. Teresa M. Reed has full, legal, and physical custody of Micheal A. Reed and Arthur J. Lincoln V. Teresa M. Reed wishes to give custody of Micheal A. Reed and Arthur J. Lincoln V to Ann Kerchoff. Ann Kerchoff will have full, legal and physical custody of Micheal A. Reed and Arthur J. Lincoln V, including the right and responsibility to make decisions regarding Micheal and Arthur's education, health, financial and any other decision that may be required to properly care for said minor. 6. Ann Kerchoff wishes to accept full, legal and physiCal custody of Micheal A. Reed and Arthur J. Lincoln V. 7. There is no requirement for Teresa M. Reed to pay child support in any manner or form. Respectfully Submitted: ame Teresa M. Reed NOTARIAL SEAL ROBERT J. GOLD, Nolary Public I-lan'~pdon '~¥~. Cumbed~d County My Commission ~_xpires July 10, 2003 IN RE: TERESA M. REED VS ANN M. KERCHOFF · IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO: 01-4242 CIVIL CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Teresa M. Reed, Plaintiff, 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 service to the party. MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 IN RE: TERESA M. REED VS ANN M. KERCHOFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO: 014242 CIVIL CUSTODY ACCEPTANCE OF SERVICE C7 I, Ann Kerchoff, Defendant in the above captioned custody case, accept servic~-0f the Petition to Modify Custody Order. Ann M. Kerchoff, tl~efendant IN RE: TERESA M. REED VS ANN M. KERCHOFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO: 01-4242 CIVIL · CUSTODY AFFIDAVIT OF SERVICE I, ~~~~~j~, the undersigned, hereby state that I served a copy of the Petition to Modify Custody Order upon the Defendant by handing the papers to ~ at the following address: 'O ~ '~ ~ 3- ~3c {~ G[ __ on the ~ day of ~_________, 2003, at approximately ~ o'clock ~_...m. 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. §4909, relating to unsworn falsification to authorities· Address: Dated: