HomeMy WebLinkAbout01-1327 FX
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IN THE COURT OF COMMON PLEAS
QFCUMBERLANDCOUNTY
STATE OF
.
ERIKA R. WILLIS,
PENNA.
Plaintiff
No. 01-1327 CIVIL TERM
VERSLJS
SHANNON M. WILLIS,
Defendant
AND NOW,
DECREE IN
DIVORCE
~d-3
DEC;::REEP THAT ERIKA R. WILLIS
AND SHANNON M. WILLIS
..or If: ~'A'" .
,2003 ,IT IS ORDERED AND
PLAINTIFF,
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAI$EP OF REC;:ORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YJ;::T BEEN ENT~RED;
No issues have been raised in this case, and no issues are outstanding.
.
ATTEST:
PROTHONOTARY
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SOCIAL SECURITY INFORMATION SHEET
PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1, ALL DIVORCES MUST INCLUDE THE
PARTIES' SOCIAL SECURITY NUMBERS. PLEASE FILL IN THE APPROPRIATE
INFORMATION AND RETURN TO THE PROTHONOTARY'S OFFICE.
COUNTY Cumberland County
DOCKET NUMBER 01-1327
PLAINTIFF'S NAME Erika R. Willis
PLAINTIFF'S SS # 097-72-1848
DEFENDANT'S NAME Shannon M. Willis
DEFENDANT'S SS# 253-35-8911
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& MAR 1 6 ?O~
Erika Willis,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE, CUSTODY
: NO, 01- 13d-7 CIVIL TERM
Shannon Willis,
Defendant
ORDER OF COURT
AND NOW, this_ day of ,2001, upon consideration of the attached
complaint, it is hereby directed that the parties and their respective counsel appear before
, the conciliator, at
on the _ day of ,200_, 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 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:
Custody Conciliator
YOU SHOULD TAKE TillS 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
AMERICANS WITH DISABILITIES ACT OF 1990
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 andreasonable
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.
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4PR a a 2001
ERIKA WILLIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
CIVIL ACTION - LAW
SHANNON WILLIS,
Defendant
NO. 01 - 1327 CIVIL
IN CUSTODY
COURT ORDER
AND NOW, this day of April, 2001, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
1. The Mother, Erika Willis, and the Father, Sharmon Willis, shall enjoy shared legal
custody of Christopher M. Willis, born April 28, 2000.
2. The Mother shall enjoy primary physical custody of the minor child.
3. The Father shall enjoy periods of temporary physical custody with the minor child at
such times and under such circumstances as the Mother may agree.
4. In the event the Father is dissatisfied with the amount of temporary custody provided
to him by the Mother or in the event Father desires to otherwise modifY this order,
the Father may petition the court to have the case again scheduled for a conference
with the Custody Conciliator.
BY THE COURT,
1.
cc: Steven Boell
Dickinson School of Law
Family Law Clinic
Sharmon Willis
335 Butler Blount Road
Fleming, GA 31309
Edward 1. Colby, Jr., Esquire
P.O. Box 618
Hynesville, GA 31310
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Erika Willis,
Plaintiff
v,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE, CUSTODY
: NO. 01-/3.2 7 CIVIL TERM
NOTICE TO DEFEND AND CLAIM RIGHTS
Shannon Willis,
Defendant
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take prompt action. You are warned that if you fail to do so, the
case may proceed without you and a decree of divorce or annulment may be entered against
you by the court. A judgment may also be entered against you for any other claim or relief
requested in these papers by the plaintiff. You may lose money or property or other rights
important to you, including custody or visitation of your children,
When the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling, A list of marriage counselors is available in
the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania,
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HA VB 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
AMERICANS WITH DISABILITIES ACT OF 1990
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.
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Erika Willis,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: DIVORCE, CUSTODY,
Shannon Willis,
Defendant
: NO, oi-f3l7 CIVIL TERM
DIVORCE COMPLAINT WITH CUSTODY COUNT
The plaintiff, Erika Willis, by her attorneys, the Family Law Clinic, sets forth the
following cause of action:
COUNT L
DIVORCE UNDER 23 Pa.C.S, SECTION 3301(c) AND 3301(d)
OF THE DIVORCE CODE
L Plaintiff is Erika Willis, who currently resides at 108 Ian Drive, Mt. Holly Springs,
PA 17065 since July 12, 2000.
2. Defendant is Shannon Willis, who currently resides at 535 Butter Blount Rd,
Fleming, GA 31309, since November 30,2000.
3. Plaintiff has been a bona fide resident of the Commonwealth for at least six months
immediately previous to the filing of this Complaint.
4. Plaintiff and defendant were married on April 3, 1999 in Liberty County, Georgia.
5. Plaintiff and defendant have lived separate and apart since July 12, 2000.
6, There have been no prior actions of divorce or for annulment between the parties.
7, The marriage is irretrievably broken.
8, Plaintiff has been advised that counseling is available and that plaintiff may have the
right to request that the court require the parties to participate in counseling.
WHEREFORE, plaintiff requests the court to enter a decree in divorce dissolving the
marnage.
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COUNT II.
CUSTODY
9, Plaintiff repeats and realleges paragraphs one through eight.
10, Plaintiff seeks custody of the following child:
Name Present Address
Christopher Willis 108 Ian Drive
Mt. Holly Springs, PA 17065
Age
10 Months
The cbild was born in wedlock.
The cbild is presently in the custody of Erika Willis, who resides at 108 Ian
Drive, Mt. Holly Springs, Pennsylvania.
During the past five years, the child has resided with the following persons and at the
following addresses:
Persons
Addresses
Dates
Erika Willis
Shannon Willis
595 Cook Rd,
Fleming, GA 31309
April 29, 2000-July 11,2000
Erika Willis
Judy Yaw
Wayne Yaw
Amber Yaw
108 Ian Drive
Mt. Holly Springs, P A 17065
July 12, 2000-Present
The mother of the child is Erika Willis, currently residing at 108 Ian Drive, Mt. Holly
Springs, Pennsylvania,
She is married.
The father of the child is Shannon Willis, currently residing at 535 Butter Blount Rd,
Fleming, Georgia.
He is married,
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11. The relationship of the plaintiff to the child is that of mother, The plaintiff currently
resides with the following persons:
Name
Judy Yaw
Wayne Yaw
Amber Yaw
Christopher Willis
Relationship
Mother
Father
Sister
Son
12. The relationship of defendant to the child is that of father. The defendant
currently resides with the following persons:
Name
Ottis M, Willis
Anne Lou Willis
Relationship
Father
Mother
13, The plaintiff has not participated as a party or witness, or in another capacity,
in other litigation concerning the custody of the child in this or another court.
Plaintiff has no information of a custody proceeding concerning the child pending in a court
of this Commonwealth or any other state,
Plaintiff does not know of a person not a party to the proceedings who has physical
custody of the child or claims to have custody or visitation rights with respect to the child.
14. The best interest and permanent welfare of the child will be served by granting the
relief requested because:
a) Plaintiff has been primary caretaker of the child since birth;
b) Plaintiff provides the child with a home with adequate moral, emotional and
physical surroundings as required to meet the child's needs;
c) Plaintiff is willing to accept custody of the child;
d) Plaintiff continues to exercise parental duties and enjoys the love and affection of
the child,
15. 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.
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WHEREFORE, plaintiff requests the court to grant her shared legal and primary
physical custody of the child.
Date
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Steven Boell /
Student Attorney
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(',. ASMoPLL
ROBERT E. RAINS
TERI L. HENNING
Supervising Attorneys
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/240-5204
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VERIFICATION
I verify that the statements made in the foregoing Divorce Complaint with Custody
Count are true and correct, to the best of my knowledge, information and belief. I understand
making any false statement would subject me to the penalties of 18 Pa.C.S. 94904, relating to
unsworn falsification to authorities.
Date: ~Jr d'f;()QJj\
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MAR 1 6 2001
0;J
Erika Willis,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
CIVIL ACTION-LAW
Shannon Willis,
Defendant
NO. 01-
J1l.- 7
CIVIL TERM
PRAECIPE TO PROCEED IN
FORMA PAUPERIS
To the Prothonotary:
Kindly allow Erika Willis, Plaintiff, to proceed in forma pauperis.
I, Steven Boell, Certified Legal Intern in the Family Law Clinic, 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 oflitigation is
attached hereto.
~~
3l@r/-01
Steven Boell
Certified Legal Intern
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RO R . RAINS
THOMAS M. PLACE
TERI L. HENNING
Supervising Attorneys
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
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Erika Willis,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
y.
: CIVIL ACTION - LAW
Shannon Willis,
Defendant
: NO, 01-/327CIVIL TERM
AFFIDAVIT SUPPORTING PRAECIPE FOR LEAVE
TO PROCEED IN FORMA PAUPERIS
1, I am the Plaintiff in the above matter and because of my fmancial condition am
unable to pay the fees and costs of prosecuting or defending the action or proceeding.
2. I am unable to obtain funds from anyone, including my family and associates, to pay
the costs of litigation.
3, I represent that the information below relating to my ability to pay the fees and costs
is true and correct.
(a) Name: Erika Willis
Address: 108 Ian Dr" Mt. Holly Springs, PA 17065
Social Security No.: 097-72-1848
(b) Employment
If you are presently employed, state
Employer: Kmart
Address: Walnut Bottom Rd., Carlisle
Salary or wages per month: $300-400 (net)
Type of work: Sales Clerk
If you are presently unemployed, state
Date of last employment:
Salary or wages per month:
Type of work:
(c) Other income within the past twelve months: Parkers
Business or profession: Gas Station/Cashier - 5,351hr,
Other self-employment:
Interest:
Dividends:
Pension and annuities:
Social security benefits:
Support payments:
Disability payments:
Unemployment compensation and supplemental benefits:
Workman's compensation.:
Public Assistance: WIC/Access Card
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:
Contributions from children:
Contributions from parents: Lives with parents
Other contributions:
Property owned
Cash:
Checking account: Yes; $54,00
Savings account: Yes; $90,00
Certificates of deposit:
Real estate (including home):
Motor vehicle: Ford Taurus
Cost, Amount Owed $
Stocks; bonds: Infant son has four savings bonds
Other:
Debts and obligations
Mortgage:
Rent:
Loans:
Other:
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Food:
Diapers:
Baby Wipes:
Medical Expenses:
$160.00 per month
$50.00 per month
$15,00 per month
$2208,64 (owed to father)
$145.00 (outstanding)
Persons dependent upon you for support
(Wife)(Husband) Name
Children, if any:
Name:
Christopher Willis
Age:
10 Months
Other persons:
Name:
Relationship:
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4, I understand that I have a continuing obligation to inform the court of improvement
in my fmancial circumstances which would permit me to pay the costs incurred herein,
5, I verify that the statements made in this affidavit are true and correct. I understand
that false statements herein are made subjectto the penalties of 18 Pa.C.S, 4904, relating to unsworn
falsification to authorities.
Date~
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Petitioner
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ERIKA WILLIS
PLAINTIFF
V.
SHANNON WILLIS
DEFENDANT
IN TIIE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-1327 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW,
Monday, March 19, 2001
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthonse, Carlisle on Friday, April 20, 2001 at 8:30 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: Isl
Hubert X. Gilroy. Esq. /J7
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with DisabilitesAct of'J990, ,Eorinform!!tiotl ab?],Itacqessible facilities and reasonable
accommodations available to disabled individmils having business before the court, please contact our office.
All arrangements must be made at least 72,,4QmS prior to any hearing or business before the court, You must
attend the scheduled'conference 'oi hearing.
YOU SHOULD TAKETHI8PAPER TO YbUItATTORNBY AT ONCE. IF YOU DO NOT
HA VB AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE 'OFFICE SET
FORTII BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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ERlKA WILLIS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
SHANNON WILLIS,
Defendant
: NO. 01-1327 CIVIL TERM
PROOF OF SERVICE
I, hereby certify that I served a true and correct copy of the Divorce Complaint with
Custody Count on Shannon Willis, residing at 535 Butter Blount Road, Fleming, GA 31309, by
U.S, mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was
complete upon receipt by Shannon Willis on the 14th day of March, 2001, as evidenced by his
signature on the attached green card.
Date: March 22, 2001
-~~
Steven Boell
Certified Legal Intern
F AMIL Y LAW CLINIC
45 N, Pitt St.
Carlisle, P A 17013
717-243-2968
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,
. Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mailpJece,
or on the front if space permits.
1. ArtIcle Addressed to:
nA"R 0 Sl-\ANoNON WlLUS
:;~ 'Bu:rTER BlOUI\lT'\<.'D.
'FLEVV\.t l\1G GsA ..3 \ 309
:/PT c ~L&er-Bb\l.L-\~
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D. Is delivery address different from Item 17
If YES, enter delivery address below:
i
3. Service Type
~ertified Mail
D Registered
o Insured Man
D Express Mall
'"P3'aeturn Receipt for MerChandise _
DC.O.D,
4. Restricted Delivery? (Extra Fee)
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2. Article Number (Copy from service /aOOO
'1oqq 3t.JoO a::) l 'a L/ q9b q '15l:-,
PS Form _3811 , Jufy 199'9 - '~ ~ Domestic Return Receipt
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102595.00-M.17B9
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ERIKA WILLIS,
Plaintiff
v
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
SHANNON WILLIS,
Defendant
NO. 01 - 1327 CIVIL
IN CUSTODY
Prior Judge:
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the following report:
1. The pertinent information pertaining to the child who is the subject of this litigation is as
follows:
Christopher M. Willis, born April 28, 2000.
2. A Conciliation Conference was held on April 20, 2001, with the following individuals in
attendance:
The Mother, Erika Willis, with her representative, Steven Boell, of the Dickinson School of
Law Family Law Clinic; the Father did not attend the conference. However, the Father was
served with notice of the conference (a proof of service was fIled of record). Also, Mother
relates that Father acknowledged to her in discussions that he was aware of the scheduled
Custody Conciliation Conference.
3. The Mother relates that the child is in her custody and Father has not seen the child since
last October.
4. The Conciliator recommends the entry of an order in the form as attached.
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D TE
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Hubert X. Gilroy, E quire
Custody Conciliat r
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IN tH'E COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ERIKA WILLIS,
Plaintiff
SHANNON WILLIS,
Defendant
NO. 01 - 1327 CIVIL
IN CUSTODY
Prior Judge:
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the following report:
I. The pertinent information pertaining to the child who is the subject of this litigation is as
follows:
Christopher M. Willis, born April 28, 2000.
2. A Conciliation Conference was held on April 20, 2001, with the following individuals in
attendance:
The Mother, Erika Willis, with her representative, Steven Boell, of the Dickinson School of
Law Family Law Clinic; the Father did not attend the conference. However, the Father was
served with notice of the conference (a proof of service was filed of record). Also, Mother
relates that Father acknowledged to her in discussions that he was aware of the scheduled
Custody Conciliation Conference.
3. The Mother relates that the child is in her custody and Father has not seen the child since
last October.
4. The Conciliator recommends the entry of an order in the form as attached.
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Hubert X. Gilroy, E quire
Custody Conciliat r
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APR 2 a 2001 '(J/J
ERIKA WILLIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v
SHANNON WILLIS,
Defendant
NO. 01 - 1327 CIVIL
IN CUSTODY
COURT ORDER
AND NOW, this ~ day of April, 2001, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
1. The Mother, Erika Willis, and the Father, Shannon Willis, shall enjoy shared legal
custody of Christopher M. Willis, born April 28, 2000.
2. The Mother shall enjoy primary physical custody of the minor child.
3. The Father shall enjoy periods of temporary physical custody with the minor child at
such times and under such circmnstances as the Mother may agree.
4. In the event the Father is dissatisfied with the amount of temporary custody provided
to him by the Mother or in the event Father desires to otherwise modify this order,
the Father may petition the court to have the case again scheduled for a conference
with the Custody Conciliator.
1.
cc:
Steven Boell
Dickinson School of Law
Family Law Clinic
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Shannon Willis
335 Butler Blount Road
Fleming,()}\ 31309
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Edward 1. Colby, Jr., Esquire
P.O. Box 618
Hynesville, (}A 31310
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In the Court of Common Pleas
Cumberland County, Pennsylvania
Ericka Willis
PLAINTIFF
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CIVIL ACTION NO. 01-1327
Shannon Willis
DEFENDANT
NOTICE OF APPEARANCE
Please take notice that the undersigned represents Shannon Willis in this matter.
The undersigned is admitted to practice law in the State of Georgia; but not in The
Commonwealth of Pennsylvania. I seek to appear specially in this matter only,
This the ..J I ~'~ay of May, 2001.
~d~lt.)IVrJ
Edward L. Colby, Jr.
GABarNo.176551
912-369-2181
P.O. Box 618
Hinesville, GA 31310
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ERIKA WILLIS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION-LAW
: IN DIVORCE, CUSTODY
SHANNON WILLIS,
Defendant
: No, 01-1327 CIVIL TERM
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under g3301(c) of the Divorce Code was filed on March 8,
2001.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing and service of the Complaint.
3, I consent to the entry of a fmal decree of divorce after service of notice of intention to
request entry of the decree.
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. g4904, relating to
unsworn falsification to authorities.
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ERIKA WILLIS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CNIL ACTION- LAW
: IN DNORCE, CUSTODY
SHANNON WILLIS,
Defendant
: No. 01-1327 CNIL TERM
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
&3301 (c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
3, I understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is filed with the
prothonotary .
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. g4904 relating to unsworn
falsification to authorities.
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ERlKA WILLIS,
Plaintiff
; IN THE COURT OF COMMON PLEAS OF
; CUMBERLAND COUNTY, PENNSYLVANIA
v,
; CNIL ACTION- LAW
: IN DNORCE, CUSTODY
SHANNON WILLIS,
Defendant
; No, 01-1327 CNIL TERM
CERTIFICATE OF SERVICE
I, Derek R. Clepper, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving a
true and correct copy of Plaintiff's Affidavit of Consent and Waiver of Intention to Request
Entry ofaDivorce Decree on Edward L. Colby, Jr" at P.O, Box 618, Hinesville, GA 31310, by
depositing a copy of the same in the United States mail, First Class, postage prepaid, this 25th day
of June, 2001.
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erek R. Clepper
Certified Legal Intern
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
(717)-243-2968
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In the Court of Common Pleas
Cumberland County, Pennsylvania
Ericka Willis
PLAINTIFF
VS.
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CIVIL ACTION NO. 01-1327
Shannon Willis
DEFENDANT
Answer
Now comes the Defendant and files this his Answer to Plaintiff's Complaint.
Count I
Defendant admits all allegations of Count I.
Count II
Defendant admits all allegations of Count II.
Relief Sought bv Defendant
Defendant seeks visitation as set forth in the attached letter to Steven Hoell and
incorporate the same by reference into the pleading.
Submitted this
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Edward 1. Colby, 1 .
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ERIKA R. WILLIS,
Plaintiff
NO. 01-1327 CNIL TERM
v,
CNIL ACTION - LAW
SHANNON M. WILLIS,
Defendant
DNORCE
PRAECIPE TO WITHDRAW AND ENTER APPEARANCE OF LEGAL COUNSEL
TO THE PROTHONOTARY:
Please withdraw the appearance of the Family Law Clinic, attorney for Plaintiff, and enter the
appearance of Diane G, Radcliff, Esquire, as attorney for Plaintiff in the above captioned matter,
Respectfully submitted,
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Family Law Clinic
45 North Pitt Street
Carlisle, P A 17013
I.D. No. '1'1]'1 :11
LIFF, ESQUIRE
344 ad
Camp Hill, PA 17011
PHONE: (717) 737-0100
Fax: (717) 975-0697
I.D. No. 32112
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
ERIKA R. WILLIS,
Plaintiff
V.
SHANNON M. WILLIS,
Defendant
NO. 01-1327 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 330Hc) OF THE DIVORCE CODE
1. I consent to the entry of a final decree in divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees
or expenses ifI do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court and
that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this Waiver are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. S4904 relating to unsworn
falsification to authorities.
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
ERIKA R. WILLIS,
Plaintiff
V.
SHANNON M. WILLIS,
Defendant
NO. 01-1327 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree in divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees
or expenses ifI do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court and
that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary .
I verifY that the statements made in this Waiver are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. {l4904 relating to unsworn
falsification to authorities.
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ERIKA R. WILLIS,
Plaintiff
V.
SHANNON M. WILLIS,
Defendant
NO. 01-1327 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on March
8,2001.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final Decree in Divorce after service of notice of intention to
request entry ofthe decree.
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. Section 4904 relating to
unsworn falsification to authorities.
Dated:~./I /KhJ~
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ERIKA R. WILLIS,
Plaintiff
V.
SHANNON M. WILLIS,
Defendant
NO. 01-1327 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
AFFIDA VJIT OF CONSENT
1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on March
8,2001.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final Decree in Divorce after service of notice of intention to
request entry of the decree.
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. Section 4904 relating to
unsworn falsification to authorities.
Dated: f)1*~ / ~~ ~
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
ERIKA R. WILLIS,
Plaintiff
NO. 01-1327 CIVIL TERM
v.
CIVIL ACTION - LAW
SHANNON M. WILLIS,
Defendant
DIVORCE
PRAECIPE OF TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the court for
entry of a divorce decree:
1. GROUND FOR DIVORCE:
Irretrievable breakdown under Section 3301(c) of the Divorce Code.
2.
DATE
a.
b.
c.
OF FILING AND MANNER OF SERVICE
Date of filina of Complaint:
Manner of service of Complaint:
Date of Service of Complaint:
OF THE COMPLAINT:
3/8/01
Certified Mail, Restricted Delivery
3/14/01
3. DATE OF EXECUTION OF THE AFFIDAVIT OF CONSENT REQUIRED BY SECTION 3301 (C) OF
THE DIVORCE CODE:
a. Plaintiff: 12/18/03
b. Defendant: 12/18/03
OR
DATE OF EXECUTION OF THE PLAINTIFF'S AFFIDAVIT REQUIRED BY SECTION 3301(D) OF
THE DIVORCE CODE AND DATE OF SERVICE OF THE PLAINTIFF'S 3301 (D) AFFIDAVIT UPON
THE DEFENDANT:
a. Date of Execution:
b. Date of Filina:
c. Date of Service:
N/A
N/A
N/A
4. RELATED CLAIMS PENDING:
No issues have been raised in this case, and there are no issues outstanding.
5. DATE AND MANNER OF SERVICE OF THE NOTICE OF INTENTION TO FILE PRAECIPE TO
TRANSMIT RECORD, A COPY OF WHICH IS ATTACHED, IF THE DECREE IS TO BE ENTERED
UNDER SECTION 3301(D) (1) (I) OF THE DIVORCE CODE:
a. Date of Service: N/A
b. Manner of Service: N/A
DATE WAIVER OF NOTICE
PROTHONOTARY:
a. Plaintiff's Waiver:
b. Defendant's Waiver:
OR
IN SECTION
3301(C)
DIVORCE
WAS
FILED
WITH
THE
12/19/03
12/19/03
DCLIFF, ESQUIRE
8 Tr' Ie Road
Camp Hill, PA 17011
Supreme Court ID # 32112
Phone: (717) 737-0100
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ERIKA R. WILLIS,
Plaintiff
NO. 01-1327 CIVIL TERM
v.
CIVIL ACTION - LAW
SHANNON M. WILLIS,
Defendant
CUSTODY
STIPULATION FOR CUSTODY ORDER
AND NOW, this 1rfJ' day of December, 2003, Erika R. Willis and Shannon M. Willis hereby
stipulate and agree that the foregoing Custody Order shall be entered by the Court in the above captioned
matter.
IN WITNESS WHEREOF the Parents, intending to be legally bound hereby, have set their hands
and seals the day and year below written.
WITNESS:
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ERIKA R. WILLIS
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SHANNON M. WILLIS
{SEAL}
{SEAL}
Date: P~A: /~.aC)<:::)d;
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
ERIKA R. WILLIS,
Plaintiff
NO. 01-1327 CIVIL TERM
v.
CIVIL ACTION - LAW
SHANNON M. WILLIS,
Defendant
DNORCE AND CUSTODY
CUSTODY ORDER
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AND NOW, this _ day of
~ , 20 O.,}, upon consideration of the within Stipulation for
Custody Order executed by Erika R. Willis, (hereinafter referred to as "Mother") and Shannon M. Willis,
(hereinafter referred to as "Father") (Mother and Father are sometimes hereinafter referred to individually
"Parent" and collectively "Parents") pertaining to their minor children: Christopher Willis, born on April
28, 2000; and Thomas Willis, born on August 21, 2002, (hereinafter referred to as the "Children"), IT IS
HEREBY ORDERED AND DECREED as follows:
A. LEGAL CUSTODY: The Parents shall share and have joint legal custody of the Children.
Pursuant to the foregoing the following shall apply:
1. Maior Decisions to Be Made Jointly: Major decisions concerning the Children's general
well-being including, but not necessarily limited to, the Children's health, welfare, education,
religious training and upbringing, shall be made by them jointly, after discussion and
consultation with each other, with a view toward obtaining and following a harmonious
policy in Children's best interest.
2. Non-Major Decisions: Day to day decisions shall be the responsibility of the Parent then
having physical custody. With regard to any emergency decisions which must be made, the
Parent having physical custody of the Children at the time of the emergency shall be
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permitted to make any immediate decisions necessitated thereby. However, the Parent shall
inform the other of the emergency and consult with him or her as soon as possible.
3. Access to Information: Each Parent shall be entitled to access to any and all information
regarding the health, education, religion, and general well being of the Children, and
pursuant thereto each Parent shall be entitled to communicate with and receive information
and documents from any persons or entities having such information and/or documents
regarding the health, education, religion, and general well being of the Children so that
informed decisions can be made.
4. Telephone Contact: Both Parents shall be afforded reasonable telephone contact with the
Children while in the other Parent's custody and for said purposes each Parent shall provide
the other Parent with his or her phone number where the Children can be reached when in
that Parent's custody. Each Parent, step-Parent, or live-in mate shall not unreasonably
interfere with the Children's right to privacy during such telephone conversations, nor shall
listen to that conversation an extension telephone. Each Parent shall see that the Children
calls the other Parent upon receipt of any phone message requesting such a return call.
5. Alcohol and Drugs: During any period of custody or visitation, neither Parent shall possess
or use any controlled substance, or consume alcoholic beverages to intoxication nor permit
any other household members and guests or other persons to possess or use any controlled
substance, or consume alcoholic beverages to intoxication in the presence of the Children.
Further both Parents are prohibited from giving the minor Children alcoholic beverages or
controlled substances to use and/or consume.
6. Supervision: Neither Parent shall leave the Children unattended in a vehicle or public
facility. Neither Parent shall leave the Children unsupervised.
7. Seat Belts: During periods of transportation, both Parents shall ensure that the Children are
wearing seatbelts and properly protected.
8. No Derogatory Comments: Neither Parent will undertake, or permit by any other person,
the poisoning of the Children's mind against the other Parent, by conversation or otherwise,
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any communication that explicitly or inferentially derides, ridicules, condemns, or in any
manner derogates the other Parent or extended family members. Neither Parent shall
attempt, or condone any attempt, directly or indirectly, to estrange the Children from the
other Parent. At all times each Parent shall encourage and foster in the Children a sincere
respect and affection for the other Parent.
9. No Discussion: Neither Parent shall discuss any aspect of the custodial situation, other than
finalized custody schedules, with the Children. Neither Parent shall discuss any pending legal
action involving the Parents with the Children. Neither Parent utilize the Children for
purposes of conveying information or inquiries pertaining to the Children and/or any pending
legal action to the other Parent.
10. Removal ami Absence: Father shall not remove the children from the Commonwealth of
Pennsylvania without Mother's consent. If either Parent intends on removing the Children
from his or her residence for a period in excess of forty-eight (48) hours that Parent shall
provide the other Parent with the address and phone number where the Children can be
reached during the period of absence.
11. Relocation: Neither Parent shall remove and relocate the Children from the jurisdiction of
the Court of Common Pleas of Cumberland County, Pennsylvania on a permanent basis
without providing the other Parent with at least ninety (90) days advance notice thereof. Said
ninety (90) day time period is designed to allow the Parents to negotiate a modification of
this Order, and in absence thereof to petition the Court for a modification if the same is
appropriate under the circumstances.
B. PHYSICAL CUSTODY: The Parents shall have joint physical custody of the Children in
accordance with the following terms:
1. Primarv Custodian's Periods: Mother shall have custody ofthe Children for all periods not
specifically reserved for Father in herein.
2. Father's Week Periods: Father shall have custody ofthe Children during the evenings when
mother works on such days, alternating weekends, and for such times as the Parents shall
mutually agree.
3. Holidays/Special Davs: The Parents shall share or alternate custody of the children on the
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major holidays as they shall hereafter mutually agree.
4. Summer Vacation Time: Each Parent shall be entitled to two (2) uninterrupted weeks of
custody of the Children under and subject to the following terms and conditions:
A. Consecutive or Non-Consecutive Weeks: The weeks are to be exercised in two (2)
non-consecutive one (l) week periods.
B. Advance Written Notice: Each Parent must provide the other Parent with at least
thirty (30) days advance written notice of his or her intention to exercise each of these
custodial weeks.
C. Conflict: Should conflict arise between the selection of said weeks the first Parent
to notify the other Parent of his or her selection shall have the right to exercise
custody on the weeks selected and the other Parent shall select other times for his or
her weeks so as to avoid any conflicts.
5. Transportation: The transportation necessary for the custodial exchanges herein set forth
shall be provided by Father.
J.
Distribution to:
Diane G. Radcliff, Esquire, 3448 Trindle Road, Camp Hill, P A 17011, Attorney for Plaintiff
Shannon M, Willis, 210 Hill Street, Apt. 6, Mt. Holly Springs, PA 17065, pro se
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