HomeMy WebLinkAbout98-04158
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4. The relationship of the plaintiff to the children is that
of mother. She is single. She currently resides with the
fOllowing persons:
Name
Twanda Anderson
Relationshil)
Daughter
Sadeek Anderson Son
5. The relationship of defendant to the child is that of
father. He is single. He currently resides with the following
persons:
Name Relationshil)
Ola Brown Aunt
6. plaintiff has not participated as a party or witness, or
in another capacity, in other litigation concerning the custody of
the children in this or another court.
Plaintiff has no information of a custody proceeding
concerning the children pending in a court of this Commonwealth.
Plaintiff does not know of a person not a party to the
proceedings who has physical custody of the children or claims to
have custody or visitation rights with respect to the
children.
7. The best interest and permanent welfare of the children
will be served by granting the relief requested because:
a) They have lived only with plaintiff from the time of their
births.
b) Plaintiff believes Defendant does not desire to exercise
custody over Twanda and Sadeek.
8. Each parent whose parental rights to the children have not
TAMMY L. CROWDER,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
ROBERT ANDERSON,
Defendant
NO. 98- oI.j/~j) CIVIL TERM
PRAECIPE TO PROCEED IN
FORMA PAUPERIS
To the Prothonotary:
Kindly allow TAMMY L. CROWDER, Plaintiff, to proceed in forma pauperis.
I, Thomas M. Place, of the Family Law Clinic, 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. The party's affidavit showing inability to pay the costs of
litigation is attached hereto.
Date: 7 - ;).) - 1<1
~(4,/-.
Thomas M. Place
Supervising Attorney
ROBERT E. RAINS
THOMAS M. PLACE
KATHERINE C. PEARSON
Supervising Attorney
DONALD MARRITZ
Staff Attorney
Marcia M. Ziegler
Student Attorney
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
(717) 243-2968
TAMMY L. CROWDER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN CUSTODY
ROBERT ANDERSON,
Defendant
: NO. 98-4158 CIVIL TERM
CERTIFICATE OF SERVICE
I, Megan C. Huff, Certified Legal Intern, hereby certify that on the 21st day of August,
at about 1:30 p.m., 1998, I served a true and Correct copy of the Custody Complaint and
Praecipe to Proceed In Forma Pauperis on Robert Anderson, presently imprisoned in the
Cumberland County Prison, by handing him the same an informing him of the contents at the
Cumberland County Prison, Carlisle, Pennsylvania. . /~/~
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V':t -'---.'
,--. 'VI /" .
Megan CYHuff I (
. \
Certified Legal Intern
F AMIL Y LAW CLINIC
45 N. Pitt Sl.
Carlisle, PA 17013
717-243-2968
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IN THE COURT OF COMMON PLE1f!Jllbt 6 19931(
CUMBERLAND COUNTY, PENNSYLVANIA .
CIVIL ACTION - LAW
IN CUSTODY
TAMMY L. CROWDER,
Plaintiff
v.
ROBERT ANDERSON,
Defendant
NO. 98- YI';'~ CIVIL TERM
CUSTODY AND VISITATION AGREEMENT
THIS AGREEMENT, made this
between plaintiff, TAMMY L.
"7,,'.1 day
CROWDER,
of '(:\."...-.\
)
and defendant,
, 1998,
ROBERT
ANDERSON, concerns the custody and visitation of the children:
Twanda Anderson, age 1 year, and Sadeek Anderson, age 2 years.
Plaintiff and defendant desire to enter into an agreement as
to the custody of the children and to have this agreement made an
Order of Court. Plaintiff and Defendant accordingly agree to the
following:
1. Mother shall have sole legal and physical custody of the
children subject to visitation by the father as mutually agreed to
by the parties.
2. Father shall not remove children from the state or keep
children overnight unless such arrangements are mutually agreed
upon by the parties.
3. The parties hereto intend to be legally bound by the terms
of this agreement and agree that it shall be made an Order of
Court.
~f ~, {LL,I.LWl
.
/Q,m t~ CA()~l
Tammy Crowder, Plaintiff
Robert Anderson, Defendant
~f1~
, Counsel for Defendant
Thomas M. Place
Supervising Attorney
...
...
9P - "lIS?
C<.-:(L
Thomas M. Place
Robert E. Rains
Katherine C. Pearson
SUPERVISING ATTORNEY
Gail R. Shearer
STAFF ATTORNEY
Marcia M. Ziegler
Student Attorney
FAMILY LAW CLINIC
45 North Pitt street
Carlisle, PA 17013
(717) 243-2968 Ie D
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ORDER
AND NOW', this
~.,
4ct ~ !-.
day of
-,
1998, the foregoing Agreement is approved and entered as an
Order of Court.
J.
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