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Home My WebLink About00-07530 ~ ~' . - I . !-CO-- ~"'~' _ Co ~ > ROBERT KISTLER and LINDA KISTLER ",;", OCT 2 6 2.DDrfJ : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLV ANlA Plaintiffs, vs. : NO,4t-OO -fO:J) clOd KOREN HAMMONS and RUSSELL CLA VEY, , GlJsbJ, : y /ere Defendants ORDER OF COURT AND NOW, this ~ day of 6,;r.Jii4 I> ,2000, based on the stipulation of the parties, the Court hereby Orders as follows: 1, Plaintiffs Robert Kistler and Linda Kistler shall have primary legal and physical custody of the minor child, Russell J. Clavey, born December 14, 1995, 2, Defendants Koren Hammons and Russell Clavey shall partial physical custody at times mutually agreeable to the parties. !'.~ -(1)~ /0 -30 -00 'K~ !t~~IMiIilW~mi!ll~~fu:ilSW'8:"I~j,j;~;i,:)f>h'~"fr'-"_"J<i1~J~iIH!M:iI C(~.lii"lIirU-"- ~. ~"I~"'" .;' - J._"'lJilill~~ JJ.Nn~~/O~SNN3d J or ,11f1i:88wno ~ Z:8 PJV Of; 1:30 ao AW10i\li}'iii';:,c." BOtdiO:i,l3-iQtl dO , __,"_ J_l._...~. . - - -~, - . -y , ,,,- , 1 r . " ~. 1,_ ,;1 _ .1- - '~, ,J _g "o~-, " ;"",'1- -,.' _,"_ '~_ _ _ ~ ~;'--' '~'[( , ROBERT KISTLER and LINDA KISTLER : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA Plaintiffs, vs. : NO. ()-O.7(f30 ~ 1..fAAV KOREN HAMMONS and RUSSELL CLA VEY, Defendants ~ STIPULATION FOR ENTRY OF AGREED ORDER 1. Plaintiffs are Robert and Linda Kistler, adult individuals, who currently reside at 22 Park Street, Mount Holly Springs, Cumberland County, Pennsylvania 17065. 2. Defendant is Koren Hammons, an adult individual with a mailing address of 22 Park Street, Mount Holly Springs, Pennsylvania, who resides at various addresses in Cumberland County. 3. Defendant is also Russell Clavey, an adult individual, who currently resides at 128 South Hanover Street, Apartment 1, Carlisle, Pennsylvania 17013. 4. plaintiffs are the in loco parentis parents of the child, Russell J. Clavey, born December 14, 1995. Defendant Koren Hammons is the natural mother of the child and Defendant Russell Clavey is the natural father of the child. The child was born out of wedlock. - -. -" -. -~ "'-, - '''' ,-," , "--,._-,...,..-, '. ".' "', 5. The relationship of the Plaintiff to the child is that of in loco parentis parents. The Plaintiffs currently resides with Russell's half sisters, Jade and Sebra Sease. 6. The relationship of the Defendant Koren Hammons to the child is that of natural mother. Defendant Koren Hammons currently resides with unknown individuals. The relationship of the Defendant Russell Clavey is that of natural father. Defendant Russell Clavey currently resides with his girlfriend, Heather Bream. 7. Since birth, the child has resided at the following addresses with the following persons: a. From birth until May 1996, the child resided at 22 Park Street, Mt Holly Springs, Pennsylvania with Plaintiffs, Defendants and his half sisters, Jade and Sebra Sease. b. From May 1996 to the present, the child has resided at 22 Park Street, Mt Holly Springs, Pennsylvania with Plaintiffs and his half sisters, Jade and Sebra Sease. At various times, Defendant Koren Hammons has resided with the child at this address. 8. Plaintiffs have not participated as a party in other litigation concerning the custody of the child in another court. Plaintiffs have no knowledge of any other custody proceedings concerning the child pending in any court of this Commonwealth. Plaintiffs do not know of any other people not a party to these proceedings who have physical custody of the child or claim to have custody or visitation rights with respect to the child. 9. Both Plaintiffs and Defendants agree that it is in the best interest of the child for the Court to enter the attached Order of Court as an Order. . ',-"-I, '~ I , ,__, -- " ~--. ",.,,~, 'c', _,,~<,,<, -"'-' ,-, 'n:~ WHEREFORE, this~day ofS-()f'k~/.2000, Robert Kistler, Linda Kistler, Koren Hammons and Russell Clavey, intending to be legally bound and waiving their right to be present when this agreement and order are presented and executed, hereby stipulate and agree that the Court may enter the following order in the above captioned case: ORDER OF COURT AND NOW, this _ day of , 2000, based on the stipulation of the parties, the Court hereby Orders as follows: 1. Plaintiffs Robert Kistler and Linda Kistler shall have primary legal and physical custody of the minor child, Russell J. Clavey, born December 14,1995. 2. Defendants Koren Hammons and Russell Clavey shall partial physical custody at times mutually agreeable to the parties. By the Court, J. The parties further agree that in the procuring of this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing by either party. . ~ , , ~' ~ '- ; - '. -'.'I.i:.io;.",k ~'. i.' - "" --' '1;;; ,';,,' 'r.:,,~,~" ,'., j',-""-".d;"-',, IN WITNESS WHEREOF, the parties, intending to be legally bound, have signed hereunto. WITNESS ~~ fP~JtJ Robert Kistler ' ~... Linda Kistler ~LM~ ~"VVl~ '-fA1M.vVI ('{~ Koren Hammons ~~ aJ Or- Russell Clavey I verifY that the statements made in the foregoing Stipulation are true and correct. I understand that false statements herein are made subject to the penalties of18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: 9/'2~ J 0<::::> I I fJl-Q; Robert Kistler .," - ,- I',;~.I, ,.- d,.., "~, JI'.' . , "', ",,-" , I verifY that the statements made in the foregoing Stipulation are true and correct. I understand that false statements herein are made subject to the penalties of18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: tI/z.s/oo I I ~~w~ I verifY that the statements made in the foregoing Stipulation are true and correct I understand that false statements herein are made subject to the penalties of18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: q ll~ /C6eJ I~ 1'i~4L Koren Hammons I verify that the statements made in the foregoing Stipulation are true and correct. I understand that false statements herein are made subject to the penalties of18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: q / ;)G It, 0 , f ~o/ Russell Clavey ~lln abr '~j_';"";'..--~~"MI~lti I - ","9,,,,,,,,,,;,,,,,",,,",""'''''JI.,",,,_r' ,'.'W,"'M. "1' ~,~ ~ , . > ,_. ~ ,~ .<, iw.Ili:!i!l;J,:i-nllillilYf:,mli" , ",.......i' .",J :j.. ~ : r::: ,- ~;~ ~,:- ):.-. " ~ .' C) Cl~1 :..) ()) -, . ," I . ,I." Q ~ ROBERT KISTLER and LINDA KISTLER Plaintiffs, vs. KOREN HAMMONS and RUSSELL CLA VEY, Defendants ,~ '.- .]., ~' c.', ., ~ OCT 2 6 zooarO : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V ANlA : No.J/CU-152/J Ciud : Custody Order of Court AND NOW, this J~ day of () ~ Petition, the filing fees are hereby waived. , 2000 after review of the attached J t~1Y/aJl IQ-3{) -(JD RXS ,k', , __~ - "~ , '" -,~ -il\l:w:~t:-" i., , '.-,' '.!Jl Jii;m"""~-- ""~ti,~lr;ltfi!d~~~ V1N\1A1A8NN3d AlNnoo O!lIlfll:Ei8V'lnO 'lZ :9 WV 081::1000 AW10NOr-LOdd "Hi ~O 3C)Jj;jO-o:rll~ . ,>" '--" ~ ,,- ,~ -- "iIMfJlidI1i' "~-'iJI""""" I" -""*' ~ ,. . "'I i I , ; I I I " - ~L, ""l -, ," , ; ,:'.tL " ,__ ~ :; ; ,:,1 ~, ' _m"","~ ~'i"..'~~ '''~'~) . ROBERT KISTLER and LINDA KISTLER : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs, vs. u.o - 7080 ~ )~ : NO. KOREN HAMMONS and RUSSELL CLA VEY, Defendants : Custody PETmON TO PROCEED IN FORMA PAUPERIS 1. We are the Plaintiffs in the above matter and because of our financial condition we are , unable to pay the fees and costs of prosecuting or defending the action or proceeding. We are representing our selves on this matter and have not paid any attorney's fees. 2. We are unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3 . We represent that the information below relating to my ability to pay the fees and costs is true and correct: (a) Name: Robert Kistler alid Linda Kistler Address: 22 Park Street Mt Holly Springs, P A (b) Emolovment (1) If you are presently employed, state (for Robert Kistll!f) Employer: Fraternal Order of Eagles Address: High Street, Carli~le, P A Salary or wages1?efmonth: $1505.00 Type of work: Biirleritll\r .,-,,~J" 1:- 'J ''''"",, , c ,~, ,'1,- v (2) If you are presently unemployed, state: Date oflast employment: N/ A Salary or wages per month: Type of work: ( c) Other income within the past twelve months Business or profession: Other self-employment: $400.00 per month Interest: Dividends: Pension and annuities: Social Security benefits: Support payments: Disability payments: Unemployment compensation and supplemental benefits: Worker's Compensation: Public Assistance: Other: (d) Other contributions to household support (Wife) (Husband) Name: If your (wife) (husband) is employed, state Employer: Salary or wages per month: Type of work: , '..'J " ,- ~;';;'"'''''''--' , "'~"~ -,I. ~ '- -' ~ -, - ',",;.,~,; - ",:,.., i: - -~ - . ",,__. ,~ '", .. " Contributions from children: Contributions from parents: Other contributions: (e) Prooertv owned Cash: $16.00 Checking account: $60.00 Savings account: Real estate (including home): 1982 Mobile Home - value $7,000.00 Motor vehicle: Make Dodge Van Year 1991 Make Ford Tauris Year 1992 Stocks or bonds: (f) Debts and obligations Mortgage: Lot Rent: $250/month Loans: Other: Electric $56; Phone $75; Gas $50/bimonthly; Oil $500 yearly; Groceries $600; Doctor Bills $400 owed; $150/ month for other doctor visits; Dentist for children $100/ month (g) Persons deoendent uoon vou for suooort Wife's Name: Linda Kistler Children, if any: Name: Jade Sease Sebra Sease Russell Clavey Age: 10 years 7 years 4 Y2 years Other persons: N/ A t* ,,'" " '"- ~ l_ , , , , , (" h , , ,,:, "';' ".'- 4. I understand that I have a continuing obligation to inform the court of improvement of my financial circumstances which would pennit me to pay the costs incurred herein. 5. I verifY that the statements made in the affidavit are true and correct I understand that false statements are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: Date: 9';;2&' - 00 flu t:~ Robert Kistler ~ Linda Kistler Gj-c)tf- DO .- '$i,;,i I I I I 1 I i 1 I Ii_: "", ~~I-#l~"'i!i'I~lllel~2ii;jiUj\rj~"Ill~Mm;hWi\:ir~~~~~,~~,~~~~UIliI~.-~'-'''''''iIiIi''''~~= ,,' '. "'..... ",~...-k';',,~';- ~"._'- u" , ~(, -"., ~ S2"~' '"2 'i:::- !if? (') .~= ::'! , ~. .. C~, C:.~ ::'::) -'") --~j 0,) c/ ' CJ ~ co ::u -< rn