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Home My WebLink About98-05987 V. 'tJ ~ ,\,) .... ."L; VI ,. ~ <J o ~ c-<l - ( \~ - .5 <:j t-- c.... ~ . c.... ~ a ~ CHARLOTTE L. BROCK, Plaintiff IN TilE COURT OF COMMON I'LEAS OF CUMBERLAND COUNTY,PENNSYLV ANIA v, CIVIL ACTION - LAW JOSLYN y, BROCK, CHARLES G. SUMLIN, CHlRROD WILLIAMS, Defendants NO, 98-5987 IN CUSTODY CERTIFICATE OF SERVICE I, ]aequeline M, Verney. Esquire, attorney for the Plaintiff, Charlotte Brock. hereby certify that I mailed a true and correct copy of the complaint and Order of Court scheduling the hearing on August 27, 1999 at 9:00 by certified mail, return receipt requested, restricted delivery to Charles G. Sumlin at 3625 Dial Street, Whistler, AL 36612-1633-25 and at the same address by US First class mail, postage prepaid, with certificate of mailing, The Certified mail was returned unclaimed, however the first class mail was not returned to the sender, The certificate of mailing is attaehed hereto as Exhibit "A" I verify that the statements made in this certificate of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S, section 4904 relating 10 unsworn falsification to authorities, Date: S'/':;':>/77 US POS TAL SFAVICe CERTIFICATE OF MAILING MA:-i"BEo uSED FOR OQMEtHIC AND INTERNATIONAL ;.fAICrxjf~<iNO-T--- PROVIDE f.OR INSURANCE - PQS1MASTER RU(::t'Nodf"fom ~"~ o ~~ c , gn ( ~ i ~~" 5.4k.C,L\!{..L.N' M. v'f-(l..NW,f,~(L~ ~ S HAN.QII.,L 5. . C.1r~~Ll P,. nOI~ Ch~ILLlS &,SlA",L'N 3'.:15 bll1.L 5TI!.H.r !Jh"rLL;!.. At '&~I'2-!"~Ji1~- 0, L 'il co gf;B'~F f1 ;" ;;;c::::J -:::;_~' C)e NQ(J)_-C =0-1 ~. .i::;~C~ bc::::J 18:" i2 W " In Onapol'C'eo!ordli"lasyl'T\i1lladdressOOlO PS Form 3817. Mar. 1989 f;UlBIT A , --- :7 ,/ ../ ~ ro ,., ,., W ,., a: ;; '" 0 :0 ~ 0 0 :J <JJ '" "W W Z <JJ '" W'" :0> og 0-' J: ~ 0:-' >- <JJ a: Z <( :lZ ;;: OW 0 U"- W WW Z-' O~ -' ~ '" U ,/ " " I .. ~ ~ UJ " ~ 0 H u.O 0: [La UJ Zltl1. 20 03C ~z 0:2 UJ 0:0' IM1 WILl! OJ " 00 noc ..>- 0>->- m "2 OW;;: mO: o:~o ":J c{ID: m- 2"C(r UJ 0:2U 0: O:Jr u. " , 0 0 0- 2 fil -' :zu 5 ~~ Ul :;:p: Pfil UlE-< ;<l uP:; H Ul:I: ~Ul 1-1 ~ p:;r<: <':~' 0::'" U " r:l ,.". p:;o :zm - 0 - - - - t' ~ \ tfio I' ,),':' I ; ,-..II" t , -l'1" II ,,\,~ ~ " -... 1'~O , ....r.. " I"... i i < ~;.,' CHARLOTTE L, BROCK IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V, JOSLYN Y. BROCK NO. 98-5987 CIVIL TERM AND NOW, this ORDER OF /0 ,.... COURT day of NOVEMBER, 1998, the Court being in receipt of the Petition of Charlotte Brock for complete and sole custody of the minor children Chandler A. Brock, born March 12, 1993, and Chase A, Brock-Williams, born June 16, 1997, a hearing thereon is scheduled for Monday, December 7, 1998, at 4:00 p.m. in the Cumberland County, Courthouse, Carlisle, Pa. 17013. Any party wishing to be heard at said hearing may appear in person, through counsel, or may make arrangements to be connected by telephone by contacting the chambers of the undersigned at (717) 240-6290. Edward E. Guido, J. CC: Charlotte L. Brock Joslyn y, Brock Charles G. Sumlin Chirrod Williams :sld CflARLOI'TE L. BR<XK, plaintiff IN THE COURT Ol" COM~ION PLEAS OF CUMBERLAND COUN1Y, PENNSYLVANIA vs. NO. 98-5987 CIVIL TER!" JOSLYN Y. BR<XK, CHARLES G. SU~lLIN, and CHIRROD WILLIAMS, Defendants C1 V1L AC:l'lON - LAI'I IN CUSTODY PRIOR JUDGE: Edward E. Guido CUS'fODY CCl'lCILIATIOO SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNI'Y RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRmrLY IN CUSl'ODY OF Chandler Alexis Brock Chase A. Brock-Williams March 12, 1993 June 16, 1997 Mother Mother 2. A Conciliation Conference was held on May 5, 1999, with the following individuals in attendance: The Maternal grandmother, Cbarlotte L. Brock, with her counsel, Jacqueline M. Verney, Esquire, and the Mother, Joslyn Y. Brock, who is not represented by counsel. Chirrod Williams, the Father of Chase A. Brock-Williams, lives in Georgia and participated in the Conference by telephone. The efforts of the Maternal grandmother's counsel to serve notice of the Conference on Charles Sumlin, the Father of Chandler Alexis Brock, were unsuccessful and Mr. Sumlin did not attend the Conference. 3. The Maternal grandmother initiated this action for temporary primary physical and legal custody of both Children, with the agreement of the Mother, to fulfill the Army's requirement that the Mother legally transfer custody to another person temporarily during her 12 week basic training and A.LT. schooling. The Mother and the Maternal grandmother have lived together, with the Children, since 1993. The Mother attempted to transfer physical and legal custody of the Children to the Maternal grandmother (to satisfy the Army's requirements) by stipulation filed Pro Se in October 1998. This Court entered an Order on October 26, 1998 advising that the Court did not have sufficient infot'mation based on the Stipulation to entet' the t'equested Onlet' ilnd scheduled a lIeat'ing fot' Novembet' 4, 199f3. This Cout't entet'C") a "econd Ot'det' on Decembet' 7, 1991, indicating that the Fathet' of Ch,1ndlet', Chades Sumlin, had t'eceived notice of the ~lothet"s t'cquest and lIeadng date but had not t'esponded and the Fathet' of Chase, Chit't'od \villiams, t'esponeled ilnd objected to the Petition. The Ot'det' advised the pat'ties to obtain lcqill counsel and also t'efet't'ed the case to the Conciliation pt'ocess. !Jetween the time of Chat'les Sumlin's t'eceipt of notice of the pt'oceedings in lilte 1998 and the scheduling of the Conciliation Confet'ence, Mt'. Sumlin appat'ently t'elocated without advising any of the padies ot' the Domestic Relations Office of his move at' new addt'ess. Neithet' the Matemal gt'andmothet' not' the ~lothet' have any infot11lation conceming ~1t'. suml in's whet'eabouts and thet'efot'e, Mt'. Sumlin did not t'eceive notice of the Conciliation Confet'ence. Accot'ding to the Mothet', Mt'. Sumlin has had no contact with the pat'ties' daughtet', Chandlet' Bt'ock since het' bit'th in 1993. 4. The Matemal gt'andmothet" s/Mothet" 13 position 00 custody is as follows: The Mothet' seeks to tt'ansfet' legal and physical custody to the Matet'nal gt'andmothet' tempot'at'ily while the Mothet' is completing the 12 week Atmy tt'aining and schooling session. Accot'ding to the Mothet', a Cout't Ot'det' tt'ansfet'dng custody is necessary as childt'en at'e not pemitted to t'eside with theit' pat'ents dudng the 12 week pedod. The Matemal gt'andmotbet', who has t'esided with both Childt'en fot' theit' entit'e lives, agt'ees to assume custody dudng this pedod of time, and both the Matemal gt'andmothet' and the Mothet' believe it is in the Childt'en' 13 best intet'est fot' tbe gt'andmothet' to do so. Accot'ding to tbe Matemal gt'andmothet' and the Mothet', Chandlet"s Fathet', Chades Sumlin, has had no contact with the Child since het' bit'th in 1993 and Chase's Fathet', Cbit't'od Williams, has had no contact with Chase since Septembet' 1997 when Chase was 3 months old. Although the Mothet' does not wish to pt'event Chit'rod \villiams ft'om having contact with Chase, she believes it would fit'st be necessary fot' the Child to be t'eintt'oduced to the Fathet' gt'adually so that a pat'ent/child relationship can develop. The Mothet' indicated that aftet' het' basic training pt'ogt'am is completed, she would be willing to wot'k with Chase's Father to make at't'angements fot' him to reestablish contact with the Child if he is intet'ested in a long tem t'elationship. Howevet', the Mother is not willing to allow the Child to be t'emoved to Geot'gia befot'e the relationship is t'eestablished. The Mothet' and Matet'nal gt'andmother do not believe that Chandler's Father, Chat'les Sumlin, has any intet'est or intention of establishing a relationship with Chandler. 5. The Fathet"s (Chit't'od williams) position on custody is as follows: Chase's Fathet' would like to develop a t'elationship with his son and would like to have custody of Chase dut'ing the Mothet"s pet'iod of tt'aining. The Father acknowledged that it would be somewhat tt'aumatic fot' the Child to be placed in his Father's custody in Geot'gia initially but believes that the Child would adjust as he develops a t'elationship with the Fathet'. Beyond the pet'iod of the Mothet"s At'ffiY tt'aining, the Fathet' expressed concet'll that the Mother may be stationed in anothet' country ot' at a location where it would be difficult for him to have any continuing contact with Chase. The Fathet' stated that he has adequate t'com fot' the Child at his cut't'ent residence and is able to pt'ovide care fot' the Child. The Fathet' t'equested a Headng on the issue of establishing partial physical custody arrangements fOI: the Fathet', if not dudng, at least aftet' the Mother's trilining hilS been completed. The I'clther <100'; not believe the flother will voluntilrily encour,,')e or support the develorXf,ent o( " relationship between tbe father and Ch"se. 6. '1'h0 Conci 1 iuto[" rcconullcnck:j an Order in the f')[,,1ll <1!} attached scheduling a Ilcarinq in tllin m..lttcr ;me! providin~J tcmporiH.'Y custody arrangements pending the tlci1dnq. J t is expected thilt the Ilcaring will require one-half d"y. ~n"(J Dat {/, (CH <] , I C~x- hL. cC. "'-'1 Dawn S. Sunday, Esquire Custody Conciliator CHARLOTTE L. BllOCK IN THE COUll'!' OF COMMON PLEAS OF CUMBERLAND COllN'I'Y, PENNSYLVANIA V. JOSLYN Y. BROCK NO. 98-5987 CIVIL TERM AND NOH, this ORDER OF 10 ,.,... COUR'I' day of NOVEMBER, 1998, the Court being in receipt of the Petition of Charlotte Brock for complete and sole custody of the minor children Chandler A. Brock, born March 12, 1993, and Chase A. Brock-Williams, born June 16, 1997, a hearing thereon is scheduled for Monday, December 7, 1998, at 4:00 p.m. in the Cumberland County, Courthouse, Carlisle, Pa, 17013. Any party wishing to be heard at said hearing may appear in person, through counsel, or may make arrangements to be connected by telephone by contacting the chambers of the undersigned at (717) 240-6290, ~-- By tC..e'ourt, ~ Edward E. Guido, J. ee: Charlotte L. Brock Joslyn Y. Brock Charles G, Sumlin Chirrod Williams :sld (:, J<"-L ,II..t(,.C'.t 11/ I -~ ) (, s ., )'. r, , , i I , I. . ~ :ti I, , ," " , CHARLOTTE L. BROCK, Plaintiff IN 1'IIE COUll'!' OF COMMotl PLEA~ OF CUMBERLAND COUNTY, I't-:NN"YI.VANIA ~ .. v, JOSLYN Y. BROCK, Defendant NO, 'lIl-','1Il'I CIVIl. TEHM QRmm_oX _COI1lI'l' AND NOW, thin 4th dilY 01 tlovf'mhl'r', l'J'IIl, this hearing is continued to give the oppor.tllllity to the fathers of the children to be heard in connection wlth UI<!<iC matters. In the interim, care and cUfitody of tlH' chi Idr',,", Challdler A, Brock, born March 12 th, 19'13, illlel Chi"''' ^, Ilr'ock -W i lliams, born July 16,1997, is placed with th"ir' nli.tr'l'llill Cjr'andmother, Charlotte L. Brock, 'y 'WI Edward E. Guido, J, Charlotte L. Brock Joslyn Y. Brock 503 B Street Carlisle, PA 17013 :1fh CHARLOTTE L, 13HOCK IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. JOSLYN Y. BROCK NO. 98-5987 CIVII~ TERM AND NOvl, this ORDER OF COURT .)(, .M, day of OCTOBER, 1998, after reviewing the parties stipulation the Court does not have sufficient information to enter the requested order. Therefore, a brief hearing on this matter is scheduled for Wednesday, November 4, 1998, at 4:00 p.m. in Courtroom # 5 of the Cumberland County Courthouse, Carlisle, Pa. By Edward E. Guido, J. cc: Charlotte L. Brock Joslyn Y. Brock \.' -'\' , - ~_,t" ~~, I,...p_.....l:\\..... Ie,),')., (0/ q fi .J ,"l :sld CI/^llIlllTl, I. IIIH)(,k I'I.^'''I'I-I' \, J" 1/11' {'()I;HI OJ' CO\I.\Il),... 1'11,,\\ OF ('I'\lIl1'IH^"" COI ::-':IY, I'I"':-':,YI,\'A"'IA NO (1 (). r (' '<:;"r r) J 'f 'J (, 'T:' \ ,-L--~~ I('~rr') J()".\'" Y IIIH Jl'k IJFI,t,...IJ^"'! ('I'S'llllJY SIII'I:I.AIII'\ II... 11I..'rd)~ "lIjllllah:d lhal I f)di:lIlf<lllll~ all adult IlIdl\ HllIal \\110 I.: II rn.' II I I, r":"l(lc... at so; II ST Carl,..!...,. Pcnn...yl\';1111:1 17011 2 l'lallllllll~;In ;1(11111 \\110 (llrrL'1I11~ fc..ak.. al ~O\ IJ, ST ('AHI.ISL/: Pl.,"IIIlS~hallia 17111.1 1 Tile Defendanl IS the legal pan:nl or Challdler A. HInck. ilnd Cha'\c A Hrcx.:k~Will;allls, Defendant ,\ Ishes 10 I!iv..: lip her ICl1al ril.dll In cU"iltKI., orthc C1fon':llICllliOlll:d JlJlnors. The 1>1:llIIlIIl \1 ill ha\e cOlllplele and sole clIslody of Chandler l\. Brock and Cha~ A Brock.Williallls ill allll1allcrs concerning their \\ell bcillg 1t' '-/'i' C I) Dale: _~ -___IL RCSJlcclrllll~ SlIblllilled: /1.J!' , ~""fIIJ.lut;L:_,!l.JJ.!0(/! > 'l Plainlill' ~' : r' J5c' " ", ;. '" '. '..L~ li' _ [ .J\ 0../ .If f ( cfendolll Dale: /,';. (' I' ijJ, w;'"'~+>:;, v~ SI"C, cIS. t\-v-" \ , , ---~ J ,~ ( {.: 7- C 7"- - c' C;':'" :.J --J ...:J -::r- --p (l', L -- (, }; :+l r) ~) If: i (I' ,j ,~ (j '" ..:, , ,<I; - . C 1,"'\, \r ,\ \, , ' : IN TI IE COURT OF COMMON PI.EAS OF CUMI3ERLAND COUNTY, : PENNSYl.VANIA Plainlilr v, . )", "\'1' \ : CIVIl. ACTION l.A W \ \ ,\ Ikli:ndant : NO,', i" i CIVIL 19 ...., : CUSTODY VISITATION ORDER OF COURT And now, this \,,'::) n I '7\, upon eonsidcration of the attaehed complaint, it is hereby dirccted that the above parties and their rcspeetivc eounsel appear before ". i' \, n '" :, ("1.."'1 Esquire, the conciliato~l at ",'_~I \..,' \ .. ':-, ",,-,'. \~\~ .~, -\', .---' Pennsylvania, on the \l day of , \".' /:c" , 19cfiiJ, at ' ", A.M,~, for a Pre-hearing Custody Conferenee. At such don ference, an effort will be made to resolve the issues in dispute; or if this eannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may be present at the conferenee. Failure to appear at the eonferenee may provide grounds for the entry of a temporary or permanent order. FOR THE COURT: By: ,-<',,\\ ,~l\ A )\ U:nNfl ~ ,f ~ . Custody Coneiliator 'n~)) YOU SHOULD TAKE TI.IlS PAPER TO YOUR LA WYER AT ONCE, IF YOU DO NOT HAVE ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, pA 17013 (717) 249-3166 1-800-990-910S UU; (J; 1'l'JIJII' CllflIU,OTTE L, BROCK, Plaintiff It! TilE COUHT OF COMMON I'I.EM; OF CUMllEHLflNlJ COUNTY, I'EtIN!;YI,Vfllllfl v. JOSLYN Y. BROCK, Defendant NO. 98-5987 CIVIL TERM 9RlJER OF COURT fiND NOW, this 7th day of December, 1998, it appears that the father of Chandler A. Brock has received notice and has not responded, but the father of Chase fl. Brock-\<Iilliams has responded and is opposed to the petition, the parties are advised that they should attempt to get counsel. This matter will be referred to the conciliation process with a hearing to be scheduled at the convenience of the conciliator who will handle this matter. Edward E. Guido, J. Charlotte L. Brock Joslyn Y. Brock 503 B Street carlisle, PA 17013 Chirrod \<Iilliams 912 Aspen Court " Hinesville, GA 31313 ". Cburt Administrator :lf~, r f. H ~,1 l~g~ \ CIIAHLCfI'J'E I.. BHOCK, plaintiff 1 N TilE mUHT Q[" ca'1MON PLF.AS OF CLJMBEHLAND COUNTY, PENNSYLVANIA vs. ~;O. 9El-5gel7 CIVIL TEH!'1 JOSLYN Y. I\HOCK, Defendant Cl VIL Al'l'ION - LAW IN CUS10DY cusroDY CGlCILIATIOO SU1MARY REPORT AND NCM, this 19th day of Febr:uar:y, 1999, the Conciliator:, having r:eceived no r:equest fr:om counselor: either: par:ty to r:eschedule the Custody Conciliation Confer:ence or:iginally scheduled for: January 19, 1999, her:eby r:elinquishes jur:isdiction in this case. FOR THE COURT, f:~r../J--~~~I Dawn S. Sunday, Esquir:e c7 / CIIARLorn: L. BROCK. : IN TIn: (:OIJRT OF COMMON PLEAS Of' Plaintiff : UJMBERLAND (,OlINTY, PENNSYLVANIA V. ,IOSLYN Y. BROCK. CHARLES G. SUMLIN, CII/RROD WILLIAMS. Defendants : CIVIL ACTION - LAW NO, 98-5987 CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW, this l , day of I\f ;', \ , 1999. upon consideration of/he attached Custody Complaint, it is hereby directed that the parties and their ~~spective c?unsel shall appea~ befo~e '\,- \",,, " \'> ,,( :( ;, i ,1-' n ' -' the Conclhator. at '}, \ ""( "\ \, ',' '(' (, (' -r.)/\ on the '--., day of \''-''\0-''''\ , 1999 at \ v..:., o'c1oc~. m.,for e-Heanng Custody Conference. At such confcrence, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a Temporary Order. All children age five or older may also be present at the Conference. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, BY: \.1:, " Ui\)- Custody Conciliator \ The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be IlliIde at least 72 hours prior to any hearing or business before the court, You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 " '.: A/5' ~/~' ,/j lielj ",,/, (/:r ;(.: ,'<'11/~ ")- t/~ '/'1 5, II., !.',<'~, -";a_d'r' ?/-./<'I"~ ~tv <I" :1;' . g / /, ((1;/ 11/,,<-/,/ ,,;;, t'i'ry ,5<",,-<,,:y During lhe past live years, the childrcn have rcsided wilh Ihc Illllowing persons and atlhe following addrcsses: 1.ISTAI,I,-'~EJ:~5QNS ADDRESSES DATl~S Charlotte L. Brock Joslyn Y. Broek 503 B, Sl. Carlislc. PA IlJlJ3-present The Mother ofthc children is Joslyn Y. Brock currently residing at 503 B, Street. Carlisle. Pennsylvania, She is single. The Father of the Chandler A. Brock is Charles G. Sumlin. He is currently residing at 9040 Berkshire Terrace, Hinesville. GA 31314, He is single, The Father ofChasc A, Brock-Williams is Chirrod Williams, He is currently residing at 325 Bay Achers Road, Apt 15-A, Jessup, GA 31545, 4, The relationship of Plaintiff to the children is maternal grandmother. The plaintiff currently resides with: NAME RELATIONSHIP Joslyn y, Brock daughter Chandler A. Brock granddaughter Chase A. Brock-Williams grandson 5, The relationship of Defendant. Joslyn y, Broek to the children is Mother. The relationship of the remaining Defendants to the respective child is Father. The Defendants currently reside with: N(\ME REI AIIONSI liP Joslyn y, Brock: Charlnltc Bruck. childrcn grandmothcr, childrcn Charlcs G. Sumlin: unkno"n Chirrod Williams: unkno\\n 6, Thc plaintill: Charlottc Brock. has not participatcd as a party or witness, or in anothcr capacity. in othcr litigation concerning the custody for the children in this or another court. Defendant. Joslyn Y. Brock has participated as a party or witness or in another capacity, in othcr litigation concerning Chandler A. Hrock. Thc court, term and number. and its relationship to this action is: Cumberland County Common Pleas Court, No. 94-7246, Custody, On Mareh 2. 1995, a eustody order was entered granting Joslyn Hrock legal and physical custody of Chandler A. Broek, following a conciliation conference where the father, Charles G. Sumlin did not appear. A copy of the Order is attached hereto as Exhibit "A", Plaintiffs have no information of the custody proceeding eoncerning the children pending in a court of this Commonwealth, Plaintiffs do 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 pennanent welfare of the ehildren will be served by granting the reliefrequested because: a, The children have lived their entire lives with the plaintiff and defendant, Joslyn y, Brock. '. :: II II II II I I i I I! ,I II 3. The mother and her attorney are hereby charged with refoponsibility of providing a certified copy of this order to the Defendant by personal service. certified mail. or some other fashion foufficient to prove that the Defendant was served at least a copy of the order in this matter, By the Court. I IIJohn H. Broujos. Esquire ilAttorney for Plaintiff Illcharles G. Sumlin. pro foe Defendant ,I /5/ ~'" p Aif~ J. TC'! H= c.'r.r--l,' f'" ~ .'. . . l ...... .~~..)':: ~:~ .;?:' r~".:-J""r~~n ;r~.; ~;~ ::;~X ,;;"::_:;;' ,:, '. ' " ':< :" ;', ." ,1 IN'" <ilA<<( 1- '.'.. " ,',', .. I"--!_~, _3...Ij ~I..71'", - /. ". ql~ , /l~' '. , !6 ~ --- .-.- r ~~ --"-,~ Protllonmary 11 sla _~:n , ,- <;'.,-'-...1'-"" ., )'....~L,<;_. ,',.... th ,';r.({qJ w, '/ /, 'Ii 1'11.5 9 / ~ II r Il-n Co btre/- ;!, iv f..5 ~ J 11,- bA, / 313/3 C)fudLS ,. Sum;"''' 9tJt(b ?JdIA A,'I-L /"W!IIO- //,'l(eJ r,'/k/ 6/1. 313J'/ I I , ~ " f \"1 ~~r' 1'1 :tf , I . ~; : I': , l ~ , I . \ ' , ~ " i , ; ! , I j, . \ '. '.\ .; ,j :.! ~ ' . , ~~<. , ' , ' CIIARU1TTi-:' "I" I'J I' "I ::; '::li< <':':1< il!o' r'(+~r.~I)!l i'LE^:; OF ;'J~lTY, !'!<lllJ:;'{I.'//\llI^ T, .",.:,: :. , "" ,.fL.1 : ! ~ JOSLYN Y. HIHF:r:, CHARLES r;, ,;U1'11.;1I, CIIIRROD I'll I.l.lt,t'l rkf ('llddllt {lIi-r)(n~' CI'/i L TEIU.1 IN 1\1-:: DRIlI':1l lW coup:!, AND 110\'1, t.his /7th day of TIIHjUst, 1999, after heaLing and at the request of the mother, Jos!,yn{, Brock, Plaintiff, Charlotte L. Brock, is qranted primary physical and legal custody of her grandchildren, Chandler Alexis Brock, born March 12, 1993, and Chase A, Brock-Williams, born July 16, 1997, Mother, Joslyn y, Brock shall be entitled to partial physical custody as agreed upon by the parties. The natural father of Chase Chirrod Williams, shall also be entitled to partial physical custody as agreed upon between Plaintiff Charlotte L, Brock and said natural father. If the parties are unable to agree on appropriate times for visitation, this Court will grant said visitation on petition of any party, This court shall retain jurisdiction, By the Court, Edward E, Guido, J. Jacqueline M. Verney, Esquire /)\.-\..'-'-(.. (( For the Plaintiff - /' (!t": C"-f'<J '/- /- ,I It