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Home My WebLink About00-08251 .L. .1 <', , , [",I ......:r_ , FEB 0 6 20(J~ MICHAEL ANTHONY STUART, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 00-8251 CHERI SARCIONE, AKA. CHERI MCGOLDRICKS, AKA. CHERI STUART, CIVIL ACTION - LAW CUSTODY Defendant ORDER OF COURT AND NOW, this '1~ day of February, 2001, it appearing that a misspelling of the name of the Defendant has appeared in the caption, the caption is amended to set forth the Defendant's name as Sherry McGoldrick. BY THE COURT, Dist: Joan Carey, Esquire Robert J..Mulderig, Esquire v In' , MICHAEL ANTHONY STUART, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-8251 SHERRY MCGOLDRICK CIVIL ACTION - LAW CUSTODY Defendant TEMPORARY ORDER OF COURT AND NOW, this -----2.L day of February, 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. This Order shall supercede all prior Custody Orders in this matter. 2. Physical and Legal Custody. The Mother, Sherry McGoldrick, shall have primary physical and legal custody of the minor Child, Seosaimhin Aine McGoldrick, born January 20, 1995. 3. Father, Michael Anthony Stuart, shall undergo a dual diagnostic evaluation to address concerns about anger management and to rule out the need for chemical dependency treatment. The evaluator shall make recommendations with regard to what if any treatments shall be necessary for the Father. The evaluator shall be chosen by agreement of the counsel. 4. The parties shall participate in co-parenting counseling to establish parental communication and assist them in the reestablishment of a relationship between Father and the minor Child. Father's initial contact with the minor Child shall be in the context of this therapeutic environment. Further initial visits between Father and the minor Child shall be supervised. It is anticipated that the duration of the visits will be gradually increased and the frequency, duration and discontinuance of supervised visitation shall be guided by the counselor. The initial supervised visits shall be one hour in duration, with supervision being provided by the program offered through the Carlisle YWCA, unless recommended otherwise by the counselor. 5. In the event that there are difficulties and either party is in need of an additional Custody Conciliation Conference within sixty days of the date of this Order, counsel for either party may contact the Custody Conciliator to schedule an additional Conference. , j No. 00-8251 BY THE COURT, ~ <'\ t<< D~O ~ I I I I , I i I ! I I I I I I, I I ~ " :! , " Ii Ii I' Ii ~ " " Dis!: Joan Carey, Esquire, MidPenn Legal Services, 8 Irvine Row, Carlisle, PA 17013 Robert J. Mulderig, Esquire, 28 S. Pitt Street, Carlisle, PA 17013 , _!DIIIM,~., 1)1':IIllIPllllll~""","""",,,,,,,,,,,,',,,,,,,,, ~-,~ """"'''''',.,., ~..~ -".. ^. ", . '"~ "~- .):, ,'" i...../ C I Pi'! I / i'A" ,: ,,"., V,...j,-'j.," '" ~} I :);:-j;L.-'~i /', l' /'clV\ 'Vi' (, I rs'yj 'ltfi '(,oU;V~1/ l...Vi'1IY!4 I, ~-"' ~, ~_. "-~" _=~~ 0 ",",~ __H. '''~' _'"'tllIl~"~"';I<Ip'~,F''''!,!!'~~''j'lli!~i<W~'m~'lAr';n!tl'IJl',~~mFt~~~~ll!~.~~ , ' I. MICHAEL ANTHONY STUART, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-8251 CHERI SARCIONE, A.K.A. CHERI MCGOLDRICKS, A.K.A. CHERI STUART, CIVIL ACTION - LAW CUSTODY Defendant CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Seosaimhin Aine McGoldrick January 20, 1995 Mother 2. A Custody Conciliation Conference was held on January 31, 2001, with the following individuals in attendance: the Father, Michael Anthony Stuart, and his counsel, Robert J. Mulderig, Esquire; the Mother, Sherry McGoldrick, and her counsel, Joan Carey, Esquire. 3. Mother's position on custody is that contact with the minor Child and Father should be supervised. Mother reports that Father has had no contact with the Child since infancy. She states that the reason for the breakup was domestic violence, which she states occurred during the pregnancy and after the birth of the Child. Mother has expressed concern about Father's attempts to contact the Child which have occurred within the last six months. Mother is also concerned that Father has problems with drugs and/or alcohol. 4. Father's position on custody is that he should be allowed to have gradually increasing contact with the Child, beginning with supervised visits, increasing to unsupervised visits, weekend days and eventually full custodial weekends with overnights. Father denies any history of violence against the Child. He states that when he has taken Christmas gifts to Mother's residence for the Child that they were thrown on the lawn. ;' I No. 00-8251 Date 5. The parties reached an agreement for a Temporary Order in the form as attached. ci6 6; ?-P" / ".;-,.-1, ~ " -' '.-, '~-: " .-," "-",--.- '--"'- :-':';;.-,,;1.,; .~~ , MICHAEL ANTHONY STUART, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00- 8~ol CIVIL TERM CHERI SARCIONE, a.k.a. CHERI MCGOLDRICKS, a.k.a. CHERI STUART, Defendant : CIVIL ACTION - CUSTODY ORDER AND NOW, this ??_..clday of I Jr.V€ _ 4r ,2000, based on the attached Petition, it is hereby ordered that neither Plaintiff nor Defendant may remove the child, Seosaimhin Aine McGoldricks, from the State of Pennsylvania without prior permission of this Court, pending a Custody Conciliation. BY THE COURT, J. COpl'e~ {f)a)ed II -;2fJ -00 II """, '''~e-.~^, <, GO foln\.,1 / / " , '" L! " : , :/ " Cv' ':!il'"''~'_''' ' ,'.. , . ."" ",,".' "jry <j,'::;: ,';;' r:', : U \_.i'--~': 1\ i t r:l\I'!~dl'h\\Jli~ \1"",'1 ",~ ._ ...J, ,t,__ ~""""""",~J~'J!i!;'Ilm "~ -- ~ .,_.- '~""-~ _,~,;mIl,~_IOJlftlWJ!lJl!l\;liI'i~A~JIl!~OII!lI~~fl'j~''''tJ~''k-lj''"PI'F'!_'''''i~~!il~iI'M~fIlfJ!:~'r<<I;i~M'i~ ,_~, V~_.l!'fj~ ..- . ...-. ,-,I 1'-, 'I~E . , MICHAEL ANTHONY STUART, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00- CIVIL TERM CHERI SARCIONE, a.k.a. CHERI MCGOLDRICKS, a.k.a. CHERI STUART, Defendant : CIVIL ACTION - CUSTODY PETITION FOR SPECIAL RELIEF AND NOW comes the Plaintiff, Michael Anthony Stuart, by and through his attorney, Robert J. Mulderig, Esquire, and file the following Petition for Special Relief: 1. Plaintiff is Michael Anthony Stuart, an adult individual whose residence is at 1917 Spring Road, Carlisle, Cumberland County, Pennsylvania 2. Defendant is Cheri Sarcione, a.k.a. Cheri McGoldricks, a.k.a. Cheri Stuart, an adult individual whose residence is at 134 Amy Drive, Pine Ridge Trailer Court, Carlisle, Cumberland County, Pennsylvania. 3. On this date Plaintiff has filed a Complaint seeking custody of his child, Seosaimhin Aine McGoldricks, to the above docket number. 4. Plaintiff believes and therefore avers that based on statements made by the Defendant to him, she is likely to remove the child from the jurisdiction of this Court once she is served with the Custody Complaint. WHEREFORE Petitioner respectfully requests this Court to issue an Order that pending a Custody Conciliation that neither party may remove the child from the State of Pennsylvania without prior permission of the Court. Respectfully Submitted TURO LAW OFFICES 1(f~PO Dat ulderig, Esqu 28 So Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff II if , -~,., I~ ,.",1.: 'I~:: . . VERIFICATION \ -\ I verify that the statements made in the foregoing Petition for Special Relief are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.e.S. !l4904 relating to unsworn falsification to authorities. '2..l - 0D\)€V\I\.~r - 2-cfX) Date Mi~ \""-'", " " if! iiJ ,ii ! ~'~iiM~_Ili:~~~,~~~ii~,,--1ili;t;l;i;;\iWjlilljn~iW[;fI~t-a' f"',.-i,",' d-,..'" .- ,,~"-.~.~. '-'lilili'tUI:JiltLi ,- . '--,-" r ~-, -.~.' i2!;'~ --,...-' ~>~ ~~' f;E; ::.::/ -< () (~ Fe:, "";,- ( .~:) i',) {".' ~:-, :"? ,'0 (:;0 -:(-") ~---- r-(, ,,'-,; ,.x..., -"'.,' ,.- I 1:" /. 1/ / )1.1 -"II "-;- "10' . "- ~"<'" I. ,"~~-"",,"~,,,-,,-, - . SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-08251 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STUART MICHAEL ANTHONY VS SARCIONE CHERI ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, RESPONDANT SARCIONE CHERI A/K/A CHERI MCGOLDRICKS A/K/A CHERI STUART but was unable to locate Her in his bailiwick. He therefore returns the ORDER OF COURT/CUSTODY , NOT FOUND , as to the within named RESPONDANT , SARCIONE CHERI A/K/A CHERI MCGOLDRICKS A/K/A CHERI STUART, DAVE MORT IS THE RESIDENT AT ABOVE ADDRESS. HE DOES NOT KNOW THE DEFENDANT. Sheriff's Costs: Docketing Service Not Found Return Surcharge 18.00 3.10 5.00 10.00 .00 36.10 ~~ . Thomas Kline Sheriff of Cumberland County ROBERT MULDERIG 11/28/2000 Sworn and subscribed to before me this /AJ- day of ~ ~.D. . /2 ~'l;.- p. 0 honotary I ~ ~~-_...'~ ,~-~,-- ~=,.~I ~, , j ......M, "',w,","'~i'r~"h' MICHAEL ANTHONY STUART, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ~ NO. 00- f ~ ~I CIVIL TERM : CIVIL ACTION - CUSTODY CHERI SARCIONE, a.k.a. CHERI MCGOLDRICKS, a.k.a. CHERI STUART, Defendant ORDER AND NOW, this Q(}{lcX. day of !uo.J2- ht- , 2000, based on th, attached Petition, it is hereby ordered that neither Plaintiff nor Defendant may remove le child, Seosaimhin Aine McGoldricks, from the State of Pennsylvania without prior permission of this Court, pending a Custody Conciliation. BY THE COURT, !-sj j tlt~ &Ai; J h~ J. }.' . . "'RUE COPVfROM'R6COAO I' ^ " "', " , -. ,:,,"" .' ".~, ,> .tnT~~lfIIti1...,I1IY_ ~",,""" . it.~~. at. 'CddI."'. ~".'~ ....... .~ . . ~ff!:t= , \ . . " . -... , ~" ~ . ~ I .. , ' ~""L"h"'_~'_1 d j.~ <" MICHAEL ANTHONY STUART, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PEI'-\JSYLVANIA () C) Ci CIVIL TEF<~ ~" veL] C) tllf"1 '-",_ : CIVIL ACTION - CUSTODY 7 f r,~ OJ." f'.':J -<' ,- j ~j r:: c, -T, <, Z ~:_~,~ 5" C:: :~) L.:, i".) '""; -< C) ::''-2 v. : NO. 00- CHERI SARCIONE, a.k.ao CHERI MCGOLDRICKS, a.k.a. CHERI STUART, Defendant .--, :!:J :_---~~ f;~ PETITION FOR SPECIAL RELIEF AND NOW comes the Plaintiff, MichaE I Anthony Stuart, by and throug his attorney, Robert J. Mulderig, Esquire, and file the following Petition for Special Relief: 1. Plaintiff is Michael Anthony Stuart, an adult individual whose rE ;idence is at 1917 Spring Road, Carlisle, Cumberland County, P 3nnsylvania 2. Defendant is Cheri Sarcione, ak.ao Cheri McGoldricl<s. a.koa. ( heri Stuart, an adult individual whose residence is at 134 Amy Drive, Pine Ridge Trailer COUl , Carlisle, Cumberland County, Pennsylvania. 30 On this date Plaintiff has filed ci Complaint seeking custody of I IS child, Seosaimhin Aine McGoldricks, to the above d Jeket number. 4. Plaintiff believes and therefore avers that based on statements made by the Defendant to him, she is likely to remove the child from the jurisdiction of this :ourt once she is served with the Custody Complaint. WHEREFORE Petitioner respectfully requests this Court to issue an ( 'der that pending a Custody Conciliation that neither party may remove the child from the State )f Pennsylvania without prior permission of the Court. Respectfully Submitted TURO LAW OFFICES II " /rt';~ Oat -- Robe ulderig, Esqu 28 So Pitt Street Carlisle, PA 17013 ("'17) 245-9688 jI,ttomey for Plaintiff " ~<"~'~ ~. I_U I.. %ll_<l',i, I, .. ~.,. VERIFICA liON I verify that the statements made in the foregoing Petition for Special Relief are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.e.S. ~904 relating to unsworn falsification to authorities. 2l- }J~~Y' '2.cf:D Date I 'I i J_~ . , - "., ,,- ~ .. MICHAEL ANTIIONY STUART PLAINTIFF V. CHERI SARCIONE A.KA CHERI MCGOLDRICKS AKA. CHERI STUART DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-8251 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 4th day of December, 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on the 4th day of January, 2001 , at 11:00 a.m. for a Pre-Hearing Custody Conference. At such conference, 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: /s/ Melissa P. Greev Es Custody Conciliato The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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 made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE TIllS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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, Pennsylvania 17013 Telephone (717) 249-3166 . ~""" .- > ~" -, ~ - 1=\1 EtrOfF\CE. . ,_ 0 ~.., '''''''O"fAOV Or:. .:"L.\\_~ !:",':J;~ 'l\r:~)~\-~ !!hi'} r ~ j 1\ - ' ' ".~ 00 GEe -5 Mi \0\ 4 \ CUMB8~IJ.NO COUNi't' P8'lNS'lLV/iJ'l~r.. fOiK-CO W. ~ ~ z., 4' ~(~ Ja(,--oo 1;1~ Ina~ Z 11j /0/ -!J--6J{/ ~ maJJ/ i; ~ ~ , \, ........ - .."""". '''''~'~_ _ '-"'i"~l!I/!!Il'i.f$lr~~K ~1lJ!R!f;WjiJ)f'~}'~"';{;~)%1~"i~'!"-~"'''''h'-N"' '~""'b""" r,l")"~,;Tj'!WW."""';]'''''''' i!!jf~'fRI~,'f" 'Ej]~W"J"Hl",,-,,Il"'~~'*-"'~'~Wl_' ., ,.,:1. j.,l'~ ,._,.- -,1-'/ , -,,-,.-- I_r ~, ," MICHAEL ANTHONY STUART, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00- fJ n CIVIL TERM CHERI SARCIONE, a.k.a. CHERI MCGOLDRICKS , a.k.a. CHERI STUART, Defendant : CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, this day of , 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , Esq., the Conciliator, at on the day of 2000, at .M., for a Pre-Hearing Custody Conference. At such conference, 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 i order. Failure to appear at the Conference may provide grounds for entry of a . temporary or permanent order. FOR THE COURT, By: 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 made 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 Ii " ,-, I ,~-: ,_ '. ,,_ 0 ':.\" 'J ~;~ MICHAEL ANTHONY STUART, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00- S'J:)'/ CIVIL TERM : CIVIL ACTION - CUSTODY CHERI SARCIONE, a.k.a. CHERI MCGOLDRICKS, a.k.a. CHERI STUART, Defendant COMPLAINT FOR CUSTODY 1. Plaintiff is Michael Anthony Stuart, an adult individual whose residence is at 1917 Spring Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Cheri Sarcione, a.k.a. Cheri McGoldricks, a.k.a. Cheri Stuart, ': I! an adult individual whose residence is at 134 Amy Drive, Pine Ridge Trailer Court, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of his child Seosaimhin Aine McGoldricks, born January 20, 1995, currently residing at 134 Amy Drive, Pine Ridge Trailer Court, Carlisle, Cumberland County, Pennsylvania. 4. The child is presently in the custody of Defendant. 5. Since the child's birth, the child has resided at the following addresses: Name Address Dates Mother 134 Amy Drive, Pine Ridge Trailer Court Carlisle, Pennsylvania 6. The relationship of the Plaintiff to the children is that of natural father. 7. The relationship of the Defendant to the children is that of natural mother. 8. The Plaintiff has not participated as a party or in any other capacity, in other litigation concerning the custody of the child in this or any other Court. 9. Plaintiff has no information of a custody proceeding concerning the child. pending in a Court of this Commonwealth. Ii ~ '- " ,.I "'^ ,..-J' . .~21 . 10. The best interest and permanent welfare of the child will be served by granting the relief requested because the Defendant has been neglectful to the care, custody and control of such child. 11. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. Not other persons are known to have or claim to have any right to custody or visitation of the child other than the parties to this action. WHEREFORE, Plaintiff requests your Honorable Court to refer this case to the Custody Conciliator for a custody conference. Respectfully Submitted TURO LAW OFFICES J;h;ib t , Date - ~~ ~. . Iderig, Esqui 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff II "I ~, - . VERIFICATION I verify that the statements made in the foregoing Custody Complaint are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pac C.S. 94904 relating to unsworn falsification to authorities. z..c~ )OlJ-eiM.~ Y' - 2..CDO Date ---'" Miclil' Ii V Ii . " n w ", ,. ~<- ~=, ~ ~. I$;;- '* ~ ") .~ "< ~ j'~ ~ J \:::> ~ '" e, <j , ' ~ ';1 :,.. ") '-'i 10 ~ '-'1 ~ cf ~ >- i-~,:: \.!) j.::"': lLl~-' M ~:J . "~- .-' c::;; .,.,~ ~'''''''''T' >- (i~_: ._''>" :~~ F!j~; ;:':',j C~d C'"J 'g!~~ :?: -.~) V , . f;l ~:"" ""- ~~ ~ ~-~, ,...., .Nl:",-",~~Wi.mk-, ._~:~_D_~: ij~I'\elk"'l'W'7'\""'~!!"'lIi~~~~~.ll$l!llW~;~'!itlJ.:t~!II'".~..r~,__ _~_;_~ "^ ". > ~ -. ,.....,,,,1 .ill!lilli>;":. SHERIFF'S RETURN - REGULAR CASE NO: 2000-08251 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STUART MICHAEL ANTHONY VS SARCIONE CHERI ET AL SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within ORDER OF COURT was served upon SARCIONE CHERI A/K/A CHERI MCGOLDRICKS A/K/A CHERI STUART the RESPONDANT at 0014:45 HOURS, on the 26th day of December 2000 at 136 AMY DRIVE PINE RIDGE TRAILER COURT CARLISLE, PA 17013 by handing to SIOBHAN SARCIONE (DAUGHTER) a true and attested copy of ORDER OF COURT together with COMPLAINT FOR CUSTODY, PETITION FOR SPECIAL RELIEF and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.10 .00 10.00 .00 31. 10 So Answers: r~~~ R. Thomas Kline 12/27/2000 TURO LAW OFFICES Sworn and Subscribed to before By: me this .5 AA- day of ~ ,;J-vv / A.D. o /l - --- YI--,----U-. ~~ 1rothonotary MICHAEL ANTHONY STUART, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00-8251 YS. : CIVIL ACTION - LAW SHERRY MCGOLDRICK, Defendant : CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Sherry McGoldrick, Defendant, 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, P A 17013 11 lli-tJ-"~' J' :"_;W:_~~iiY_~~iH!iI~'!1l!~~;if.jI~~I1~mhl~f.'~"'~'I~~'ii,(-",,~~1J;,a'ilW;.'ltjH_ii~ ", "j.~iMrtlt...;- ". , ,~ ". '" ,'('"~,-, -~ . ---"- '""IIi''" '-<jill{'. -11iIIi'':;-~ ,- .." 0 0 c: C:l .,,5: ;:;e; on ("p :.:~:i [pr.r, 0 ",,-:r~ J~-C: __, C> , ~ 2C' '<,._,- C9.;..:,~ .h" ,,:,r'1 ~c " ,:;j;:(~~ ~8 -;c,' ~~:~ - >c: 0.:' cyn 2:: '" :< l:"" r-.;, s:, -< ,_ -~"c~~p "": consent of Plaintiff and Defend. ant: I /J II D / ~. ~~ '---~~ G 'ck, D d t . 'I /7) . ),~1V ~~.~// . )ban Carey, Attorney for pJ tiff, 'MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 > - MICHAEL ANTHONY STUART, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00-8251 vs. CNIL ACTION - LAW SHERRY MCGOLDRICK, Defendant CUSTODY o 0 c CUSTODY ORDER -o~ S !;2 rn ~'C: ~ z~ - AND NOW, this l L_( day of November, 2001, upon consideratiO~the: agreement of the parties, the following order is entered: i8 ~ ..". 1. This Order shall supersede all prior Custody Orders in this matter. ~ v::> 2. The defendant/mother, Sherry McGoldrick shall have sole physical and legal custody of the minor child, Seosaimhin Aine McGoldrick, born January 20, 1995. 3. The mother shall have the right to make all decisions regarding the child including but not limited to religious, medical, educational, and/or relocation decisions. BY THE COURT, \, , Plaintiff, Pro se 141 easant Drive South Carlsi e, PA 17013 1/1'-1 - CbrF~ r~R-S60'2{(r Q/~ ..JcJ )'Z(j~( [~Dtcq A:.cN1C$ rn;;:J(L~c( -I-d My ,0daf/2..(7 ~I 1 ;;J: c) .." :.:.::1 ;l~ (j:~ (~-~m ;:;; ~ .j~h'-(,' ff..t'"'"'~~ Ii.iiif1M.Iii~~;:~~RtMhM~~IH~\~1",r.lft,$:J!ti4'iiljW<t'<::".;.;...ilfiBliW_\iiil~~:w~':"""-~,.;~" ~. ~.h.",... ""m_ co. ,0 ,~~O', ,,"''''',- .p. _,_~ "",,OJ, <" ,. ~~ ri' ~Hi ;,~, ";""--""o'';;;~-jltitji''- '11 :] II .1 I "--" 0 c::> C> c::: .'-n '5: ;;e ....j -00-7 0 ";~~ mrn ,~ Z::r) Z' .1"" <:n ~~ C-~1/) .:..::: ..:-~ ".~J "::r, \20 -0 .--n :t: (J~;;;; >0 .,..(, 20 l.f! OITl ~c::: ~ ~ c- 55 - "<